SUPPORTING STATEMENT 

FOR 

BRIDGE PERMIT APPLICATION GUIDE 

OMB Control No.: 1625-0015

Collection Instruments: Instruction

A.	JUSTIFICATION

1.  Circumstances which make the collection of information necessary.

Under the provisions of 33 U.S.C. 401, 491, and 525, it shall not be
lawful to construct a bridge or causeway over navigable waters of the
United States unless the plans and location of such structures have been
approved by the Secretary of Homeland Security through the Commandant,
U. S. Coast Guard.  The plans and map of the location must be in such
detail as may be required for a full understanding of the bridge
project.  The procedures of obtaining an individual bridge permit are
set forth in 33 CFR 115.50 and 115.60.  The procedure essentially calls
for a letter of application with letter size drawings (plans) and map
showing the proposed bridge project and its location.

Section 102(2)(C) of the National Environmental Policy Act of 1969
(NEPA), as amended, requires federal agencies to assess in detail the
environmental impacts of proposed major federal actions on the quality
of the human environment.  40 CFR 1500-1508 sets forth the procedures,
and 40 CFR 1502.3 specifically mandates the requirement for impact
statements.

2.  Purpose of the Information Collection

It is against the law to build a bridge over the navigable waters of the
United States without approval of the plans and location of such
structures.  The Coast Guard, before a bridge permit is issued or
denied, uses the information provided by the applicant to evaluate the
effect the bridge project will have on the reasonable needs of
navigation and on the human environment.  The applicants are private
entities, Federal, state, or local government agencies, or organizations
employing more than 100 persons. 

3.  Consideration of the use of improved information technology to
reduce the burden.

Currently applicants can submit the required material electronically to
the Coast Guard via email, CD-ROM or posting documents to applicant
websites for Coast Guard download.  Development of the Bridge Permit
Application Guide (BPAG), COMDTPUB P16591.3 (series) and the Bridge
Administration Manual (BAM), CONDTINST M16590.5 (series) have prevented
waste within the Coast Guard.  The BPAG provides a standard for
assisting applicants in compiling the required information and
documents.    The BAM provides the same standard for Coast Guard field
units and Headquarters to review and evaluate permit applications.  

4.  Efforts to identify duplication.

The granting of a bridge permit over the navigable waters of the United
States is a unique function that falls solely under the jurisdiction of
the Coast Guard.  There is no duplication in the collection of necessary
information to complete an application.  The procedures for developing
environmental assessments or environmental impact statements (40 CFR
1506) require that duplicative efforts be eliminated between federal,
state and local governments.  Thus, where practicable, joint public
meetings or hearings are held, joint public notices can be issued, and
environmental documents/statements, reports, and analyses can be
referenced and/or adopted.  Additionally, Executive Order 13604:
Improving Performance of Federal Permitting and Review of Infrastructure
Projects, directed federal agencies to improve the permitting and review
process for infrastructure projects throughout the country.  Agency
implementation of the EO further reduced duplicative efforts for the
collection of materials from bridge permit applicants between the Coast
Guard and other federal agencies. 

5.  Methods used to minimize the burdens to small business. 

Not applicable.  The respondents are, with private entities, Federal,
state, or local government agencies, or organizations employing more
than 100 persons.

6.  Consequences to the Federal program if collection were not done or
conducted less frequently.

The result of either not collecting this information or conducting it
less frequently would be noncompliance with statutory and regulatory
requirements.  The Coast Guard’s bridge permit program would become
ineffective and their inability to make informed decisions on whether
proposed bridges or bridge modifications would meet the reasonable needs
of navigation with due consideration of the effects on the human
environment could jeopardize maritime navigation.   Every application
for a Coast Guard bridge permit must go through this collection process.
 The Coast Guard has no influence on how many bridge applications it
receives annually.  Federal funding for transportation projects is the
largest influence.

7.  Special circumstances that require collection to be conducted in an
inconsistent manner.

None.

8.  Solicitation of Comments.

A 60-day Notice will be published in the Federal Register to obtain
public comment on this collection.  

9.  Provide any payment or gift to respondents.

Not applicable.  Neither applicants nor respondents to public notices on
bridge projects are compensated for providing data or information.

10.  Assurances of confidentiality provided to respondents.

Not applicable.  Bridge permit case records are public records and
subject to applicable provisions of Title 49 Code of Federal Regulations
Part 7, Public Availability of Information Transportation (49 CFR 7). 
(From COMDTINST M16590.5C, Bridge Administration Manual, paragraph
1.M.2.).

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

Not applicable.  The Bridge Permit Application Guide contains no
questions of a personal or private nature.

12.	Estimate of annual hour and cost burden.

Frequency of Response:  Usually once, when applying for Coast Guard
approval of proposed bridge construction or bridge modification.  

Applicant cost to provide the information contained in the Bridge Permit
Application Guide can vary greatly depending upon the level of
environmental documentation required under NEPA.  There are three levels
of NEPA documentation: categorical exclusions (CE), environmental
assessments (EA) and environmental impact statements (EIS).  For the
purposes of this OMB evaluation categorical exclusions shall be
considered low impact projects by the Bridge Program since they
typically require minimal coordination and documentation.  Also, all
calculations are based on FY14 figures. FY14 is the larger data set over
the past three fiscal years and is reflective of the 17% yearly increase
in permit applications. Application preparation for low impact projects
account for approximately 61% of Coast Guard Bridge Permit Applications.
 EAs and EISs require a much more rigorous analysis and take more time
and capital to produce so they are considered to be high impact projects
by the Program.  Application preparation for high impact projects
account for approximately 39% of Coast Guard Bridge Permit Applications.

Number of Bridge Permit Applicants (Respondents):  

FY14 – Low Impact 81 + High Impact 52 = 133 total

FY13 – Low Impact 74 + High Impact 43 = 117 total

FY12 – Low Impact 66 + High Impact 33 = 99 total

The majority of the applications received by the Coast Guard are from
federal applicants such as the Federal Highway Administration (FHWA),
for which the Coast Guard is not the lead federal agency for NEPA.  The
Coast Guard is not the lead federal agency for approximately 77% of
Coast Guard Bridge Permit Applications because all Federal actions must
comply with the provisions of the National Environmental Policy Act
(NEPA) of 1969.  For these 77% the applicant is another federal agency
(FHWA, Federal Railroad Administration (FRA)/Federal Transit
Administration (FTA), etc).  Any Federal applicant for a bridge permit
becomes responsible as the lead federal agency under NEPA to conduct a
NEPA evaluation.   The NEPA documentation has already been prepared at
the time of application since the lead federal agency is required to
prepare NEPA documentation when federal funding is involved.  The below
numbers do not include the number of hours and associated costs a
federal applicant spends on NEPA documentation since the documentation
is not a sole requirement of the Coast Guard, but a requirement that is
met before a Coast Guard Bridge permit application is considered.  

Due to staffing limitations, the Coast Guard typically requires the
applicant to prepare the NEPA documentation when the Coast Guard is the
lead federal agency, approximately 23% of the time.  NEPA documentation
requirements vary based upon the impacts and complexity of the project. 
Implementation procedures are based on Council on Environmental Quality
(CEQ) Regulations found in 40 CFR 1500-1508.   When a private
entity/owner applies for a Coast Guard bridge permit the Coast Guard
must now assume lead federal agency responsibilities for NEPA.  The
Coast Guard Bridge Program often coordinates with the private applicant
to have them produce the NEPA documentation for the Coast Guard to
expedite the permit process, as allowed by the CEQ regulations.  The
cost to do this then falls to the applicant.  Market research suggests
that low impact (CE) projects typically take 120 hours to produce a NEPA
document at an estimated cost of $12,000.  High impact (EA and EIS)
projects typically take between 500 (EA) and 5,000 (EIS) hours to
produce a NEPA document at an estimated cost of between $50,000 (EA) and
$500,000 (EIS).  Sections a. and b. below represent low and high impact
projects, respectively. 

The calculations contained below are based upon the level of NEPA
documentation required for the proposed project and reflect the low
impact/high impact determination.  The costs shown are also based upon
the schedule of hourly rates for personnel contained in enclosure (2) to
COMDTINST 7310.1P.  Total estimated respondent financial cost for FY14
is shown in Section d. at $941,322.00.  These calculations do not
include the hours and cost for NEPA documentation preparation described
above.

Application preparation by the applicant for low impact projects
(categorical exclusions).  These projects account for approximately 61%
of Coast Guard Bridge Permit Applications.  Rates are based on COMDTINST
7310.1P Coast Guard Reimbursable Standard Rate dated 

11 February 2015.

	Within government (I/G)

	Outside government (O/G)

	Pre-application consultations w/federal, state, local govt.

			(GS-13/14, O/G $101)  X  8 hrs		=	$808.00

	Application preparation (GS-11, O/G $61)  X  40 hrs	=	$2,440.00

	Clerical (GS-5/8, O/G $50)  X  4 hrs	=	$200.00

	Drawings prepared (GS-9, O/G $51)  X  10 hrs	=	$510.00

	

	Respondent financial burden per application		=	$3,958.00

Respondent burden hours per application, low impact 	= 	62 hrs

	Total Respondent hours - 62  X  81 applications (61% of 133, FY14)	=   
    5,022hrs

	Total Respondent Cost - $3,958.00  X  81 applications	=       
$320,598.00

		

Application preparation for high impact projects (environmental
assessments and environmental impact statements).  These projects
account for approximately 39% of Coast Guard Bridge Permit Applications.


Note: the hourly differences between an environmental assessment and an
environmental impact statement are evident in the NEPA document
preparation, and not with the other Bridge Permit Application
requirements, as described below. 

Within government (I/G)

Outside government (O/G)

	Pre-application consultations w/federal, state, local govt.

		(GS-13/14, O/G $101)  X  87 hrs		=	$8,787.00

	Application preparation (GS-11, O/G $61)  X  40 hrs	=	$2,440.00

	Clerical (GS-5/8, O/G $50)  X  4 hrs	=	$200.00

	Drawings prepared (GS-9, O/G $51)  X  10 hrs	=	$510.00	

	Respondent financial burden per application		=       	$11,937.00

	Respondent burden hours high impact (87+40+4+10 hrs)	=	141 hrs

Total Respondent hours - 141 hrs  X  52 applications (39% of 133, FY14)
=       	7,332 hrs

	Total Respondent Cost - $11,937.00  X  52 applicants	=	$620,724.00 

		

FY14 total respondent hours (5,022+7,332) = 12,354 hrs 

FY14 total respondent cost ($320,598+$620,724) = $941,322.00

13.	Provide an estimate of the annualized capital/start-up costs to
respondents.

The estimated cost for the copying, postage and handling of a bridge
permit application:

Low Impact Project 							=	$50.00 

Total Respondent Cost - $50.00 X 81 applications	=        $4,050.00

		(61% of 133, FY14)

High Impact Project 							=	$200.00 

Total Respondent Cost - $200.00 X 52 applications	=        $10,400.00

		(39% of 133, FY14)

FY 14 estimated total cost							=	$14,450.00

14.  Estimates of annualized cost to the Federal Government.

The estimated annual federal cost for administration for FY14 is
$1,580,160.50; this number will change slightly from year to year
depending on the number of applications received in that year.  This
estimate is primarily federal personnel salary and overhead costs
associated with field and headquarters time expended in processing a
respondent's application for a bridge permit or permit amendment.  The
costs are directly related to working with and evaluating the
information collected from respondents in order to make the federal
decision required on bridge project impacts on navigation and on the
human environment.  Personnel costs are calculated from information in
enclosure (2) to COMDTINST 7310.1P.

Prepare District jurisdictional and navigational determinations, review
and provide feedback for application package, prepare and distribute
Coast Guard public notice and agency notifications, review and address
public concerns, and prepare District Findings of Fact (total 78.4
hours).  These actions differ very little between low impact and high
impact projects as well as between Coast Guard lead vs. non-lead federal
agency.

	CG application review and acknowledgment	

		(GM-12, I/G $67)  X   12 hrs	 =	 $804.00

	CG jurisdictional/navigation clearance determinations & coordination	

		(GM-12, I/G $67)  X   25 hrs	 =	$1,675.00

	Prepare and distribute CG Public Notice/Agency Notifications

		(GS-13/14, I/G $94)  X   .50 hrs	 =	 $47.00

		(GS-12, I/G $67)   X   11 hrs	 =	 $737.00

	Review and prepare public notice responses

		(GS-12, I/G $67)   X   3.5 hrs	 =	 $234.50

Prepare District Findings of Fact.  Same for low and high impact, same  
                                 for Coast Guard lead vs. non-lead

		(GS-12, I/G $67)  X   26 hrs	 =	 $1,742.00

		78 hrs		 $5,239.50

When the Coast Guard IS NOT the lead federal agency, review and comment
on preliminary and final environmental documents, attend
resource/regulatory agency meetings and draft Finding of No Significant
Impact (FONSI) or Record of Decision (ROD) for high impact projects. 
These projects account for approximately 80% of Coast Guard Bridge
Permit Applications.

	Review and comment on preliminary and final environmental documents. 

		(GS-12, I/G $67)   X   18 hrs	 =	$1,206.00

	Attend resource/regulatory agency meetings. 

		(GS-12, I/G $67)   X   3 hrs	 =	$201.00

	Draft FONSI or ROD for high impact projects. 

		(GS-12, I/G $67)   X   5 hrs	 =	$335.00

			26 hrs	$1,742.00

When the Coast Guard IS the lead federal agency review environmental
documents, to include reviewing applicant prepared environmental
documents and coordination and consultation with natural resource
agencies (average for low and high impact = 37 hours).  These projects
account for approximately 20% of Coast Guard Bridge Permit Applications.

Please note that the following dollar amounts; $1675.00, $804.00,
$1541.00 and $446.50; are used in both the LOW and HIGH impact
calculations.

Review applicant-prepared preliminary and final environmental documents 

 (GS-12, I/G $67)   X   25 hrs	 =	$1,675.00

Attend resource/regulatory agency meetings. 

		(GS-12, I/G $67)   X   12 hrs	 =	$804.00

Circulate and address comments and concerns. 

	Low Impact

		(GS-12, I/G $67)  X   17 hrs	 =	$1,139.00

	High Impact

		(GS-12, I/G $67)  X   60 hrs	 =	$4,020.00

Draft CE determination, FONSI or ROD, review and comment on final
environmental document.

	Low Impact

		(GS-12, I/G $67)  X   8 hrs	 =	$536.00

	High Impact

		(GS-12, I/G $67)  X   58hrs	 =	$3,886.00	

Prepare final environmental document/cover for agency signature, prepare
permit package for District/Commandant review, prepare transmittal
letter/case file and completion report.

	Same for low and high impact

		(GS-12, I/G $67)  X   23hrs	 =	$1,541.00

		(GS-13/14, I/G $94)  X   4.75 hrs	 =	$446.50

			89.75 hrs	Low impact =  	$6,141.50

			182.75 hrs	High impact = 	$12,372.50

Coast Guard HQ receives application package, evaluates impacts on
navigation and the environment, prepares written evaluations, bridge
permit or denial, and transmittal letter to District.  This section
applies to all applications.

	Low Impact 

		(GS-15, I/G $109)  X    3.50 hrs	=	$381.50

		(GS-13, I/G $80)   X   33.50 hrs	=	$2,680.00

		

			37 hrs	Low impact =	$3,061.50

	High Impact 

		(GS-15, I/G $109)  X    5.50 hrs	=	$599.50

		(GS-13, I/G $80)   X   47.50 hrs	=	$3,800

		

			53 hrs	High impact =	$4,399.50

FY14 Coast Guard hours per response:	

	Low impact projects, Coast Guard not the lead federal agency 	= 141.00
hrs (a+b+d(low))

	Low impact projects, Coast Guard is the lead federal agency 	= 204.75
hrs (a+c(low)+d(low))

	High impact projects, Coast Guard not the lead federal agency 	= 157.00
hrs (a+b+d(high))

High impact projects, Coast Guard is the lead federal agency 	= 313.75
hrs (a+c(high)+d(high))

FY14 Total Cost burden hours:

The calculations in this section are based upon 133 projects for FY14. 
61% were considered low impact (81 applications).  Of this 22% were
Coast Guard lead (18 applications) and 78% were not Coast Guard lead (63
applications).  39% of the applications were considered high impact
projects (52 applications).   Of this 17% were Coast Guard lead (9
applications) and 83% were not Coast Guard lead (43 applications). 
These numbers are used to generate the Coast Guard burden hours.

Total Coast Guard burden hours (low impact projects, Coast Guard not the
lead federal agency)   = 8,883 hrs (63 applications X 141 hrs) 

Total Coast Guard burden hours (low impact projects, Coast Guard is the
lead federal agency)      = 3,685.50 hrs (18 applications X 204.75 hrs) 

Total Coast Guard burden hours (high impact projects, Coast Guard not
the lead federal agency)   = 6,751 hrs (43 applications X 157 hrs) 

Total Coast Guard burden hours (high impact projects, Coast Guard is the
lead federal agency)     = 2,823.75 hrs (9 applications X 313.75 hrs) 

Total Coast Guard burden hours, FY 11 = 22,143.25 hrs

FY14 Federal government financial burden  

Coast Guard financial burden (low impact projects/Coast Guard not the
lead federal agency)        = $632,709.00 ($10,043.00(a+b+d(low) X 63
applications) 

Coast Guard financial burden (low impact projects/Coast Guard is the
lead federal agency)          = $259,965.00 ($14,442.50 (a+c(low)+d(low)
X 18 applications) 

Coast Guard financial burden (high impact projects/Coast Guard not the
lead federal agency)      = $489,383.00 ($11,381.00 (a+b+d(high) X 43
applications) 

Coast Guard financial burden (high impact projects/Coast Guard is the
lead federal agency)         = $198,103.50 ($22,011.50
(a+c(high)+d(high) X 9 applications)

Total Federal Cost (FY14, 133 applications) 	=      $1,580,160.50

15.  Reason for changes or adjustments in the burden.

Total public burden hours for FY 14 are calculated to be 12,354. 
Starting with the last OMB approval period, the Program utilizes
quarterly reporting data (Bridge Program Quarterly Activities Report)
from each district office to generate more accurate permit data then
previously available.  The data presented in this justification
represents the best information currently available.  

Growth identified between FY12 and FY14 (average of 17%) is indicative
of normal permit request growth rates currently being experienced within
the Program and this rate of growth is anticipated to continue in the
future.

16.	Plans for tabulation, statistical analysis and publication.

Not applicable.  No publication of collected information or statistical
analysis is planned.

17.	Approval for not to explain the OMB expiration date.

USCG will display the OMB control number and expiration date of OMB
approval of this information collection on the next revision to the BPAG
(currently under development).

18.	Exception to the certification statement.

There are no exceptions.  

B.    COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

Not applicable.  The collection does not employ statistical methods.

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