1018-0066 Supporting Statement A rev

Supporting Statement A for

Paperwork Reduction Act Submission

OMB Control Number 1018-0066

Marine Mammal Marking, Tagging, and Reporting Certificates

Forms R7-50, R7-51, and R7-52

50 CFR 18.23(f)

Terms of Clearance: None

1. Explain the circumstances that make the collection of information necessary.

Under Section 101(b) of the Marine Mammal Protection Act of 1972, as amended, Alaska Natives residing in Alaska and dwelling on the coast of the North Pacific or Arctic Ocean may harvest polar bear (Ursus maritimus), northern sea otter (Enhydra lutris kenyoni), and Pacific walrus (Odobenus rosmarus divergens) for subsistence or handicraft purposes. Section 109(i) of the MMPA authorizes the Secretary of the Interior (Secretary) to prescribe marking, tagging, and reporting regulations applicable to the Alaska Native subsistence and handicraft take. Acting on behalf of the Secretary, the Fish and Wildlife Service (we, Service) published regulations at 50 CFR 18.23(f). These regulations require, among other things, Alaska Natives to report harvested marine mammals to the Service and have them tagged. The collection of this information is integral to the reporting of the harvest.

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.

We use the information that we collect from Alaska Natives to run the Marking, Tagging, and Reporting Program. This program improves our decisionmaking ability by substantially expanding the quality and quantity of harvest and biological data upon which we base future management decisions. Further, it provides us the ability to make inferences about the condition and general health of the populations. Without authority to collect this harvest information, our ability to measure the take of polar bears, northern sea otters, and walrus would be inadequate. Harvest information allows us to make rational, knowledgeable decisions regarding the Alaska Native harvest. The information to be collected from Alaska Natives is exactly the same as currently approved. We do not disseminate any of this information to the public.

• Date of kill. Provides information on chronology of the harvest that will be used in population modeling and in determining which cohorts are being killed.

• Sex of the animal. Provides information used in population modeling, determining the status of populations, and predicting population trends.

• Kill location. Provides information on the distribution and relative abundance of the three species, the level and intensity of the harvest, and the impact on the species and their subpopulations.

• Form of transportation used to make the kill of polar bears (R7-51). Provides information on the level of use of available transportation methods. Such data are useful in determining trends toward the use of more modern and efficient means of transportation, which may increase the mobility of Alaska Natives and possibly increase the level of harvest (e.g., the use of aircraft to assist in locating polar bears).

• Amount of time (i.e., hours/days) spent hunting each polar bear (R7-51). The amount of effort exerted to harvest these animals will vary with the availability of animals, individual hunter skills, weather conditions, etc. With other factors being constant, the amount of time necessary to take these species is an indicator of density and/or availability. The use of catch per unit effort is well established as a requirement of effective wildlife management.

• Type of take for walrus (LK = live killed, BF = beach found; R7-50). This information increases the accuracy of the known mortality and harvest data. Without this information, Alaska Natives would only be required to provide for marking, tagging, and reporting purposes those walrus that were actually known to be killed by them. Consequently, the accuracy of the known mortality, harvest, and biological data would be significantly diminished. Likewise, a component of the ivory entering the marketplace would be unmarked, making it difficult to determine if such ivory were illegally obtained. Requiring all ivory that has been taken or collected (pursuant to the Alaska Native exemption) to be marked, tagged, and reported simplifies Service enforcement efforts.

• Number of otters present in and number of otters harvested from pod (R7-52). We use this information as an indicator of both otter density across their range and hunter effort with regard to harvest activity.

• Condition of the polar bear and whether or not cubs were present (R7-51). We use this information (1) as an indicator of both polar bear density across their range and hunter effort with regard to harvest activity, and (2) to obtain basic polar bear behavioral observations resulting from hunter activity.

• Name of the hunter or possessor of the specified parts at the time of marking, tagging, and reporting. The tagging officials located in the individual villages are paid based on the number of animals tagged. The name and signature of the hunter are intended for purposes of internal control, and to reduce the chance of false reporting for the tagging official's economic gain.

We do not place any additional reporting burden on the Alaska Natives. Service personnel or authorized Service representatives will obtain other information on the three reporting forms (R7-50, R7-51, and R7-52) without input from the Alaska Native.

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.].

The forms are available in paper only. We considered the possibility of using improved information technology to reduce burden on the Alaska Natives, but were unable to identify any such technology. Much of the improved information collection and reporting technology that is commonplace in the contiguous 48 States does not exist in coastal Alaska due to the remoteness of villages situated along thousands of miles of coastline, marked differences in life styles, and social and economic conditions in these villages.

The requested information is unique to each individual Alaska Native hunter, and no other sources are available. The information changes with each location and each animal killed, and it is necessary for the individual hunter(s) to provide the required parts of each animal killed and the information associated with those kills. We have attempted to minimize the burden on Alaska Natives by establishing a network of individuals in this program at logical and strategic locations around the State. These individuals are in place to receive reports from Alaska Native hunters so that time necessary for complying with these marking and reporting stipulations is minimized. However, it is necessary for hunters to report in person each individual kill so that Service representatives can (1) attach marks and tags to the marine mammal parts and (2) collect information important for wildlife management purposes from the parts provided (e.g., measurements of polar bear and northern sea otter skulls and walrus tusks).

4. Describe efforts to identify duplication.

We only collect the minimum information necessary. No other Service office collects this information nor are we aware of any other Federal agency that conducts similar information.

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

This collection of information will not affect small businesses or other small entities. Approximately 2,038 individual Alaska Native hunters of polar bear, sea otter, and walrus will report on the kills they make. The Service expects to have personnel (or representatives) in most coastal villages to do the marking and tagging and to complete the reports.

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 the collection were not conducted or conducted less frequently, we could not conduct the Marking, Tagging, and Reporting Program, and the data essential to properly manage polar bears, Pacific walrus, and northern sea otters in Alaska would be lost. Circumstances vary with individual hunters and with each individual animal killed. There is no information otherwise available that can be used in place of the information that we collect on the reporting forms.

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.

We ask respondents to report information more often than quarterly. The Marking, Tagging, and Reporting Program is intended to gather reports of all kills and to tag or mark, as appropriate, skins, skulls, and tusks of marine mammals killed to reduce illegal trade in walrus ivory and polar bear and northern sea otter skins. We use the data from the reports for management of polar bears, northern sea otters, and walruses. If these reports were submitted quarterly rather than as now required (i.e., within 30 days of take), the accuracy of the data would be seriously compromised, thereby reducing our ability to make sound management decisions. Increased illegal traffic of marine mammal parts could ensue. There are no other circumstances that require information to be collected 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 July 12, 2007, we published a Federal Register notice (72 FR 38096) informing the public of our intent to ask OMB to renew approval for this information collection and soliciting comments for 60 days. The comment period ended on September 10, 2007. We received one comment. The comment expressed opposition to the killing of wildlife by Alaska Natives. We note the concerns raised by this individual; however, the harvest of marine mammals by certain Alaska Natives for certain purposes is specifically exempted from otherwise prohibited activities by Section 101(b) of the Marine Mammal Protection Act (MMPA) of 1972, as amended (16 U.S.C. 1361 et seq.). We did not make any changes to our information collection.

In 2007, we conducted interviews with village taggers already participating in the program. Results from these interviews indicate that our estimate of the burden required to complete the tagging certificates is correct and has not changed since the last renewal 3 years ago. Following is contact information for those interviewed:

Jeffrey Feldpausch 1950 HPR #D Sitka, Alaska 99835	Rolf Christiansen P.O. Box 78 Old Harbor, AK 99643
Tommy Oleuman P.O. Box 1130 Barrow, AK 99723	Dean Kulowiyi P.O. Box 48 Savoonga, AK 99769
Mike See P.O. Box 253 Hoonah, AK 99829	Austin Ahmasuk P.O. Box 693 Nome, AK 99762
John Boone P.O. Box 3087 Valdez, AK 99686	Roger Alexander P.O. Box 987 Wards Cove, AK 99928

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 are made to respondents.

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

The hunter must print his name and sign the certification containing harvest information, but we do not ask for social security numbers or other sensitive information. This information is protected by provisions of the Privacy Act of 1974.

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.

12. Provide estimates of the hour burden of the collection of information.

Since the Service's 2004 request for OMB approval for this program, experience indicates that approximately 1,190 walruses, 52 polar bears, and 796 northern sea otters are killed each year. From this, we have estimated that the total time required for Alaska Natives to complete the program's requirements is 510 hours per year. Using an average rate of $22.00* per hour for salary and benefits, we estimate the dollar value of the annual burden hours for this collection to be $11,220.

*May 2006 Occupation Employment and Wage Estimate for Alaska, Fishing, Farming, and Forestry occupations. Mean hourly wage of $16.92 multiplied by 1.3 for benefits. http://www.bls.gov/oes/current/oes_ak.htm#b45-0000

ACTIVITY/REQUIREMENT	ANNUAL NO. OF RESPONDENTS	TOTAL ANNUAL RESPONSES	COMPLETION TIME PER RESPONSE	TOTAL ANNUAL BURDEN HRS	TOTAL BURDEN COST TO PUBLIC ($22.00/HR)
Form R7-50 – Walrus	1,190	1,190	15 minutes	298	$ 6,556
Form R7-51 – Polar Bear	52	52	15 minutes	13	286
Form R7-52 – Sea Otter	796	796	15 minutes	199	4,378
Totals	2,038	2,038		510	$11,220

13. Provide an estimate of the total annual [nonhour] cost burden to respondents or recordkeepers resulting from the collection of information.

There is no nonhour cost to respondents. Some Alaska Native hunters may incur travel expenses to comply with the rule. Since we have personnel or authorized representatives in individual villages or in nearby villages to do the actual marking and tagging, costs to Alaska Natives are not significant and in the majority of instances do not occur.

14. Provide estimates of annualized costs to the Federal Government.

We estimate the total annual cost to the Federal Government to implement and enforce the program is $330,982.

Estimated Annualized Costs to the Federal Government 2007-2010
Position or description of cost estimate	Grade / per hour	Annual salary/cost	Annual salary plus benefits (1.3 X Annual rate)	Percent of time working on MTRP	Total
Marine Mammals Management Costs
Wildlife Biologist MTRP	GS 7 step 4	$43,293.36	$56,281.37	100.00%	$56,281.37
Wildlife Biologist MTRP	GS 12 step 5	$78,846.14	$102,499.98	100.00%	$102,499.98
Clerical	GS 7 step 1	$39,229.63	$50,998.52	33.00%	$16,829.51
Payments to Taggers		$35,000.00			$35,000.00
Cost of Tags and supplies		$6,000.00			$6,000.00
Travel		$30,000.00			$30,000.00
Law Enforcement Costs
Support Staff	50/hr	$104,000.00	$135,200.00	0.96%	$1,297.92
Special Agent	66/hr	$137,280.00	$178,464.00	24.00%	$42,831.36
Resident Agent In Charge	73/hr	$151,840.00	$197,392.00	5.80%	$11,448.74
Assistant Agent In Charge	91/hr	$189,280.00	$246,064.00	5.80%	$14,271.71
Special Agent In Charge	88/hr	$183,040.00	$237,952.00	1.90%	$4,521.09
Travel, per diem, lodging		$10,000.00			$10,000.00
Total					$330,981.68

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

For this information collection renewal, we are estimating that there will be 2,038 responses totaling 510 burden hours. This is a decrease of 518 responses and 129 burden hours from our previous request. We base these adjustments on actual recent annual harvest levels in Alaska that show Alaska Native hunters annually kill fewer animals than we previously estimated.

16. For collections of information whose results will be published, outline plans for tabulation and publication.

There are no plans to publish the results of this information collection. We tabulate results monthly and use the information, along with census data, to determine if a population is depleted as defined in the MMPA.

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.

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.

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