Supporting Statement A for 2133-0510 8.11.2025

Department of Transportation

Maritime Administration

Information Collection Request (ICR)

OMB 2133-0510

Request for Waiver of Service Obligation, Request for Deferment of Service Obligation, Application for Review

SUPPORTING STATEMENT

INTRODUCTION: This submission is to request a three-year approval from the Office of Management and Budget (OMB) for the information collection entitled OMB 2133-0510 (Request for Waiver of Service Obligation, Request for Deferment of Service Obligation, Application for Review), which expires on August 31, 2025. There was a reduction in the total burden hours for this collection. There are no other changes, so this collection will be submitted as an extension without change of a currently approved collection.

1. JUSTIFICATION

1. Circumstances Making the Collection of Information

Information collection is essential for determining if a graduate of the United States Merchant Marine Academy (USMMA) or subsidized graduate of a State Maritime Academy (SMA) that was a participant in the Student Incentive Payment (SIP) Program has a valid circumstance preventing them from fulfilling the requirements of the service obligation contract signed at the time of their enrollment in a Federally subsidized maritime academy training program. It also permits the Maritime Administration (MARAD) to determine if a graduate who wishes to defer the service obligation to attend graduate school is eligible to receive a deferment. Their service obligation is required by law.

This information collection establishes overall compliance with the service obligation contract in support of the Economic Growth and Trade and National Security goals identified in the DOT Strategic Plan. The graduates are required to serve as commissioned officers in the U.S. Naval Reserve (or officer of the U.S. armed force reserves). As an aspect of the service obligation, they become the Navy's single largest source of naval reserve officers except for Naval Reserve Officers Training Corp (ROTC). In their civilian capacities, they are first required to sail on their professional merchant marine licenses, or work in the maritime industry ashore. This dual role makes the graduates especially valuable because national defense planning initiatives and the Nation's economic needs depend upon available, highly trained personnel.

2. Purpose and Use of the Information Collection

USMMA graduates and SMA SIP graduates use form MA-935, Request for Waiver of Service Obligation (MA-935), to request a waiver of their service obligation requirement; form MA-936, Request for Deferment of Service Obligation (MA-936), to defer their service obligation; or form MA-937, Application for Review of Waiver Deferment Decision (MA-937), to request one final review of the MARAD decision made on these requests by the Maritime Administrator.

The information collected on these forms is then reviewed by the responsible government agencies (MARAD, Department of Defense (DOD), U.S. Coast Guard and National Oceanic and Atmospheric Administration (NOAA)), as part of the service obligation compliance function. Failure to collect this information would make it difficult for MARAD to determine compliance with the obligation and the enabling statute.

Every student and graduate of the USMMA and each SMA SIP subsidized student and graduate of the State maritime academies incurs a mandatory service obligation as a participant in the Federal maritime academy program. This obligation consists of: (1) completing the academy’s course of instruction; (2) maintaining a license as an officer in the merchant marine of the United States for at least six years following graduation from a maritime academy; (3) serving as a commissioned officer in the U.S. Naval Reserve, the U.S. Coast Guard Reserve or any other reserve unit of an armed force of the United States for at least eight years following graduation from a maritime academy; and (4) serving as a merchant marine officer on U.S.-flag vessels, as an employee in a U.S. maritime-related industry ashore or as a commissioned officer on active duty in an armed force of the United States, NOAA Corps or USPHS Corps. The employment service obligation is three years for SIP subsidized state maritime academy graduates and five years for U.S. Merchant Marine Academy graduates. The graduates of the USMMA and the SMA graduates provide an annual report to MARAD between January and March that provides service obligation compliance data for the previous year.

3. Automation or Use of Information Technology

The information is confidential and personal in nature. An electronic web-based internet submission and collection of annual reports is available for USMMA graduates and SMA Student Incentive Payment (SIP) program graduates to request waivers for part or all of their service obligation, or deferment of their service obligation.

4. Efforts to Identify Duplication

There is no duplication of information collection since the content of these forms is not required of the students and/or graduates in any other situation. There is no other agency collecting the forms for deferment or waiver information.

5. Impact on Small Businesses or Other Small Entities

The requested information does not impact small businesses or other small entities. Respondents are individuals desiring a waiver or deferment of their service obligation. The burden to the applicant is as minimal as statutes and regulations permit.

6. Impact of Not Conducting or Less Frequent Collection of Information

The intent of the statute is that waivers and deferments only be requested and granted in justifiable situations. The reporting burden is minimized because the applicant reports no information until a waiver or deferment of the service obligation is desired. There would be no technical or legal obstacles if the use of improved information technology to reduce the burden were considered necessary.

7. Special Circumstances Relating to the Guideline 5 CFR 1320.5

There are no special circumstances that require the collection of information to be conducted in any manner described below:

• Requiring respondents to report information to MARAD more often than quarterly;

• Requiring respondents to prepare a written response in fewer than 30 days after receipt of a collection instrument;

• Requiring respondents to submit more than one original copy 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;

• Requiring the use of any statistical data 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;

• Requiring any pledge of confidentiality; or

• Requiring respondents to submit any proprietary or trade secrets.

8. Public Comments in Response to the Federal Register Notice and Outside

Consultation

MARAD published a 60-day notice and request for comments on this information collection in the Federal Register (FR 24192, Vol. 90, No. 108) on June 5, 2025, indicating comments should be submitted on or before August 5, 2025. No comments were received. A 30-day notice will now be published in the Federal Register to solicit public comments.

9. Explanation of Any Payments or Gifts to Respondents

No payments or gifts are provided to respondents.

10. Assurance of Confidentiality and Protection of Privacy

A Privacy Act Notice is contained in the Service Obligation Contract that each student signs. This notice states that any information provided by the student/graduate will not be divulged, without prior written authorization, to anyone other than persons directly involved in monitoring the service obligation (e.g., school officials, employers, DOD, U.S. Coast Guard and NOAA). Further, the only information released is that which is specific to the request.

11. Justification for Sensitive Questions

There are no questions of a sensitive nature.

12. Estimate of Annualized Burden Hours and Cost

1. Estimated Annualized Burden Hours

Approximately five graduate students will apply once for a waiver of service obligation annually for a total five responses. Each applicant will take 10 minutes (0.16666667 hours) to complete their response to the request for waiver (MA-935) for a total .83/ 1 hour. Additionally, a total five graduate students will file a request for deferment (MA-936) once annually, for a total five responses. Each applicant will take 10 minutes (0.16666667 hours) to complete their deferment request for a total .833/1 hour. Additionally, one graduate student will apply for review of waiver or deferment decision ( MA-937) once a year. This individual will take approximately 10 minutes (0.16666667 hours) to complete this application for a total .16/0 hours. Therefore, the total combined respondents and responses for this collection is 11, while the total burden hours are 2 hours, which can be calculated as shown in the table below:

Form Name/ Type of Action	Total Respondents		Total Responses per Respondent		Total Responses		Time Taken to Respond (Hrs. in decimals)		Total Burden Hours
MA-935	5	*	1	=	5	*	.16666667 (10 mins.)	=	.83 or 1
MA- 936	5		1		5		.16666667 (10 mins.)		.83 or 1
MA-937	1		1		1		.16666667 (10 mins)		.16 or 0
COMBINED TOTAL	11		3		11		.500000007 (30 mins.)		2

2. Estimated Annualized Cost Burden

The Bureau of Labor and Statistics (BLS)¹ estimates that the average hourly wage for Compliance Officers (13-1041) is $ 40.86. When combined the total compensation rate of 29%², the annualized hourly rate is $ 52.71. Therefore, the total annualized cost burden for all tasks associated with preparing and submitting responses to this collection is $ 105.42, which can be calculated as shown in the table below:

Title and Code of Respondents	Hourly Wage	Compensation Rate of 29%		Number of Employees		Total Annualized Burden Hours		Total Annualized Cost Burden
Compliance Officers (13-1041)	$ 40.86	$ 52.71	*	1	*	2	=	$ 105.42

13. Estimate of the Total Annual Cost Burden to Respondents and/or Record Keeper

There are no capital, start-up, operation, or maintenance costs associated with this

information collection.

14. Estimate of Federal Government Costs

The annual cost to the Federal Government for processing applications associated with

this collection is $ 943.58:

According to the Office of Personnel Management (OPM)³ wage tables, the hourly rate

for a (GS 13, Step 5) Federal employees with a Washington-Baltimore-Arlington

locality pay is $ 65.48. When combined with the Federal Employee Compensation rate

of 31%⁴, the total hourly wage rate for this employee is $ 85.78. This employee will

take approximately one hour to review each response to this collection for a total

$ 943.58, which can be calculated as shown in the table below:

FTE Grade and Step & CRF Program Related Task	Hourly Wage	Average Hourly Wage Rate with 31% Compensation		Total Employees		Total Time for Per application ( Avg. Hours)		Total Responses		Total Federal Government Wages
GS 13 (Step 5): Review & Process applications	$ 65.48	$ 85.78	*	1	*	1	*	11	=	$ 943.58

15. Explanation of Program Changes or Adjustments

Since the last renewal, there was a reduction of the total burden hours from 7 to 2 hours, due to less time taken for respondents to complete the forms associated with this collection.

16. Publication of Data Collection Results

There are no plans to publish any information collected for statistical use.

17. Display of the OMB Expiration Date

MARAD is not seeking approval to avoid displaying the OMB expiration date.

18. Exceptions to the Certification Statement

There are no exceptions to the certificate statement.

1 The hourly wage estimate is taken from current BLS tables: https://data.bls.gov/oes/#/industry/000000 .

2 Per BLS Employee Compensation Memo, the total compensation rate for the private sector is 29%, :https://www.bls.gov/news.release/pdf/ecec.pdf

3 The hourly Federal Government wage is taken from OPM 2024 wage tables: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/25Tables/html/DCB_h.aspx

4 Per BLS Employee Compensation Memo, the total compensation rate for the Federal Government is 31%, :https://www.bls.gov/news.release/pdf/ecec.pdf