IC 2133-0505 Supporting Statement

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS
UNDER 5 CFR PART 1320
Information Collection: 2133-0505, Voluntary Tanker Agreement (VTA)

A.

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.
This collection of information supports DOT's Security, Preparedness and Response Strategic
Goal.
The Revised Voluntary Tanker Agreement is a voluntary agreement, in accordance with section
708, Defense Production Act, 1950, as amended (50 U.S.C. App. 2158), under which
participants agree to contribute, either by direct charter to the Department of Defense (DOD) or
to other participants, tanker capacity as requested by the Maritime Administrator at such times
and in such amounts as the Administrator shall determine to be necessary to meet the essential
needs of DOD for the transportation of petroleum and petroleum products in bulk by sea.
The Maritime Administrator recertifies the need for and the Attorney General approves the
agreement every two years.
The Maritime Administration's (MARAD) Revised Voluntary Tanker Agreement asks that each
participant, when requested by the Maritime Administrator, submit reports setting forth
information on controlled tonnage necessary for the carrying out of the agreement. The
information would consist of distribution of tanker capacity necessary to satisfy DOD emergency
requirements.
Information on controlled tonnage is fleet inventory information that is maintained routinely for
company operation and management purposes. No unique information is required by the
Government for the purpose of the agreement and no report format is prescribed for submission
of the information. All that is required is that a list of the names of ships owned, chartered or
contracted for by the participant, and their size and flags of registry be provided to MARAD on
request. Technical data on the tanker is supplied from MARAD files. As a practical matter, we
do not foresee a need for the participants to maintain records until the agreement is activated.
MARAD will maintain all records of meetings and communication between MARAD and
participants.
2.
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 information received will be used by MARAD personnel to evaluate tanker capability and

make plans for the use of this capability to meet national emergency requirements. This
information will be used by both MARAD and Department of Defense to establish overall
contingency plans. The contingency plans, with accompanying tanker data, are classified and
not available to the general public.
.
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 provides a total electronic option for this collection. The applications are sent by email
and returned by email.
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.
An examination of the Catalog of Federal Domestic Assistance and the Catalog of Federal
Paperwork Requirements did not reveal any similar information collections.
The input of data from each tanker company will affirm the number of tankers committed to the
Voluntary Tanker Agreement and is therefore unique and necessary.
5.
If the collection of information impacts small businesses or other small entities (Item
5 of OMB Form 83-I), describe any methods used to minimize burden.
Tanker owners are generally not small business as defined by the Small Business Administration
criteria. If small businesses want to apply, there is no restriction.
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 burden.
Collection has been infrequent due to inactivity of the agreement. However, three applications to
participate in the VTA were received in the last two years. Prior to that, the Agreement was
under revision for several years as the government considered updating and modernizing the
VTA document.
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;

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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;

•

requiring respondents to submit more than an original and two copies of any
document;

•

requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records for more than three years;

•

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;

•

requiring the use of a statistical data classification that has not been reviewed
and 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

•

requiring respondents to submit proprietary trade secret, or other confidential
information unless the agency can demonstrate that it has instituted procedures
to protect the information's confidentiality to the extent permitted by law.

There are no special circumstances that require the collection of information to be conducted in a
manner described above.
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
recordkeeping, 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

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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 60-day notice and request for comments on this
information collection in the Federal Register on February 26, 2010, (75 F.R 9014, copy
attached) indicating comments should be submitted on or before April 27, 2010. No comments
were received.
9.
Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are provided to respondents.
10.
Describe any assurance of confidentiality provided to respondents and the
basis for the assurance in statute, regulation, or agency policy.
All data collected from individual companies will be maintained and treated by MARAD as
confidential and will not be released to the general public. The Voluntary Tanker Agreement
requires MARAD to take all necessary steps to protect proprietary or classified data.
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.
Not applicable. There are no questions 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.

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•

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.

•

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.

Number of
Respondents
15
x

Responses
Per
Respondent
1

Total
Responses
Annually
15
x

=

Hours
Total
Per
Hours
Response
Annually
1
= 15

A determination of the estimated number of hours required per response was made after
consultation with several respondents.
It is estimated that one employee spends approximately one hour of their time collecting and
assimilating the information submitted with each response. Therefore, given an average salary
of $22.00 per hour, the total cost to the respondents is as follows:

Number of
Respondents
15
x

Per
Response
1
x

Cost
Per
Hour
$22 x

Number
of
Hours
1
=

Hours
Other
Total
Cost
Cost
Cost
Annually
Annually
Annually
$330
+ $40 *
= $370

13.
Provide an estimate of the total annual cost burden to respondents or
recordkeepers 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 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

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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.

(a) Total Capital and Start-Up Costs Estimate: There are no capital or start-up costs
associated with this information collection.
(b) Total Operation and Maintenance and Purchase of Services Estimate: There are
no operation and maintenance costs associated with this information collection.
14.
Provide estimates of annualized cost to the Federal 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: One GS-7 employee at an hourly wage of approximately $20.00 to collate the 15
responses is estimated to take approximately 1.5 hours to perform these tasks. Postage costs are
also included in this collection.
Number of
Hourly
Project
Employees
Wage
Time
1 x
$22.92 x
2 hours
Overhead at 85%
Sub-total
Times 15 responses per year
Plus additional cost for mailings $ 0.00

=
=
=
=

Cost Per
Letter
$ 45.84
$ 38.96
$ 84.80
$1,272.06

Maximum Total Annual Cost to Federal Government: $1,272.06
15.
Explain the reasons for any program changes or adjustments reported in items 13
or 14 of OMB Form 83-I.
The number of respondents for this information collection has decreased as last reported in 2007. There
are fewer tankers participating in the program.

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For collections of information whose results will be published, outline plans for
tabulation and publication. Address any complex analytical techniques that will be used.
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.
Not applicable.
17.
If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
None.
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. There are no exceptions to the certificate statement.
.

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