Supporting Statement for Paperwork Reduction Act Submissions
“Backcountry Use Permit (36 CFR 1.5, 1.6, and 2.10)”
OMB Control Number 1024-0022
Terms of Clearance: None
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 National Park Service (NPS) is requesting renewal of approval for the information collection requirements associated with permits implementing provisions of agency regulations pertaining to the use of public lands (OMB Control 1024-0022). Standard Form 10-404A, Backcountry Use Permit, is the primary form used to implement a backcountry reservation system and provide access into backcountry zones where registration is required or limits are imposed in accordance with regulations. Such permitting enhances the ability of the NPS to issue hazard warnings, to conduct search and rescue efforts, and provide resource protection.
The objectives of the permit system are: (1) to assure that requests by backcountry users are evaluated by park managers in accordance with applicable statutory law and NPS regulations; (2) that a consistent set of standards and permitting criteria are used throughout the agency; and (3) to the extent possible, ensure that a single permitting document is used to provide this benefit and to document the activity covered under this program.
In order to provide campers desiring access to the backcountry with continuing opportunities for solitude, as well as to provide a means of disseminating public safety messages regarding backcountry travel, the NPS, in 1976, initiated a backcountry registration system in accordance with the regulatory authority found in 36 CFR 1.5, 1.6 and 2.10. This system assures campers of finding routes and campsites that are not crowded beyond their capacity. The quality of both the recreational experience and the physical setting thereby remain uncompromised.
“The Service thus established shall…conserve the scenery and the natural and historic objects and wildlife there-in…in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” {emphasis added]
16 U.S.C. 1a Administration of the National Park Service
“…The authorization of activities shall be construed and the protection, management and administration of these areas shall be conducted in light of the high public value and integrity of the National Park System and shall not be exercised in derogation of the values and purposes for which these various areas have been established…”
16 U.S.C. 3 Rules and Regulations
“The Secretary of the Interior shall make and publish such rules and regulations as he may deem necessary or proper for the use and management of the parks, monuments and reservations under the jurisdiction of the National Park Service…”
36 CFR 1.5 Closures and public use limits.
36 CFR 1.6 Permits.
36 CFR 2.10 Camping and food storage.
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.
NPS backcountry program managers, by designating access routes and overnight camping locations, can redistribute users in response to high fire danger, snow, water or wind hazard, bear activity and other situations that may temporarily close a portion of the backcountry. The NPS also uses the permit system as a means of ensuring that each backcountry user receives up-to-date information on backcountry sanitation procedures, food storage procedures, wildlife activity, trail conditions, and weather forecasts so that NPS concerns for visitor safety are met.
Each permittee files an itinerary showing proposed travel routes and overnight stays. In the event of an overdue hiker, or the existence of emergency situations such as wildfires, NPS personnel can check along the proposed permitted route and locate, warn, treat for injuries, or evacuate users who are in danger from the situation or have become injured or lost.
The backcountry permit collects information on the amount, location, timing, and type of backcountry use. The amount of use is measured by the number of people and user nights. The location is indicated by the entry and exit trailheads and travel zone(s). The day of the week and season are shown by the date of entry and exit. The type of use (hiking, boating, stock trip) identifies the method of travel. All of this information provides the manager with a good estimate on use of park resources.
This information monitors use levels and is necessary in order to identify any impacts to the resources. The collection of this information provides critical information to backcountry managers.
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.
Requested information is unique to the applicant and no other source is available. The information is collected at the trail head on the day the backcountry use starts, so it is not possible to collect the information electronically. The requested information is needed to ensure that the applicant can find trail routes and campsites that are not overcrowded. Direct contact between the applicant and NPS staff is important in order to convey park rules, regulations, safety information, and current weather information. Park safety conditions and circumstances vary throughout the year, and occasionally day by day. There is no other opportunity to collect this information that would ensure uniform presentation of advisories, warnings, and educational material. However, this form is available on the web, but not fillable at this time. The website address is www.nps.gov/policy/DOrders/BUP.pdf.
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.
Not applicable. The NPS collects no similar information pertaining to backcountry use.
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.
Not applicable. This collection does not impose a burden on small businesses.
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.
Backcountry users do not present themselves as identifiable park users through any other statistical or visitor contact method. There is no other single opportunity to ensure uniform presentation of advisories, warnings and educational material, or implement a backcountry camper registration system.
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.
Respondents complete the information collection form as they reach the trailhead and begin their backcountry hike. Information requires between 3 – 5 minutes to complete. A copy is retained by the respondent, and a copy is retained by the park. Backcountry users only need to fill the form out when they enter the backcountry. More frequent users will complete the form more often.
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 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 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.
The NPS published a 60-day notice to solicit public comment in the Federal Register on March 8, 2007 (Volume 72, page 10555). No public comments were received.
Over the past 3 years, the following individuals completed the information collection form and were contacted about their experience. They stated that the average time required to fill out the form was three minutes.
Ms. Naomi Chakrin
P.O. Box 298
Yosemite, California 95389
Telephone: 209/372-0309 (summer daytime)
Ms. Caroline Anaya
741 El Cerrito Way
Gilmore, California 95020
Telephone: 209/372-0309 (summer daytime)
Mr. Chuck Carter
P.O. Box 577
Yosemite, California 95389
Telephone: 209/372-0354 (daytime summer)
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
Not applicable. No payments or gifts will be given to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
Not applicable. No confidential information is requested.
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.
Not applicable. No sensitive questions are asked.
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 13.
There will be approximately 285,000 respondents. It will take an average of 5 minutes per respondent to fill out the permit, so the burden estimate is 23,750 hours per year multiplied by $20.00 or $475,000.
13. Provide an estimate for the total annual 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. 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 collections 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.
There are no non-hour costs.
14. Provide estimates of annualized costs 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
The estimated cost to the Federal Government is $722,475. This is based on an estimated 10 minutes spent by an employee with each of the estimated 285,000 permits issued at $15.21 per hour (GS-7 pay rate, 2007).
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
There are no program changes or adjustments.
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.
Not applicable.
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.
Not applicable.
18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
Not applicable.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act |
| Author | Lee Dickinson |
| File Modified | 2007-06-12 |
| File Created | 2007-06-12 |