Supporting Statement 

for 

Enhanced Maritime Domain Awareness via 

Electronic Transmission of Vessel Transit Data

OMB No.: 1625-0112

COLLECTION INSTRUMENTS:  Instruction

A.  Justification

1.  Circumstances that make the collection of information necessary.  

As stated in The National Strategy for Maritime Security (September
2005) (NSMS), a key national security requirement is the effective
understanding of all activities, events, and trends within any relevant
domain – air, land, sea, space, and cyberspace – that could threaten
the safety, security, economy, or environment of the United States and
its people.  Awareness and threat knowledge are critical for securing
the maritime domain and the key to preventing adverse events.  Knowledge
of an adversary’s capabilities, intentions, methods, objectives,
goals, ideology, and organizational structure, plus factors that
influence his behavior, are used to assess adversary strengths,
vulnerabilities, and centers of gravity.  Also, information on critical
infrastructure and other potential targets of adverse events allows for
their adequate protection and coordination of efforts to provide that
protection.  Such knowledge is essential to supporting decision-making
for planning, identifying requirements, prioritizing resource
allocation, and implementing maritime security operations.  Domain
awareness enables the early identification of potential threats and
enhances appropriate responses, including interdiction at an optimal
distance with capable prevention forces.  

The Maritime Transportation Security Act of 2002 (MTSA) (Pub. L.
107-295, 46 U.S.C. 70115) mandates, consistent with international
treaties, that the U.S. Coast Guard (delegated from the Secretary)
“develop and implement a long-range automated vessel tracking system
for all vessels in United States waters that are equipped with the
Global Maritime Distress and Safety System [GMDSS] or equivalent
satellite technology.  The system shall be designed to provide the
Secretary the capability of receiving information on vessel positions at
interval positions appropriate to deter transportation security
incidents.  The Secretary may use existing maritime organizations to
collect and monitor tracking information under the system.”  The
International Convention for the Safety of Life at Sea, 1974, as amended
(SOLAS) implemented the international regime for Long Range
Identification and Tracking (LRIT) of Ships in SOLAS, Chapter V,
Regulation 19-1 (SOLAS V/19-1).  The U.S. implementing regulations are
in 33 CFR 169 subpart C.  

The MTSA also mandates certain vessels carry onboard Automatic
Identification System (AIS) equipment.  MTSA (46 U.S.C. 70114) further
directs the Secretary of the Department in which the Coast Guard is
operating to “implement a system to collect, integrate, and analyze
information concerning vessels operating on or bound for waters subject
to the jurisdiction of the United States.”  The Coast Guard
established a Nationwide AIS (NAIS) project to collect AIS transmissions
and enhance our Maritime Domain Awareness (MDA) by providing information
that helps assess the potential threat posed by a vessel operating in
waters under U.S. jurisdiction as well as by enhancing navigation safety
and mitigating collision amongst AIS-networked vessels.  

The collection of information also supports the following strategic
goals:

Department of Homeland Security

Awareness – Identify and understand threats, assess vulnerabilities,
determine potential impacts and disseminate timely information to our
homeland security partners and the American public. 

Prevention – Detect, deter and mitigate threats to our homeland.

Protection – Safeguard our people and their freedoms, critical
infrastructure, property, the economy of our nation from acts of
terrorism, natural disasters, or other emergencies.

Coast Guard

Maritime Security – Protect the public, the environment, and U.S.
economic interests – in the nation’s ports and waterways, along the
coast, on international waters, or in any maritime region as required to
support national security.

Maritime Safety – Protect our maritime borders from all intrusions by
halting the flow of illegal drugs, aliens, and contraband into this
country through maritime routes; preventing illegal fishing; and
suppressing violations of federal law in the maritime region.

Protection of Natural Resources – Eliminate environmental damage and
natural resource degradation associated with all maritime activities,
including transportation, commercial fishing, and recreational boating.

National Defense – Defend the nation and enhance regional stability in
support of the National Security Strategy.

Maritime Mobility – facilitate maritime commerce, and reduce
interruptions and impediments to the economic movement of goods and
people, especially in Vessel Traffic Service areas.

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

Maritime Security

Maritime Safety

Protection of Natural Resources

2.  Purposes of the information collection.  

The Coast Guard collects and retains vessel information that is
broadcast via transponder-style equipment (such as LRIT or AIS).  This
information is primarily used by the USCG.  However, the data, combined
and correlated with other information may be shared with Federal, State,
and local government agencies and foreign governments partnering with
the Coast Guard in an effort to expand MDA; and, with other responsible
maritime interest to enhance marine safety, security and environmental
protection.  Vessels subject to AIS-carriage requirements under MTSA
also have access to the same near real-time information provided by
other AIS-equipped vessel’s in their vicinity (VHF-FM radio range),
increasing their own awareness and ability to prevent accidents.  

As discussed above, the MTSA mandates the Coast Guard require certain
vessels to transmit vessel transit data.  Data from the vessels
transmitted by LRIT & AIS is collected and compiled outside of the LRIT
or AIS system to provide the Coast Guard with a near real-time common
operating picture of the maritime environment.  The Coast Guard compiles
this data, correlate it with other sources the Coast Guard has access
to, and analyzes this information to detect anomalies and, identify
potential threats to the nation and the environment.  The information is
included in the Coast Guard’s Common Operational Picture (COP) for
sharing and dissemination to decision-makers.  The COP is the primary
National Maritime system for sharing operational data among those who
need it to perform or support Coast Guard roles and other national
missions 

This information collection, storage, and analysis greatly expands the
breadth and depth of the Coast Guard’s and our Nation’s MDA.  LRIT &
AIS enhance security by providing the United States with the identities
and current location of vessels off our coastlines.  This provides the
United States time to evaluate the security risk posed by a vessel and
then respond, if necessary, to reduce the risk of a possible security
threat.  In addition, there is also an immediate safety benefit by
enhancing the information available to SAR services.  Accurate
information on the location of a vessel in distress as well as vessels
in the area that could lend assistance will save valuable response time
to affect a timely rescue.  The storage of vessel transit data also
allows for analysis in support of such needs as vessel movement trend
analysis, anomaly detection, and increasing efficiencies in the
performance of Coast Guard missions.

3.  Consideration of the use of improved information technology.  

Vessel transit data is collected electronically via a transponder-style
system.  Transponders transmit information automatically without the
need for voice radio communications.  We estimate that 100% of the
reporting requirements are done electronically.  

4.  Efforts to identify duplication.  

There is no Federal, State, or local agency that requires this
information collection.  Therefore, there is no duplication of
information collection efforts by the government.  The information
collected from this effort may be used by other agencies in support of
their own goals.  

5.  Methods 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 not done or
conducted less frequently.

If vessel transmissions were not collected, the Coast Guard would not
avail itself of critical identification information on a large and
diverse vessel population transiting our maritime domain.  This could
significantly impact marine safety, security and environmental
protection, limit the Coast Guard’s ability to respond to a vessel
emergency in a timely and efficient manner, and undermine our MDA.  

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 will be published in the Federal Register to obtain
public comment on this collection.  

9.  Provide any payments or gifts to respondents.  

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

10.  Describe any assurance of confidentiality provided to respondents. 

There are no assurances of confidentiality provided to the respondents
for this information collection.  

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

There are no questions of sensitive language.  

12.  Estimates of reporting and recordkeeping hour and cost burdens of
the collection of information.

The estimated annual number of respondents is 9,535 (613 + 8,922).

The estimated annual number of responses is 534,557 (613 + 533,944).

The estimated annual hour burden is 47,245 (204 + 47,041).

The estimated annual cost burden is $1,481,119 (22,848 + 1,458,271). 

FOR THE LRIT REPORTING AND RECORDKEEPING REQUIREMENTS—

The estimated number of respondents is 613 annually.  We estimate the
number of responses to be 613 annually.

We estimate that annually each respondent will have a 20-minute burden. 
This burden accounts for—

a one-time GMDSS LRIT system initialization for each vessel, 

subsequent annual system check, and 

occasional logbook entries when a ship master switches off the LRIT
equipment or the LRIT equipment fails to operation.  

Once the LRIT equipment is on and initialized, no further action is
necessary.  Data transmission from the equipment will occur
automatically.  

Therefore, we estimate the annual hour burden is 204 hours for all
vessels (613 U.S. ships x 1/3 hour = 204 hours).  Assuming the
Vessel’s Master performs the required LRIT actions (at an hourly rate
of $112/hour, the annual cost burden is $22,848 (204 hours X $112/hour).
 

FOR THE AIS REPORTING REQUIREMENTS—

Number of Respondents

Respondents are summarized in the table below.

Total Respondents

Vessel Type	Total Respondents

Domestic	8,848

Foreign-Flag	74

Total	8,922



Number of Responses

Total Annual Number of Responses = (Total Vessel Number *
Initializations per Year) + (Total Domestic Vessel Number * Avg. Number
of Domestic Entry Responses per Year) + (Total Foreign-Flag Vessel
Number * Avg. Number of Foreign-Flag Entry Responses per Year).  These
statistics are summarized in the table below and elaborated upon in the
following sub-sections.

Total Annual Responses

Vessel Type	Total Vessel Number	Initialization Responses Per Year	Avg.
Number of Entry Responses Per Year	Total Number of Responses Per Year 

Domestic	8,848	1	9 and 164*	533,574

Foreign-Flag	74	1	5	370

Total	8,922	-	-	533,944

*The variation in the number of trips made is dependent on the vessel
class.

Estimated Hour Burden

The Coast Guard estimates that it takes a one-time sum of 20 minutes to
initialize (& annually conduct system upgrades) the AIS on a vessel and
5 minutes per voyage to enter vessel specific information into the AIS
system.  Furthermore, the Coast Guard estimates that a domestic vessel
will take an average of 9 and 164 voyages per year, dependent upon the
vessel class and includes current users, that require information entry
into the AIS systems while foreign-flag vessels will take an average of
5 voyages per year requiring the same updates.  The total number of
burden hours then is estimated to be the following:

Initialization

2,920 hours for domestic ships not yet equipped to initialize the AIS
System (8,848 domestic ships * 1/3 hour (0.33) per initialization).

24 hours for foreign-flag vessels not yet equipped to initialize the AIS
system (74 foreign-flag vessels * 1/3 (0.33) hour per initialization).

2,944 total annual hour burden for both domestic and foreign-flag
vessels not yet quipped to initialize onboard AIS systems.

Voyage Specific Information Entry

44,066 hours for domestic ships to enter voyage specific information
(8,848 domestic ships * 1/12 hour (0.083) per entry * 164 voyages per
year for certain vessel classes (9 voyages per year for other vessel
classes).

31 hours for foreign-flag vessels to enter voyage specific information
(74 foreign-flag vessels * 1/12 hour (0.083) per entry * 5 voyages per
year).

44,097 total annual hour burden for both domestic and foreign-flag
vessels to enter voyage specific information into onboard AIS systems.

Total Annual Hour Burden for AIS Initialization and Vessel Specific
Information Entry

47,041 total annual hour burden for AIS initialization and vessel
specific information entry (2,944 total hour burden for initialization +
44,097 total annual hour burden for voyage specific information entry).

Estimated Cost Burden

The industry cost is based on an average hourly wage of $31/hour.    

Estimate Hourly AIS Initialization Cost Per Year

Vessel Type	Initialization Hours	Hourly Cost	Total Hourly Cost

Domestic	1/3	$31.00	$10.33

Foreign-Flag	1/3	$31.00	$10.33



Estimate Hourly AIS Update Entry Cost Per Year

Vessel Type	Ind. Voyage Entry Hours	Avg. Number of Voyages	Hourly Cost

Domestic	1/12	9 (and 164)	$31.00

Foreign-Flag	1/12	5	$31.00



Total Estimate Hourly Cost for AIS Initialization and AIS Update Entry 

Vessel Type	Annual Initialization Cost	Annual Update Entry Cost

Domestic	$10.33	$23.25

Foreign-Flag	$10.33	$12.92

*Initialization is performed once, updates are annual.

The estimated annual cost burden is:

$1,456,566 for domestic ships ($31.00 * 46,986 total domestic burden
hours)

$1,705 for foreign-flag vessels [$31.00 * 55 (24 initial + 31 voyage
specific) total foreign-flag burden hours]

$1,458,271 total annual burden for affected domestic and foreign-flag
vessels

13.  Total annualized capital and start-up costs.

There are no capital, start-up or maintenance costs associated with this
information collection.  

14.  Estimates of annualized Federal Government costs.

For LRIT, we estimate that the U.S. Government will incur data
transmission costs of approximately $223,750 (613 vessels x 4
transmission per day/vessel x 365 days/year (or about 895,000
transmissions) x $0.25 per transmission) annually from U.S. vessels. 
For AIS, we estimate that the U.S. Government cost is approximately $26
million per year to operate the Nationwide AIS capability.  Thus, the
estimated annual Federal Government cost is about $26.23 million/year.  

15.  Explain the reasons for the change in burden.  

The change in burden is an ADJUSTMENT due to a change (i.e., increase)
in the estimated annual number of responses.  There is no proposed
change to the reporting or recordkeeping requirements of this
collection.  The reporting and recordkeeping requirements, and the
methodology for calculating burden, remain unchanged.  

16.  Plans for tabulation, statistical analysis, and publication.  

This information collection will not be published for statistical
purposes.  

17.  Approval to not display expiration date.  

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

18.  Explain each 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 information collection does not employ statistical methods.  

  Found at --   HYPERLINK "https://www.hsdl.org/?view&did=456414" 
https://www.hsdl.org/?view&did=456414 . 

  As defined in The National Strategy for Maritime Security, the
“maritime domain” is all areas and things of, on, under, relating
to, adjacent to, or bordering on a sea, ocean, or other navigable
waterway, including all maritime-related activities, infrastructure,
people, cargo, and vessels and other conveyances.  Note: The maritime
domain for the United States includes the Great Lakes and all navigable
inland waterways such as the Mississippi River and the Intra-Coastal
Waterway.  

  AIS is an international standard for ship-to-ship, ship-to-shore, and
shore-to-ship communication of information, including vessel identity,
position, speed, course, destination, and other data of critical
interest for navigational safety and maritime security.  

  Figure rounded.

  Equivalent to a Coast Guard Commander (i.e., O-5) (out-of-government
rate), per COMDTINST 7310.1L.

  Based on Coast Guard subject matter expert information, some updates
may take only 30 seconds; however, this estimate is not included in the
estimates of this supporting statement.

  This figure is based on loaded labor rates provided by the Bureau of
Labor Statistics.  

1625-0112

  PAGE  6  of   NUMPAGES  6 

