Supporting Statement

for

Vessel Identification System

OMB No.: 1625-0070

COLLECTION INSTRUMENTS:  Instruction 

A.  Justification.  

1.  Circumstances that make the collection of information necessary.  

Title 46 U.S.C. chapter 125 required the establishment of the Vessel
Identification System (VIS).  The implementing regulations are in 33 CFR
Part 187.  State and territory participation in VIS is entirely
voluntary.  However, to participate, States and territories must comply
with certain requirements to ensure the integrity and uniformity of the
information provided to VIS.  A State or territory must sign a
Memorandum of Agreement (MOA) with the Coast Guard before participating
in the VIS.  

This information collection supports the following strategic goals:

Department of Homeland Security

Prevention

Service

Coast Guard

Mobility

Prevention Policy & Response Policy Directorates (CG-5P & CG-5R)

Reduce the number and/or impact of waterways impediments

2.  Purpose of the information collection.  

VIS comprises a nationwide information system for identifying
recreational, commercial, and public vessels that are numbered or titled
under the laws of a State or territory.  VIS includes information
identifying vessels and vessel owners, and information to assist law
enforcement officials in the investigation of stolen vessels or other
legal investigation, such as fraud.  Furthermore, individuals who borrow
money to purchase a vessel in a State or territory that both
participates in VIS and holds certification of compliance (with
guidelines for State or territory titling systems) are deemed to have
preferred mortgage status.

All 50 States and 6 territories have the opportunity to participate in
the VIS program.  The 6 territories are Guam, Puerto Rico, U.S. Virgin
Islands, American Samoa, District of Columbia, and Northern Mariana
Islands.  

3.  Considerations of the use of improved information technology.  

We estimate that all of the reporting requirements can be done
electronically.  At this time, we estimate that 100% are collected
electronically.  

4.  Efforts to identify duplication.  

Only the States and territories that participate in VIS have the
information required by this program.

5.  Methods used to minimize the burden to small businesses if involved.
 

This information collection does not have an impact on small businesses
or other small entities.  

6.  Consequences to the Federal program if collection were conducted
less frequently.  

Without regular updates to the VIS, the data would not be useful for law
enforcement purposes.  The primary benefits of VIS come from its ability
to serve as a tracking device much like the Vehicle Identification
Number found in automobiles.  As a tracking device, the benefits of VIS
are in:

the recovery of stolen or missing vessels, which will benefit boat
owners, local and State law enforcement agencies and boat insurers;

the purchase of a vessel, which will make it less likely to unknowingly
purchase a stolen vessel, which can be a financial disaster if the
rightful owner shows up to claim it; and

the discovery of liens, unpaid taxes, and claims that are lodged against
a vessel, and that can become the unexpected responsibility of the new
owner.

Without VIS, these benefits are not realized.  

7.  Special collection circumstances.  

This information collection is conducted in manner consistent with the
guidelines in 5 CFR 1320.5(d)(2).  

8.  Consultation.  

A 60-Day Notice (See [USCG-2015-0689], August 13, 2015, 80 FR 48550) and
30-Day Notice (XX XX, 2015, 80 FR XXXXX) were published in the Federal
Register to obtain public comment on this collection.  The Coast Guard
has not received any comments on this information collection.     

9.  Provide any payment or gift to respondents.  

There is no offer of monetary or material value for this information
collection.  

10.  Describe any assurance of confidentiality provided to respondents.

The VIS application is an authorized-user-only website requiring user
log in, available to Numbering and Titling, Registration and Law
Enforcement personnel of VIS participating States and Federal Agencies. 


11.  Additional justification for any questions of a sensitive nature.  

There are no questions of sensitive language.  

12.  Estimate of annual hour and cost burden to respondents.

The estimated number of respondents is 34.  

The estimated number of annual responses is 859.  

The estimated annual hour burden is 5,164 hours.  

The estimated annual cost burden is $372,272.   

The burden to respondents is provided in Appendix A.  The wage rates
used are in accordance with the current edition of COMDTINST
7310.1(series) for “Out-Government” personnel.

VIS Data Transfers:  We estimate that it will take a technical
specialist about 6 hours to prepare and submit VIS data.  For each
participating State and territory, we estimate that this data transfer
will occur every 2 weeks (or 26 times per year).  The position of a
technical specialist is analogous to a GS-12.  

MOA Applications:  We estimate that it will take a program specialist
about 16 hours to prepare an MOA application.  We estimate that we will
receive 1 MOA application per year.  The position of a program
specialist is analogous to a GS-14.

13.  Total of annualized capital and start-up costs.  

Much of the information to be included in the VIS database is already
collected by States and territories when registering vessels.  The
start-up cost is the cost of developing the VIS interface and conversion
software at the State and territory level.  The Coast Guard estimates
the average start-up cost per State or territory is $55,000.  Thus, the
average annual start-up cost is $55,000 ($55,000 * 1 entity per year).  

14.  Estimates of annualized cost to the Federal Government.  

The estimated annual Federal Government cost is $480,752 (see Appendix
B).  The estimate is comprised of 2 elements.  First, we estimate the
VIS Database cost of $480,000 annually.  Second, we estimate that it
will take a technical specialist about 8 hours to review and process
each MOU.  Coast Guard program and legal specialists conduct the review.
 The position of a technical specialist is analogous to a GS-14.  The
wage rate shown is in accordance with the current edition of COMDTINST
7310.1(series) for “In-Government” personnel.  

15.  Explain the reasons for change in the burden.

The change in burden is an ADJUSTMENT due to a change (i.e., decrease)
in the estimated annual number of responses.  There is no proposed
change to the reporting requirements of this collection.  The reporting
requirements remain unchanged.  The methodology for calculating burden
was changed to more accurately reflect current practices for VIS Data
Transfers and to account for the MOA Application process.  Previously,
we estimated that all 56 States and territories would send us VIS data
250 times per year, and that additional separate error reconciliation
reports (over 100,000) would be sent to the CG.  Current practice is for
the 33 participating States and territories to regularly submit VIS data
in such a manner that we no longer receive separate error reconciliation
reports.  

16.  Plans for tabulation, statistical analysis and publication.  

This information collection will not be published for statistical
purposes.

17.  Approval for not explaining the expiration date for OMB approval.  

The Coast Guard will display the expiration date for OMB approval of
this information collection.  

18.  Exception to the certification statement.  

The Coast Guard does not request an exception to the certification of
this information collection.  

B.  Collection of Information Employing Statistical Methods:

This section does not apply because the collection of information does
not employ statistical methods.

  In accordance with 46 U.S.C. Chapter 123.  

  The CG/State-Territory MOA calls for data transfer at least monthly.  

  The MOA calls for at least monthly, we estimate every 2 weeks or 26
times per year.  

1625-0070

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