1028-0070 Part A Consumers Rpt 2017-04-17

1028-0070 Part A Consumers Rpt 2017-04-17.docx

Consolidated Consumers' Report (Form 9-4117-MA)

OMB: 1028-0070

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Supporting Statement A


Consolidated Consumers’ Report (1 form: 9-4117-MA)


OMB Control Number 1028-0070


Terms of Clearance: None



Justification


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


The authorities for this collection are:

  • National Materials and Minerals Policy, Research and Development Act of 1980 (30 U.S.C. 1601 et seq.)

  • National Mining and Minerals Policy Act of 1970 (30 U.S.C. 21(a))

  • Strategic and Critical Materials Stock Piling Act (50 U.S.C. 98 et seq.)

_____________________________________


The U.S. Department of the Interior (DOI) has policy responsibility for the Nation’s mineral resources and their derived industries. The National Mining and Minerals Policy Act of 1970 (30 U.S.C. 21(a)) and the National Materials and Minerals Policy, Research and Development Act of 1980 (30 U.S.C. 1601 et seq.) make it incumbent upon the Secretary of the Interior to be informed about and to inform the Congress of important developments, including crises, in the minerals industries. Many of the responsibilities regarding mineral resources are assigned to the U.S. Geological Survey (USGS), where they are discharged through a staff that includes chemists, economists, engineers, geologists, mineral commodity specialists, and physicists.


Two fundamental activities—mining and agriculture—form the basis of the Nation’s wealth because they furnish all the raw materials and most of the energy that are used in all other industries. Additionally, the mining industry supplies the fertilizers, pesticides, and soil conditioners that significantly enhance the performance of the agricultural sector. For those raw materials not produced domestically in sufficient quantities, supplies must be imported. This adversely affects the U.S. balance of trade and, for some materials, puts U.S. industries at risk of supply disruptions because of global political developments. Imports may also compete with domestic production, thus jeopardizing U.S. jobs. Accordingly, the Government requires accurate, timely data on raw materials production and related industries to formulate policies that ensure national security and economic well-being. The USGS canvass forms are the fundamental means by which data on minerals, mining, and related materials production are obtained.


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.


The data obtained from this collection are used by Government agencies, Congressional offices, educational institutions, research organizations, financial institutions, consulting firms, industry, and the public. These data provide ways of identifying consumption trends, making demand analyses on varying time cycles, and assembling meaningful conclusions concerning such important indicators as industry vitality. The consumption of the 12 metal and ferroalloys on this form is highly variable and must be analyzed each month to furnish information and data for reports and indexes that are prepared more frequently than on an annual basis.


With this information collection, the USGS collects and analyzes data on consumption and stocks of the 12 metals and ferroalloys listed on this form—a number of which have traditionally been considered as strategic and critical. Each company reports commodity data consistent with industry standards and as mutually agreed upon by the company and the USGS mineral commodity specialists.


Information gathered from this collection is used by the Secretary of the Interior in the annual report to the Congress on the state of domestic mining and mineral industries as required by 30 U.S.C. 1601 et seq. The USGS routinely uses this information to provide analyses and data for decision-making purposes to the Congress and various Presidential councils and commissions. The National Security Council, in particular, has frequently used USGS data in relation to materials mobilization studies and sustainability analyses.


The data collected are analyzed and used by the USGS to issue, as promptly as possible, various publications that provide essential information while carefully protecting trade secrets and privileged or proprietary commercial or financial information. These data form a substantial part of the internal USGS Minerals Information Data System (MIDS), which the USGS uses in legislative programs, research programs, economic studies, analyses, and land use and environmental impact studies. These data are also used to respond to nationwide and global requests for minerals information.


Furthermore, the Strategic and Critical Materials Stock Piling Act (50 U.S.C. 98 et seq.) requires the Secretary to collect data on strategic and critical materials to assist in determining stockpile goals. The Secretary assigned this responsibility for data collection to the U.S. Bureau of Mines (USBM) and transferred the responsibility to the USGS after the USBM was abolished in 1996.


Uses of the Information


The U.S. Department of Commerce (DOC) uses these USGS data in studies of minerals mobilization, to recommend trade policy and to resolve disputes under the International Trade Administration, to assist in export development, to develop materials research, to develop annual data on the output of U.S. industries, to develop global mineral production and trade data, and to derive gross domestic product estimates by industry and by State under the Bureau of Economic Analysis.


The U.S. Department of State (DOS) uses USGS data to support global commodity negotiations, to analyze relations with foreign mineral producers, to recommend tariffs and quotas, and to develop a global minerals database.


The U.S. Agency for International Development (USAID) uses USGS data to assist in determining which minerals are of interest to the United States for development in developing nations.


The Federal Trade Commission (FTC) and the U.S. International Trade Commission (USITC) use USGS data in studies of antitrust activities, unfair trade practices, and false advertising or misrepresentation of mineral goods or commodities.


The U.S. Department of Defense (DOD) uses USGS data to determine research on materials and minerals within research laboratories of the Army, Navy, and the Air Force, sea lanes that must be protected, Defense Production Act Title III projects; National Defense Stockpile (NDS) goals and specifications; details of procurement, storage and disposal; and suppliers of mineral commodities.


The Federal Reserve Board uses USGS data to develop periodic (monthly, quarterly, and annual) indicators of industrial production and capacity and capacity utilization.


The National Science Foundation (NSF), the National Academy of Sciences, the National Academy of Engineering, and the National Research Council use USGS data to ensure maximum benefits from all mineral research.


The U.S. Department of Transportation (DOT), the Interstate Commerce Commission, and the U.S. Army Corps of Engineers use USGS data to determine national and State transportation requirements for the minerals industry.


In addition to the use of USGS data by the majority of Federal Government departments, reports and information are in demand by many types of organizations, including the following:


  • Participating companies

  • Industrial marketing groups

  • Industrial and agricultural sectors

  • Electric utilities

  • Financial institutions

  • The general public, especially academic, consulting, and legal organizations

  • Export associations

  • Global industry associations

  • Minerals management companies

  • State governments


  • Domestic trade associations




Sectors of the public that use the data collected by the USGS include, but are not limited to: concrete, construction, metals, ceramics, refractories, electric utilities, electronic engineering, chemical, coal, paper, rubber, plastics, and agricultural industries. The USGS customer base (recipients of these data) is well over 35,000 entities and increases considerably each year.


The Department of Energy (DOE), the Department of Homeland Security (DHS), the World Bank, the Federal Highway Administration (FHA), and most of our sister agencies within the DOI also rely on these data. The data collected are used to determine the economic health of the Nation, factored into the gross domestic product, and used in forecasts and trend projections in the building and construction industries, which are closely linked to the issue of rebuilding the infrastructure of the country. This information is not available from any other source.


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.


On-line electronic forms, which collect the same data as the paper forms, are available to registered users at the Minerals Information Data System Web site (https://mids.er.usgs.gov). Immediate on-line registration is available where new users are granted immediate access. For security purposes, additional new users (two or more) for the same operation will be notified automatically by email if another user signs up for the same operation.


We expect that 19% of the universe for this information collection will continue to be registered to respond electronically. Paper forms will remain an option for submission because not all industry respondents are able to or wish to transmit their data to the USGS by electronic means.


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.


These data are not collected by any other Federal or State agency, trade association, or other public sources. To avoid duplication, the USGS reviews data collection practices with other agencies, including the U.S. Department of Labor, DOC, and USITC, as well as industry associations such as the American Iron and Steel Institute, the Institute of Scrap Recycling Industries, the International Tungsten Industry Association, the International Chromium Development Institute, the International Copper Study Group, and the International Lead and Zinc Study Group.


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


The canvass form is designed to minimize the burden to all respondents by only requesting essential data. The format is common to the reporting industry.


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 USGS provides information necessary for sound Federal, State, and industry decision-making. If data are not made available as soon as possible, or canvasses were conducted less frequently, the monitoring of stockpile materials for national defense would be impeded by the gap in statistics. The level of domestic and foreign productivity and economic fluctuation would be much less apparent or missed, and that data simply would not be timely enough to be reliable for decisions that affect minerals vulnerability, potential environmental impacts, current economic trends, and future needs. These decisions, in turn, have an effect on such aspects of our economy as taxes, royalty payments, tariffs, land use, environmental regulations, water use, and transportation.


Collection of monthly and annual data allows economic analysis that can capture variations that a longer time interval could not. Collection of these data on a biennial basis would not be practical because the industry respondents do not normally have the data in convenient format except on a monthly, quarterly, semiannual, or annual basis. A 2-year canvass, for example, would require respondents to alter their accounting procedures or manually add 2 years of data. This would increase their reporting burden. Also, multiyear data are less meaningful and less convenient for analysis by industry and other Government agencies.


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 that is not designed to produce valid and reliable results that can be generalized to the universe of study;

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

* 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.


The data collected by the monthly canvass are absolutely necessary if the USGS is to meet the demands for current, reliable information for industry and Government mineral analysts who prepare monthly and bimonthly indexes and commodity reports to analyze the industry. Additionally, the data are necessary if the USGS is to meet the requirements of 30 U.S.C. 21(a) for the minerals that have erratic supply, demand, value, availability, or seasonal production patterns. The ferrous and related metals covered by this canvass have volatile markets or seasonal production patterns; therefore users of the published information are able to track trends on a monthly basis. Collecting data on a monthly basis, rather than at less frequent intervals, such as quarterly, semiannually, or annually will allow important trends to be detected earlier.


Some commodity data are needed monthly because of the importance of these industries to the industrial economy, such as for the transportation, construction, and electronics sectors. DOD planners use these data to evaluate purchase and disposal plans for the NDS. The mining and metal products industries regularly use these data to evaluate production and consumption plans. Minerals policy planners need the most up-to-date information in making decisions concerning these industries.


This collection is consistent with the above provisions; however, under the terms of the USGS standard for handling proprietary data included in the supplementary documents (see the USGS brochure entitled “Proprietary Data—How They are Protected at the U.S. Geological Survey), companies can and usually do specify that the data they supply be shared only in aggregated form. These terms ensure that the USGS will continue to receive proprietary data in confidence.


The canvass form is designed to collect only the required data, thus minimizing the individual response time, and to ensure that respondents are not required to maintain or provide data in a format other than that in which the data are customarily maintained.


If a company receives a monthly canvass, then it will not receive an annual canvass of the same type for those commodities. Most canvasses that are conducted annually are done so for two reasons: (1) because of the small size of the companies involved and (2) the desire to limit reporting burden on them. Although the number of small companies canvassed annually is large, the aggregate data collected is small, thus permitting monthly estimates based on the previous year’s data without significant impact on the overall accuracy of monthly production or consumption. Another reason for instituting an annual reporting basis in these circumstances relates to the willingness or capability of a company to complete a monthly canvass. On a few occasions, exceptions have been made to allow a company to voluntarily report annually on a temporary basis.


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 three 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 three years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.


On January 24, 2017, a 60-day Federal Register notice (82 FR 8206) was published announcing this information collection. Public comments were solicited for 60 days ending March 27, 2017. We did not receive any public comments in response to that notice.


As part of the routine canvassing process, respondents are regularly asked to comment on the design of this form and to make recommendations that help maintain consistency with industry’s methods of accounting. USGS mineral commodity specialists are routinely contacted by Federal and State agencies, Members of Congress, trade associations, the financial community, private companies, universities, and private citizens who request general and specific data and information.


When persons outside the USGS submit requests for information, the USGS mineral commodity specialists and statistical assistants respond in a timely manner. The USGS receives and responds to several thousand e-mail and telephone inquiries each month. During these discussions and interactions, views are exchanged on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, reporting format, data elements to be recorded, disclosed, or reported, burden estimates and other aspects of this information collection. These views help the USGS to improve its data collection and publications.


On the basis of such feedback, information-use patterns are established commodity by commodity. Once patterns are determined, the canvass form is revised to collect data and to meet the information needs. As information request patterns change, the data collected and reported are modified. Within the last 3 years of the Office of Management and Budget approval period for this collection, no direct changes were made to the collection instrument.


The list below identifies industry contacts who were consulted on the burden estimates and other aspects of this information collection. These industry contacts had no suggested changes to the form.


Western Foundries

Longmont, CO

Date of contact: January 9, 2017

Haynes International, Inc.

Kokomo, IN

Date of contact: January 9, 2017

Owens-Illinois Inc.

Tracy, CA

Date of contact: January 12, 2017



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


No payments or gifts are made to respondents.


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


30 U.S.C. 1601 et seq. ensures the confidentiality of all data reported by persons or firms engaged in any phase of mineral or mineral-material production or large-scale consumption.


To implement 30 U.S.C. 1601 et seq., the USGS withholds all data reported as “Company Proprietary Data,” and such data will be disclosed only in the aggregate so as not to reveal the data from a single respondent. USGS policy states that absent specific company permission, aggregated data can be reported only if it represents three or more companies and if no one company accounts for more than 75% of the total or if no two companies account for more than 90% of the total. Except in response to requests by Congress or by Federal defense agencies for appropriate purposes and in some instances to a State government under a cooperative agreement (Memorandum of Understanding), proprietary data will never be disclosed without the specific permission of the company as represented in the disclosure query. The disclosure statement and query are printed on the canvass form.


The USGS standard for handling proprietary canvass data included in the supplementary document, Proprietary Data Brochure, further discusses protections for USGS proprietary data including penalties associated with violations.


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 ask for information of a sensitive nature.


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

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated 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.

* 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.


Variations can be expected in the reporting burden for completion of this form because of the differences in operation size and accounting systems. The data sought are those routinely maintained in the course of business. For some companies with more than one plant, the submission takes the form of a consolidated report covering all company operations. This greatly reduces the reporting burden.


Based on our previous experience and consultation with industry contacts as summarized in response 8, we estimate the total annual burden for this collection of information (including the time for reviewing instructions, searching data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information) to be approximately 1,055 hours. Approximately 263 respondents will report data either monthly or annually. The average completion time is 45 minutes per form.


Table 1: Consolidated estimates of annual burden (private sector)



PRIVATE SECTOR


Form No.

Frequency

Number of

Respondents

Responses

Completion Time

Burden Hours








1

9-4117-MA

Monthly

104

1,248

45 min

936

2

9-4117-MA

Annually

159

159

45 min

119

T O T A L S

263

1,407


1,055


We estimate the total dollar value of this collection to be $34,045 (Table 2 below). We arrived at this figure by multiplying the estimated burden hours for the private sector by the current dollar value (including benefits) of burden hours for the private sector, $32.27. This wage figure is based on the Bureau of Labor Statistics news release USDL-16-0463 for Employer Costs for Employee Compensation—December 2015 at https://www.bls.gov/news.release/archives/ecec_12082016.pdf, dated December 8, 2016.


Table 2: Estimated Dollar Value of Respondent Annual Burden Hours


Activity

Sector

Annual Number of Responses

Total Annual Burden Hours

Dollar Value of Burden Hours (Including Benefits)

Total Dollar Value of Annual Burden Hours

Completing canvass forms

Private

1,407

1,055

$32.27

$34,045

All

1,407

1,055


$34,045




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 reflected in item 12.)

* 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 (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.

* 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 economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.


There is no non-hour cost burden, recordkeeping, nor any fees associated with collection of this information.


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 total annual cost to the Federal Government is $415,929. This includes the operational expenses of $100,076 (Table 3 below). Operational expenses include mailing, overhead, printing, processing, and non-Federal support.


Table 3: Annualized Operational Expenses and estimated costs


Operational Expenses


Estimated Cost

Printing of canvass forms


$145

Mailing lists compilation and maintenance


$626

Mailing operation


$1,506

Editing, coding, tabulation, analyzing


$53,743

ADP processing


$43,506

Electronic publication of results


$550

Total


$100,076


The total estimated cost to the Federal Government for processing and reviewing information received as a result of this collection is $315,853 (Table 4 below). This includes Federal employee salaries and benefits. The table below shows Federal staff and grade levels performing various tasks associated with this information collection. We used the Office of Personnel Management Salary Table 2016-DCB (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/DCB_h.pdf) for the Washington, D.C. – Baltimore Locality Pay Area to determine the hourly rate. We multiplied the hourly rate by 1.6 to account for benefits (as implied by the BLS news release USDL-16-0463).


Table 4: Federal Employee Salaries and Benefits


11

2

3

42

5

6

Positions

Average grade and step

Estimated average

hourly rate without

benefits

Estimated Federal employee

Hours (annualized)

Estimated average

hourly rate including benefits (1.6 x average

hourly rate)

Estimated Federal employee salary/benefit annualized

costs

Mineral Commodity Specialists

GS-13/8

$56.02

1,690

$89.63

$151,475

Statistical Assistants

GS-7/3

$22.97

2,510

$36.75

$92,243

Computer Specialists

GS-13/8

$56.02

250

$89.63

$22,408

Editors

GS-12/8

$47.11

250

75.38

$18,845

Mineral Records Administrator

GS-11/8

$39.30

70

$62.88

$4,402

Management

GS-14 /8

$66.20

250

$105.92

$26,480







Totals



5,020


$315,853


1 The grades/steps in the table represent an average of several employees at several grades/steps–some of the

employees may work full-time on the collection, while other employees may work part-time.

2 Column 6 / Column 5 (differences due to rounding)


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


We estimate that there will be 1,407 annual responses totaling 1,055 burden hours. This is a net decrease of 497 responses and 373 burden hours from our previous request of 1,904 responses and 1,428 burden hours. The difference represents an adjustment in estimated resources and corresponding burden hours based upon our experience in administering this program over the last 3 years.


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.


The MIDS mainframe system and off-the-shelf software packages such as spreadsheets are used to compile and tabulate the data and to prepare tables for publication. National, State, and regional tabulations are prepared and published annually at https://minerals.er.usgs.gov/minerals/ in table format from data collected by this canvass. Preliminary estimates are prepared and published in the Mineral Commodity Summaries (https://minerals.usgs.gov/minerals/pubs/mcs/) which is the earliest Government publication to furnish estimates covering the previous year’s nonfuel mineral industry. Data are also published in the monthly, quarterly, and annual issues of the Mineral Industry Surveys (https://minerals.usgs.gov/minerals/pubs/commodity/mis.html) series and the Annual Reports from the Minerals Yearbook (https://minerals.usgs.gov/minerals/pubs/myb.html) and other USGS publications.


Tables present various aspects of commodities, such as consumption and production of products together with industry stocks. Economic changes are incorporated and industry trends and activities are studied. Statistical data are processed and analyzed by the USGS National Minerals Information Center’s Data Collection and Analysis Section, which also establishes timing for all key steps in the work.


Tabulation and publication of data are governed by the USGS standard for handling proprietary canvass data. Data are available via the Internet and in print for select publications in the USGS minerals information series.


Monthly, quarterly, and semiannual tables are generally published within 50 workdays from the end of the reporting month. Annual data are generally published within 9 months from the end of the reporting year.


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.


We will display the OMB control number and expiration date on the single form in this collection.


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


There are no exceptions to the certification statement.

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