revised 0625.0237.suppstmt.SC.6.2.11

SUPPORTING STATEMENT

U.S. Department of Commerce

International Trade Administration

Internet Website Forms

OMB Control No. 0625-0237

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.

The International Trade Administration’s (ITA) U.S. Commercial Service (CS) is mandated by Congress to broaden and deepen the U.S. exporter base. The CS accomplishes this by providing counseling, programs and services to help U.S. firms export and conduct business in overseas markets. This information collection package enables the CS to provide appropriate export services to U.S. exporters.

The dissemination of international market information and potential business opportunities for U.S. exporters are critical components of the Commercial Service’s export assistance programs and services. U.S. companies conveniently access and indicate their interest in these services by completing the appropriate forms via CS U.S. Export Assistance Center websites.

The forms ask U.S. exporters standard questions regarding details about their company, export experience, information about the products or services they wish to export and exporting goals. A few questions are tailored to a specific program type and will vary slightly with each program. (More details about specific forms and uses are provided in Question 2.) CS staff use this information to gain an understanding of client’s needs and objectives in order to provide appropriate and effective export assistance tailored to an exporter’s particular requirements.

The Commercial Service (CS) is implementing an initiative to standardize its client in-take and registration system, streamline the forms used by clients to request export assistance and populate select forms with previously collected client data by March 2012. The initiative will have a major impact on the collections in this package and is expected to eliminate some currently used forms.

The CS is evaluating the collections in this package to prepare for both the standardization and streamlining launch in March 2012 and the package renewal due by April 2012. Prior to finalizing and submitting the renewal package, the CS would like to implement minor changes to some forms (Export.gov Registration, Business Service Providers, Local Event Form and Industry Focused Promotion) to test their effectiveness in serving multiple uses and to assist CS staff in adjusting to new processes. The CS would like to begin using the modified collections in mid-June to gain enough experience to finalize the renewal package by October 2011.

The CS is proposing to make the following types of minor revisions to the forms:

• Addition of supplementary information and instructions

• Text revisions to improve clarity and appropriateness (such as revisions to make a form more appropriate for use by foreign firms)

• Translation of some English language forms into foreign languages

• Deletion of fields that are no longer needed

• Addition of limited new fields consistent with the intent of the approved form

• Moving the placement of questions to improve the organization and layout of a form

2. Explain how, by whom, how frequently, and for what purpose the information will be used. If the information collected will be disseminated to the public or used to support information that will be disseminated to the public, then explain how the collection complies with all applicable Information Quality Guidelines.

U.S. companies that are interested in obtaining export assistance or participating in a CS export-related program will provide the CS with information about:

• The export-related programs and services that they wish to participate in;

• Company background such as product/service to be exported, industry, company size, export experience, company contact information, client name and contact information;

• Exporting goals and objectives such as markets of interest, industries, and potential end-users; and

• CS relationships such as the U.S. Export Assistance Center(s) previously contacted and CS staff with whom the client may have previously worked.

The collected information will be used by CS staff in counseling and assisting clients and in fulfilling U.S. firms’ requests for export assistance services and programs.

The collection is voluntary and the frequency will be on-going and will depend upon the demand U.S. companies have for CS services and programs.

Export.gov Client Registration (minor changes proposed)

The CS proposes to make minor modifications to the Export.gov Client Registration so that it is better suited to assess a client’s export experience and become the standard CS registration form and serve as the basis for a new standardized client in-take process. The Export.gov Client Registration form is expected to eliminate the need for multiple client in-take forms.

Proposed Changes

Currently Approved Text	Proposed Changes	Explanation
Account type		Delete. Field not needed.
Contact Middle Initial		Delete. Field not needed.
Contact Suffix		Delete. Field not needed.
Fax Number		Delete. Field not needed.
Business Type		Delete. Field not needed.
	Confirm e-mail address	New field.
	Estimated percentage of annual sales derived from exporting* Less than 5% 5% –9% 10% - 19% 20% - 29% 30% or more	New field, mandatory.
	Estimated Percentage of Annual Sales derived from Exporting?*	New field, mandatory.
	Dunn & Bradstreet No.:	New field.
	How did you find us?*	New field. Mandatory.
Mr./Ms./Dr.*	Salutation (Mr./Ms./Dr.)	Test revision. Field now optional.
Company Web Site	Business Web Site*	Test revision. Field now mandatory.
Number of Employees	Number of Employees in Business*	Test revision. Field now optional.
Industry*	Select Your Industry Sector(s)*	Text revision.
Countries of Interest*	Countries Your Business is Currently Exporting To (Select up to 5)* [Note: “not currently exporting” will be added to the currently approved drop-down list of countries ]	Text revision.
Business Address Line 1*	Business Address Line 1	Field now optional.
Business City*	Business City	Field now optional.
Business Country*	Business Country	Field now optional.
	We ask that you allow us to help you to expand your exports by connecting you to relevant trade resources of the U.S. Government by providing your consent below: I authorize Export.gov to share our company and product information with other Trade Promotion Agencies of the U.S. Government. I authorize Trade Promotion Agencies to contact me.	New field.

Burden

There is no change in burden associated making minor changes to the Export.gov “Client Registration.” The estimated total burden remains unchanged at 12,000 annual respondents and 2,000 burden hours.

Business Service Provider Registration Form (minor changes proposed)

The Commercial Service Business Service Provider (BSP) Program is an online program to help U.S. exporters and international buyers identify professional export service providers to assist them in the assessment, financing or completion of an export transaction. BSP is offered to U.S. export services providers as well as export services providers located in overseas markets. Companies that provide a product or service that may be useful to the U.S. exporter/international buyer in completing the export transaction are eligible to apply for the program. U.S. Export Assistance Centers in the U.S. and Commercial Service overseas posts offer this program. The on-line BSP Directory is available on office websites.

The on-line directory on each website includes the export service providers’ contact information and a description of the specific product/service. The on-line directory is organized by type of export service to enable U.S. exporter/local buyer to locate assistance needed. Eligible firm types include, among others, freight forwarders, legal services, banking and trade finance services, consulting firms and marketing firms.

The CS has been using one registration form to serve both domestic and international markets and has found a need to make minor changes to the currently approved domestic form so that it is more appropriate for international use. We have been “making do” with one form and have found that it causes confusion among international clients. The CS would like to use 2 versions of the BSP Registration Form, one for domestic use (currently approved) and a new one for international use. The CS would also like to make minor revisions to the Domestic BSP Registration Form to eliminate duplicative information and to improve consistency with other registration forms. The proposed changes are described in the following section.

Proposed Changes

1. Domestic Business Service Provider Registration Form

Currently Approved Text	Proposed Changes	Explanation
	Please complete this form to indicate your interest in participating in the Commercial Service’s Business Service Provider Program. A Trade Specialist will review your registration and contact you. Please note that the fee for each Business Service Provider category is [fee will vary depending upon market.]	Add introductory text. Office-specific information may vary.
	Number of Employees* Single Select Dropdown List with: < 5 5-9 10-19 20-49 50-99 100-499 500- 999	Add this mandatory field because the CS charges fees based upon company size.
Please enter your company's point of contact and company description in the following fields as you would like the information posted on our on-line Business Service Provider directory(s).	Please enter your company's point of contact information and address, if different from above, and company description in the following fields as you would like the information posted on our on-line Business Service Provider directory(s).	To prevent duplication, Clients will be asked to provide the information only if it is different from what was previously provided.
Point of Contact Name Point of Contact Title Point of Contact Phone Point of Contact Fax Point of Contact E-mail Address Company Address If different than the address provided	Contact Name Contact Title Contact Phone Contact Fax Contact E-mail Address Company Address	Text revision.
Complete Business Service Provider Description*	Complete Business Service Provider Description* Describe your company and the service you provide in 500 characters or less. This description may be edited for length and clarity. Please e-mail an electronic copy of your logo as a.jpg or .gif document (save as web file) with a width of exactly 200 pixels and height of up to 200 pixels to your Commercial Service contact.	Add instructions.
Please Select Your Business Service Provider Category*	Business Service Provider Categories* I agree to pay for each category I choose. (Hold Ctrl-Key to select more than one): [Note: Use existing dropdown box with category options]	Add instructions.
Your U.S. Commercial Service Contact Are you currently working with one of our U.S. Department of Commerce offices/ U.S. Export Assistance Centers?* If yes, please enter the International Trade Specialist and office you are currently working with.		Delete field. It can be obtained via ITA’s Client Tracking System.
How were you introduced to our Business Service Provider directories?* __ Trade seminar/conference/event __ Federal government agency __ Local government agency __ Local school/university __ Non-profit trade organization __ Internet research __ Referred __ Other	How did you learn about this program?*	Text revision. Replace list with open text box.

1. International Business Service Provider Registration Form

Currently Approved Text

Proposed Changes

Explanation

Please complete this form to indicate your interest in participating in the Commercial Service’s Business Service Provider Program. A Trade Specialist will review your registration and contact you. Please note that the fee for each Business Service Provider category is [fee will vary depending upon market.]

Add introductory text. Office-specific information may vary.

Country* [select from drop-down list]

New field

State Zip Code

Province Postal Code

Text revision - appropriate for foreign clients.

Number of Employees* Single Select Dropdown List with: < 5 5-9 10-19 20-49 50-99 100-499 500- 999

Add this mandatory field because the CS charges fees based upon company size.

Please enter your company's point of contact and company description in the following fields as you would like the information posted on our on-line Business Service Provider directory(s).

Please enter your company's point of contact information and address, if different from above, and company description in the following fields as you would like the information posted on our on-line Business Service Provider directory(s).

To prevent duplication, Clients will be asked to provide the information only if it is different from what was previously provided.

Point of Contact Name Point of Contact Title Point of Contact Phone Point of Contact Fax Point of Contact E-mail Address Company Address If different than the address provided

Contact Name Contact Title Contact Phone Contact Fax Contact E-mail Address Company Address

Text revision.

Complete Business Service Provider Description*

Complete Business Service Provider Description* Describe your company and the service you provide in 500 characters or less. This description may be edited for length and clarity. Please e-mail an electronic copy of your logo as a.jpg or .gif document (save as web file) with a width of exactly 200 pixels and height of up to 200 pixels to your Commercial Service contact.

Add instructions.

Please Select Your Business Service Provider Category*

Business Service Provider Categories* I agree to pay for each category I choose. (Hold Ctrl-Key to select more than one): [Note: Use existing dropdown box with category options]

Add instructions.

Your U.S. Commercial Service Contact Are you currently working with one of our U.S. Department of Commerce offices/ U.S. Export Assistance Centers?* If yes, please enter the International Trade Specialist and office you are currently working with.

Delete field. It can be obtained via ITA’s Client Tracking System.

Trade References* Please provide at least two references of companies with whom you have conducted business (U.S. companies if possible).

New field.

How were you introduced to our Business Service Provider directories?* __ Trade seminar/conference/event __ Federal government agency __ Local government agency __ Local school/university __ Non-profit trade organization __ Internet research __ Referred __ Other

How did you learn about this program?*

Text revision. Replace list with open text box.

Additionally, the CS plans to translate the International Business Service Provider Registration Form into the following languages:

Arabic	French	Japanese	Spanish
Bulgarian	German	Korean	Thai
Chinese	Greek	Polish	Ukrainian
Croatian	Hebrew	Portuguese	Vietnamese
Czech	Hungarian	Romanian	Turkish
Dutch	Indonesian	Russian
Finnish	Italian	Slovak

Burden

The CS does not anticipate a burden change related to the form modifications and the addition of an international version. International clients have been “making do” with the currently approved form. We expect to maintain the currently approved 195 annual burden hours and 1,167 respondents.

Local Event (minor changes proposed)

A Local Event can be organized by either a CS domestic or international office to provide specialized advice/assistance/instruction to exporters on a variety of export-related topics or to promote U.S. products/services to international buyers. The events are often seminars conducted by a guest speaker who is an expert on a particular trade-related topic of interest to U.S. exporters or international buyers. International companies that participate in these events often have the option of scheduling private meetings with the presenter, other participants or CS staff.

U.S. and international firms indicate their interest in participating in a particular event by completing and submitting a Local Event registration form. The CS has been using one registration form to serve both domestic and international markets and has found a need to make minor changes to the currently approved form so that it is more appropriate for international use. We have been “making do” with one form and have found that it causes confusion among international clients. The CS would like to use 2 versions of the Local Event Registration Form, one for domestic use and one for international use. The currently approved Local Event Form will continue to be used domestically as is and the CS would like to create an international version by making some minor changes to the current Local Event form as described in the following section.

The form consists primarily of standard company information questions such as contact information, background, details about products/services, industry, end-users and exporting objectives. These company information questions are standard for all of the Local Event forms regardless of the event type. The form also includes event-specific questions that will vary with each event depending on the specific event circumstance. The CS requests approval for the standard company questions and the ability to adapt the event-specific questions and/or response options for the specific event.

Proposed Changes

International Local Event Form

Currently Approved Text	Proposed Changes	Explanation
State*	Province	Text revision. Field not mandatory.
Zip code*	Postal code	Text revision. Field not mandatory.
Available to meet on <Date> in CS <office>?*	Available to meet on <date>?*	Text revision.
Preferred Time of Meeting* Also indicate if you would prefer meeting <country>firm at our company.	Preferred time of meeting?* Also indicate where meeting should take place.	Text revision.
Have you previously tried to export to <country>?	Have you previously tried to import from the U.S.?	Text revision.
Products you are looking to sell to <country>? (Please describe)	Products/services you are looking to buy from the U.S. (Please describe)	Text revision.
I am currently looking for representation in <Country> Yes No Prefer direct sales	I am currently looking for representation in <Country> Yes No Prefer direct imports	Text revision to be applicable for foreign importers.
Countries in <Region> from which we are not exporting from the U.S.		Delete field. Does not apply to foreign buyers.
Your local U.S. Department of Commerce [section]		Delete. Does not apply to foreign buyers.
Are you currently working with one of our U.S. Department of Commerce offices/U.S. Export Assistance Centers?		Delete field. It can be obtained via ITA’s Client Tracking System. It is not needed.
If yes, please enter the International Trade Specialist with whom you are now working.		Delete field. It can be obtained via ITA’s Client Tracking System.
If known, feel free to add the name of your trade specialist if not listed above.		Delete field. It can be obtained via ITA’s Client Tracking System.
In the past 24 months, have you or has your company utilized any market research reports or trade promotion programs, or received trade counseling from the U.S. Commercial Service or one of its Export Assistance Centers?		Delete field. The information is collected via another form in 0625-0237.
If so, have these programs or information assisted you in completing any export sales?		Delete field. The information is collected via another form in 0625-0237.
If time allows, could you explain your export successes as a result of assistance provided by the U.S. Export Assistance Center.		Delete field. The information is collected via another form in 0625-0237.

Additionally, the CS plans to translate the International Local Event Form into the following languages:

Arabic	French	Japanese	Spanish
Bulgarian	German	Korean	Thai
Chinese	Greek	Polish	Ukrainian
Croatian	Hebrew	Portuguese	Vietnamese
Czech	Hungarian	Romanian	Turkish
Dutch	Indonesian	Russian
Finnish	Italian	Slovak

Burden

The CS does not anticipate a burden change related to the addition of an International Local Event Form. International clients have been “making do” with the currently approved form. We expect to maintain the currently approved 195 annual burden hours and 1,167 respondents.

Industry Focused Program (minor changes proposed)

The “Showcase Global Industry Focused Promotion" (IFP) program is an online trade lead generating platform to inform U.S. exporters about foreign buyers that are actively sourcing U.S. exports. U.S. Commercial Specialists conduct this program at domestic and international trade shows to help match foreign buyers with U.S. exporters.

The Industry Focused Promotion (IFP) International Buyer Registration form consists primarily of standard company information questions such as contact information, products/services, and participation at the trade show. These company information questions are standard for all of the IFP International Buyer forms regardless of the trade show. This form is necessary because it enables international buyers to meet with U.S. manufacturers and service providers and purchase U.S. goods and services.

For each trade show a list of the U.S. trade show exhibitors is included on the International Buyer Industry Focused Promotion form. The list of participating U.S. firms will vary with each trade show. The form is then publicized among International firms in a variety of markets who may have an interest in purchasing the goods and services offered by the U.S. firms. It also allows buyers visiting the show to set appointments to meet with the U.S. companies that they are interested in.

Proposed Changes

Industry Focused Promotion (IFP) Program International Buyer Registration Form

Currently Approved Text	Proposed Changes	Explanation
Industry Focused Program Directory	Industry Focused Promotion (IFP) Program	Text revision.
Contact Information	Contact and Company Information	Text revision.
Company Name	Company Name*	Mandatory field, consistent with other forms.
First Name	First Name*	Mandatory field, consistent with other forms.
Last Name	Last Name*	Mandatory field, consistent with other forms.
Salutation*	Salutation	Not mandatory field, consistent with other forms.
Function	Title/Responsibility	Text revision.
Street	Company Address*	Mandatory field, consistent with other forms.
City	City*	Mandatory field, consistent with other forms.
State	Province	Text revision.
Country	Country*	Mandatory field, consistent with other forms
Email	Email*	Mandatory field, consistent with other forms
Email confirmation		Delete field.
Please describe your company/products/services and objectives:*	Please describe your company/products/services and objectives:* (For the franchise industry: please indicate your investment capacity in U.S. dollars)	Text revision. Necessary to know franchise investment capacity to match with appropriate U.S. firms.
Please describe your status* End-user Agent/Distributor/Rep Importer Other	Please describe your status* End-user Agent/Distributor/Rep Importer Master Franchise Area Developer Unit Franchisee Other	Text revision. Add three franchise options for franchise industry use.

Additionally, the CS plans to translate the form into the following languages:

Arabic	French	Japanese	Spanish
Bulgarian	German	Korean	Thai
Chinese	Greek	Polish	Ukrainian
Croatian	Hebrew	Portuguese	Vietnamese
Czech	Hungarian	Romanian	Turkish
Dutch	Indonesian	Russian
Finnish	Italian	Slovak

Burden

The burden associated with the Industry Focused Program International Buyer Registration Form is expected to remain unchanged at 1,167 annual respondents and 195 annual burden hours.

ShowTime (no changes)

ShowTime is a trade promotion program that provides U.S. exporters with market briefings and counseling services at major trade shows. Exporters can meet with several CS market and industry specialists for technical assistance on identifying specific high-potential export markets.

The ShowTime form consists primarily of standard company information questions such as contact information, background, details about products/services, industry, end-users, participation at the trade show, trade show booth number, convenient meeting dates and times and exporting objectives. These company information questions are standard for all of the ShowTime forms regardless of the trade show. The form also includes trade show-specific questions that will vary with each trade show, such as the names of the CS industry experts that will participate and the countries represented by the CS experts. The event-specific questions are indicated in red for illustration purposes on the attached form. The CS requests approval for the standard company questions and the ability to adapt the event-specific questions and/or response options for each trade show.

Preliminary Consultation (currently approved)

Note: In the future, as the CS moves to a standard client in-take process, this form will no longer be used.

The Preliminary Consultation instrument is used by new clients at the initial stage of their relationship with the CS and requests information such as company contact information, company background, size, export experience, usual method of selling their product, industry, end users of the product or service, and exporting objectives. These details enable the CS to understand the client, the client’s needs and export objectives, effectively prepare for a one-on-one meeting and thus provide the client with appropriate counseling and export services.

Market Express Bulletin (no changes)

The Market Express Bulletin provides U.S. exporters with monthly updates of new export-related resources such as market research, trade events and export compliance events that have been listed on ITA and CS export-related websites.

The Market Express form allows exporters to sign-up to receive the Market Express Bulletin

e-mail messages notifying them when new resources become available in their industry and/or market of interest.

The Market Express form consists of standard company information questions such as contact information, background, details about products / services and industry. The form also includes market research, trade event and export compliance options that an exporter may select and these options will vary with each Bulletin. These options are indicated in red on the attached form.

Reporting International Success (no changes)

The CS is required by OMB and Congress to annually measure and report on the number of firms that have exported as a result of CS assistance and the dollar value of those exports.

The “Reporting International Success” form is used to capture this information. The form is electronically sent to CS clients who have worked with the CS during the past 12 months to identify whether the client has exported as a result of CS assistance. The form can be submitted to the CS via e-mail.

Featured U.S. Exporter (no changes)

The Featured U.S. Exporter (FUSE) service provides opportunities for U.S. exporters to

promote their products and services to international buyers, distributors and representatives by listing their company profile on the CS international office websites. These on-line listings offer U.S. exporters an effective and inexpensive way to gain international exposure and test international markets. The FUSE form is necessary so that interested clients can register for the service and provide the necessary company and product/service information to be listed on CS websites.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques or other forms of information technology.

Companies access these forms via ITA and CS websites and they submit them electronically.

4. Describe efforts to identify duplication.

There is no duplication of information collection requirements. The information collected by the documents in this package represents unique client information that is required by the CS to efficiently and effectively provide services to U.S. exporters and to document the effectiveness of our services in creating export successes. The information collected on these documents is not available elsewhere in government.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

The majority of these forms have been in use by the Commercial Service for 3 years and during this time no negative feedback has been received from either clients or client-facing staff regarding the use of these forms.

Minor changes have been proposed to some forms to make them easier to use by U.S. exporters and foreign buyers. These minor changes include text changes, layout improvements and the addition of instructions.

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

If approval is not granted for use of these documents, the CS ability to conduct its congressional mandate of broadening and deepening the export base will be severely hindered. The CS’ ability to support the President’s National Export Initiative will also be jeopardized.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

The collection will be conducted in a manner consistent with OMB guidelines.

8. Provide a copy of the PRA Federal Register Notice that solicited public comments on the information collection prior to this submission. Summarize the public comments received in response to that notice and describe the actions taken by the agency in response to those comments. Describe the 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.

A Federal Register Notice soliciting public comment was published on November 28, 2008 (Volume 73, Number 230) page 72447-72448. No comments were received.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

Respondents will not receive payments or gifts.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

The CS plans to use the collected information internally and does not plan to disseminate the information.

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.

No questions of a sensitive nature are asked.

12. Provide an estimate in hours of the burden of the collection of information.

The proposed minor changes do not materially affect the total burden. The total estimated annual burden hours remain at 21,335. The few seconds that may be saved by eliminating a few fields will likely be balanced out by the time spent reading additional clarifying instructions. In the instances where an international version of a form is proposed, the overall burden will remain unchanged because the number of respondents that use a foreign language form will be subtracted from the number that use the English language form.

Form Name	Estimated annual # of respondents	Annual burden hours	Previous Annual # respondents (2009)	Previous burden hours per document (2009)
Preliminary consultation	1,167	195	1,167	195
Local event	1,167	195	1,167	195
ShowTime	1,167	195	1,167	195
Market Express Bulletin	1,167	195	1,167	195
Export.gov registration	12,000	2,000	12,000	2,000
Reporting International Success	1,166	194	1,166	194
Industry focused program	1,167	195	1,167	195
FUSE	1,167	195	1,167	195
Business Service Providers	1,167	195	1,167	195
TOTAL	21,335	3,559	21,335	3,559

13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in #12 above).

There is no cost to respondents associated with this collection.

14. Provide estimates of annualized cost to the Federal government.

Government employees will spend approximately 10 minutes reviewing each completed document.

Estimated annual government employee hours to review completed documents = 3,555 hrs.

Annualized cost to the Federal Govt.: 3,555 hr. X $25/hr. = $88,875.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB 83-I.

Program changes: Please see the response to question #2 in this Supporting Statement for details on the proposed minor changes.

16. For collections whose results will be published, outline the plans for tabulation and publication.

The results will not be published.

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

Not applicable.

18. Explain each exception to the certification statement identified in Item 19 of the

OMB 83-I.

Not applicable.