2006-1004-0029-SupportingStatement

15

Supporting Statement for Paperwork Reduction Act Submissions

OMB Control Number 1004-0029

Terms of Clearance: The BLM is reminded of the need to consult with persons outside of the agency to obtain their views on the information collection. Upon BLM’s next submission, it must document the name, address, and phone numbers of such individuals in the supporting statement. The burden estimate for this collection appears low. BLM should verify the burden collection estimate with a sample of the respondents. BLM is encouraged to combine 1004-0029 with 1004-0010 and 1004-0011.

The terms of clearance are addressed in question 8 of this supporting statement. In addition, the BLM has combined information collection 1004-0010 and 1004-0011 into information collection 1004-0029.

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Color-of-Title Act of December 22, 1928, as amended by the Act of July 28, 1953

(43 U.S.C. 1068, 1068a, 1068b), authorizes the Secretary of the Interior to issue a patent to an individual, group, or corporation who has a valid color-of-title claim. The Bureau of Land Management (BLM) collects and uses the information to determine if an applicant meets the statutory requirements of the Color-of-Title Act and regulations. The Act provides that any individual, group, or corporation who has evidence giving the appearance of having title to public lands that are administered by the BLM and legal title to the land remains vested in the United States may file a color-of-title claim. Any applicant who satisfied all requirements for a claim of class 1 or class 2 will receive a patent conveying title to the land upon payment of the sale price of the land. The 43 CFR part 2540 regulations provide guidelines and procedures for filing and processing color-of-title claims.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. [Be specific. If this collection is a form or a questionnaire, every question needs to be justified.]

An application for a color-of-title claim is comprised of the following forms: (a) 2540-1, Color-of-Title Application; (b) 2540-2, Conveyances Affecting Color or Claim of Title; and (c) 2540-3, Color-of-Title Tax Levy and Payment Record. An applicant must submit the forms at the same time (as one application) and the BLM must process the information contained on the forms at the same time (as one application) in order to determine if the respondent meets the requirements of the Color-of-Title Act. The BLM uses the information to determine if an applicant meets the statutory requirements of the Color-of-Title Act and regulations. Response to this information is mandatory if the applicant wishes to obtain title to the land. Failure to provide the necessary information will result in the rejection of the color-of-title application. We collect and use the information as follows:

Form 2540-1, COLOR-OF-TITLE APPLICATION: The BLM uses this information to identify the applicant, the land claimed by the applicant, the type of claim, the circumstances under which the applicant came into possession of the land claimed and the current structural and cultural characteristics of the land.

Serial Number: The BLM is responsible for creating the serial number. Each form will be labeled with an identical serial number and placed in a single case file labeled with the serial number.

Item #1: Name of applicant. The BLM collects this information to identify the applicant (individual, group, or corporation) making the claim.

Item #2: Address. The BLM collects this information to transact business and communicate with the applicant by mail.

Item #3: Phone. The BLM collects this information to communicate with the applicant by phone.

Item #4: Legal description of lands claimed (township, range, section, subdivision, meridian, county, state, number of acres). The BLM collects this information to identify the exact location and extent of the lands the applicant is claiming.

Item #5: Type of application (class I, class 2 or both). The BLM collects this information to determine the type of claim the applicant is applying for.

Item #6: Are you the record title holder? (The form asks for explanation if the answer is negative.) If the applicant is not claiming the land as the record title owner, the BLM collects this information to determine what interest the applicant has in the land.

Item #7: By what written instrument do you assert ownership (deed, will, court order, etc.)? Attach copy of instrument to application. The BLM collects this information to determine on what written document the applicant is basing the claim.

Item # 8: On what date did you first learn that you did not have clear title? The BLM collects this information to determine if the applicant held the land in good faith. The date the applicant first learned they did not have clear title to the land is essential in determining compliance with the good faith requirements of the Act.

Item #9: From what source did you obtain this information? The BLM collects this information to determine if the applicant held the land good faith. The source the applicant obtained the information from is essential in determining the good faith requirements of the Act.

Item #10 a, b, c, d, e: Have you had title to the land searched, Yes or No? If yes, please complete the following information about the examiner (name, address, phone number, and date of examination)? The BLM collects this information to communicate with the examiner who searched the title for the applicant, compare the examiner's information with the records of the United States, and resolve any discrepancies in the title information that may exist.

Item #11a: Total purchase price paid by you for the above-described property. The BLM collects this information to determine the final purchase price of the land claimed.

Item #11b: Estimated value of structural and cultural improvements on date of purchase. The BLM collects this information to determine the final purchase price payable by the applicant to the United States. The land applied for will be appraised on the basis of its fair market value at the time of the appraisal. The value resulting from improvements or development by the applicant or his predecessors will be deducted from the appraised price and consideration will be given to the equities of the applicant.

Item #11c: Estimated value of existing structural and cultural improvement added since purchase. The BLM collects this information to determine the final purchase price payable by the applicant to the United States. The land applied for will be appraised on the basis of its fair market value at the time of the appraisal. The value resulting from improvements or development by the applicant or his predecessors will be deducted from the appraised price and consideration will be given to the equities of the applicant.

Item #11d: Amount received for forest products sold since purchase. The BLM collects this information to determine the final purchase price payable by the applicant to the United States. The amount of any revenue generated from the sale of forest products since purchase will be included in the final purchase price.

Item #12a: Is the land currently under cultivation, Yes or No? The BLM uses this information to determine if the applicant meets the requirements of a class 1 claim.

Item #13a: Specify which calendar years cultivated. The BLM uses this information to determine if the applicant meets the requirements of a class 1 claim.

Item #13b: Acres cultivated. The BLM uses this information to determine if the applicant meets the requirements of a class 1 claim.

Item #14: List any improvements to property. The land applied for will be appraised on the basis of its fair market value at the time of the appraisal. The value resulting from improvements or development by the applicant or his predecessors will be deducted from the appraised price and consideration will be given to the equities of the applicant.

Item #15: If claim originated before January 1, 1901, are you also applying for the mineral estate? Yes, No, or Not applicable. The BLM uses this information to determine if the applicant is requesting title to the minerals. Conveyance of Federally-owned minerals underlying the land claimed by the applicant cannot be made unless the BLM prepares a mineral report to evaluate the minerals.

Item #16a: Enclose the filing fee of $10. The applicant is required by 43 CFR 2541.2(a)(2) to pay an application fee.

Item #16b: Form 2540-2 showing all conveyances affecting title to the lands? The applicant is required by 43 CFR 2541.2(c)(1) to furnish itemized data relating to all record and non-record title conveyances. The BLM uses this information to determine if any irregularities in the chain of title exist.

Item #16c: Form 2540-3 showing levy and payment of taxes for each year of claim (Required of Class 2 claimants only)? The applicant is required by 43 CFR 2541.2(c)(2) to furnish itemized information relating to tax levies and payments on the land claimed. The BLM uses this information to determine taxes levied and paid on the land claimed.

Certification: The applicant must certify the truth of all statements in the application by signing and dating the application. The certification begins the process of examining the respondent’s eligibility to acquire clear title to the land claimed under the Color-of-Title Act, as provided in the implementing regulations.

Form 2540-2, CONVEYANCES AFFECTING COLOR OR CLAIM OF TITLE: The BLM uses this information to trace the chain of title to the land claimed by an applicant.

Applicant’s Last Name. The BLM collects this information to identify the applicant making the claim and uses this to link the forms submitted by the applicant.

Legal description of lands claimed (township, range, section, subdivision, meridian, county, and state). The legal description must be listed as recorded in public records of the county concerned as required by 43 CFR 2541.2(c)(1). The BLM collects this information to identify the exact location of the land the applicant claims.

Grantor. Property in the form of land must have a recorded owner. The names of the grantor and the grantee for the conveyance must be provided as required by law. The BLM uses this information to trace the land title back to the original or current land owner.

Grantee. Property in the form of land must have a recorded owner. The names of the grantor and the grantee for the conveyance must be provided as required by law. The BLM uses this information to trace the land title back to the original or current land owner.

Date. The BLM uses this information to determine when the transfer of title occurred between the grantor and grantee. The information is vital in determining if the applicant meets the eligibility requirements of a class 1 claim.

Recorded Volume. The BLM uses this information to verify that each conveyance of record is recorded in the county or parish records.

Page. The BLM uses this information to verify that each conveyance of record is recorded in the county or parish records.

Reservations, restrictions, type of conveyance (mortgage, lease, fee, etc.). The BLM uses this information to identify rights reserved in the conveyance (i.e., oil and gas, all minerals, right-of-way, etc.) and the type of conveyance document (i.e., quitclaim deed, warranty deed, will, or tax sale) used to transfer title to the land from the grantor to the grantee.

Certification. The public official administering the county tax records or a certified abstractor certifies the recorded information. The official signature, address, title, and date of certification are required by law to identify encumbrances and conveyances affecting the validity of the application for public lands as required by 43 CFR 2541.2(c)(1).

Form 2540-3, COLOR-OF-TITLE TAX LEVY AND PAYMENT RECORD: The BLM uses this information to determine if there is a break in the chain of title to the land claimed under class 2 color-of-title.

Applicant’s Last Name. The BLM collects this information to identify the applicant making the claim.

Give legal description of land claimed (township, range, section, subdivision, meridian, county, and state). The BLM uses this information to determine if the location of the claimed Federal land is described as provided in 43 CFR 2541.2(b). The legal description must be listed as recorded in public records of the county concerned as required by 43 CFR 2541.2(c)(1).

Tax year. The BLM uses this information to determine if taxes have been paid in all the years necessary to qualify the applicant legally to receive a property right from the Federal Government according to 43 CFR 2541.2(c)(2).

Payor. The BLM uses this information to identify the entity that paid the tax in each year and to show that the applicant is legally qualify to receive a property right from the Federal Government according to 43 CFR 2541.2(c)(2).

Amount of Tax (Levy). The BLM uses this information to determine the amount of the tax that was required to be paid in each year.

Amount of Tax (Payment). The BLM uses this information to determine if the entire tax levied each year was paid so as to qualify the applicant legally to receive a property right from the Federal Government according to 43 CFR 2541.2(c)(2).

Certification. The public official administering the county tax records or a certified abstractor certifies the recorded information. The official signature, address, title, and date of certification are required by law to identify encumbrances and conveyances affecting the validity of the application for public lands as required by 43 CFR 2541.2(c)(1).

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden [and specifically how this collection meets GPEA requirements.].

In accordance with the Government Paperwork Elimination Act (GPEA), the public can fill out and download forms; however, they cannot submit electronically at this time.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The information collection is unique to the Color-of-Title Act and regulations. The BLM is the only agency collecting this information. The BLM is unable to use or modify existing information collections to process new applications because the applicant's responses are distinct, unrelated, and specific to their claim.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The information collection does not significantly impact small entities. The collection applies to an individual, group, or corporation who has a valid color-of-title claim.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The BLM is the only agency responsible for carrying out the provisions of the Color-of-Title Act which authorizes the Secretary of the Interior to issue a patent to an individual, group, or corporation who has a valid color-of-title claim. Less frequent collection would mean no collection at all. Reducing the burden will preclude the collection of sufficient information to determine if the applicant meets the statutory requirements of the Act and regulations, and thus preclude applicants from receiving benefits provided by law.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

*requiring respondents to report information to the agency more often than quarterly;

*requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

*requiring respondents to submit more than an original and two copies 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;

*in connection with a statistical survey, 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;

*that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

*requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines. We do not exceed the guidelines in 5 CFR 1320.5

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice [and in response to the PRA statement associated with the collection over the past three years] and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. [Please list the names, titles, addresses, and phone numbers of persons contacted.]

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

As required in 5 CFR 1320.8(d), the BLM published a 60-day notice in the Federal Register on April 21, 2005 (70 FR 20765), soliciting comments from the public and other interested parties. The comment period closed on June 20, 2005. We did not receive any comments from the public in response to this notice or unsolicited comments from respondents covered under these regulations. A copy of the notice is attached.

During the approval period, we consulted with the following respondents affected by this information collection to verify the accuracy of our burden estimates. All respondents concurred with our burden hour and cost estimates and had no suggestions for changes.

Mrs. Vonnie Ortgies (Respondent-Applicant), Case File No. MTM-093464, 261 Ash Street

Lewistown, Montana 59457, (406) 535-8906

Mrs. Jeanette Stevens (Respondent-Applicant), Case File No. OROR-061080, P.O. Box 515

Cannon Beach, Oregon 97110, (503) 436-2457

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

The applicant receives no payments or gifts.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The applicant's confidentiality is protected to the extent consistent with the Freedom of Information Act (5 U.S.C. 552).

Under the privacy provisions of the E-Government Act of 2002, individuals/respondents were informed as to whether or not providing the information is mandatory to obtain a benefit. The BLM has firewalls to protect website access, strong security and password protection of the information in the database, and other security measures to protect electronic information.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

We do not require respondents to answer questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

*Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

*If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

*Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

The BLM’s color-of-title application is comprised of forms (2540-1, 2540-2, and 2540-3). Respondents must submit the applicable forms at the same time and the BLM must process the forms at the same time in order to determine if respondents meet the requirements of the Color-of-Title Act. The information collected on the forms is available through the personal knowledge of the respondent, records on file in the BLM, and records on file in the county where the land are located. The response time and cost burden are based on information obtained from respondents and the BLM's experience with the information collection. The average response time per respondent and cost to respondent includes the time necessary to complete the form, answer the questions, and gather the information. The BLM's estimate of the time it takes a respondent to supply the information was verified by consultations with several respondents (see item #8 in the supporting statement). Estimates are based on data within a three-year period from FY 2003 to FY 2005 (10/1/2002 to 9/30/2005).

FORM 2540-1, COLOR-OF-TITLE APPLICATION
Estimates of the Hour Burden
(a) Number of responses received (FY 2003 to FY 2005)	21
(b) Frequency of response	1
(c) Annual number of responses (21 ÷ 3)	7
(d) Annual response time per respondent	1 hour
(e) Annual response time for this collection (7 x 1)	7
Annualized Cost to the Respondents for the Hour Burden
(f) Hourly cost per respondent	$20
(g) Annual cost per respondent ($20 x 1)	$20
(h) Annualized cost to respondents for collection ($20 x 7)	$140

FORM 2540-2, CONVEYANCES AFFECTING COLOR OR CLAIM OF TITLE
Estimates of the Hour Burden
(a) Number of responses received (FY 2003 to FY 2005)	21
(b) Frequency of response	1
(c) Annual number of responses (21 ÷ 3)	7
(d) Annual response time per respondent	1 hour
(e) Annual response time for this collection (7 x 1)	7
Annualized Cost to the Respondents for the Hour Burden
(f) Hourly cost per respondent	$20
(g) Annual cost per respondent ($20 x1)	$20
(h) Annualized cost to respondents for collection ($20 x 7)	$140

FORM 2540-3, COLOR-OF-TITLE TAX LEVY AND PAYMENT RECORD
Estimates of the Hour Burden
(a) Number of responses received (FY 2003 to FY 2005)	21
(b) Frequency of response	1
(c) Annual number of responses (21 ÷ 3)	7
(d) Annual response time per respondent	1 hour
(e) Annual response time for this collection (7 x 1)	7
Annualized Cost to the Respondents for the Hour Burden
(f) Hourly cost per respondent	$20
(g) Annual cost per respondent ($20 x 1)	$20
(h) Annualized cost to respondents for collection ($20 x 7)	$140

FORM 2540-1, COLOR-OF-TITLE APPLICATION; FORM 2540-2, CONVEYANCES AFFECTING COLOR OR CLAIM OF TITLE; FORM 2540-3, COLOR-OF-TITLE TAX LEVY AND PAYMENT RECORD
These estimates are based on the annualized cost for the Federal Government to process the Forms at the same time as one application per respondent. A respondent must submit the forms at the same time (as one application), and the BLM must process the information contained on the forms at the same time (as one application) in order to determine if the respondent meets the requirements of the Color-of-Title Act.
Estimates of the Hour Burden of the Collection of Information for 2540-1, 2540-2, & 2540-3
(a) Number of responses received (FY 2003 to FY 2005)	21
(b) Frequency of response	1
(c) Annual number of responses (21 ÷ 3)	7
(d) Annual response time per respondent	3 hours
(e) Annual response time for this collection (7 x 3)	21
Annualized Cost to the Respondents for the Hour Burden for 2540-1 2540-2, & 2540-3
(f) Hourly cost per respondent	$60
(g) Annual cost per respondent ($60 x 3)	$180
(h) Annualized cost to respondents for collection ($180 x 7)	$1,260

13. Provide an estimate of the total annual [non-hour] cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

*The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information [including filing fees paid]. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

*If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

*Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

Estimates are based on data within a three-year period from FY 2003 to FY 2005 (10/1/2002 to 9/30/2005). Respondents incur no annual capital or start-up costs to prepare for or respond to the information collection. Respondents do not need to purchase any computer software or hardware to comply with this information collection. An application for a color-of-title claim is comprised of the following forms: (a) 2540-1, Color-of-Title Application; (b) 2540-2, Conveyances Affecting Color or Claim of Title; and (c) 2540-3, Color-of-Title Tax Levy and Payment Record. A respondent must submit the forms at the same time (as one application), and the BLM must process the information contained on the forms at the same time (as one application) in order to determine if the respondent meets the requirements of the Color-of-Title Act. Pursuant to 43 CFR 2541.2, each application must be accompanied by a filing fee of $10, which is non-refundable. Respondents are not required to submit a $10 non-refundable filing fee for each form. One $10 non-refundable filing fee covers all of the forms.

Total Annual [non-hour] Cost Burden to Respondents or Recordkeepers for Collection
(a) Total capital and start-up cost	0
(b) Total operation/maintenance and purchase of services cost	0
Application Filing Fee for Collection
(c) Annual number of responses	7
(d) Non-refundable application fee per respondent	$10
(e) Annual non-refundable application filing fee for this collection ($10 x 7)	$70

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

An application for a color-of-title claim is comprised of the following forms: (a) 2540-1, Color-of-Title Application; (b) 2540-2, Conveyances Affecting Color or Claim of Title; and (c) 2540-3, Color-of-Title Tax Levy and Payment Record. A respondent must submit the applicable forms at the same time (as one application), and the BLM must process the information contained on the forms at the same time (as one application) in order to determine if the respondent meets the requirements of the Color-of-Title Act.

Annualized Cost to the Federal Government: The estimates are based on the annualized cost for the Federal Government to process the forms (2540-1, 2540-2, & 2540-3) at the same time as one application per respondent.
(a) Annual number of responses	7
(b) Number of hours to evaluate a response	10 hours
(c) Hourly cost to evaluate a response	$25
(d) Total cost to evaluate a response ($25 x 10)	$250
(e) Annual cost to evaluate and process applications ($250 x 7)	$1,750
(f) Annual non-refundable application fee for this collection	$70
(g) Annualized cost to Federal Government for this collection ($1,750 - $70)	$1,680

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

The annual reporting estimates are as follows.

FORM 2540-1, COLOR-OF-TITLE APPLICATION: Since the last approval, the number of respondents decreased from 11 to 7 annually. Respondents are required to submit only one application. This decrease resulted in the total annual hours requested from 11 hours to 7 hours for a decrease adjustment of 4 hours.
Item	Previous Collection		This Collection		Difference
(a) Number of respondents		11		7		4
(b) Total annual responses		11		7		4
(c) Total annual hours requested		11		7		4

FORM 2540-2, CONVEYANCES AFFECTING COLOR OR CLAIM OF TITLE: Since the last approval, the number of respondents decreased from 11 to 7 annually. Respondents are required to submit only one application. This decrease resulted in the total annual hours requested from 11 hours to 7 hours for a decrease adjustment of 4 hours.
Item	Previous Collection		This Collection		Difference
(a) Number of respondents		11		7		4
(b) Total annual responses		11		7		4
(c) Total annual hours requested		11		7		4

FORM 2540-3, COLOR-OF-TITLE TAX LEVY AND PAYMENT RECORD: Since the last approval, the number of respondents (applicants) decreased from 11 annually to 7 annually. Respondents are required to submit only one response (application). This decrease resulted in the decrease in the total annual hours requested from 11 hours to 7 hours, for a decrease adjustment of 4 hours.
Item	Previous Collection		This Collection		Difference
(a) Number of respondents		11		7		4
(b) Total annual responses		11		7		4
(c) Total annual hours requested		11		7		4

FORM 2540-1, COLOR-OF-TITLE APPLICATION; FORM 2540-2, CONVEYANCES AFFECTING COLOR OR CLAIM OF TITLE; FORM 2540-3, COLOR-OF-TITLE TAX LEVY AND PAYMENT RECORD. These estimates are based on the annualized cost for the Federal Government to process the forms at the same time as one application per respondent. A respondent must submit the forms at the same time (as one application), and the BLM must process the information contained on the forms at the same time (as one application) in order to determine if the respondent meets the requirements of the Color-of-Title Act. The previous collection totals are based on what the totals would have been if the forms had been processed as one application per respondent.
Item	Previous Collection		This Collection		Difference
(a) Number of respondents		11		7		4
(b) Total annual responses		11		7		4
(c) Total annual hours requested		33		21		12

The estimates are based on the annualized cost for the Federal Government to process the forms (2540-1, 2540-2, & 2540-3) at the same time. Respondents must submit the applicable forms at the same time, and the BLM must process at the same time in order to determine if respondents meet the requirements of the Color-of-Title Act. Respondents are not required to submit a $10 non-refundable filing fee for each form. One $10 non-refundable filing fee covers all of the forms. Pursuant to 43 CFR 2541.2, each application must be accompanied by a filing fee of $10, which is non-refundable. For this current request, the non-refundable application filing fee is $70. Since the last approval, the annual total of non-refundable application filing fees for this collection has decreased from $110 annually to $70 annually, a decrease adjustment of $40. This decrease is due to the decrease in the average number of respondents (applicants) from 11 annually to 7 annually.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

We have no plans to publish this information collection.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We are not requesting approval to not display the expiration date.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

There are no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on the OMB Form 83-I is checked "Yes", the following documentation should be included in the Supporting Statement to the extent that it applies to the methods proposed:

1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection method to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

2. Describe the procedures for the collection of information including:

*Statistical methodology for stratification and sample selection,

*Estimation procedure,

*Degree of accuracy needed for the purpose described in the justification,

*Unusual problems requiring specialized sampling procedures, and

*Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separately or in combination with the main collection of information.

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.

This information collection does not employ statistical methods.