1014-aa31-pr-ss-2016

Supporting Statement A

30 CFR Part 250, Adjustments to Cost Recovery Fees

OMB Control Number 1014-NEW

Current Expiration Date: New

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

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 Outer-Continental Shelf (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; and to preserve and maintain free enterprise competition.

The Independent Offices Appropriations Act (31 U.S.C. 9701), the Omnibus Appropriations Bill (Pub. L. 104-133, 110 Stat. 1321, April 26, 1996), and OMB Circular A-25, authorize Federal agencies to recover the full cost of services that confer special benefits. Under the Department of the Interior’s implementing policy, BSEE is required to charge fees for services that provide special benefits or privileges to an identifiable non-Federal recipient above and beyond those which accrue to the public at large. Plans, applications, permits, throughout various regulatory requirements in the 30 CFR 250 regulations, are subject to cost recovery and BSEE regulations specifying service fees for these requests are in 30 CFR 250.125.

The proposed rule is a complete revision of the existing non-hour cost burdens under 30 CFR 250; moreover it adds new costs, and revises other costs. OMB approved the IC burden of the current 30 CFR part 250 regulations under Control Numbers 1014-0022, Subpart A (84,391 hour burden, $1,371,458 non-hour cost burden; expiration 8/31/17); 1014-0024, Subpart B ($39,589 non-hour cost burden; expiration 11/30/2018); 1014-0025 Applications for Permit to Drill ($862,104 non-hour cost burden, expiration 4/30/2017); 1014-0026, Applications for Permit to Modify ($361,625 non-hour cost burden, expiration 5/31/2017); 1014-0003, Subpart H ($323,481 non-hour cost burden; expiration 12/31/2017); 1014-0011, Subpart I, ($392,874 non-hour cost burden, expiration 5/31/2017); 1014-0016, Subpart J ($1,508,968 non-hour cost burden, expiration 8/31/2018); 1014-0019, Subpart K ($1,361,176 non-hour cost burden, expiration 1/31/2019); 1014-0002, Subpart L ($322,479 non-hour cost burden, expiration 10/31/2016); 1014-0015, Subpart M ($138,188 non-hour cost burden, expiration 12/31/2017); and 1014-0010, Subpart Q ($1,686,396 non-hour cost burden, expiration 10/31/2016), respectively.

When this proposed rule is finalized and codified, the various non-hour cost burdens and one new hour burden will be removed from this collection of information and consolidated with their primary information collection burden under their respective OMB Control Numbers. Hour burdens are included in the regulatory requirements of various OMB-approved ICRs, of which only one is changing and discussed in this ICR.

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.

One requirement containing hour burdens is being added to 30 CFR 250, subpart A via this proposed rulemaking. In § 250.125(c) operators/lessees may request a refund within 150 days of initial payment. BSEE will use the information submitted in order to fulfill refund requests.

The majority of this collection does not pertain to hour/information burden; it only applies to non-hour cost burdens. Also, the number of annual responses included in this ICR are not changing.

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.

All cost recovery fees that are to be submitted, must be filed electronically through the Pay.gov website. Payments above the current U.S. Treasury credit card limit must be made through the automated clearing house (ACH-debit). The burden to submit the fees and the subsequent confirmation receipts is minimal.

All refunds are requested electronically through:

https://www.data.bsee.gov/homepg/data_center/other/refundrequest/requestrefund.asp.

The information required is as follows:

*Identify method of original payment

Choice of ACH or Credit Card

*Memo (reason requesting refund), all refunds most have a justification.

*Application Name: A drop down box with options to choose one of the 31 fees

*Date of Original Payment:

*Agency Tracking ID:

*Pay.Gov Tracking ID:

*Contact Name:

*Name on Credit Card:

*Fee Amount Paid (US Dollars):

*E-mail address:

*Phone Number (including area code):

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.

The information collected is unique to each lease, and similar information is not available from other sources. None of the cost recovery fees (non-hour cost burdens) that will be submitted are collected by any other Federal agency.

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 an economic effect on a substantial number of small entities. Any direct effects primarily impact the OCS lessees, operators, and pipeline right-of-way users. However, many of these OCS lessees and operators may have less than 500 employees and would be considered small businesses as defined by the Small Business Administration. Under the Department of the Interior’s implementing policy, BSEE is required to charge fees for services that provide special benefits or privileges to an identifiable non-Federal recipient above and beyond those which accrue to the public at large; therefore, the non-hour cost burden cannot be reduced since by doing so the fee would not cover the full cost of the service provided.

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.

If we did not collect these cost recovery fees, we would not be remunerated for the special services we are providing specifically to the oil and gas industry working on the OCS. The Independent Offices Appropriations Act (31 U.S.C. 9701), the Omnibus Appropriations Bill (Pub. L. 104-133, 110 Stat. 1321, April 26, 1996), and OMB Circular A-25, authorize Federal agencies to recover the full cost of services that confer special benefits. Under the Department of the Interior’s implementing policy, BSEE is required to charge fees for services that provide special benefits or privileges to an identifiable non-Federal recipient above and beyond those which accrue to the public at large. Plans, applications, permits, throughout various regulatory requirements in the 30 CFR 250 regulations, are subject to cost recovery and BSEE regulations specifying service fees for these requests are in 30 CFR 250.125.

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;

Operators may submit more than quarterly but are not required to. Cost recovery fees are submitted with plans, applications, permits, etc. There is no set time of when an operator, lessee, or pipeline right-of-way holder will submit such requests along with the respective cost recovery fee since the requests vary depending on the phase of industry’s production and development work process.

(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.

Items (b) through (h) are not required by 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 1320.11(d), BSEE is providing the initial 60-day review and comment process through the preamble of the proposed rulemaking. BSEE will address in the preamble to the final rulemaking any comments received and make necessary adjustments where applicable.

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

BSEE will not provide payments 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 Part 2); and under regulations at 30 CFR 250.197, Data and information to be made available to the public or for limited inspection; and 30 CFR Part 252, OCS Oil and Gas Information Program.

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.

This collection does not include questions of a sensitive nature.

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 include Federal OCS oil, gas, and sulphur lessees/operators, as well as pipeline right-of-way holders. It should be noted that not all of the potential respondents will submit a non-hour cost burden in any given year and some may submit multiple times, including refund requests.

HOUR BURDEN TABLE

Citation 30 CFR 250	Reporting and Recordkeeping Requirements	Hour Burden	Average No. of Annual Responses	Annual Burden Hours
125; 126; 292; 1000; 1015; 1303	Cost recovery fees, applications, confirmation receipts, etc., verbal approvals pertaining to fees.	Cost Recovery Fees and related items are covered individually throughout Part 250		0
Subpart A
125(c)	Request refund, including a reason for the refund, within 150 days of the initial payment.	3 min.	200 requests	10
TOTAL			200 responses	10 hours

(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 $147/hour. This cost is broken out in the following table using the Society of Petroleum Engineers (SPE) data dated September 2015. See SPE document/website: http://www.spe.org/industry/docs/15SalarySurveyHighlights.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)
Finance or Administration	$110.51	$154.72	10%	$15.47
Engineering - Other	$104.23	$145.92	90%	$131.33
Weighted Average ($/hour)				$147

*A multiplier of 1.4 (as implied by BLS news release USDL 16-1808, September 8, 2016 (see http://www.bls.gov/news.release/ecec.nr0.htm)) was added for benefits.

Based on a cost factor of $147 per hour, we estimate the hour burden as a dollar equivalent is $1,470 ($147 x 10 hours = $1,470).

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 reflected 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.

The non-hour cost burden estimates only pertain to the specific fees in regulatory requirements. Since the hour burden is included in the regulatory requirements of various OMB approved ICRs, which are not changing, it is not discussed, nor is it shown in the burden table. Submissions generally vary by section. All responses are mandatory. We currently receive $7,366,838 in cost recovery fees (non-hour cost burdens); this rulemaking proposes increasing that total by $8,620,949 for a total of $15,987,787. Refer to the following table for a breakdown of the burdens.

[Existing non-hour cost burden/cost recovery fees are in regular font; proposed non-hour cost burden/cost recovery fees and text are in italic font; new fees are in bold font]

NON-HOUR COSTS BURDEN BREAKDOWN

Citation 30 CFR part 250	Service/Cost Recovery Fee	Non-Hour Cost Burdens
Subpart A
171(e)	Suspension of Operations and/or Suspension of Production (SOO/SOP) Request	$2,123 x 646 requests = $1,371,458
		$3,055 x 646 requests = $1,973,530
Subpart B
292(q)	Deepwater Operations Plan [simple and complex]	$3,599 x 11 plans = $39,589
		$14,290 x 7 simple DWOPs = $100,030
		$70,333 x 4 complex DWOPs = $281,332
Applications for Permit to Drill
410(d); 513(b); 1617(a)	Application for Permit to Drill [initial permit]	$2,113 x 408 applications = $862,104
		$10,420 x 408 applications = $4,251,360
Application for Permit to Modify
465(b); 513(b); 613(b); 1618(a); 1704(g)	Application for Permit to Modify [initial permit]	$125 x 2,893 applications = $361,625
		$1,680 x 2,893 applications = $4,860,240
Subpart H
842	New Facility Production Safety System Application for facility with more than 125 components	$5,426 x 1 application = $5,426
		$3,976 x 1 application = $3,976
	Pre-production Inspection – offshore	$14,280 x 1 offshore = $14,280
		$13,534 x 1 offshore = $13,534
	Pre-production Inspection – shipyard	$7,426 x 1 shipyard = $7,426
		$14,567 x 1 shipyard = $14,567
842	New Facility Production Safety System Application for facility with 25-125 components	$1,314 x 4 applications = $5,256
		$548 x 4 applications = $2,192
	Pre-production Inspection – offshore	$8,967 x 1 offshore visit = $8,967
		$8,508 x 1 offshore visit = $8,508
	Pre-production Inspection – shipyard	$5,141 x 1 shipyard = $5,141
		$9,818 x 1 shipyard = $9,818
842	New Facility Production Safety System Application for facility with fewer than 25 components	$652 x 10 applications = $6,520
		$463 x 10 applications = $4,630
	Pre-production Inspection – offshore	$4,338 x 1 offshore visit = $4,338
	Pre-production Inspection – shipyard	$1,967 x 1 shipyard = $1,967
842	Production Safety System Application – Modification with more than 125 components reviewed	$605 x 174 applications = $105,270
		$1,278 x 174 applications = $222,372
	Pre-production Inspection – offshore	$9,313 x 1 shipyard visit = $9,313
	Pre-production Inspection – shipyard	$8,100 x 1 shipyard visit = $8,100
842	Production Safety System Application – Modification with 25-125 components reviewed	$217 x 615 applications = $133,455
		$439 x 615 applications = $269,985
	Pre-production Inspection – offshore	$6,765 x 1 offshore = $6,765
	Pre-production Inspection – shipyard	$7,326 x 1 shipyard = $7,326
842	Production Safety System Application – Modification with fewer than 25 components reviewed	$92 x 345 applications = $31,740
		$386 x 345 applications = $133,170
	Pre-production Inspection – offshore	$4,513 x 1 offshore = $4,513
	Pre-production Inspection – shipyard	$2,141 x 1 shipyard = $2,141
Subpart I
905(l)	Platform Application – Installation – Under the Platform Verification Program	$22,734 x 3= $68,202
		$28,311 x 3 = $84,933
905(l)	Platform Application – Installation – Fixed Structure Under the Platform Approval Program	$3,256 x 12 = $39,072
		$1,914 x 12 = $22,968
905(l)	Platform Application – Installation – Caisson/Well Protector	$1,657 x 20 = $33,140
		$1,914 x 20 = $38,280
905(l)	Platform Application – Modification/Repair	$3,884 x 65 applications = $252,460
		$1,975 x 65 applications = $128,375
Subpart J
1000(b)	Submit application and all required information and notices to install new lease term pipeline (L/T P/L).	$3,541 x 61 L/T P/L applications = $216,001
	Submit application and all required information and notices to modify a L/T P/L – Shallow Water (less than 1,000 ft.)	$1,584 x 2 applications = $3,168
	Submit application and all required information and notices to modify a L/T P/L – Deepwater (greater than 1,000 ft.)	$3,663 x 59 applications = $216,117
1000(b)	Submit application and all required information and notices to modify a L/T P/L	$2,056 x 102 L/T P/L applications = $209,712
	Submit application and all required information and notices to modify a L/T P/L - Minor	$651 x 99 minor modifications = $64,449
	Submit application and all required information and notices to modify a L/T P/L - Major	$1,696 x 3 major modifications = $5,088
1000(b)	Pipeline Application Modification (ROW)	$4,169 x 190 applications = $792,110
	Pipeline Application Modification (ROW) - Minor	$455 x 184 minor applications = $83,720
	Pipeline Application Modification (ROW) - Major	$1,800 x 6 major applications = $10,800
1008(e)	Pipeline Repair Notification	$388 x 156 = $60,528
	Pipeline Repair Notification	$557 x 156 notifications = $86,892
1015(a)	Pipeline ROW Grant Application	$2,771 x 62 applications = $171,802
	Pipeline ROW Grant Application – Shallow Water (less than 1,000 ft.)	$1,662 x 38 ROWs in shallow water = $63,156
	Pipeline ROW Grant Application – Deepwater (greater than 1,000 ft.)	$3,796 x 24 ROWs in Deepwater = $91,104
1015(a)	Pipeline Conversion of Lease Term to ROW	$236 x 15 applications = $3,540
		$494 x 15 applications = $7,410
1018(b)	Pipeline ROW Assignment	$201 x 275 P/L ROW requests = $55,275
		$397 x 275 P/L ROW requests = $109,175
Subpart K
1156(a)	500 Feet From Lease/Unit Line Production Request	$3,892 x 20 requests = $77,840
		$5,440 x 20 requests = $108,800
1157	Gas Cap Production Request	$4,953 x 22 requests = $108,966
		$11,962 x 22 requests = $263,164
1158(a)	Downhole Commingling Request	$5,779 x 30 requests = $173,370
		$14,064 x 30 requests = $421,920
Subpart L
1202(a); 1203(b); 1204(a).	Complex Surface Commingling and Measurement Application	$4,056 x 67 applications = $271,752
		$8,205 x 67 applications = $549,735
1202(a); 1203(b); 1204(a).	Simple Surface Commingling and Measurement Application	$1,371 x 37 applications = $50,727
		$3,514 x 37 applications = $130,018
Subpart M
1303(d)	Voluntary Unitization Proposal or Unit Expansion	$12,619 x 8 requests = $100,952
		$27,288 x 8 requests =$218,304
	Unitization Revision	$896 x 41 revisions = $36,736
	Unitization Revision – Exhibit A, Exhibit B, and Successor Unit Operator/Sub-operator	$1,683 x 36 Exhibit A/B = $60,588
	Unitization Revision – Exhibit C	$3,255 x 5 Exhibit C = $16,275
Subpart Q
1727	Application to Remove a Platform or Other Facility	$4,684 x 240 applications = $1,124,160
		$2,846 x 240 applications = $683,040
1751(a); 1752(a)	Application to Decommission a Pipeline (Lease Term)	$1,142 x 213 applications = $243,246
		$857 x 213 applications = $182,541
1751(a); 1752(a)	Application to Decommission a Pipeline (ROW)	$2,170 x 147 applications = $318,990
		$980 x 147 applications = $144,060
NEW NON-HOUR COST BURDEN		$44,463
REVISED NON-HOUR COST BURDEN		$15,943,324
TOTAL NEW and Revised Non-Hour Cost Burdens		$15,987,787

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 $69/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 (1.6* x $/hour)	Percent of time spent on collection	Weighted Average ($/hour)
Financial Analyst	GS-13/5	$45.86	$68.79	100%	$68.79
Weighted Average ($/hour)					$69

*A multiplier of 1.4 (as implied by BLS news release USDL 16-1808, September 8, 2016 (see http://www.bls.gov/news.release/ecec.nr0.htm)) was added for benefits.

To analyze and review the information required by § 250.125(c), we estimate the government will spend an average of 0.5 hour for each hour spent by respondents for a total of 5 burden hours.

Based on a cost factor of $69 per hour, we estimate the total gross annualized cost to the Government is $345 (10 hours x 0.5 hour = 5 hours x $69 = $345).

The rest of this ICR covers an increase in cost recovery fees; therefore, there is no additional cost to the Federal government for those items.

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

This is a new collection of information; therefore, represents a program increase of 10 burden hours. Once the requirements of this rulemaking have been codified, BSEE will consolidate these additional burden hours into the primary collection for 30 CFR 250, Subpart A, under OMB Control Number 1014-0022.

This ICR includes changes to BSEE’s cost recovery program due to rulemaking. A large portion of the non-hour cost burdens are not new requirements, but the fees have been revised (both increases and decreases). We currently receive $7,366,838 in cost recovery fees (non-hour cost burdens); this rulemaking proposes increasing that total by $8,620,949 for a total program change of $15,987,787. The actual program increases are those burdens indicated as Revised or NEW in the burden table displayed in Section A.13 above.

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 tabulate or 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.

There are no forms in this information collection request; however, BSEE displays the OMB control number at § 250.199. BSEE will post the OMB control number and expiration date on the refund request webpage.

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

We are not making any exceptions to the “Certification for Paperwork Reduction Act Submissions.”