Federal Register - September 1, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules at grade level GS13 to review the information resubmitted for the course approval request. We estimate the costs
of modified firefighting course approvals resubmissions in Table 6.
TABLE 6SUMMARY OF RESUBMISSION COSTS FOR MODIFIED FIREFIGHTING TRAINING COURSES
Employee type
Hourly burdened wage
Number of course providers
Average hours
Total cost 30
A
B
C
A B C
Industry Cost
Government Cost
Government Cost
Training Specialist
GS7
GS13
$45.40
44.67
94.22
8
8
8
6
1
5
$2,179
357
3,769
Total Government Cost
4,126
Total Cost
$6,305
We estimate the total costs to course providers from initial applications and any resubmissions to be approximately $8,444 $6,265 + $2,179, and the total costs to government to be approximately $15,988 $11,862 + $4,126. Together, we estimate the costs of evaluating approval requests, for the modified basic firefighting courses to be $8,444 +
$15,988, or $24,432. This cost would occur during the first year of implementation.
As discussed above, course providers would need to seek a renewal every five years if they wish to continue to offer the course. This course renewal would include a submission similar to that
initially provided to and approved by the Coast Guard. Since the Coast Guard would have previously reviewed and approved the course submission, the Coast Guard does not estimate that it would take course providers nearly as long to prepare all materials for the Coast Guard. Specifically, we estimate that the same training specialist who spent 6 hours on an initial course approval request would only spend 1
hour on a renewal request, and the renewal request would be submitted without any revisions.31 We further estimate that all 23 providers would submit a request for renewal of a course approval because we do not expect
turnover in course providers based on a review of previous course approval renewals. The Coast Guard, however, would spend the same amount of time reviewing the renewal requests as it spent with the initial approval request to ensure that the course still meets regulatory requirements, or 1 hour of GS7 time and 6 hours of GS13 time.
These costs would occur 5 years after each approval, or in year 6. We estimate the course renewal costs in Table 7. The 10-year distribution of undiscounted and discounted costs from both the initial and renewal requests are recorded in Table 8.
TABLE 7COURSE RENEWAL SUBMISSION COST
Employee type
Burdened wage
Number of course providers
Hours
Total cost
A
B
C
A B C
Industry Cost
Government Cost
Government Cost
Training Specialist
GS7
GS13
$45.40
44.67
94.22
23
23
23
1
1
6
$1,044
$1,027
$13,002
Total Government Cost
$14,029
Total Cost
$15,073
TABLE 8DISCOUNTED COSTS OVER A 10-YEAR PERIOD OF ANALYSIS IN 2020 DOLLARS DISCOUNTED AT 7% AND 3%
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1
2
3
4
5
6
7
8
9
30 Numbers
may not add due to rounding.
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Discounted costs
Undiscounted costs
Year
7%
$24,432
0
0
0
0
15,073
0
0
0
$22,834
0
0
0
0
10,044
0
0
0
31 According to SMEs from the Coast Guards Office of Merchant Mariner Credentialing.
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Frm 00018
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3%
$23,721
0
0
0
0
12,623
0
0
0
