0013-ss-16-gps

Supporting Statement A

30 CFR Part 250, Subpart A, General

Notice to Lessees and/or Operators (NTL) - Gulf of Mexico OCS Region - GPS (Global Positioning System) for MODUs (Mobile Offshore Drilling Units)

OMB Control Number 1014-0013

Expiration Date: January 31, 2016

Terms of Clearance None.

General Instructions

A completed Supporting Statement A must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified below. If an item is not applicable, provide a brief explanation. When the question, “Does this information collection request (ICR) contain surveys, censuses, or employ statistical methods?” is checked "Yes," then a Supporting Statement B must be completed. The Office of Management and Budget (OMB) reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The Outer Continental Shelf (OCS) Lands Act at 43 U.S.C. 1334 authorizes the Secretary of the Interior to prescribe rules and regulations necessary for the administration of the leasing provisions of that Act related to mineral resources on the OCS. Such rules and regulations will apply to all operations conducted under a lease, right-of-way, or a right-of-use and easement. Operations on the OCS must preserve, protect, and develop oil and natural gas resources in a manner that is consistent with the need to make such resources available to meet the Nation’s energy needs as rapidly as possible; to balance orderly energy resource development with protection of human, marine, and coastal environments; to ensure the public a fair and equitable return on the resources of the OCS; to preserve and maintain free enterprise competition; and to ensure that the extent of oil and natural gas resources of the OCS is assessed at the earliest practicable time. Section 43 U.S.C. 1332(6) states that “operations in the outer Continental Shelf should be conducted in a safe manner by well-trained personnel using technology, precautions, and techniques sufficient to prevent or minimize the likelihood of blowouts, loss of well control, fires, spillages, physical obstruction to other users of the waters or subsoil and seabed, or other occurrences which may cause damage to the environment or to property, or endanger life or health.”

To carry out these responsibilities, the Bureau of Safety and Environmental Enforcement (BSEE) issues regulations to ensure that operations in the OCS will meet statutory requirements; provide for safety and protect the environment; and result in diligent exploration, development, and production of OCS leases. In addition, we also issue Notice to Lessees (NTLs) that provide clarification, explanation, and interpretation of our regulations. These NTLs are used to convey purely informational material and to cover situations that might not be adequately addressed in our regulations.

The subject of this information collection (IC) request is an NTL, GPS (Global Positioning System) for MODUs (Mobile Offshore Drilling Units). This NTL requires MODUs to be equipped with multiple tracking/location devices so that during a storm event (hurricane) the respondent, as well as BSEE, will have the capability to monitor their locations. This NTL also provides BSEE GPS data access thereby granting BSEE real-time location information as needed for the Hurricane Response Team (HRT).

The primary regulation for this IC is 30 CFR 250, Subpart A, approved under the OMB Control Number 1014-0013. However, in connection with this subpart, the burden requirements in the NTL are in addition to the currently approved paperwork burdens under those requirements.

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. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

After Hurricane Ike, 2008, due to the loss of an ENSCO MODU, the National Oceanic and Atmospheric Administration and US Army Corps of Engineers conducted numerous side-sonar searches for dangerous submerged debris in several places in and around the Gulf of Mexico waters, including off the Louisiana coast, the Houston Ship Channel, and the Galveston areas. These searches continued for numerous days, with multiple government agencies, and covered well over 75 square statute miles. Nothing was found.

On March 6, 2009, the SKS Satilla, a 900-ft Norwegian flagged tank ship carrying approximately 130K MT of crude oil, reported listing 8 degrees and taking on water about 65-miles offshore of Galveston, TX. It was determined that the SKS Satilla had hit the sunken MODU that was submerged approximately 24 feet below the surface of the water, that had been missing since Hurricane Ike. The MODU was displaced off the coast of Louisiana during Hurricane Ike and ended up off the coast of Galveston, roughly 105 miles away.

The information to be collected is necessary for BSEE to assess the whereabouts of any MODU becoming unmoored due to extreme weather situations; as well as, to follow the path of that facility to determine if other facilities/pipelines, etc., were damaged in any way. The offshore oil and gas industry will use the information to determine the safest and quickest way to either remove the obstacles or to fix and reuse them.

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 and specifically how this collection meets GPEA requirements.

Respondents may electronically notify BSEE with the relevant information.

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.

No information submitted will be duplicative; the information collected is unique to each MODU. Similar information is not available from other sources. The Department of the Interior and the USCG has Memoranda of Understanding that define the respon­sibilities of their agencies with respect to activities in the OCS. These are effective in avoiding duplication of regulations and reporting requirements.

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

This collection of information could have a significant economic effect on a substantial number of small entities. Any direct effects primarily impact the OCS lessees and operators. However, many of the OCS lessees and operators may have less than 500 employees and are considered small businesses as defined by the Small Business Administration. The known and potential damage to OCS facilities due to severe weather conditions is such that the hour burden on any small entity subject to these requirements cannot be reduced to accommodate them without jeopardizing safety and environmental concerns.

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.

The known and potential damage to OCS facilities by severe weather is such that the information must be collected to ensure safety of operations and pollution prevention and thus prevent future vessel accidents. The frequency of submission is on occasion.

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

(a) requiring respondents to report information to the agency more often than quarterly;

(b) requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

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

(d) requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than 3 years;

(e) 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;

(f) requiring the use of statistical data classification that has been reviewed and approved by OMB;

(g) 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 of data with other agencies for compatible confidential use; or

(h) 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.

Not applicable in this collection.

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 in response to the PRA statement associated with the collection over the past 3 years 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 obtained or those who must compile records should occur at least once every 3 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.

As required in 5 CFR 1320.8(d), BSEE published a 60-day notice in the Federal Register (80 FR 29743, May 22, 2015). Also, 30 CFR 250.199 explains that we will accept comments at any time on the information collection burden of our 30 CFR 250 regulations. The regulations inform the public that they may comment at any time on a collection of information and provide the address to which they should send comments. We display the OMB control numbers and provide the address for sending comments to BSEE. The required PRA public disclosure and comment statement is displayed on the NTL. We received no comments in response to the Federal Register notice or unsolicited comments.

To prepare this information collection renewal request, companies were contacted to determine the estimated burden this subpart places on respondents: The following company representatives that commented were:

Angel Rodriguez, Marine Technical Advisor, BP America Inc,

200 Westlake Park Boulevard, Houston, TX 77079

Susan Wilson, Lead Regulatory Specialist, GHP Billiton Petroleum (GOM) Inc,

1360 Post Oak Blvd, Suite 150, Houston TX 77056

The respondents had no concerns regarding the availability of data, frequency of collection, clarity of instructions, and elements being collected. The respondents did identify some non-hour cost burdens that we were not aware of; therefore, we have incorporated these non-hour costs burdens into the collection and they are reflected in the burden table in Section A.12. These same respondents/companies provided the hour burden estimates as well.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

We will not provide payment or gifts to respondents in this collection.

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

BSEE will protect proprietary information according to the Freedom of Information Act (5 U.S.C. 552) and DOI’s implementing regulations (43 CFR 2), and 30 CFR 250.197, Data and information to be made available to the public or for limited inspection.

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 collection does not include sensitive or private questions.

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

(a) 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 hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

(b) If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

Potential respondents comprise Federal oil and gas lessees and operators that drill using MODUs. It should be noted that not all of the potential respondents will submit information in any given year and some may submit multiple times. We expect that there are approximately 80 Gulf of Mexico OCS MODUs already equipped with a tracking/locator system. Each MODU requires multiple tracking/locator devices for redundancy. Since the lessees and operators have already installed the GPS systems, this IC covers only burdens for:
- replacing/repairing locator devices and/or adding devices for new MODUs added to the group;

- paying monthly rental fees for GPS tracking purposes only, or

- paying rental fees for the GPS devices themselves as well as associated tracking information.

The frequency of response is on occasion and responses are required to obtain and/or retain a benefit. In calculating the burdens, we obtained information from companies, listed in Section A.8., that supply these kinds of equipment and services. We estimate the total annual burden hours to be 1, as detailed in the following chart.

BURDEN BREAKDOWN

NTL - GPS for MODUs Gulf of Mexico OCS Region	Hour Burden		Average No. of Annual Responses	Annual Burden Hours
	Non-Hour Cost Burdens
1 – Notify BSEE with tracking/locator data access and supporting information; notify BSEE Hurricane Response Team as soon as operator is aware a rig has moved off location.	15 mins.	1 rig*		1 hour (rounded)
	15 mins.	1 notification*
2 – Purchase and install tracking/locator devices – (these are replacement GPS devices or new rigs).	20 devices per year for replacement and/or new x $325.00 = $6,500
3 – Pay monthly tracking fee for GPS devices already placed on MODUs/rig.	40 rigs at $50/month = $600/year = $24,000.
4 – Rent GPS devices and pay monthly tracking fee per rig.	40 rigs @ $1,800 per year = $72,000.
TOTAL BURDEN			102 Responses	1 Hour
			$ 102,500 non-hour cost burden

* We have not had to activate any tracking devices since this requirement has been in place.

(c) 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.

The average respondent cost is $91/hour. This cost is broken out in the following table using the Society of Petroleum Engineers (SPE) data dated September 2014. See SPE document/website: http://www.spe.org/industry/docs/14SalarySurveyHighlights.pdf

Position	Hourly Pay rate ($/hour estimate)	Hourly rate including benefits (1.4* x $/hour)	Percent of time spent on collection	Weighted Average ($/hour/ rounded)
Non-Engineering Technical	$65	$91	100%	$91
Weighted Average ($/hour)				$91

*A multiplier of 1.4 (as implied by BLS news release USDL 15-1132, June 10, 2015 (see http://www.bls.gov/news.release/ecec.nr0.htm)) was added for benefits.

Based on a cost factor of $91 per hour, we estimate the hour burden as a dollar equivalent is $91 ($91 x 1 hour = $91).

13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflect in Item 12).

(a) The cost estimate should be split into two components: (1) a total capital and start-up cost component (annualized over its expected useful life) and (2) 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 (including filing fees paid for form processing). 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.

(b) If cost estimates are expected to vary widely, agencies should present ranges of cost burden 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.

(c) 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.

Under this collection, the lessees and operators have already installed the GPS systems; therefore, we estimate a non-hour cost burden of $102,500 which consists of:

- replacing/repairing locator devices and/or adding devices for new MODUs added to the group;

- paying monthly rental fees for GPS tracking purposes only, or

- paying rental fees for the GPS devices themselves as well as associated tracking information.

We have identified no other non-hour cost burdens for this collection of information. See burden table in A.12 for a breakdown of the burdens.

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.

The average government cost is $72/hour. This cost is broken out in the below table using the current Office of Personnel Management salary data for the REST OF THE UNITED STATES (http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/).

Position	Grade	Hourly Pay rate ($/hour estimate)	Hourly rate including benefits (1.5* x $/hour)	Percent of time spent on collection	Weighted Average ($/hour)
Clerical	GS-7/5	$21	$32	5%	$2
Petroleum Engineer	GS-13/5	$45	$68	75%	$51
Supv. Petroleum Engineer	GS-15/5	$63	$95	20%	$19
Weighted Average ($/hour)					$72

* *A multiplier of 1.5 (as implied by BLS news release USDL 15-1132, June 10, 2015, 2014 (see http://www.bls.gov/news.release/ecec.nr0.htm)) was added for benefits.

To analyze and review the information respondents submit, we estimate the Government will spend an average of approximately 5 hours for every 1 hour spent by respondents. The total estimated Government time is (5 x 1 = 5) hours. Based on a cost factor of $72 per hour, the cost to the government would be $360 (1 burden hours x 5 = 5 hours x $72 = $360).

15. Explain the reasons for any program changes or adjustments in hour or cost burden.

The currently approved OMB inventory includes 1 burden hour and $102,500 non-hour cost burdens associated with this collection. In this ICR, both the hour and non-hour cost burdens will remain the same, as based on input from industry, listed in A.8.

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.

BSEE will not publish the data.

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.

Not applicable. BSEE is not seeking a waiver from the requirement to display the expiration date of the OMB approved IC.

18. Explain each exception to the topics of the certification statement identified in, “Certification for Paperwork Reduction Act Submission.”

Not applicable. To the extent that the topics apply to this collection of information, BSEE is not making any exceptions to the Certification for Paperwork Reduction Act Submissions.