1018-0093 supporting statement A

Supporting Statement A for
Paperwork Reduction Act Submission
OMB Control Number 1018-0093
Federal Fish and Wildlife Permit Applications and Reports—
Management Authority
50 CFR 12, 13, 14, 15, 16, 17, 18, 21, 23
FWS Forms 3-200-19--200-37, 3-200-39--3-200-53, 3-200-58, 3-200-61,
3-200-64--3-200-66, 3-200-69, 3-200-70, 3-200-73, and 3-200-76
Note: This Information Collection Request (ICR) includes applications and reports currently
approved under other OMB control numbers. If OMB approves this ICR, we will submit a
request to discontinue OMB Control Numbers 1018-0130 and 1018-0134.
Terms of Clearance: None.
1. Explain the circumstances that make the collection of information necessary.
We collect information on application forms and in reports (in form and nonform format) to
determine if applicants for permits meet the requirements mandated by:
•
•
•
•
•
•
•

Bald and Golden Eagle Protection Act.
Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES).
Endangered Species Act.
Lacey Act (Injurious Wildlife).
Marine Mammal Protection Act.
Migratory Bird Treaty Act.
Wild Bird Conservation Act.

Service regulations implementing these statutes and the CITES treaty are in Chapter I,
Subchapter B of Title 50, Code of Federal Regulations. These regulations stipulate general
and specific requirements that when met allow us to issue permits to authorize activities that
are otherwise prohibited.
2. Indicate how, by whom, how frequently, and for what purpose the information is to
be used. If the information collected will be disseminated to the public or used to
support information that will be disseminated to the public, explain how the
collection complies with all applicable Information Quality Guidelines.
All Service permit applications are in the 3-200 series of forms, each tailored to a specific
activity based on the requirements for specific types of permits. We collect standard
identifier information for all permits, such as the name of the applicant and the applicant’s
address, telephone and fax numbers, social security or tax identification number, and e-mail
address. Standardization of general information common to the application forms will make
the filing of applications easier for the public as well as expedite our review of applications.

The information that we collect on applications and reports is the minimum necessary for us
to determine if the applicant meets/continues to meet issuance requirements for the
particular activity. Respondents submit application forms periodically as needed;
submission of reports is generally on an annual basis. We examined applications in this
collection, focusing on questions frequently misinterpreted or not addressed by applicants.
We have made clarifications to many of our applications to make it easier for the applicant to
know what information we need.
In addition to the forms and reports previously approved for this collection, we have:
•

Incorporated FWS Form 3-200-61 (American Ginseng Report) and nonform information
collections for Approval of CITES Exports, Furbearer Reports, American Alligator
Reports, Plant Rescue Center Application for Participation, and Plant Rescue Center
Report of Receipt and Condition of Specimens. These information collections are
currently approved under OMB Control No. 1018-0130, which expires August 31, 2009.

•

Included FWS Forms 3-200-69 (Eagle/Import/Transport of Bald and Golden Eagle for
Scientific or Exhibition Purposes (CITES)) and 3-200-70 (Export/Re-Import/Transport of
Bald and Golden Eagle for Indian Religious Purposes (CITES)). These information
collections are currently approved under OMB Control Number 1018-0022, which
expires July 31, 2007.

•

Included FWS Form 3-200-76 (Export of Caviar or Meat of Paddlefish or Sturgeon
Removed from the Wild (CITES) currently approved under OMB Control Number 10180134, which expires March 31, 2010.

Note: We have not revised the information collected or the burden associated with the
above applications and reports from that previously approved.
•

Developed three new report forms (3-200-30a, 3-200-39a, and 3-200-40a) and one
nonform report to simplify the reporting process for permittees. The information that we
collect for reports is not a new requirement and was previously requested as a condition
of the applicable permit. In our previous request, we included the burden for these
reports with that requested for the specific application. The report forms provide the
permittee with a suggested format for submitting the reporting requirement associated
with activities authorized by their permit/authorization. These forms also provide
potential applicants with an idea of what will be required if they receive the authorization
requested.

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.].
Forms in this collection will be available to applicants in a fillable format on our forms and
permits websites, by mail, or by fax. Applicants may complete the fillable application online,
but must send the application form with an original signature and the applicable processing
fee by mail. Applicants may send supporting information by e-mail or fax, if we already have
their application and they are able to reference an application number.
At this time, we do not have a system for electronic submission of permit application forms
2

or reports; however, we are actively developing the system and are pilot testing two Service
application forms that have current OMB approval.
4. Describe efforts to identify duplication.
The information that we collect is unique to the applicant and is not available from any other
source. Other than the general identifying information standard for each application,
collection of duplicate information is minimal.
We have established "master permit files” and “programmatic files" for certain types of
permits. This procedure allows applicants who frequently apply for these permits (e.g.,
CITES export permits) to submit most of the required information only once, instead of each
time that they apply. Under this system, the applicant only needs to submit information
specific to the immediate activities. We continue to identify areas where establishment of
"master files" and “programmatic files" would meet our goals of reducing burden, while
ensuring that the applicant’s activities meet the permit/authorization issuance criteria.
We developed an electronic permit issuance and tracking system that greatly improves
retrieval of file information, further reducing duplicate information requests for use in
renewals, extensions, and repeat applications. Ongoing development of our permit
issuance and tracking system will ensure that no duplication arises among Service offices.
5. If the collection of information impacts small businesses or other small entities,
describe the methods used to minimize burden.
This collection will not have a significant impact on small entities. Small businesses or small
entities must provide the same information required of individual applicants. We collect only
the minimum information necessary to establish eligibility and to assess the effect of the
permit program.
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.
If we do not collect the information or if we collected the information less frequently, we
could not implement many wildlife protection programs that are mandated by law. Further,
we could not issue applicants a permit, certificate, or authorization letter, since the collected
information is either required on the permit, certificate, or authorization itself or is needed to
make the necessary biological and legal findings under applicable statutes and treaties. In
certain cases where programmatic, biological, and/or legal findings can be made as a result
of an initial application, we can use a less burdensome process for subsequent requests, as
long as the information provided to make the original findings remains the same.
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;
3

*
*
*

*

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.

No special circumstances exist that require us to collect the information in a manner
inconsistent with OMB guidelines.
8. Provide 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 (or in response to a PRA statement) and describe actions
taken by the agency in response to these comments.
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.]
On February 22, 2007, we published in the Federal Register (72 FR 8002) a notice of our
intent to request that OMB approve this information collection. In that notice, we solicited
comments for 60 days, ending on April 23, 2007. We received one comment. The comment
did not address issues surrounding the proposed collection of information or the cost and
hour burden estimates, but instead objected to other aspects of our program, such as level
of issuance of permits, interpretation of laws, clarity of Federal Register notices related to
other processes and procedures, and the accuracy of the level of the application fees. We
have not made any changes to this collection as a result of the comment.
We contacted the following groups that consistently use our forms and solicited comments
on the information collection.
Steve Olson
Director of Government Affairs
Association of Zoos and Aquariums
[email protected]
Carla Cicero
Museum Specialist
Museum of Vertebrate Zoology
[email protected]

Ellen Paul
Executive Director
The Ornithological Council
[email protected]
Dave Self
President Elect
Florida Nurserymen & Growers Association
[email protected]

4

Rick Parsons
Director of Wildlife Conservation
Safari Club International
4800 West Gates Pass Road, Tucson,
Arizona 85745-9490
Susan Clubb, Conservation and Research
Committee/ Cooperative Breeding Programs
American Federation of Aviculture
[email protected]

Marshall Meyers
Government Affairs
Pet Industry Joint Advisory Council
[email protected]
Eric Klaphake
Legislative Committee
Association of Reptilian and Amphibian
Veterinarians
[email protected]

Regulatory Affairs Professionals Society
(RAPS)
11300 Rockville Pike, Suite 1000, Rockville,
MD 20852
[email protected]

Necessity of Collection. All agreed that the collections were necessary, except in the
following circumstances:
•

FWS Form 3-200-49. One commenter asked why there needs to be a conservation
relationship delineated in the Wild Bird Conservation Act Cooperative Breeding
Program application.
Response: This conservation relationship is part of the issuance criteria and this
question must remain part of the application.

•

FWS Form 3-200-41. One commenter asked if the requested inventory needs to
include Endangered Species Act listed species/specimens that are not eligible for
the Captive-bred Wildlife Registration (CBW).
Response: We agree it is not necessary that the inventory for this application
include those species/specimens not able to be covered under the CBW, and we
have indicated this on the application form. However, if the applicant’s experience
does not include activities with the specific species he/she is requesting to add to a
CBW, he/she may need to provide this inventory data to substantiate experience with
similar species.

Burden Estimates. All agreed that our estimates were accurate except in the following
circumstances:
•

FWS Form 3-200-24. One commenter indicated that the time burden estimate might
be a little low for novice applicants. This commenter went on to state that the time
burden estimates on application forms 3-200-49 and 3-200-65 were underestimates.

•

FWS Forms 3-200-27 and 3-200-29. Another commenter indicated that updates to
the burden time were needed on application forms 3-200-27 and 3-200-29. This
commenter went on to state that it would be useful to see all of the reporting burdens
expressed consistently (e.g., not 120 minutes on one application and 2 hours on the
next).
Response: We believe that the approximate time burdens for each application
(including those emphasized in these comments) accurately reflect the estimated
time for the average applicant to complete the application in question. For
5

consistency, we have standardized the time units. For applications, completion
times of 70 minutes or less are expressed in minutes and completion times over 70
minutes are expressed in hours and minutes, as appropriate.
Ways to Enhance the Quality, Utility, and Clarify of Information. Three commenters
made suggestions regarding the application form formats:
•

FWS Form 3-200-48. One commenter indicated that the Service wildlife ports where
the import declaration for their bird(s) can occur are limited to those close to U.S.
Department of Agriculture bird quarantine stations; therefore, the list of Service
wildlife ports should contain a note to that effect.
Response: All application forms that contain the wildlife declaration question have a
standardized list of ports for Service wildlife declaration. The port of declaration is
chosen by the applicant from this standardized list, in consideration of all factors (to
include other Federal agency requirements) influencing the logistics of their specific
situation.

•

FWS Form 3-200-24. One commenter stated that the IATA website link is not useful
for answering the question.
Response: We have removed this link and have standardized the question to assist
the applicant in responding.

•

Consistency. A commenter indicated several areas where consistency in common
questions across applications would improve the quality of information. For certain
common questions, the commenter provided insights into areas where clarification
may be needed. The questions where consistency is warranted are: request for
transport information; request for CITES Appendix I import permit information;
request for current location information; and request for location of parental stock
information. The questions where clarification is warranted are: request for transport
information and requests that can be answered with supporting documentation.
Specifically, the commenter indicated that it would be helpful if there were more
detail on the transport regulations and their associated guidelines, to include web
links where appropriate. Clarification would be useful on the types of documentation
that can be submitted to identify the specimen(s), the specimen’s(s) origin(s), or
species holdings of an institution. This commenter also indicated that on application
forms 3-200-25, 3-200-27, 3-200-29, 3-200-31, 3-200-37, and 3-200-41, language
and enclosures/web links could be updated so certain questions are clearer and/or
would provide the information appropriate to address the permit issuance criteria.
Finally, this commenter emphasized that the direction for the principal officer to sign
in blue ink should be in bold type, as this instruction is easily missed.
Response: We have attempted to standardize common questions across
applications wherever feasible. With regard to the specific instances where
clarification or language and enclosure/web links updates are needed, we have
taken these into account and have added clarifications and updates where warranted
and feasible.

6

Ways to Minimize Burden. All agreed that the burden was within acceptable limits except
in the following circumstances:
•

FWS Form 3-200-49. One commenter indicated that we should not require all of the
original program information to be repeated in cases of reissuance/amendment.
This same commenter also indicated applicants should be able to utilize electronic
signatures rather than a traditional hard copy signature.

•

Use of Databases. One commenter emphasized the ability for their members to be
able to use their member-wide database records to answer certain questions, the
implication being it would be helpful in reducing the burden of information submission
on the applicant’s end.

Response: We revised FWS Form 3-200-49 to indicate when applicants do not need to
repeat certain information. At this time, we do not have a system for electronic
submission of permit application forms or report forms; however, we are actively
developing the system and hope to have a system soon that will accept electronic
signatures. Regarding referencing a specific membership’s record type as a type of
supporting documentation that can be submitted for certain questions, we will accept this
specific membership’s record type as supporting documentation where appropriate to
augment answers to specific questions. However, applicants should not use this
documentation in lieu of answering a specific question. The applicant should consider
which application questions the mentioned records would serve to augment. We can
provide guidance on appropriate supporting documentation to all applicants regardless
of their membership affiliation.
In addition to this specific public outreach, we also attend meetings of groups where a
significant portion of the membership submits applications. At these meetings, we provide
guidance on submitting applications and receive general feedback on the forms. We
attempt to incorporate the general comments in our application forms where appropriate.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
We do not provide payments or gifts to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
We do not provide any assurance of confidentiality. The information collected is subject to
the requirements of the Privacy Act and the Freedom of Information Act as explained in the
notices portion of all applications.
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.
We do not ask questions of a sensitive nature.

7

12. Provide estimates of the hour burden of the collection of information.
We estimate that there will be approximately 8,155 respondents annually for the applications
and reports included in this ICR. We anticipate receiving approximately 12,097 responses
annually, totaling 8,950 annual burden hours. The completion times vary substantially
depending on the activity. At an average rate of $35 per hour for salary and benefits, we
estimate the dollar value of the annual burden hours for this collection to be $313,250. See
Attachment A for a breakout of burden hours and costs for each information collection.
13. Provide an estimate of the total annual [non-hour] cost burden to respondents or
record keepers resulting from the collection of information.
We estimate the nonhour cost burden to respondents for this information collection to be
$941,270. These costs are primarily for application processing fees, which range from $0 to
$300. There are no processing fees for reports. However, we have estimated the nonhour
cost burden for the American Ginseng Report (FWS Form 3-200-61) to be $3,000 for travel
and printing costs. Federal, tribal, State, and local government agencies and those acting in
their behalf are exempt from processing fees. See Attachment A for a breakout of nonhour
burden costs for each information collection.
14. Provide estimates of annualized costs to the Federal Government.
The annual cost to the Federal Government for this information collection is approximately
$1,894,731. These costs are primarily for staff time to review and process applications and
reports. We estimate an average of $50 per hour for salary and benefits.
Review/processing time varies from 15 minutes to 30 hours depending on the activity. See
Attachment A for a breakout for each information collection.
15. Explain the reasons for any program changes or adjustments.
We are estimating 12,097 responses, totaling 8,950 annual burden hours for this collection.
This is an increase of 2,790 responses and 2,204 annual burden hours from our previous
request. Part of this increase is a result of incorporating information collections contained in
1018-0022, 1018-0130, and 1018-0134 (652 responses and 1,907 burden hours) in this
collection. The remaining increase is a result of adjustments to our estimates, based on
experience over the past 3 years. The reduction in nonhour burden costs of $14,730 from
our previous request is because our previous request erroneously included application
processing fees for exempt entities.
16. For collections of information whose results will be published, outline plans for
tabulation and publication.
There are no plans for publication of the results of these information collections.
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 will display the OMB control number and expiration date.

8

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.

9

Attachment A

CONSOLIDATED BURDEN TABLE
OMB 1018-0093
Activity

Average time Cost to
Government
(hrs) per
response for ($50/hr)
Govt review

Total nonhour
burden cost to
applicants

Average
Total dollar
value of burden nonhour
hours ($35/hr) burden cost
per
response**

Total
annual
burden
hours

Average
completion
time per
response
(minutes)

Number of
annual
responses

Number of
annual
respondents

3-200-19 - application

1031

1083

20

361

$12,635

100

$108,300

3.5

$189,525

3-200-20 - application

15

21

60

21

$735

100

$2,100

7.5

$7,875

3-200-21 appllication
3-200-21 associated report
3-200-22 - application

134

201

45

151

$5,285

100

$20,100

7.5

$75,375

100

135

15

34

$1,190

0

$0

0.25

$1,688

70

95

20

32

$1,120

100

$9,500

4.5

$21,375

3-200-23 - application

127

241

45

181

$6,335

75

$17,250

5

$60,250

3-200-24 - application

170

485

45

364

$12,740

100

$41,500

6

$145,500

3-200-25 - application

46

64

60

64

$2,240

100

$6,400

5

$16,000

3-200-26 - application

618

865

20

288

$10,080

100

$86,500

1.5

$64,875

3-200-27 - application

68

113

45

85

$2,975

100

$9,700

5

$28,250

3-200-28 application
3-200-29 application*

57

95

30

48

$1,680

87.5

$8,313

1.75

$8,313

108

270

70

316

$11,060

125

$25,625

1.83

$24,705

3-200-30 - application

73

81

60

81

$2,835

100

$8,100

7

$28,350

3-200-30a - report

64

69

30

35

$1,225

0

$0

0.50

$1,725

3-200-31 - application

3

3

120

6

$210

100

$200

6.5

$975

3-200-32 - application

105

614

60

614

$21,490

125

$58,000

3

$92,100

3-200-33 - application

20

303

120

606

$21,210

200

$60,600

7

$106,050

3-200-34 - application

41

107

20

36

$1,260

125

$13,375

4.5

$24,075

3-200-35 - application

3

3

60

3

$105

100

$200

6.5

$975

* Total burden hours adjusted to reflect totals entered by ROCIS because of rounding.
** Nonhour burden cost per response is application fee
***Nonhour burden cost is for travel/printing expenses

Attachment A

CONSOLIDATED BURDEN TABLE
OMB 1018-0093
Activity

Average time Cost to
Government
(hrs) per
response for ($50/hr)
Govt review

Total nonhour
burden cost to
applicants

Average
Total dollar
value of burden nonhour
hours ($35/hr) burden cost
per
response**

Total
annual
burden
hours

Average
completion
time per
response
(minutes)

Number of
annual
responses

Number of
annual
respondents

3-200-36 - application

3

3

60

3

$105

100

$200

7.5

$1,125

3-200-37 - application

110

165

120

330

$11,550

100

$15,900

20

$165,000

3-200-39 - application

7

7

60

7

$245

100

$300

4

$1,400

3-200-39a - report &
recordkeeping
3-200-40 - application

7

7

30

4

$140

0

$0

0.50

$175

2

2

60

2

$70

100

$100

4

$400

3-200-40a* - report

2

2

30

2

$70

0

$0

0.25

$25

3-200-41 - application

87

87

120

174

$6,090

200

$13,000

6

$26,100

3-200-41a - report

83

83

30

42

$1,470

0

$0

0.50

$2,075

3-200-42 - application

20

21

60

21

$735

62.5

$1,063

3

$3,150

3-200-43 - application

16

19

140

44

$1,540

131.25

$1,969

30

$28,500

3-200-44 - application

1

1

30

1

$35

150

$150

3.5

$175

3-200-44a* - report

1

1

60

1

$35

0

$0

1.00

$50

3-200-45 - application

77

77

30

39

$1,365

100

$7,700

3.5

$13,475

3-200-46 - application

335

369

30

185

$6,475

50

$18,450

4

$73,800

3-200-47 - application

7

16

120

32

$1,120

100

$800

6.5

$5,200

3-200-48 - application

3

4

60

4

$140

100

$300

4

$800

3-200-49 - application

3

4

180

12

$420

200

$600

8

$1,600

3-200-50 - application

2

2

600

20

$700

0

$0

7

$700

3-200-51 - application

2

2

480

16

$560

250

$500

8

$800

* Total burden hours adjusted to reflect totals entered by ROCIS because of rounding.
** Nonhour burden cost per response is application fee
***Nonhour burden cost is for travel/printing expenses

Attachment A

CONSOLIDATED BURDEN TABLE
OMB 1018-0093

Activity

Average time Cost to
Government
(hrs) per
response for ($50/hr)
Govt review

Total nonhour
burden cost to
applicants

Average
Total dollar
value of burden nonhour
hours ($35/hr) burden cost
per
response**

Total
annual
burden
hours

Average
completion
time per
response
(minutes)

Number of
annual
responses

Number of
annual
respondents

3-200-52 - application

145

198

15

50

$1,750

100

$15,000

2.5

$24,750

3-200-53 - application

4

4

120

8

$280

100

$300

6.5

$1,300

3-200-58 - application

50

50

60

50

$1,750

0

$0

3

$7,500

3-200-61 ***- report

25

25

2610

1088

$38,080

120

$3,000

2

$2,500

3-200-64 - application

115

137

30

69

$2,415

75

$10,275

3

$20,550

3-200-65 - application

2

2

2400

80

$2,800

100

$200

5

$500

3-200-66* application

50

50

30

26

$910

50

$1,900

1

$2,500

3-200-69* application

3

3

30

3

$105

75

$150

1

$150

16

16

30

8

$280

0

$0

1

$800

3975

5565

30

2784

$97,440

75

$355,650

2

$556,500

12

120

180

360

$12,600

150

$18,000

8

$48,000

2

2

720

24

$840

0

$0

4

$400

52
10
3
70
8155

52
10
3
140
12097

60
60
60
30

52
10
3
70
8950

$1,820
$350
$105
$2,450
$313,250

0
0
0
0

$0
$0
$0
$0
$941,270

1
1
1
0.5

$2,600
$500
$150
$3,500
$1,894,731

3-200-70 - application
3-200-73* application
3-200-76 - application

Approval of CITES
Export
Furbearer Report
Alligator Report
PRC - Application
PRC - Report
Totals

* Total burden hours adjusted to reflect totals entered by ROCIS because of rounding.
** Nonhour burden cost per response is application fee
***Nonhour burden cost is for travel/printing expenses