2007-1004-0132SupportStatement

15

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION

OMB CONTROL NUMBER 1004-0132

Terms of Clearance: None.

Information Collection 1004-0074 and ICR Reference Number 200607-1004-001 are combined into information collection 1004-0132.

SECTION 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 Bureau of Land Management (BLM) has the following authorities for collecting the required information from those who wish to participate in the exploration, development, production, and utilization of geothermal resources on BLM-managed public lands, and geothermal resources on lands managed by other surface management agencies:

1. The Energy Policy Act of 2005 (P. L. 109-58);

2. The Mineral Leasing Act of 1920 (30 U.S.C. 181 et seq.);

3. The Geothermal Steam Act of 1970 (30 U.S.C. 1001‑1028), as amended;

4. The Act of August 7, 1947 (Mineral Leasing Act of Acquired Lands) (30 U.S.C. 351‑359);

5. The Department of the Interior Appropriations Act of 1981 (42 U.S.C. 6508);

6. The Attorney General's Opinion of April 2, 1941 (40 Op. Atty. Gen. 41);

7. The Federal Property and Administrative Services Act of 1949 (40 U.S.C. 471 et seq.) provides the authority for leasing lands acquired from the General Services Administration;

8. The National Environmental Policy Act of 1969; and

9. The regulations at 43 CFR part 3200 through subpart 3287.

2. Explain how, by whom, how frequently, and for what purpose the information is 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.]

The BLM needs the required information to approve lease activities for geothermal resources and unit agreements, process nominations for geothermal lease sales, and monitor compliance with granted approvals. In most cases, we do not require a specific form to collect the required resource and environmental information, since we generally gather the information through the course of industry operations.

Lessee Qualifications 43 CFR Subpart 3202

The respondent must submit proof of the qualifications to hold a geothermal lease to the BLM upon request within 30 days after receipt of the request. The BLM needs this information to verify that respondent meets all the lessee qualification requirements.

Competitive Leasing 43 CFR Subpart 3203

The respondent must submit a letter to the BLM to nominate lands that you request to be placed on a competitive sale. The BLM needs this information to compile the Notice of Competitive Geothermal Lease Sale.

Noncompetitive Leasing Other than Direct use Leases 43 CFR Subpart 3204

The respondent must file a noncompetitive lease application for lands that were not sold at a competitive lease sale. The BLM needs this information to process noncompetitive lease applications.

Direct Use Leases 43 CFR Subpart 3205

The respondent must file an application for a direct use lease for any lands on which the BLM manages geothermal resources. The BLM needs this information to process the application for a direct use lease.

Lease Issuance 43 CFR Subpart 3206

The respondent must accept all lease stipulations; make all required payments to the BLM; sign a unit joinder or waiver, if applicable; and comply with the maximum limit on acreage holdings before the BLM issues a lease. The BLM needs this information to determine if we can issue a lease.

Lease Terms and Extensions 43 CFR Subpart 3207

The respondent must perform development activities that provide geologic or reservoir information during the lease term and extension. The BLM needs this information to approve the various development activities during the lease term.

Additional Lease Information 43 CFR Subpart 3210

The respondent must submit a request in writing to the BLM to segregate, consolidate, or readjust the lease terms. The BLM needs this information to approve the various adjustments to the lease.

Filing and Processing Fees, Rent, Direct Use Fees, and Royalties 43 CFR Subpart 3211

The respondent must submit the required fees for the following non-form information/actions:

(1) Nomination of lands for competitive leasing;

(2) Competitive lease application;

(3) Noncompetitive lease application;

(4) Assignment and transfer of record title or operating rights;

(5) Name change, corporate merger or transfer to heir/devisee;

(6) Lease consolidation; and

(7) Lease reinstatement.

The BLM needs this information to process these various actions.

Lease Suspensions and Royalty Rate Reductions 43 CFR Subpart 3212

The respondent must submit a request in writing to the BLM to:

(1) Suspend the operations and production for a producing lease;

(2) Suspend, reduce, or waive royalty or rental; and

(3) Apply for a production incentive.

The BLM needs this information to determine if the respondent qualifies for these actions.

Relinquishment, Termination, and Cancellation 43 CFR Subpart 3213

The respondent must submit a request in writing to the BLM to relinquish, terminate, or cancel the lease. The BLM needs this information to determine if the respondent qualifies for these actions.

Personal and Surety Bonds 43 CFR Subpart 3214

The respondent must submit a bond to cover:

(1) Any activities related to exploration, drilling, utilization, or associated operations on a Federal lease;

(2) Reclamation of the surface and other resources;

(3) Royalty payments; and

(4) Compliance with the requirements of 43 CFR part 3200.

The BLM needs this information to determine who is liable for these actions.

Bond Release, Termination, and Collection 43 CFR Subpart 3215

The respondent must file a replacement bond after the BLM collects against the bond. The BLM needs this information to determine who is liable for these actions.

Transfer 43 CFR Subpart 3216

The respondent may file a request to the BLM to transfer:

(1) Record title;

(2) Operating rights;

(3) Estate transfers;

(4) Corporate mergers; and

(5) Name changes.

The BLM needs this information to approve these actions.

Cooperative Agreements 43 CFR Subpart 3217

The respondent must submit to BLM an application and the information under this subpart to establish a cooperative agreement for any lands the BLM manages the geothermal resources. The BLM needs this information to process the application for a cooperative agreement.

Exploration Operations 43 CFR Subpart 3251

The respondent must file with the BLM Form 3200-9, Notice of Intent to Conduct Geothermal Resource Exploration Operations, and the required information under this subpart to obtain approval of operations on BLM-managed lands. The BLM needs this information to approve the application.

Specific information we request on Form 3200-9:

(1) The names and addresses of the Applicant(s), Operator, and Contractor(s) and the telephone number of the Operator. We require this information to identify all persons who will be conducting operations on the lands and to correspond with them.

(2) Description of lands by township, with map or maps showing lands to be entered or affected. We require this information to determine the area to be entered or disturbed by the proposed exploration operations.

(3) Type of operations to be conducted. We require this information to determine whether the applicant/operator/contractor is complying with the provisions of the regulations.

(4) Exploration operations will be conducted during the period (date) of commencement and completion. We require this information to determine how long the applicant/operator/contractor intends to conduct exploration operations on the land.

(5) Amount and type of financial assurance to be supplied: Surety bond, Rider to Nationwide bond, Rider to Statewide bond, Bond to be furnished. We require the applicant to indicate the type of bond coverage that will cover the exploration operations.

(6) Signatures. We require signatures to demonstrate that the applicant/operator/contractor understands that he/she must comply with the provisions of the notice of intent.

Conducting Exploration Operations 43 CFR Subpart 3252

The respondent must file with the BLM Form 3260-3, Geothermal Sundry Notice, to obtain approval of operations on BLM-managed lands. The BLM needs this information to approve the application.

Specific information we request on Form 3260-3:

Items 1-14 provide location of the well, its status, the responsible operator, the appropriate surface management agency, and the type of work requested. Item 15 provides for the current conditions of the well (hole size, casing, perforations, etc.). Item 16 allows for identification of associated engineering forms and specifications. Item 17 certifies the agreement between the operator and the BLM. The subsequent report would provide a record of what was done and the results. We use this information to assess the feasibility of future work.

Reports: Exploration Operations 43 CFR 3253

The respondent must submit to the BLM a complete exploration operations report after 30 days:

(1) Complete any geophysical exploration operations;

(2) Complete the drilling of temperature gradient well(s) approved under the notice of intent to conduct exploration;

(3) Plug and abandon a temperature gradient well; and

(4) Plug shot holes and reclaim all exploration sites.

The BLM needs this information to ensure compliance with the requirements.

Exploration Operations Relief and Appeals 43 CFR Subpart 3256

The respondent must submit a request in writing for a variance from the BLM requirements for exploration operations. The BLM needs this information to determine if the respondent qualifies for the variance.

Drilling Operations Permit 43 CFR Subpart 3261

The respondent must file with the BLM Form 3260-2, Geothermal Drilling Permit, and the requirements of this subpart to obtain approval of operations on BLM-managed lands. The BLM needs this information to approve the application for a drilling permit.

Specific information we request on Form 3260-2:

Items 1-17 identify the lessee/operator, well location, approximate starting dates, and lease numbers. Items 18-21 provide for the altitude of the ground and derrick floor above sea level and how it was determined, along with the associated drilling and casing programs containing size and weight of casing, setting depth of each string, and the amount of cement to be used. Item 22 provides a summary of the associated requirements for a drilling permit, e.g., blowout prevention diagram and access road maps. Item 23 certifies the agreement between the operator and the BLM.

Reports—Drilling Operations 43 CFR Subpart 3264

The respondent must file with the BLM Form 3260-4, Geothermal Well Completion Report, within 30 days after you complete a well. The BLM needs this information to approve all aspects of the activities related to drilling operations.

Specific information we request on Form 3260-4:

Items 1-12 identify the operator, well type and location, and type of completion. Items 13-23 provide technical information covering the depth, direction, core sizes, and dates of completion. Items 24-28 provide data on the casing, liner, tubing, workover, or completion activity (cement squeeze, fracture, etc.), and the perforation records. Item 29 provides information on past drilling and completion reports. Items 30-31 indicate the current status of the well and whether or not it is commercially viable. Item 32 certifies the agreement between the operator and the BLM. Items 33-37 provide important well test data.

Utilization Plans and Facility Construction Permits 43 CFR Subpart 3272

The respondent must file an application with the BLM for a utilization plan and facility permit in accordance with the requirements in this subpart for any lands where the BLM manages the geothermal resources. The BLM needs this information to process the application for a utilization plan and facility permit.

How to Apply for a Site License 43 CFR Subpart 3273

The respondent must file an application with the BLM for a site license and the information under this subpart for any lands the BLM manages the geothermal resources. The BLM needs this information to process the application for a site license.

Commercial Use Permit 43 CFR Subpart 3274

The respondent must file an application with the BLM for a commercial use permit and the information under this subpart for any lands the BLM manages the geothermal resources. The BLM needs this information to process the application for a commercial use permit.

Reports—Utilization Operations 43 CFR Subpart 3276

The respondent must submit to BLM monthly reports in accordance with the information under this subpart for facility and lease operations involving Federal geothermal resources. The BLM needs this information to process the approval of the facility and lease operations involving Federal geothermal resources.

Application, Review, and Approval of a Unit Agreement 43 CFR Subpart 3281

The respondent must submit to BLM an application and the information required under this subpart to establish a unit agreement or area for any lands the BLM manages the geothermal resources. The BLM needs this information to process the application for a unit agreement or area.

Participating Area 43 CFR Subpart 3282

The respondent must submit to BLM an application and the information required under this subpart to establish a unit agreement or area for any lands the BLM manages the geothermal resources. The BLM needs this information to process the application for a unit agreement or area.

Unit Agreement Modifications 43 CFR Subpart 3283

The respondent must submit to the BLM a request in writing to revise a unit agreement or area for any lands where the BLM manages the geothermal resources. The BLM needs this information to process the request to revise the unit agreement or area.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological 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. They cannot submit the forms to BLM electronically at this time. However, the BLM will implement a user name password authentication process for E-Forms, pending implementation of HSPD-12. We enrolled and trained users in Oregon, Wyoming, Arizona, Montana, Nevada, and Utah in limited use of the Property and Sign program areas. We will continue training on the use of E-Forms in FY 2007. In FY 2008, we will identify super users as we expand the use of E-Forms into other program areas beyond the Property and Sign program. The Department will schedule full implementation of HSPD-12 in FY 2008. This implementation will provide an easier enrollment and use process for E-Forms with a Level 4 strong multifactor authentication token. In FY 2008, the BLM will fully implement E-Forms using the Smart Card across all program areas to provide organizational maturity of the use and understanding to both program and technical staff. After full implementation and training in use of the E-Forms across all program areas for internal uses, the BLM will prepare to respond and provide service to the public for E-Forms signed and delivered via the Internet. We project public use to be in place by FY 2009.

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.

No duplication of information occurs in the information we collect. The requested information is unique to the operator/operating rights owner and the lease and is not available from any other data source. No similar information is available or able to be modified. The information is required to receive a benefit.

5. If the collection of information impacts small businesses or other small entities describe any methods used to minimize burden.

The BLM is not required to collection information on whether information on whether the respondents qualify as small businesses or small entities. Based on the previous submission, consultation with industry professionals, and agency research, the BLM determined that the majority of businesses with geothermal leasing operations do not qualify as a small business. The BLM estimated 230 respondents that may qualify as a small business. The information we require from all respondents is limited to the minimum necessary to authorize geothermal operations on public lands.

6. Describe the consequence to the 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 the burden.

If we did not collect the information, geothermal resources leasing activities and operations could not occur. Leases and geothermal operations provide revenue to the U.S. Treasury. Less frequent collection would mean no collection of information at all.

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 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 the 60-day notice in the Federal Register on June 21, 2006 (71 FR 35695) soliciting comments from the public and other interested parties. The comment period closed on August 21, 2006. The BLM did not receive any comments from the public in response to this notice.

During the approval period, we consulted with the following respondents to solicit comments on the burden hour and cost estimates, availability of data, frequency of collection, and clarity of instructions. Based on these consultations, the burden estimates in Question 12 reflect their input.

Mr. Lane Lasrich

Landman

Zephyr Corporation

2597 East Bridger Blvd.

Sandy, UT 84093

(801) 942-0525

Ms. Mary Sellers

Independent Landman

Seller Search

2771 S. Roslyn St.

Denver, CO 80231

(303) 751-8266

Mr. Stewart Johnson

Geologist

Ormat Nevada Inc.

6025 Neil Rd., Suite 300

Reno, NV 89511

(775) 356-9029, Ext. 2215

Mr. Kevin Talkington

Land Manager

Calpine –The Geysers

10305 Socrates Mine Rd.

Middletown, CA 95461

(707) 431-6191

Ms. Missy Miller

Senior Compliance Coordinator

Caithness Operating Company

9590 Prototype Ct., Suite 200

Reno, NV 89521

(775) 850-2266

We sought comments on these geothermal forms included in this information collection.

All the respondents surveyed responded that these forms are straightforward and clear as to instructions and reasonable as to information requirements.

The hour burden for each form was estimated at 8 hours for reviewing instructions, gathering and maintaining data, and completing and reviewing these forms.

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

We do not provide payments or gifts to the respondents.

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

We protect the respondent’s confidentiality 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 provides no promises that the application will be protected under the Privacy Act.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, or other matters that are commonly considered private. The 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 when 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.

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 estimated time includes that necessary for all operation activities in the regulations. The conversion rate is $75 per hour except where indicated.

Form Number Estimates of Hour Burden	3260-3	3200-9	3260-2	3260-4
# of responses received (FY 2004 to FY 2006)	300	35	35	35
Frequency of response	On occasion	On occasion	On occasion	On occasion
Annual number of responses	100	12	12	12
Average response time for this collection	8 hours	8 hours	8 hours	10 hours
Annual response time for this collection	800 hours	96	96	120
Hourly cost per respondent	$75	$ 688	$ 688	$ 688
Annualized cost to respondents	$60,000	$66,048	$66,048	$82,560

Burden Hours Information Collected		Number of Actions per Year	Burden Hours per Action	Total Annual Burden Hours	Total Annual Burden Cost
a	43 CFR subpart 3202 Lessee Qualifications	79	1	79	$5,925
b	43 CFR subpart 3203 Competitive Leasing	300	20	6,000	$450,000
c	43 CFR subpart 3204; Noncompetitive Leasing	50	40	200	$15,000
d	43 CFR subpart 3205; Direct Use Leasing	10	10	100	$7,500
e	43 CFR subpart 3206; Lease Issuance	300	1	300	$22,500
f	43 CFR subpart 3207; Lease Terms and Extension	50	1	50	$3,750
g	43 CFR subpart 3210; Additional Lease Information	50	1	50	$3,750
h	43 CFR subpart 3211; Fees	300	1	300	$22,500
i	43 CFR subpart 3212; Lease Suspensions and Royalty Rate Reductions	10	40	400	$30,000
j	43 CFR subpart 3213; Relinquishment, Termination, and Cancellation	10	40	400	$30,000
k	43 CFR subpart 3214; Bonds	10	4	40	$3,000
l	43 CFR subpart 3215; Replacement bonds	10	4	40	$3,000
m	43 CFR subpart 3216; Transfers	30	60	180	$13,500
n	43 CFR subpart 3217; Cooperative Agreements	10	40	400	$30,000
o	43 CFR subpart 3251; Exploration Operations (Form 3200-9)	12	8	96	$7,200
p	43 CFR subpart 3252; Conducting exploration operations (Form 3260-3)	100	8	800	$60,000
q	43 CFR subpart 3253; Reports: Exploration Operations	12	8	96	$7,200
r	43 CFR subpart 3256; Exploration Operations Relief and Appeals	10	8	80	$6,000
s	43 CFR subpart 3261; Drilling Operations Permit (Form 3260-2)	12	8	96	$7,200
t	43 CFR subpart 3264; Reports-Drilling Operations/Recordkeeping (Form 3260-4)	12	10	120	$9,000
u	43 CFR subpart 3272; Utilization Plans and Facility Construction Permits	10	10	100	$7,500
v	43 CFR subpart 3273; Site License	10	10	100	$7,500
w	43 CFR subpart 3274; Commercial Use Permit	10	10	100	$7,500
x	43 CFR subpart 3276; Reports Utilization Operations	10	10	100	$7,500
y	43 CFR subpart 3281; Unit Agreements	10	10	100	$7,500
z	43 CFR subpart 3282; Participating Area	10	10	100	$7,500
aa	43 CFR subpart 3283; Unit Agreement Modifications	10	10	100	$7,500
TOTAL		1,447		10,137	$789,525

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.

Respondents are not required to purchase additional computer hardware or software to comply with these information requirements. There is no filing fee associated with this information collection. There are no capital and start-up costs involved with this information collection.

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.

We estimate the annual cost to the Federal Government to process the responses to this information collection is $108,525 (1,447 x $75 per hour to process). The cost estimate is the result of a cost recovery survey to determine the average cost for processing the information.

Annualized Cost to the Federal Government
(a) Annual number of responses	1,447
(b) Average number of hours to evaluate a response	1
(c) Hourly cost to evaluate a response	$75
(d) Total cost to evaluate a response (1 x $75)	$75
(e) Annualized cost to Federal Government for this collection (1,447 x $75)	$108,525

Typical or average situation where three Federal employees at different grade levels are involved in processing a response to an information collection:

Employee	Annual wage	Hourly wage
GS-5, clerical	$30,386	$15
GS-9, professional	$46,041	$22
GS-13, managerial	$79,397	$38
TOTAL		$75

15. Explain the reasons for any program changes or adjustments.

Burden	Previous Collection	This Collection	Change
Responses	835	1,447	+612
Burden Hours	1,850	10,137	+8,287

There are 136 responses and 1,112 burden-hour changes due to an adjustment in the agency estimate. There are 1,311 responses and 9,025 burden-hour program changes due to the Energy Policy Act of 2005.

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.

The BLM will not publish the results of this 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.

The BLM will display the expiration date of the OMB approval on the forms included in this information collection.

18. Explain each exception to the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions to the certification statement.