0648-0448 Supporting Statement Part A 2021-0702

SUPPORTING STATEMENT

U.S. Department of Commerce

National Oceanic & Atmospheric Administration

Coral Reef Conservation Program

OMB Control No. 0648-0448

Abstract

This request is for extension of a currently approved information collection.

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 Coral Reef Conservation Act of 2000 (16 U.S.C. 6401 et seq.) was enacted on December 14, 2000, to preserve, sustain and restore the condition of coral reef ecosystems; to promote the wise management and sustainable use of coral reef ecosystems to benefit local communities and the Nation; to develop sound scientific information on the condition of coral reef ecosystems and the threats to such ecosystems; to assist in the preservation of coral reefs by supporting conservation programs, including projects that involve affected local communities and non-governmental organizations; to provide financial resources for those programs and projects; and to establish a formal mechanism for the collecting and allocating of monetary donations from the private sector to be used for coral reef conservation projects. Under section 6403 of the Act, the Secretary is authorized to provide matching grants of financial assistance for coral reef conservation projects. Section 408(c) of the Act authorizes at least $8,000,000 annually for financial assistance projects under the Program.

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.

Collection activities for this program are outlined below and include: 1. Applicant creation and submission of requests for waivers of the non-Federal matching funds requirement; and 2. Review of project proposals by Federal Agencies and non-Federal entities with jurisdiction or management authority over coral reef ecosystems in the area where the project is to be conducted.

As per section 6403(b) of the Act, NOAA will require that Federal funds for any coral conservation financial assistance project may not exceed 50 percent of the total cost. However, the Administrator may waive all or part of the matching requirement if the Administrator determines that no reasonable means are available through which an applicant can meet the matching requirement and the probable benefit of the project outweighs the public interest in the matching requirement. The suitability for a waiver is determined after the applicant has submitted a written request with the application package and provided the proper justification.

As per section 6403(f) of the Act, NOAA will review eligible coral reef conservation proposals using an external governmental review and merit-based peer review. As part of this review, NOAA will request and consider written comments on the proposal from each Federal agency, state government, or other government jurisdiction, including the relevant regional Fishery Management Councils established under the Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq.), or any National Marine Sanctuary, with jurisdiction or management authority over coral reef ecosystems in the area where the project is to be conducted. Pursuant to this requirement of the Act, NOAA will apply the following standard in requesting comments: (A) Proposals for projects in state or territorial waters, including Federal marine protected areas in such waters (e.g., National Marine Sanctuaries), will be submitted to that state or territorial government’s designated U.S. Coral Reef Task Force point of contact for comment; (B) proposals for projects in Federal waters will be submitted to the relevant Fishery Management Council for comment; (C) proposals for projects which require Federal permits will be submitted to the Federal agency which issued the permit for comment; (D) proposals for projects in Federal marine protected areas managed by Federal agencies (e.g., National Wildlife Refuges, National Parks, National Marine Sanctuaries, etc.) will be submitted to the respective Federal management authority for comment; and (E) NOAA will seek comments from other government entities, authorities, and/or jurisdictions, including international entities for projects proposed outside of U.S. waters, as necessary based on the nature and scope of the proposed project.

Match Waivers Requests. A request for a full or partial waiver to the required 1:1 non-federal matching funds is made by an applicant when there are no reasonable means available to meet the requirement and the probable benefit of the proposed project outweighs the public interest in such matching requirement, as stated in the Coral Reef Conservation Act of 2000. The request letter is only used for the purpose of determining whether or not a waiver should be granted and is attached to the official award file for future reference. There are no other uses for these request letters.

Application Reviews. The Coral Reef Conservation Act of 2000 states that not later than 6 months after receiving a project proposal, the proposal must be shared with the relevant Federal agencies, State governments, or other government jurisdiction with jurisdiction or management authority over coral reef ecosystems in the area where the project is to be conducted for written comment to be considered. These reviews and comments are for internal use only and are not shared publicly. The review is not mandatory and selections will be made based on the selection criteria identified in the Notice of Funding Opportunity.

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.

Information will be collected electronically via the Department of Commerce Grants Online system. In the event that electronic submission is not available, paper submissions may be allowable pursuant to the Notice of Funding Opportunity.

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 Question 2

Information collected is specific to the Coral Reef Conservation Program and is not expected to be duplicated. The applicant/recipient would not make this information publicly available, so there is no other source from which this information could be obtained.

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

Small businesses are eligible applicants and instructions are written to require a minimal burden of all applicant types.

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.

In order to maintain the grant program meet all legal requirements mentioned above, the collection may not be collected less frequently than annually, however, individual competitions are set to occur at different lengths so that individual applicants may not be required to submit collections annually.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines.

There are currently no known circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines.

8. If applicable, provide a copy and identify the date and page number of publications 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 describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

A notice was published in the Federal Register on March 22, 2021 (86 FR 15204). No comments were received.

NOAA reached out to 8 of individuals 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. No comments were received.

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

The agency does not plan to provide a payment or gift to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

In order to maintain confidentiality of Personal Identifiable Information (PII) (i.e., SSNs) and Business Identifiable Information (BII), all submissions are sent to the agency through a secured system, Grants Online (DOC) via grants.gov (Federal). Applicants may also submit confidential information through certified mail or another secure service of their choice. NOAA shares applications for review through either the Grants Online system or Accellion Kiteworks (secured).

Grants Online is hosted within the boundary of NOAA system of record 1101 and a current PIA is on file.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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 agency does not find these types of questions necessary and does not ask them.

12. Provide estimates of the hour burden of the collection of information.

Information Collection	Type of Respondent (e.g., Occupational Title)*	# of Respondents/year (a)	Annual # of Responses / Respondent (b)	Total # of Annual Responses (c) = (a) x (b)	Burden Hrs / Response (d)	Total Annual Burden Hrs (e) = (c) x (d)	Hourly Wage Rate (for Type of Respondent)* (f)	Total Annual Wage Burden Costs (g) = (e) x (f)
CRCP Administration Matching Funds Waiver Request	General and Operations Manager	5	1	5	2.1	10.5	$60.45	$634.73
CRCP Reviewer Comments	General and Operations Manager	7	6	42	3	126	$60.45	$7,616.70
Totals	En			47		136.5		$8,251.43

The BLS’s Occupational Outlook Handbook - https://www.bls.gov/bls/blswage.htm was used to determine hourly wage rates.

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13. Provide an estimate for 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 already reflected on the burden worksheet).

Record keeping is done electronically by the Grants Online system. There is no measurable cost associated with this activity. There are no capital costs or operating and maintenance costs associated with this information collection.

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.

Cost Descriptions	Grade/Step	Loaded Salary /Cost	% of Effort	Fringe (if Applicable)	Total Cost to Government
Federal Oversight	GS-13/5 (x 1)	$117,516	10%		$11,752
Other Federal Positions	GS-12/8 ( x 3)	$107,548	10%		$32,264
Contractor Cost (x 7)		$70,000	5%	n/a	$24,500
Travel
Other Costs:
TOTAL				n/a	$68,516

15. Explain the reasons for any program changes or adjustments reported in ROCIS.

The number of respondents, responses, and time burden has been updated to correct the methodology used to calculate those numbers. Previously, all merit reviewers’ time was included. This was an inaccurate estimate as it did not separate Federal and contract staff from the public and counted all merit reviews for each application instead of just review of relevant Federal agencies, State governments, or other government jurisdiction with jurisdiction or management authority over coral reef ecosystems in the area where the project is to be conducted as required by the Coral Reef Conservation Act of 2000. The NOAA federal and contractor staff information has been removed from the estimates below, resulting in a decrease in burden for those areas.

The annual cost to the federal government was also recalculated in this revision to more accurately reflect the time and effort of the government spent on this collection. The previous government cost was cited as $4,458.

Information Collection	Respondents		Responses		Burden Hours		Reason for change or adjustment
	Current Renewal / Revision	Previous Renewal / Revision	Current Renewal / Revision	Previous Renewal / Revision	Current Renewal / Revision	Previous Renewal / Revision
CRCP Administration Matching Funds Waiver Request	5	11	5	11	10.5	17
CRCP Reviewer Comments	7	78	42	140	126	280	.
Total for Collection	12	89	47	151	136.5	297
Difference	-77		-104		-160.5

Information Collection	Labor Costs		Miscellaneous Costs		Reason for change or adjustment
	Current	Previous	Current	Previous
CRCP Administration Matching Funds Waiver Request	$634.73	Not previously calculated	$0	$0
CRCP Reviewer Comments	$7,616.70	Not previously calculated	$0	$35	All submissions are electronic, so there are no longer misc. costs to the respondent.
Total for Collection	$8,251.43	N/A	$0	$35	f
Difference	+ 8,251.43		-$35

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.

This information is not published or made publicly available.

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.

The agency plans to display the expiration date for OMB approval of the information collection on all instruments.

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

The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

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