0508 supporting statement 070908rev

SUPPORTING STATEMENT
CERTIFICATION REQUIREMENTS FOR DISTRIBUTORS OF NOAA ELECTRONIC
NAVIGATIONAL CHARTS/NOAA HYDROGRAPHIC PRODUCTS OMB CONTROL
OMB CONTROL NO. 0648-0508

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
Electronic navigational charts (ENCs) are one of NOAA’s products under its Nautical Charting
Program. Official NOAA ENCs which conform to International Hydrographic Organization
(IHO) standards may be used in a type approved display system, such as an Electronic Chart
Display and Information System (ECDIS), to comply with Federal nautical chart carriage
requirements administered by the U.S. Coast Guard.
In 2005, NOAA established a certification program for the redistribution* of official NOAA
ENCs (Final Rule 0648-0508 (71 FR 52906)), codified in 15 CFR part 995, in order to ensure the
quality and content of official NOAA ENCs remains intact throughout the redistribution process.
The information collected allows NOAA to administer the regulation, and to better understand
which ENCs are being distributed more often, resulting in products that meet the needs of the
customer in a timely and efficient manner.
2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
The information collected by NOAA's Office of Coast Survey (OCS) regarding the redistribution
of official ENCs allows OCS to better allocate resources towards ENC production and product
improvement. This information provides utility to the end-user, whereby OCS is continuously
improving the quality of the ENC product that is distributed to the end-user, either by the
Certified ENC distributor program or via the free downloads on the NOAA website.
In the original submission there were requirements for the certification process. NOAA certified
eight distributors between 2005 and 2008, and does not anticipate further applications. The next
renewal will include a re-certification burden, as the initial five-year certification period will
have expired.
As part of a twice-yearly reporting process, the certified distributors are required to report to
NOAA the following from their records, for all customers during the six-month period:

*Redistribution refers to the distribution of NOAA charts, by a non-Federal entity that includes or displays
hydrographic data.

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Distribution Customer
Vessel Name
ENC
Subscription type.
This allows NOAA to evaluate which particular product is in high demand and to adjust
production schedules accordingly.
In addition, certified ENC distributors are required to report via email any error detected during
the conversion process that apparently originates in the NOAA ENC files. This allows OCS to
quickly make the correction and re-post the data for distribution via the web. A typical email
consists of:
ENC Name
Error Type.
As explained in the preceding paragraphs, the information gathered has utility. NOAA OCS
will retain control over the information and safeguard it from improper access, modification, and
destruction, consistent with NOAA standards for confidentiality, privacy, and electronic
information. See the answer to Question 10 of this Supporting Statement for more information
on confidentiality and privacy. The information collection is designed to yield data that meet all
applicable information quality guidelines. Although the information collected is not expected to
be disseminated directly to the public, results may be used in scientific, management, technical
or general informational publications. Should NOAA OCS decide to disseminate the
information, it will be subject to the quality control measures and pre-dissemination review
pursuant to Section 515 of Public Law 106-554.
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
Responses from the Certified ENC Distributors are all electronic and sent via email. All
distributors have an Excel spreadsheet which they submit for the twice-yearly report.
4. Describe efforts to identify duplication.
The Office of Coast Survey is the only agency that produces official ENCs for the nation's coast.
Therefore it is the only agency which manages a collection for the Certified ENC Distributors.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
This collection does not involve small businesses or other small entities.

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6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Without the reporting requirement from the distributors, OCS would be unable to better focus
their production efforts to those products that are in high demand by the end-users.’
The reporting of errors found in our data during the conversion process is an invaluable aspect of
quality control of the OCS ENC data. It is an established feedback mechanism that allows OCS
to react quickly and repair data to ensure that the end-user ultimately receives data that is
consistent and correct.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
There are no special circumstances that require the collection to be conducted in a manner
inconsistent with OMB guidelines.
8. Provide information on the PRA Federal Register Notice that solicited public comments
on the information collection prior to this submission. Summarize the public comments
received in response to that notice and describe the actions taken by the agency in response
to those comments. Describe the 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.
A Federal Register Notice was published on May 8, 2008 (73 FR 26082). No public comments
were received.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts will be given to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
15 CFR part 995.21 addresses a registry of data users for the distribution program. Within the
CFR it states that "NOAA agrees to treat such information as proprietary."
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.
N/A.
12. Provide an estimate in hours of the burden of the collection of information.
Number of respondents: 8
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Total annual responses expected: 16 semi-annual reports plus 208 error reports = 224.
Average response time: 1 hour per semiannual report and 1-2 hours (1.5) per error report.
Total annual hours: (16 x 1) + (208 x 1.5) = 328.
Hourly Labor Cost: $25
Total Annual Labor cost: $8,000.
13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in #12
above).
The annual recordkeeping cost burden is $0: all report information may be emailed to NOAA at
no cost to the distributor. All other costs of equipment associated with producing the product are
considered to be part of customary and usual business of private practices.
14. Provide estimates of annualized cost to the Federal government.
Annualized labor costs to the federal government are $6,000. There are no costs above normal
labor.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
The reporting burden decreased by 208 hours. Adjustments are based on the following factors:
Negative adjustments:
•
•
•
•
•
•
•

The previous estimates were based on 9, rather than 8, respondents. Since the burden per
respondent was estimated at 60 hours per year, this removes 60 hours.
No certification applications are expected in the next three years, removing another 16
hours/5 years for each of 8 respondents = 26 hours.
Set-up and maintenance of data registries is no longer counted as burden, as it is a normal
business practice, already in use by the respondents before certification (this burden was
counted in error in the original submission), removing 198 hours.
Routine checking for and reporting of corruption of data when downloading is also
considered a normal business practice, removing 8 hours.
No NOAA testing of respondents’ compression/decompression and
encryption/decryption software and documentation is needed, removing 2 hours.
Re;ports which were formerly required quarterly are now required twice per year, and
their hourly estimate has decreased from 1.5 hours to 1 hour, removing a total of 32
hours.
Labeling of software to distinguish for customers what is and is not official NOAA ENC
data has already been accomplished, removing 192 hours.

Subtotal of decreases due to adjustments: 518 hours.
Error reports were previously estimated at a total of 2 hours annually, while currently they are
estimated at 312 hours, resulting in a positive adjustment of 310 hours.

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The net decrease is thus 208 hours.
Cost adjustment: No costs estimated in the previous request are included, either because: 1) they
were incorrectly counted as costs for this particular information collection, rather than as normal
business costs, e.g. computer and software upgrades, or 2) they have been determined not to be
applicable, e.g. cost of mailing labels for reports which are actually submitted electronically.
Cost estimate for the next three years: $0.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
These results will not be published.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
N/A.
18. Explain each exception to the certification statement identified in Item 19 of the
OMB 83-I.
N/A.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistical methods.

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