Oct 2008 Revised - 2133-0029 Justification

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

1

Justification
1.

Explain the circumstances that make the collection of information
necessary. Identify any legal or administrative requirements that
necessitate the collection. Attach a copy of the appropriate section
of each statute and regulation mandating or authorizing the
collection of information.
Quality Shipbuilding information from the Maritime Administration
(MARAD) and the Navy is absolutely necessary for the
Administration and Congress to formulate national shipbuilding
policies. To more effectively comply with Agency directives, the
Maritime Administration, in joint effort with the Naval Sea Systems
command, and major U.S. commercial shipyards, needs to define
and continuously monitor this country's active shipbuilding industrial
base in an accurate, uniform, comprehensive and timely manner.
This data collection effort will assist in addressing these problems,
respond to a major request from the shipbuilding industry itself and
aid in supplying quality shipbuilding information to the Office of
Management and Budget for their budget analysis cycles.
In compliance with the Merchant Marine Act of 1936, as amended
MARAD conducts this survey to obtain information from the
shipbuilding and ship repair industry to be used primarily to
determine if an adequate mobilization base exists for national
defense and for use in a national emergency. The following
sections directly apply:
46 U.S.C. 50102 (2006). Survey of merchant marine. (a) In
general. The Secretary of Transportation shall survey the
merchant marine of the United States to determine whether
replacements and additions are required to carry out the
objectives and policy of section 50101 of this title. The
Secretary shall study, perfect, and adopt a long-range
program for replacements and additions that will result, as
soon as practicable, in-- (1) an adequate and wellbalanced merchant fleet, including vessels of all types, that
will provide shipping service essential for maintaining the
flow of foreign commerce by vessels designed to be readily
and quickly convertible into transport and supply vessels in a
time of national emergency; (2) ownership and operation of
the fleet by citizens of the United States insofar as

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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practicable; (3) vessels designed to afford the best and
most complete protection for passengers and crew against
fire and all marine perils; and (4) an efficient capacity for
building and repairing vessels in the United States with an
adequate number of skilled personnel to provide an
adequate mobilization base.

46 U.S.C. 50106 (2006). Studies on the operation of
vessels. (a) Relative costs. The Secretary of Transportation
shall investigate, determine, and keep current records of the
relative cost of marine insurance, maintenance, repairs,
wages and subsistence of officers and crews, and all other
items of expense, in the operation of comparable vessels
under the laws and regulations of the United States and
those of the foreign countries whose vessels are substantial
competitors of American vessels. (b) Shipyards. The
Secretary shall investigate, determine, and keep current
records of the number, location, and efficiency of shipyards
in the United States. (c) Navigation laws. The Secretary
shall examine the navigation laws and regulations of the
United States and make such recommendations to Congress
as the Secretary considers proper for the amendment,
improvement, and revision of those laws and for the
development of the merchant marine of the United States.

Specifically, this report will support the Maritime Administrative
Order 72-1, Section 3.05, that charges MARAD's, Office of
Business and Workforce Development with the following tasks:
i.

maintaining current records on shipyard facilities,
workload, employment and suppliers in the U.S:

ii.

developing ship contract delivery dates, analysis of
shipbuilder's planned and actual performance, and
scheduling and expediting key event activities scheduling a
mobilization ship program;

iii.

measuring shipyard capacity and production and
maintaining shipyard reporting and information systems;
and,

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029
iv.

2.

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analysis of specific shipbuilding programs and extensions
of contract delivery dates.

Indicate how, by whom, and for what purpose the information is to
be used. Except for a new collection, indicate the actual use the
agency has made of the information received from the current
collection.
The central objective of this data collection effort is to provide the
core information for the following reports, services, projects and
database :
Shipyard Activity Report -- a quarterly report for related shipbuilding
industry use that monitors current U.S. commercial ship
construction and is distributed to both government agencies and
private organizations;

Shipyard Reporting and Information System - a report issued upon
MARAD or industry request that provides basic construction and
ship characteristic information on commercial vessels built in U.S.
shipyards from 1951 to present time
Shipyard Electronic Catalog / MAR-VIEW System- a computer
program being developed by MARAD to display shipyard facility,
capability and orderbook information
Official Shipbuilding Information Base - database utilized in varying
degrees by all the previously mentioned reports, services and
projects.
Shipyard Evaluation and Analysis System (SEAS) - a computer
program utilized upon MARAD, DOD, or industry request for the
analysis of shipbuilding programs and U.S. shipbuilding
mobilization capabilities; and,
An important function of this information is the extending of the firm
work manpower curves beyond the present period to their
completion in both the official shipbuilding status reports and
requested SEAS runs. Most other data improvements are basically

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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solving missing and obsolete data problems in the official
shipbuilding information base. However, in addition to enhancing
the performance of MARAD, the improved data is shared with the
Navy, as well as other Government agencies, to ensure that similar
or mutual analyses of shipbuilding programs will generate less
conflict between each agency's results.
In particular, the most important function of this information is the
newly instituted MAR-VIEW system. This system will be utilized by
the Office of the Secretary of the Department of Transportation to
provide information on shipyards and their orderbooks to those with
the need to know.
Without the availability of this data as it's currently being supplied
the preceding reports and analyses either could not be generated
or would be of significantly reduced integrity.

3.

Describe whether, and to what extent, the collection of information
involves the use of automated, electronic, mechanical, or other
technological collection techniques or other forms of information
technology. Also describe any consideration of using information
technology to reduce burden.
MARAD has provided respondents with the option of responding
100 percent via electronic means including e-mail, FAX, and
internet web form.

4.

Describe efforts to identify duplication. Show specifically why any
similar information already available cannot be used or modified for
use for the purposes described in item 2 above.
This office is in frequent contact with counterpart offices in the
Navy, MSC, Coast Guard, and private organizations to assure the
information we receive available to them, thus eliminating any need
for duplicative data collection efforts.
To our knowledge the U.S. shipbuilding and repair industry does
not provide this type of data to any other government or private

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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organization.

5.

If the collection of information involves small businesses or other
small entities, describe the methods used to minimize burden.
The annual burden for each respondent is a total of two hours of
clerical work. The same level of information detail is required from
all respondents, thus the already small burden cannot be effectively
reduced without a loss in aggregate data integrity. This information
is presently ascertained by the best means available.

6.

Describe the consequence to Federal program or policy activities if
the collection is not conducted or is conducted less frequently, as
well as any technical or legal obstacles to reducing the burden.
The Government Performance and Results Act require Federal
agencies to establish performance goals and measures to assess
progress being made toward achieving intended program
outcomes. Performance goals are contained in the DOT
Performance Plan and Maritime Administration Performance Plan
with DOT. The survey of the shipbuilding industry and the collection
of data on a quarterly basis is essential to our ability to answer the
questions asked by the Office of the Secretary and the Congress
regarding the performance goals.
In addition, regularly required informational responses to Congress
would be severely impacted. Even more importantly, the current
health of an industry, as well as economic well-being, which is
critical to our national defense posture, cannot be surveyed any
less frequently without significant loss of data reliability.

7.

Explain any special circumstances that would cause an information
collection to be conducted in a manner:
•

requiring respondents to report information to the agency
more often than quarterly;
At this time there are no special circumstances that would
require the collection of information more frequently than
quarterly.

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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•

requiring respondents to prepare a written response to a
collection of information in fewer than 30 days after receipt of
it;
We ask the respondents provide us with the requested data
25 days from the date of request. This facilitates the timely
availability of data and the timely dissemination of the data to
management and other Government agencies.

•

requiring respondents to submit more than an original and two
copies of any document;
Respondents are requested to submit only an original
document.

•

requiring respondents to retain records, other than health,
medical, government contract, grant-in-aid, or tax records for
more than three years;
No retention requirements are put on the respondents.

•

in connection with a statistical survey, that is not designed to
produce valid and reliable results that can be generalized to
the universe of study;
This data collection is not subject to statistical methods or
analysis

•

requiring the use of a statistical data classification that has not
been reviewed and approved by OMB;
The data collection has been previously approved by OMB.

•

that includes a pledge of confidentiality that is not supported
by authority established in statute or regulation, that is not
supported by disclosure and data security policies that are
consistent with the pledge, or which unnecessarily impedes
sharing data with other agencies for compatible confidential
use; or
Data is shared with other government agencies on a need to
know basis.

•

requiring respondents to submit proprietary trade secret, or
other confidential information unless the agency can
demonstrate that it has instituted procedures to protect the

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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information’s confidentiality to the extent permitted by law.
Not applicable.

8.

If applicable, provide a copy and identify the date and page number
of publication in the Federal Register of the agency's notice required
by 5 CFR 1320.8(d), soliciting comments on the information
collection prior to submission to OMB. Summarize public comments
received in response to that notice and describe actions taken by the
agency in response to these comments. Specifically address
comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain
their views on the availability of data, frequency of collection, the
clarity of instructions and record-keeping, disclosure, or reporting
format (if any), and on the data elements to be recorded, disclosed,
or reported.
Consultation with representatives of those from whom information is
to be obtained or those who must compile records should occur at
least once every three years - even if the collection of information
activity is the same as in prior periods. There may be circumstances
that may preclude consultation in a specific situation. These
circumstances should be explained.
The Maritime Administration published a Federal Register notice
and request for comments on this information collection in the
Federal Register on June 18, 2008, indicating comments should be
submitted on or before August 18, 2008. No comments were
received.
In addition, MARAD employees communicate with the Shipbuilder’s
Council of America, American Shipbuilding Association, Naval Sea
Systems Command, and major U.S. commercial shipyards in an
effort to define and continuously monitor this country’s active U.S.
shipbuilding industrial base. The basic content of this report is
agreeable to all the concerned parties. Several respondents have
verified that the requested shipbuilding data is indeed readily
accessible and maintained as a matter of standard bookkeeping
and management practice.

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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9.

Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
Not applicable, no payments are provided.

10.

Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.
The data requested is readily available in the shipbuilding industry,
however, upon occasion, it might be considered business sensitive.
For that reason, MARAD's policy is to limit access to raw data to inhouse use. This approach has been mutually agreed upon with the
respondents.

11.

Provide additional justification for any questions of a sensitive
nature, such as sexual behavior and attitudes, religious beliefs, and
other matters that are commonly considered private. This
justification should include the reasons why the agency considers
the questions necessary, the specific uses to be made of the
information, the explanation to be given to persons from whom the
information is requested, and any steps to be taken to obtain their
consent.
The information requested is not of a sensitive nature.

12 .

Provide estimates of the hour burden of the collection of information.
The statement should:
•

Indicate the number of respondents, frequency of response,
annual hour burden, and an explanation of how the burden
was estimated. Unless directed to do so, agencies should not
conduct special surveys to obtain information on which to
base hour burden estimates. Consultation with a sample
(fewer than 10) of potential respondents is desirable. If the
hour burden on respondents is expected to vary widely
because of differences in activity, size, or complexity, show
the range of estimated burden and explain the reasons for the
variance. Generally, estimates should not include burden
hours for customary and usual business practices.

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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Current number of respondents: 200
Annual number of responses per respondent: 4
Annual burden per respondent: 2 hour (average)
Again, this shipbuilding data is readily available in the
shipbuilding industry. The estimated time consumed for
collecting, compiling and typing the requested shipbuilding
data, on average, for this report per response is as follows:
Collection of data
Compilation of data
Typing of data or clerical help
TOTAL

15 minutes
5 minutes
10 minutes
30 minutes

A shipyard's reporting burden may vary from a high of
45 minutes to a low of 15 minutes depending upon the
quantity of major oceangoing vessels being constructed in
each shipyard.

13.

•

If this request for approval covers more than one form, provide
separate hour burden estimates for each form and aggregate
the hour burdens in item 13 of OMB Form 83-I.
Not Applicable

•

Provide estimates of annualized cost to respondents for the
hour burdens for collections of information, identifying and
using appropriate wage rate categories. The cost of
contracting out or paying outside parties for information
collection activities should not be included here. Instead, this
cost should be included in item 14.
2 hours / respondent = $70.00 (@ estimated billing rate of
$35/hour)
Times 200 respondents = $14,000.00 Total Annual cost

Provide an estimate of the total annual cost burden to respondents
or record keepers resulting from the collection of information. (Do
not include the cost of any hour burden shown in items 12 and 14).
•

The cost estimate should be split into two components: (a) a
total capital and start-up cost component (annualized over its

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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expected useful life); and (b) a total operation and
maintenance and purchase of services component. The
estimates should take into account costs associated with
generating, maintaining and disclosing or providing the
information. Include descriptions of methods used to estimate
major cost factors including system and technology
acquisition, expected useful life of capital equipment, the
discount rate(s), and the time period over which costs will be
incurred. Capital and start-up costs include, among other
items, preparations for collecting information such as
purchasing computers and software; monitoring, sampling,
drilling and testing equipment; and record storage facilities.
•

If cost estimates are expected to vary widely, agencies should
present ranges of cost burdens and explain the reasons for
the variance. The cost of purchasing or contracting out
information collection services should be a part of this cost
burden estimate. In developing cost burden estimates,
agencies may consult with a sample of respondents(fewer
than 10), utilize the 60-day pre-OMB submission public
comment process and use existing economic or regulatory
impact analysis associated with the rulemaking containing the
information collection, as appropriate.

•

Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to
October 1, 1995, (2) to achieve regulatory compliance with
requirements not associated with the information collection,
(3) for reasons other than to provide information or keep
records for the government, or (4) as part of customary and
usual business or private practices.
The estimated annual cost burden to respondents per
response is as follows:
(a) Total Capital and Start-Up Costs Estimate:
None
(b) Total Operation and Maintenance and Purchase of
Services Estimate:
None

14.

Provide estimates of annualized cost to the Federal

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SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029
Government. Also, provide a description of the method used
to estimate cost, which should include quantification of hours,
operational expenses (such as equipment, overhead, printing,
and support staff), and any other expense that would not have
been incurred without this collection of information. Agencies
also may aggregate cost estimates from items 12, 13, and 14 in
a single table.
The total annual cost to the Federal Government for processing the
collection is estimated as follows:

4 mailing costs of 75 envelopes (@ $.42 each)
400 pages of printings ($0.10 each)
Return mailing of data
100 hours compilation time (estimated billing of $35/hr.)
TOTAL

$126.00
$40.00
$50.40
$3,500.00
$3,716.40

Since this is a voluntary form submittal on the part of the respondents,
the noted participation level indicates the number of shipyards which
are anticipated to provide us information this number can be expected
to and does vacillate over time. The basic burden per respondent has
not changed.

15.

Explain the reasons for any program changes or adjustments
reported in items 13 or 14 of OMB Form 83-I.
Not Applicable

16.

For collections of information whose results are planned to be
published for statistical use, outline plans for tabulation, statistical
analysis, and publication. Provide the time schedule for the entire
project, including beginning and ending dates of the collection of
information, completion of report, publication dates and other
actions.
Data is entered into a computerized database presented in tabular and
graphic forms. One report is prepared - Shipyard Activity Report
Data collection effort commences:

January. 1
April 1

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PAPERWORK REDUCTION ACT SUBMISSION
UNDER 5 CFR PART 1320
INFORMATION COLLECTION: 2133-0029

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July 1
October 1
End of collection period

January 25
April 25
July 25
October 25

Publication of reports

March 1
June 1
September 1
December 1

As previously mentioned in the Justification, the requested
shipbuilding data will be utilized in MARAD's shipbuilding reports,
services, projects and database. Only the official shipbuilding
information base, SEAS projects, the official shipbuilding status
report require all the data supplied by this report. The remaining
shipbuilding reports, projects and services use only those sections
of the submitted form that are pertinent. Additionally, all
shipbuilding information received is shared with NAVSEA.
Quarterly shipbuilding information will be requested via electronic
mail, and by regular mail where electronic distribution it not
feasible, at the beginning of each quarter. Twenty-five days are
allowed for responses and fifteen days are allowed for data
implementation. The actual publication dates of the official quarterly
shipbuilding status report and shipyard activity report are
respectively, two months after the end of each quarter.

17.

If seeking approval not to display the expiration date for OMB
approval of the information collection, explain the reasons that
display would be inappropriate.
Not applicable.

18.

Explain each exception to the certification statement identified in
Item 19, “Certification for Paperwork Reduction Act Submissions,” of
OMB Form 83-I.
Not applicable.