0056 2022 Ss (20221115)

November 2022

SUPPORTING STATEMENT

Horse Protection Regulations

OMB NO. 0579-0056

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Horse Protection Act (HPA) of 1970 (P.L. 91-540), as amended July 13, 1976 (P.L. 94-360), was enacted to prevent showing, exhibiting, selling, or auctioning of “sore” horses, and certain transportation of sore horses in connection therewith, at horse shows, horse exhibitions, horse sales, and horse auctions. “Soring” is a process whereby chemical or mechanical agents, or a combination thereof, are applied to the limbs(s) of a horse in order to exaggerate its gait(s). A “sore” horse is one that has been subjected to prohibited practices and, as a result, suffers, or can reasonably be expected to suffer, physical pain or distress, inflammation, or lameness when walking, trotting or otherwise moving. A horse that is “sore” is prohibited from entering or participating in HPA-regulated events because exhibitors, owners, and trainers of such horse may obtain unfair advantage over individuals exhibiting horses that are not “sore.”

Section 1828 of the HPA authorizes the promulgation of regulations to implement the provisions of the Act. Those regulations are found in Title 9, Chapter I, Part 11, of the Code of Federal Regulations. Part 11 delineates the responsibilities of horse industry organizations (HIOs), designated qualified persons (DQPs), management of regulated horse events, and persons who have control over regulated horses [Sections 1823 and 1824 of the HPA]. An HIO wishing to certify a program to license DQPs to inspect horses for compliance under the HPA must satisfy and abide by the requirements of the HPA and regulations. After requesting and receiving USDA certification from Animal and Plant Health Inspection Service (APHIS), HIOs must maintain an acceptable DQP program and recordkeeping systems. Managers and operators of HPA-regulated events may appoint and retain the services of DQPs to inspect and detect a horse that is sore or otherwise noncompliant with the HPA, and both managers and DQPs are required to provide and/or maintain certain information. Persons who own, train, show, exhibit, sell, transport, or otherwise have custody of, or direction or control over any horse shown, exhibited, sold, or auctioned or entered for the purpose of being shown, exhibited, sold, or auctioned at any horse show, horse exhibition, or horse sale or auction must also satisfy and abide by the requirements of the HPA and regulations.

APHIS works with HIOs on an ongoing basis to oversee their performance under the HPA.  Throughout the year, APHIS uses training sessions, conference calls, and open letters to HIOs, event managers, exhibitors, owners, trainers, custodians, and farriers involved in HPA-covered activities to provide communication and feedback to address issues and strengthen enforcement under the Act.  Data collected throughout the year from within APHIS and from the HIOs and event management provide an account of the HIOs’ performance and progress toward eliminating the soring of horses and promoting fair competition.  HIOs, through their certified licensing programs for DQPs, provide the primary means of detecting sored horses.

Title 9, Chapter I, Part 12, of the Code of Federal Regulations provides the Rules of Practice applicable to adjudicatory, administrative proceedings under Sections 1825(a), (b) and (c) of the HPA. Subpart A incorporates the Uniform Rules of Practice for the Department of Agriculture promulgated in subpart H of part 1, subtitle A, title 7, Code of Federal Regulations. Subpart B sets forth Supplemental Rules of Practice allowing stipulations in settlement of particular matters if specified procedures are followed.

APHIS is asking OMB to approve, for an additional 3 years, the use of these information collection activities to enforce the HPA.

2. Indicate how, by whom, how frequently, 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.

APHIS uses the following information collection activities to enforce the Horse Protection Act.

Access to and Inspection of Event Management Records; (9 CFR 11.5(a)(1) and 11.23(a)); (Business; Not-for-Profit)

The management of any regulated event must provide APHIS representatives with unlimited access to any records required to be kept by regulation or otherwise maintained and must permit any APHIS representative to examine and make copies of any and all records pertaining to any horse, either required in any part of the regulations, or otherwise maintained, during ordinary business hours or such other times as may be mutually agreed upon. Such access is needed to ensure required records are being kept and to access and use information relevant to enforcement of the regulations.

Request for Certification of DQP Program and Detailed Outline of Such a Program, Including Standards of Conduct and Procedures for Enforcing Such Standards;
(9 CFR 11.7(b) and 11.7(d)(7)); (Business)

DQPs can only be licensed through USDA certified programs known as HIOs that have received approval to select, train, and monitor these individuals in the performance of their duties. Any HIO or association desiring Department certification to train and license DQP’s under the Act shall submit to the Administrator a formal request in writing for certification of its DQP program and a detailed outline of such program for Department approval. These detailed requests are needed to ensure that HIOs’ programs will meet the requirements of the regulations. The request must include the following elements:

(1) The criteria to be used in selecting DQP candidates and the minimum qualifications and knowledge regarding horses each candidate must have in order to be admitted to the program.

(2) A copy of the formal training program, classroom and practical, required to be completed by each DQP candidate before being licensed by such horse industry organization or association, including the minimum number of hours, classroom and practical, and the subject matter of the training program. Such training program must include the following:

(i) Two hours of classroom instruction on the anatomy and physiology of the limbs of a horse. The instructor teaching the course must be specified, and a resume of said instructor's background, experience, and qualifications to teach such course shall be provided to the Administrator.

(ii) Two hours of classroom instruction on the HPA and regulations and their interpretation. Instructors for this course must be furnished or recommended by the Department.

(iii) Four hours of classroom instruction on the history of soring, the physical examination procedures necessary to detect soring, the detection and diagnosis of soring, and related subjects. The instructor teaching the course must be specified and a summary of said instructor's background, experience, and qualifications to teach such course must be provided to the Administrator.

(iv) Four hours of practical instruction in clinics and seminars utilizing live horses with actual application of the knowledge gained in the above subjects. Methods and procedures required to perform a thorough and uniform examination of a horse shall be included. The names of the instructors and a resume of their background, academic and practical experience, and qualifications to present such instruction shall be provided to the Administrator.

(v) One hour of classroom instruction regarding the DQP standards of conduct promulgated by the licensing organization or association.

(vi) One hour of classroom instruction on recordkeeping and reporting requirements and procedures.

(3) A sample of a written examination which must be passed by DQP candidates for successful completion of the program along with sample answers and the scoring thereof and proposed passing and failing standards.

(4) The criteria to be used to determine the qualifications and performance abilities of DQP candidates selected for the training program and the criteria used to indicate successful completion of the training program, in addition to the written examination.

(5) The criteria and schedule for a continuing education program and the criteria and methods of monitoring and appraising performance for continued licensing of DQPs. A continuing education program for DQPs shall consist of not less than 4 hours of instruction per year.

(6) Procedures for monitoring horses in the unloading, preparation, warm-up, and barn areas, or other such areas.

(7) The methods to be used to insure uniform interpretation and enforcement of the Horse Protection Act and regulations by DQPs and uniform procedures for inspecting horses for compliance with the Act and regulations.

(8) Standards of conduct for DQPs promulgated by the organization or association. Note: Requirements set forth in 9 CFR 11.7(d)(7) are that each HIO shall promulgate standards and shall provide administrative procedures for initiating, maintaining, and enforcing such standards. Minimum standards are set forth in the regulations. Such standards are needed to ensure that DQPs properly enforce the regulations.

(9) A formal request for Department certification of the DQP program.

List of DQPs and Notification to USDA of Changes to the List and Any Warnings or Revocations Issued to Any DQP; (9 CFR 11.7(c)(2) and (3)); (Business)

HIOs must submit a list to the APHIS Administrator of names and addresses of all DQPs that have successfully completed the certified DQP program and been licensed under the HPA and regulations. They must then notify the USDA of any additions or deletions of names of licensed DQPs from the list or of any change in the address of any licensed DQP or any warnings and license revocations issued to any DQP licensed by the HIO within 10 days of such change. This information is needed to ensure that the list of licensed DQPs contains current information, and it is used when APHIS performs visits to horse shows to review the performance of the DQPs.

HIO Report of Violations and Recordkeeping; (9 CFR 11.7(d)(3) and 11.21(d)); (Business)

This report is received by USDA from HIOs on a monthly basis. The report provides the identity of all regulated horse events that have retained the services of DQPs licensed by the HIO during the month covered by the report and the identity of all horses at each regulated horse event that the licensed DQP recommended be disqualified or excused for any reason. Information concerning the identity of regulated horse events must include the name and location of the event, the name and address of the manager, and the date(s) of the event. Information concerning the identity of disqualified or excused horses must include the registered name of each horse and the name and address of the owner, trainer, exhibitor, or other person having custody of or responsibility for the care of the horse. This information helps APHIS verify that the HIO applied the proper penalty for the alleged violation of the Act or regulations to the responsible parties and also helps us verify if soring is continuing in a specific area or not.

Certified DQP Program Written Warning to DQP of Unsatisfactory Performance; (9 CFR 11.7(f)(1)); (Business)

The HIO will report unsatisfactory DQP performance to APHIS. APHIS uses this information to review DQP performance.

Certified DQP Program Cancellation of DQP License After Warning; (9 CFR 11.7(f)(1)); (Business)

The HIO will report canceled DQP licenses to APHIS. APHIS uses the information to ensure that the list of licensed DQPs contains current information.

Request by DQP to USDA to Appeal License Cancellation; (9 CFR 11.7(f)(1)); (Individual)

This request is submitted by DQPs within 30 days of confirmation of cancellation of a license by an HIO. A request is necessary for the USDA to be aware of the DQP’s desire to appeal.

Appeal of Revocation and DQP Access to Records (previously titled Appeal of Revocation); (9 CFR 11.7(g)); (Business)

Any horse industry organization whose DQP program certification has been revoked may appeal such revocation to the Administrator in writing within 30 days after the date of such revocation and, if requested, shall be afforded an opportunity for a hearing. All DQP licenses issued by a horse industry organization whose DQP program certification has been revoked shall expire 30 days after the date of such revocation, or 15 days after the date the revocation becomes final after appeal, unless they are transferred to a horse industry organization having a program currently certified by the Department. A request is necessary for the Administrator to be aware of the HIO’s desire to appeal, and a written request provides documentation for legal purposes.

Written Notification to USDA and Certified DQP Programs by Event Management of Unsatisfactory DQP Performance; (9 CFR 11.20(b)(1)); (Business)

This notification is submitted to USDA by event management when DQP performance has failed. This information is reviewed by USDA and the certified DQP program to determine whether further action is necessary to ensure adequate DQP performance.

Records of Events Containing Tennessee Walking Horses or Racking Horses Maintained by Management; (9 CFR 11.22(a) and (d)); (Business; Not-for-Profit)

These records must be kept by event management for at least 90 days. The Administrator may, in specific cases, require that horse event records be maintained by management for a period in excess of 90 days. These records are used by APHIS to follow-up if further information is needed in the investigation of alleged violations of the Act or regulations.

Providing Contact Information for Recordkeeper; (9 CFR 11.22(b) and (c)); (Business; Not-for-Profit)

The management of any regulated horse event must designate a person to maintain the required records. Management must furnish to any APHIS representative, upon request, the name and address (including street address, or post office box, and ZIP code) of the person designated to maintain the records. This information is used by APHIS to access the records if necessary.

Inspection of Horse Industry Organization Records; (9 CFR 11.23(b)); (Business)

Horse industry organizations with certified DQP programs must permit any APHIS representative, upon request, to examine and copy any and all records relating to the DQP program that are required by any part of the regulations. Such access is needed to ensure required records are being kept and to access and use information relevant to assessing compliance with the Act and regulations.

Management Report to USDA of Any Regulated Horse Event Involving Tennessee Walking Horses or Racking Horses; (9 CFR 11.24(a)); (Business; Not-for-Profit)

Within 5 days following the conclusion of any regulated horse event containing Tennessee Walking Horses or racking horses, the management of such event must submit to the Regional Director for the State in which the event was held, the information required by the regulations for each horse excused or disqualified and the reasons for such action. If no horses are excused or disqualified, management must submit a report so stating. This information is necessary to determine whether management provided compliance inspections at HPA-regulated events, and, if so, the findings of such inspections. APHIS uses this information to assess HIO performance and compliance with the Act and the regulations.

Management Report to USDA of Any Regulated Horse Event Not Involving Tennessee Walking Horses or Racking Horses; (9 CFR 11.24(b)); (Business)

Within 5 days following the conclusion of any regulated horse event that does not contain Tennessee Walking Horses or racking horses, the management of such event must inform the Regional Director for the State in which the event was held, of any case where a horse was excused or disqualified because it was found to be sore. This information is necessary to determine whether management provided compliance inspections at HPA-regulated events, and, if so, the findings of such inspections. APHIS uses this information to assess HIO performance and compliance with the Act and the regulations.

Required Information in Rulebooks and Rulebook Submission; (9 CFR 11.25(a) and (e) and 11.41); (Business)

In accordance with 9 CFR 11.41, HIOs having certified DQP programs and sponsoring regulated horse events must furnish their rulebooks to USDA by March 1 of each year. Section 11.25(a) requires that each HIO must include in its rulebook penalties that equal or exceed the penalties listed in Section 11.25(c) and must also require dismissal of horses that cannot be inspected [a penalty listed in Section 11.25(d)]. Section 11.25(e) requires that each HIO provide a process in its rulebook for alleged violators to appeal penalties. The process must be approved by the Department. These provisions are necessary to allow APHIS to assess compliance with the regulations by ensuring that certain provisions are incorporated into the rulebook.

Appeals and Reports; (9 CFR 11.25(e)); (Business)

The HIO must submit to the Department all decisions on penalty appeals within 30 days of the completion of the appeal. When a penalty is overturned on appeal, the HIO must also submit evidence composing the record of the HIO's decision on the appeal. This provision is necessary to allow the Department to ensure appropriate due process is provided to alleged violators of the Act or regulations and to ensure accurate records of penalties enforced.

Certified DQP Program Quarterly Reports on Disciplinary Action and Recordkeeping (previously titled Certified DQP Program Quarterly Reports on Disciplinary Actions); (9 CFR 11.41); (Business)

HIOs having certified DQP programs and sponsoring regulated horse events must furnish to USDA quarterly reports of all disciplinary actions taken against the management of any horse show, horse exhibition, horse sale, or horse auction, any exhibitor, or any licensed DQP, for alleged violations of the Horse Protection Act or regulations, and the results thereof. The first report is an annual report due by March 1 of each year. In order to be able to submit these reports, HIOs must therefore keep records of disciplinary actions for one quarter (until a quarterly report is submitted) and keep quarterly reports for three to nine months until an annual report is submitted. APHIS uses this information to assess the HIOs’ enforcement of the HPA and compliance with the Act and the regulations.

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.

All of the required information may be submitted electronically via email or fax. Approximately 25% of the required information is submitted by regular mail, courier services (such as FedEx, UPS, etc.) to APHIS at the respondents’ preference.  The use of electronic submissions (fax and e-mail) affords a decrease in notification time, record of submission, and reduction of paperwork, costs, and mailing activities.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose described in item 2 above.

APHIS is the only Federal Agency responsible for administering the Horse Protection Act. The information it collects while administering the Act is not available from any other sources.

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

All business respondents are considered small businesses. The information collection and records requirements are the minimum needed to verify compliance with the HPA and Federal regulations.

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 the information were collected less frequently or not collected, APHIS would not be able to accurately assess compliance with the HPA.

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;

DQPs subject to license cancellation must submit their appeals to the USDA within 30 days of notification.

Show management staff reporting unsatisfactory DQP performance must submit their reports to the USDA immediately after the event for review and potential action.

Event management reports of any horse show, exhibition, auction, or sale at which they conducted inspections of horses must be submitted to USDA within 5 days of the event.

• 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 secret, 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.

No other special circumstances exist that would require this collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5.

8. 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. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, soliciting comments on the information collection prior to submission to OMB.

APHIS engaged in productive consultations with the following individuals concerning the information activities associated with this program. It contacted these respondents by email and phone to discuss the information APHIS collects to administer its horse protection regulations.

The individuals had no concerns with how the Agency and the respondents obtain the necessary data and how frequently; how much data is available; the convenience and clarity of reporting formats and other collection instruments; and the clarity of, and necessity for, any recordkeeping requirements and had no further recommendation.

Victor Gibson, Representative

DQP Services HIO

Unionville, TN

Phone: 229.376.6407

Email: victordgibson55@yahoo.com

Mitsy Marquez, Representative

CFTA HIO

Norco, CA

Phone: 909.744.0150

Email: mitsy.marquez@abc.com

Teresa Bippen, Representative

FOSH HIO

St. Louis, MO

Phone: 314.409.3861

Email: tbippen1957@yahoo.com

On Tuesday, March 8, 2022, APHIS published in the Federal Register (87 FR 12926), a 60-day notice seeking public comments on its plans to request a 3-year approval of this collection of information. On Tuesday, March 29, 2022, APHIS published a notice in the Federal Register (87 FR 17977), correcting a phone number in the original notice. APHIS did not receive any public comments.

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

There are no payments of gifts provided to respondents.

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

No assurance of confidentiality is provided to any respondent.

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.

There are no questions of a sensitive nature asked of the respondents.

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. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

See APHIS Form 71.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

APHIS estimates the total annualized cost to the respondents to be $104,982. APHIS arrived at this figure by multiplying the total burden hours (2,650) by the estimated average hourly wage of the above respondents ($27.34) and then multiplying the result by 1.449 to capture benefit costs.

The average hourly rates used to calculate the estimates include the following:

SOCC Code	Average Salary	Occupation Description
39-2011	$18.38	Animal trainers
11-9013	$37.71	Agricultural managers/event managers (farmers, ranchers and other agricultural managers)
43-1011	$30.47	Supervisors of office and administrative support workers (HIO personnel (first-line supervisors of office and administrative support workers)
45-1011	$22.80	Importers and individuals transiting various commodities not eligible for importation into the United States (first-line supervisors of farming, fishing, and forestry workers occupations)
	$27.34	Average Hourly Salary

The rates were found at the U.S. Bureau of Labor Statistics website https://www.bls.gov/
oes/current/oes_stru.htm. The average hourly salary in the last renewal was overstated by 43 cents. The average hourly salary for agricultural managers has decreased by 92 cents per hour due to market changes. These two changes reflect a slightly overall decreased average salary from that reported in the previous submission.

According to DOL BLS news release USDL-22-0469 dated March 18, 2022 (see https://www.bls.gov/news.release/pdf/ecec.pdf), benefits account for 31 percent of employee costs, and wages account for the remaining 69 percent. Mathematically, total costs can be calculated as a function of wages, resulting in a multiplier of 1.449.

13. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates 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.

There is no additional cost burden to the respondents.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

See APHIS Form 79. The estimated annual cost for the Federal Government is $57,604.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

	Requested	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate	Change Due to Potential Violation of the PRA	Previously Approved
Annual Number of Responses	2,258	0	0	693	0	1,565
Annual Time Burden (Hr)	2,650	0	0	604	0	2,046

This request for renewal is for 2,258 estimated annual responses and 2,650 estimated annual burden hours, reflecting an increase of 693 responses and 604 burden hours from the previous renewal request. The number of respondents increasing from 289 to 442.

Adjustments to the Agency estimates resulted in an increase in the number of reported events attended by the HIOs and USDA. In fiscal year 2019, there was an increase in the number of regulated events organized by the horse industry. However, in fiscal years 2020 and 2021, the SARS-CoV-2 pandemic resulted in a dramatically reduced number of events and therefore were not utilized to calculate the estimate for this renewal since it would not accurately reflect the expected or typical burden.

Specific adjustments to Agency estimates are:

(B) Business; (NP) Not-for-Profit

9 CFR	ACTIVITY	RESP	PREVIOUS RESP./HRS	NEW RESP./HRS	DIFFERENCE RESP./HRS	TYPE OF CHANGE
11.5(a)(1); 11.23(a)	Access to and Inspection of Event Management Records	B	20/20	46/46	26/26	E
11.5(a)(1); 11.23(a)	Access to and Inspection of Event Management	NP	44/44	46/46	2/2	E
11.7(f)(1)	Certified DQP Program Written Warning to DQP of Unsatisfactory Performance	B	4/2	1/1	-3/-1	E
11.20(b)(1)	DQP Access to Records	B	86/86	253/253	167/167	E
11.22(a)(d)	Records of Events Containing Tennessee Walking Horses or Racking Horses Maintained by Management	B	86/86	253/253	167/167	E
11.22(b)(c)	Providing Contact Information for Recordkeeper	B	86/7	253/21	167/14	E
11.22(b)(c)	Providing Contact Information for Recordkeeper	NP	188/15	188/16	0/1	E
11.24(a)	Management Report to USDA of Any Regulated Horse Event Involving Tennessee Walking Horses or Racking Horses	B	86/43	253/127	167/84	E
11.41	Certified DQP Program Quarterly Reports on Disciplinary Actions	B	14/21	14/28	0/7	E

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

The APHIS Horse Protection Act web site is used to transmit information to the public concerning the enforcement of the Act. The web site has a listing of HIOs and DQPs, as well as the Federal Disqualification and Civil Penalty List, for the public to use at horse shows. Any information placed on the Web site has been verified by the HIOs. The Web site is located at https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/SA_HPA.

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 associated with this information collection.

18. Explain each exception to the certification statement identified in Item 19 "Certification for Paperwork Reduction Act."

The agency is able to certify compliance with all provisions under Item 19 of OMB Form 83i.

B. Collection of Information Employing Statistical Methods

This information collection does not employ statistical methods.

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