Supporting statement (Ordinances)

SUPPORTING STATEMENT FOR RECORDKEEPING AND REPORTING
REQUIREMENTS FOR 25 C.F.R. PARTS 519, 522, 523, 524, 556 AND 558

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.
The Indian Gaming Regulatory Act, (25 U.S.C. § 2701 et seq., 102 Stat. 2467, Pub. L.
100-497 (IGRA), governs the regulation of gaming on Indian lands. IGRA establishes National
Indian Gaming Commission (NIGC) authority to oversee Indian gaming. IGRA sets standards
for the regulation of gaming, including requirements for the approval or disapproval by the
Chairman of tribal gaming ordinances and resolutions. Section 2705(a)(3) requires the Chairman
of the NIGC to review and approve all class II and class III tribal gaming ordinances and
resolutions before they become effective.
25 C.F.R. § 522.2 and § 522.3
IGRA requires the collection of certain information to make possible the Chairman’s
approval of gaming ordinances and resolutions. 25 C.F.R. § 522.2 regulates the approval of tribal
gaming ordinances, a necessary prerequisite for gaming under IGRA. To make possible the
Chairman’s approval of those gaming ordinances, and to allow him to make sure that the
ordinances meet IGRA’s requirements, the section requires tribes to submit to the NIGC: (1) a
copy of the gaming ordinance to be approved, a copy of the authorizing resolution by which it
was enacted by the tribal government, a request for approval of the ordinance or resolution; (2) a
description of procedures the tribe will employ in conducting background investigations on key
employees or primary management officials; (3) a description of procedures the tribe will use to
issue licenses to primary management officials and key employees; (4) copies of all gaming
regulations; (5) a copy of any applicable tribal-state compact; (6) a description of disputeresolution procedures for disputes arising between the gaming public and the tribe or
management contractor; (7) identification of the law enforcement agent that will take fingerprints
and a description of the procedures for conducting criminal history checks; and (8) designation
of an agent for service of process for the tribe.
25 C.F.R. § 522.3 regulates when tribes must submit any amendments to their previously
approved gaming ordinances. Further, the regulation requires the tribe to submit the same
information requested under 25 C.F.R. § 522.2. The regulation states that tribes must submit
amendments to the NIGC within 15 days after adoption of that amendment.
25 C.F.R. § 522.12

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IGRA recognizes that tribes may revoke approval of gaming, just as it requires them to
authorize it. If, however, a tribe revokes authorization for class III gaming, then the Chairman
does not need to approve that ordinance or resolution. Section 2710 (d) (2) (D) states that if a
tribe chooses to revoke an ordinance or resolution that permitted class III gaming, then it must
provide the Chairman notice of its intent to do so. 25 C.F.R. § 522.12 requires that the Chairman
publish the notice and submitted resolution or ordinance in the Federal Register.
25 C.F.R. § 523.2 and § 523.4
IGRA requires the collection of certain information to make possible the Chairman’s
approval of gaming ordinances. 25 C.F.R. § 523.2 and § 523.4 regulate the approval of tribal
gaming ordinances passed prior to enactment of NIGC regulations in 1993 when the Secretary of
the Interior still handled ordinance approvals. These regulations allow the Chairman to request a
review of those previously approved ordinances for his own determination. To make possible the
Chairman’s approval of these previously reviewed gaming ordinances, and to ensure that they
comply with IGRA’s requirements, the section requires tribes to submit to the NIGC: (1) a copy
of the gaming ordinance to be approved, a copy of the authorizing resolution by which it was
enacted by the tribal government, a request for approval of the ordinance or resolution; (2) a
description of procedures the tribe will employ in conducting background investigations on key
employees or primary management officials; (3) a description of procedures the tribe will use to
issue licenses to primary management officials and key employees; (4) copies of all gaming
regulations; (5) a copy of any applicable tribal-state compact; (6) a description of dispute
resolution procedures for disputes arising between the gaming public and the tribe or
management contractor; (7) identification of the law enforcement agent that will take fingerprints
and a description of the procedures for conducting criminal history checks; and (8) designation
of an agent for service of process.
25 C.F.R. § 523.4 regulates when tribes must submit any amendments made prior to the
NIGC regulations. Further, the regulation requires the tribe to submit the same information
requested under 25 C.F.R. § 523.2. This section requires tribes to submit amendments to the
NIGC within 15 days after adoption of that amendment.
25 C.F.R. PART 524
IGRA also provides tribes, and in some cases other parties, with the ability to appeal the
Chairman’s decision on a gaming ordinance to the full Commission. This right of appeal ensures
that the Chairman exercises his statutory duties in conformity with the law. Because 25 C.F.R.
Part 524 provides respondents with the right to appeal the Chairman’s decision regarding an
ordinance to the full Commission, it requires the tribe or other entity seeking an appeal to file a
concise statement setting forth reasons that the Chairman's was wrong. This appeal must be filed
with the Commission within 30 days after notice of the Chairman's disapproval of an ordinance
or amendment. The Commission will make its decision within 90 days of receiving the appeal
notice.
25 C.F.R. § 556.3, § 556.4, and § 556.5

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IGRA’s section 2710 requires tribes to conduct background investigations on key
employees and primary management officials involved in class II and class III gaming. This is to
ensure the integrity of gaming and avoid the introduction of criminal elements into Indian
gaming operations. To protect gaming from the criminal element, under 25 C.F.R. § 556.4, the
Commission requires tribes to insist on submission of the following information from applicants:
1) name, social security number, birth place and date, citizenship, gender, and languages; 2)
business, employment positions and ownership interests; 3) names and addresses of three
references; 4) current address and phone for business and residence; 5) description of business
relationships or interests with Indian tribes; 6) description of business relationships or interests
with Indian gaming in general; 7) name and address of any licensing agency that the person
applied to; 8) any listed felonies; 9) any misdemeanors within 10 years; 10) any other criminal
charge within the last 10 years; 11) name and address of any licensing agency outside of gaming
that the person applied to; 12) photo; 13) any other relevant information; 14) fingerprints. To
ensure compliance with these regulations and the Commission’s mission to protect the integrity
of gaming, the Commission requires tribes under 25 C.F.R. § 556.3 to warn applicants regarding
the penalty for false statements in their application materials. Likewise Section
2710(b0)(2)(F)(ii)(III) requires, and 25 C.F.R. § 556.5 implements the requirement that tribes
submit reports regarding each of the investigations completed on applicants and whether the
applicant meets the eligibility and suitability criteria for gaming.
25 C.F.R. Part 558
IGRA’s section 2710 requires tribes to conduct background investigations on key
employees and primary management officials involved in class II and class III gaming. This is to
ensure the integrity of gaming and avoid the introduction of criminal elements into Indian
gaming operations. To ensure compliance with these regulations and the Commission’s mission
to protect the integrity of gaming, the Commission requires tribes under 25 C.F.R. Part 558 to
maintain suitability determinations and background investigation reports on key employees and
primary management officials. For those reasons, the statute and the regulations also require
tribes to make a decision on whether an applicant is eligible to receive a license and send that
report and findings to the Commission for review. To ensure the integrity of gaming, the statute
requires the Commission to review those reports and decide if it has any objection to an applicant
receiving a gaming license. Further, the statute requires the Commission to insist that tribes
notify it whenever a licensee has their license suspended.
25 C.F.R. PART 519
As part of any legal service of process regarding any action or review item, the Chairman
will be required to serve official determinations on tribes, tribal operators, or management
contractors. For this reason 25 C.F.R. Part 519 requires these persons to designate an agent for
service by written notification to the NIGC.
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.

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25 C.F.R. § 522.2 and § 522.3
The information submitted in connection with an ordinance will be used by the Chairman
for approving or disapproving tribal ordinances and resolutions as required by IGRA’s section
2710(b)(1)(B) and (d)(1)(A). This information allows the Chairman to decide whether an
ordinance meets IGRA’s statutory requirements and helps the Chairman ascertain whether an
adequate regulatory system exists within the tribal gaming operation. The Chairman uses the
information to determine whether the tribe has created an adequate system to regulate gaming
and protect Indian gaming from criminal influence. The Chairman also reviews the information
presented to ensure that the ordinance or resolution was enacted in accordance with all applicable
tribal laws. Failure to request this information from tribes would render the Chairman unable to
complete his statutory duties under IGRA.
25 C.F.R. § 522.12
The information submitted in connection with an ordinance is used by the Chairman to
determine whether class III gaming has been revoked and thus rendered illegal. The Chairman
uses this notice to stay apprised of which Indian gaming operations offer class III gaming and
which do not.
25 C.F.R. § 523.2 and § 523.4
The information submitted in connection with an ordinance will be used by the Chairman
for approving or disapproving tribal ordinances and resolutions as required by IGRA’s section
2710(b)(1)(B) and (d)(1)(A). This information allows the Chairman to decide whether an
ordinance meets IGRA’s statutory requirements and helps the Chairman ascertain whether an
adequate regulatory system exists within the tribal operation. The Chairman uses the information
to determine that the tribe has created an adequate system to regulate gaming and protect Indian
gaming from criminal influence. The Chairman also reviews the information presented to ensure
that the ordinance or resolution was enacted in accordance with all applicable tribal laws. Failure
to request this information from tribes would render the Chairman unable to complete his
statutory duties under IGRA.
25 C.F.R. PART 524
The information submitted in connection with an ordinance appeal will be reviewed by
the Commission as part of its statutory obligations to ensure that the Chairman has properly
executed his statutory duties. The information contained in the administrative appeal will assist
the Commission in framing the issues and providing an appeal process that is thorough and
complete. If this information were unavailable to the Commission, the parties would have no
administrative recourse for decisions that did not comply with IGRA. To ensure that the
Chairman has completed his statutory duties in conformity with the law, the Commission must
review a complete record on appeal.
25 C.F.R. § 556.4, § 556.5, and Part 558

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The information submitted in connection with an ordinance will be used by the
Commission, in accordance with its statutory duties, for reviewing tribal decisions to license key
employees and primary management officials. The Commission must review this information,
and continually monitor tribal compliance, to ensure that tribal gaming avoids the criminal
element and maintains its integrity. Thus, the Commission reviews licensing reports to ensure
that no criminal element enters the tribal gaming system.
25 C.F.R. PART 519
This information submitted in connection with an ordinance is needed to perfect the
Chairman’s legal obligation to provide tribes proper and legal service of process about
ordinances or resolutions that have been approved or disapproved. If the collection of
information were not conducted as described, the NIGC would lack confidence that official
determinations have been legally and effectively served.
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, e.g., permitting electronic submission of responses, and
the basis for the decision for adopting this means of collection. Also, describe any
consideration of using information technology to reduce burden.
25 C.F.R. § 522.2 and § 522.3
Information may be submitted to the NIGC by any compatible electronic means, but this
is not done very often. No specific technological collection techniques are employed.
25 C.F.R. § 522.12
See supporting statement for sections 522.2 and 522.3.
25 C.F.R. § 523.2 and § 523.4
See supporting statement for sections 522.2 and 522.3.
25 C.F.R. PART 524
See supporting statement for sections 522.2 and 522.3.
25 C.F.R. § 556.4, § 556.5, and § 558
Almost 64% of the information submitted in connection with background investigations
is received here electronically. The tribes send the information via e-mail and other means. This
method significantly reduces the review time and costs associated with file maintenance. This
method has vastly improved response time between the tribes and the Commission and reduces
time and costs for investigation review.

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25 C.F.R. PART 519
See supporting statement for sections 522.2 and 522.3.
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.
25 C.F.R. § 522.2 and § 522.3
IGRA requires a certain minimum degree of regulation in each tribe’s gaming ordinance,
and the tribes have the sovereign ability to pass more stringent requirements on any subject.
Thus, each tribe’s ordinance will be unique. The Commission, therefore, does not collect
duplicate information pertaining to Indian gaming because each tribal gaming ordinance will
vary. Likewise, licensing information and determinations are unique to each applicant, as are the
facts and issues in an ordinance appeal.
25 C.F.R. § 522.12
See supporting statement for sections 522.2 and 522.3.
25 C.F.R. § 523.2 and § 523.4
See supporting statement for sections 522.2 and 522.3.
25 C.F.R. PART 524
See supporting statement for sections 522.2 and 522.3.
25 C.F.R. § 556.4, § 556.5, and § 558
See supporting statement for sections 522.2 and 522.3.
25 C.F.R. PART 519
See supporting statement for sections 522.2 and 522.3.
5.
If the collection of information impacts small business or other small entities (item 5
of OMB Form 83-1), describe any methods used to minimize burden.
25 C.F.R. § 522.2 and § 522.3
Not applicable.

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25 C.F.R. § 522.12
Not applicable.
25 C.F.R. § 523.2 and § 523.4
Not applicable.
25 C.F.R. PART 524
Not applicable.
25 C.F.R. § 556.3, § 556.4, § 556.5, and § 558
Not applicable.
25 C.F.R. PART 519
Not applicable.
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.
25 C.F.R. § 522.2 and § 522.3
IGRA requires an ordinance submission (and all corresponding information) for a
one-time approval or disapproval of tribal gaming ordinances and resolutions. Thus tribal
gaming operators need only submit the information once unless amendments are later made.
Tribes must submit those amendments to the Chairman for review. The statute requires both the
Chairman and the Tribe to approve class II and III gaming on Indian lands, so non-submission of
ordinances is not an option. The Chairman already imposes the collection requirements as
infrequently as possible.
25 C.F.R. § 522.12
The submission requirements apply only when a tribe adopts an ordinance or resolution
that revokes class III gaming. No tribe has done so in recent years.
25 C.F.R. § 523.2 and § 523.4
The submission requirements apply to the approval or disapproval of tribal gaming
ordinances and resolutions. Thus, tribes need only submit the information once unless
amendments are later made. In that case, those amendments must be submitted to the Chairman.
The Chairman must review these ordinances and amendments for approval or fail in his statutory

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duty to protect Indian gaming’s integrity. The Chairman already imposes these collection
requirements as infrequently as possible.
25 C.F.R. PART 524
The frequency of filing appeals is inextricably linked to disapprovals of ordinances or
resolutions by the Chairman. The Commission must review all appeals from the Chairman’s
decisions or fail in its statutory duty to protect the integrity of Indian gaming and ensure due
process for tribes seeking administrative review of the Chairman’s decisions. The Commission
already imposes these collection requirements as infrequently as possible.
25 C.F.R. § 556.4, § 556.5, and Part 558
The frequency of the need to provide relevant background and licensing information is
inextricably linked to the hiring of primary management officials or key employees. Failure of
the Commission to ensure that an adequate system is in place and that the tribe complies with its
reporting obligations would constitute a failure of its statutory duties and of its obligation to
protect the integrity of Indian gaming.
25 C.F.R. PART 519
The collection of information required by this section would occur upon the designation
of an agent for service of process or a change of designation. The Chairman already imposes this
collection requirement as infrequently as possible.
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;
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, which 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 statue or regulation, which is not supported by disclosure and data
security policies that are consistent with the pledge, or which unnecessarily impedes
sharing of data with other agencies for compatible confidential use; or

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-

requiring respondents to submit proprietary trade secrets, 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.

25 C.F.R. § 522.2 and § 522.3
IGRA, 25 U.S.C. § 2716, requires the Commission to keep confidential trade secrets,
privileged or confidential, commercial or financial information, or information related to
ongoing law enforcement investigations. 25 U.S.C. § 2716 removes from the Commission any
discretion it otherwise would have to disclose information that falls within FOIA exemptions 4
and 7 and requires the Commission to disclose such information only to other law enforcement
agencies for law enforcement purposes.
25 C.F.R. § 522.12
See supporting statement for 25 C.F.R. § 522.2 and § 522.3.
25 C.F.R. PART 524
See supporting statement for 25 C.F.R. § 522.2 and § 522.3.
25 C.F.R. § 523.2 and § 523.4
See supporting statement for 25 C.F.R. § 522.2 and § 522.3.
25 C.F.R. § 556.4, § 556.5, and Part 558
See supporting statement for 25 C.F.R. § 522.2 and § 522.3.
Further, the tribes will report this information to the Commission whenever it becomes
available. This ensures that the Commission is up-to-date on all background investigations and
eligibility determinations happening in Indian Country. Such continuous reporting is necessary to
ensure integrity in Indian gaming and avoid criminal influence.
25 C.F.R. PART 519
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 C.F.R. § 1320.8(d), soliciting
comments on the information collection prior to submission to OMB. Summarize public
comment 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.

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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 prior periods. There may be circumstances
that may preclude consultation in a specific situation. These circumstances should be
explained.
On February 16, 2012, a notice containing the information collections requirement was
published in the Federal Register allowing the public an opportunity to comment on the
requirements. The public comment period closed on April 16, 2012. No public comments were
received.
9.
Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Not applicable.
10.
Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
25 C.F.R. § 522.2 and § 522.3
With regard to confidential information, the Commission must ensure the integrity of
Indian gaming and that it is kept free from criminal influence. To that end, the Commission must
require the maintenance and reporting of certain confidential information. The Commission has
established a system of records for maintaining and protecting confidential information.
However, the Commission will not reveal any personal information of individuals received in
connection with a background investigation under the Privacy Act. 5 U.S.C. § 552(a). Further,
the Commission will not reveal information that constitutes a trade secret or information
connected to an ongoing law enforcement investigation. 25 U.S.C. § 2716 removes from the
Commission any discretion it would otherwise have to disclose information that falls within
FOIA exemptions 4 and 7 and requires the Commission to disclose such information only to
other law enforcement agencies for law enforcement purposes. Information in these categories
can become issues during an appeal of the Chairman’s decisions or during the reporting of a
background investigation. Thus, steps will be taken to protect the information and ensure
continual integrity in gaming.
25 C.F.R. PART 524
See supporting statement for 25 C.F.R. § 522.2 and § 522.3

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25 C.F.R. § 523.2 and § 523.4
See supporting statement for 25 C.F.R. § 522.2 and § 522.3
.
25 C.F.R. § 556.4, § 556.5, and Part 558
See supporting statement for 25 C.F.R. § 522.2 and § 522.3

25 C.F.R. PART 519
Not applicable.
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. No sensitive questions are asked.
12.
Provide estimates of the hour burden of the collection of information. The statement
should:
-

-

-

Indicate the number of respondents, frequency of responder 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 hour burden, and explain the reasons for the variance. Generally,
estimates should not include burden hours for customary and usual business
practices.
If this request for approval covers more than one form, provide separate hour
burden estimates for each form and aggregate the hour burdens on Item 13 of OMB
Form 83-1.
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.

See attached Chart. Hourly rate was based upon average prevailing rate for the services
required.

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13. 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 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 description 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 economics 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 11 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.
See attached chart.

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.
See attached chart. As a general matter, cost rate was based upon prevailing rate of
personnel assigned to task. Support services are included in cost estimates.

15.
Explain the reasons for any program changes or adjustments reported in items 13
or 14 of OMB Form 83-1.
No change from previous submission.

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16.
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.
25 C.F.R. § 522.2, § 522.3, and § 523.4
This is an ongoing information collection with no ending date and no plans for
publication. (This item is identical for all supporting statements.)
25 C.F.R. PART 524
This is an ongoing information collection with no ending date and no plans for
publication. (This item is identical for all supporting statements.)
25 C.F.R. § 523.2
This is an ongoing information collection with no ending date and no plans for
publication. (This item is identical for all supporting statements.)
25 C.F.R. § 556.4, § 556.5, and § 558
This is an ongoing information collection with no ending date and no plans for
publication. (This item is identical for all supporting statements.)
25 C.F.R. PART 519
This is an ongoing information collection with no ending date and no plans for
publication. (This item is identical for all supporting statements.)
17.
If seeking approval to not display the expiration date for OMB approval of
information collection, explain the reasons that display would be inappropriate.
Not applicable.
18.
Explain each exception to the certification statement in Item 19, "Certification for
Paperwork Reduction Act Submissions," of OMB Form 83-1.
Not applicable. The NIGC certifies compliance with 5 C.F.R. § 1320.9.
B.

Collection of Information Employing Statistical Methods.

This section is not applicable. Statistical methods are not employed.

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