Supporting Statement A for 
Paperwork Reduction Act Submission

OMB Control Number 1018-0127
Horseshoe Crab Tagging Program
FWS Forms 3-2310 and 3-2311

Terms of Clearance:  None.

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

The Fish and Wildlife Act of 1956 (16 U.S.C. 742f) requires the Department of the Interior to take steps “required for the development, advancement, management, conservation, and protection of fishery resources.” In addition, the Endangered Species Act of 1973 (16 U.S.C. 1531-1544), the Wildlife Coordination Act (16 U.S.C. 661-666c), and the Anadromous Fish Conservation Act (16 U.S.C. 757a – 757g) each authorize the Department of the Interior to enter into cooperative agreements with stakeholders to protect and conserve fishery resources. 

Horseshoe crabs play a vital role commercially, biomedically, and ecologically along the Atlantic coast.  Horseshoe crabs are commercially harvested and used as bait in eel and conch fisheries.  Biomedical companies along the coast also collect and bleed horseshoe crabs at their facilities.  Limulus Amoebocyte Lysate is derived from crab blood, which has no synthetic substitute, and is used by pharmaceutical companies to test sterility of products.  Finally, migratory shorebirds also depend on the eggs of horseshoe crabs to refuel on their migrations from South America to the Arctic.  One bird in particular, the red knot, feeds primarily on horseshoe crab eggs during its stopover.  That bird is under a status review for listing under the Endangered Species Act.  

Horseshoe crab management has come under intense scrutiny, as crab populations appear to be on the decline, particularly in Delaware Bay.  Horseshoe crabs are managed by State agencies along the Atlantic coast under the coordination of the Atlantic States Marine Fisheries Commission.  The Commission was formed in 1942 by the 15 Atlantic coast States (Maine through Florida, including Pennsylvania) to assist in managing and conserving their shared coastal fishery resources. The Commission’s responsibility is to develop management plans “to promote the better utilization of the fisheries, marine, shell, and anadromous, of the Atlantic seaboard by the development of a joint program for the promotion and protections of such fisheries.” 

In 1998, the Commission released the first fishery management plan for horseshoe crabs (Fishery Management Report No. 32).  Under the monitoring programs that the fishery management plan supports, Component E requires biomedical companies to participate in a coordinated tagging program to evaluate post-bleeding mortality of crabs.  In 1999, the Commission released the Horseshoe Crab Stock Assessment Report (Stock Assessment Report No. 98-01), which recommends that a long-term tagging program be developed to define management units.  Tagging studies can also be used to address some of the research and data needs in the fishery management plan, including determining beach fidelity, spawning frequency, timing of migrations, and population size in Delaware Bay.  Both of the above reports are available online at http://www.asmfc.org.  

The Commission asked the Fish and Wildlife Service to coordinate a coastwide tagging program for horseshoe crabs to ensure that the program is standardized across States and research programs and to relieve individual States of the burden of coordinating a program that crosses State boundaries.

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.  

Over the past 3 years, the tagging program has provided essential information to fishery managers about the life history, population size, and migratory patterns of horseshoe crabs on the Atlantic coast.  State and Federal fishery managers use the information to more effectively manage crab populations to sustain the dependent resources, including the commercial fishery, biomedical industry, and ecologically dependent bird species.  Researchers also use tagging information to describe important life history characteristics of horseshoe crabs.

Members of the general public use the Horseshoe Crab Recapture Report (FWS Form 3-2310) to report tagged crabs and provide the following information:

•	Circular white tag (this is the primary tag placed on each crab): 
	--  presence or absence of tag (for tag retention evaluation)
	--  tag number (to determine information on an individual crab)
	--  whether or not tag was removed 

•	Other tag (some crabs have a secondary tag):
	--  presence or absence of tag (for tag retention evaluation)
	--  tag number (to determine information on an individual crab)
	--  whether or not tag was removed.

We collect the above information so that we know whether the animal is still at large or if the tag has been removed so that the crab will no longer be recognizable by that number.

•	Crab condition:  Whether crab was alive or dead when found or if a tag was found without a crab.  We use this information to determine mortality and tag retention.

•	Date captured or found.  Timing of recapture is important in determining timing of migrations and spawning frequency for individuals.

•	Crab fate:  Whether crab was kept or released.  This information will help us determine commercial harvest impacts on crab populations.

•	Reporter type:  Beach comber, commercial fishermen, biomedical company or some sort of researcher.  It is important to know what groups are encountering tagged crabs.

•	Capture method:  Hand collection or collection in some kind of fishing gear.  To better protect the crab population, we need to know to which types of fishing gear crabs are most susceptible.
•	
Capture location:  Body of water, beach or location and nearest city.  We need this information so that we can determine migratory patterns and coastal population structure of crabs.

•	Reporter information:  Name, address, and phone number.  We use this information to send the reward package to the person providing information about a tagged horseshoe crab.   The phone number allows us to contact the person if we have questions about the data provided.

•	Comments.  Miscellaneous information provided by reporter.

Agencies that tag and release horseshoe crabs (States, universities, businesses, and nonprofit organizations) complete the Horseshoe Crab Tagging Release Form (FWS Form 3-2311) and provide the following data:

•	Organization Name.  Identifies which organization released the crabs so that we can provide them with related recapture information at a later date.

•	Contact person name.  Allows us to contact the individual responsible for providing the data to clarify information if necessary.

•	Tag #: Unique number assigned to each crab, preprinted on tag.

•	Sex.  Necessary to determine differences between sexes in mortality, migration, etc.

•	PW(mm).  We use the prosomal width (width of the crab at the widest point) to determine differences in sizes of crabs along their range.

•	Capture site.  

•	Latitude (optional).

•	Longitude (optional).

•	Waterbody.

•	State. 

We use information on the capture site, latitude, longitude, waterbody, and State to determine migratory patterns.

•	Date.  We use the tagging date to determine timing of migration, longevity, and spawning frequency.

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.].

All tags are printed with a toll-free phone number and a mailing address.  The public may report finding tagged crabs using either of those methods or by completing an online form at the Maryland Fishery Resources Office (MRFO) website.  We will advertise the availability of the online form at beaches where tagged crabs are frequently encountered and also in reward package mailings to the public.  We estimate that 80 percent of the public who find tagged crabs will report via the toll free number, 20 percent via online form, and less than 1 percent via mail.

We expect 80 percent of the tagging agencies to submit electronic files of tagging data by email and 20 percent to send completed paper datasheets to the MRFO.  

4.	Describe efforts to identify duplication.  

Atlantic coast States manage horseshoe crabs under the Atlantic States Marine Fisheries Commission fishery management plan for horseshoe crabs.  The Commission encourages all States to use our tags in order to have a coordinated coastwide tagging effort.  A private organization has sponsored tagging efforts in the past.  However, it has nearly eliminated its tagging program and is encouraging tagging organizations to participate in the Fish and Wildlife Service sponsored program to eliminate any duplication of effort and to increase coastwide coordination.

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

The collection does not significantly impact small entities.  We collect the minimum information necessary to monitor horseshoe crabs.

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 tagging program were not conducted, the State fishery managers would have less basic life history information available to them to manage horseshoe crab populations.  Horseshoe crab eggs are an important food source for migratory shorebirds.  If horseshoe crabs are over-harvested, shorebird populations may be impacted adversely.  Reduced availability of horseshoe crab eggs may adversely affect the red knot (a shorebird), which is currently under a status review by the Fish and Wildlife Service to be considered for listing under the Endangered Species Act.  Biomedical companies also use horseshoe crab blood to derive Limulus Amoebocyte Lysate, an important pharmaceutical product that currently has no synthetic substitute.  Mismanagement of the crab populations could also impact human health if Lysate could no longer be collected.

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.

The usefulness of this data would be compromised if the collection of recapture information did not occur on a continual basis.  It would be impossible to track trends in crab movement and stock definitions.  In addition, if members of the public did not report recapture data at the time they found the crab, the recapture may not be reported.  There are no other circumstances that require the collection to be conducted 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 June 24, 2008, we published in the Federal Register (73 FR 35705) a notice of our intent to renew our information collection authority from OMB.  In that notice, we solicited comments for 60 days, ending on August 25, 2008.  We received comments from one individual.  The commenter did not address the necessity, clarity, or accuracy of the information collection, but did oppose the use of horseshoe crabs by biomedical companies and proposed a ban on the use of horseshoe crabs for any purpose. We have not made any changes to our information collection as a result of the comment.

State representatives who were on the Horseshoe Crab Technical Committee of the Atlantic States Marine Fisheries Commission in 1999 decided what data we needed to collect for tagged crabs.  Individuals involved in the original data collection decision included:

Tom O’Connell, Maryland Department of Natural Resources, toconnell@dnr.state.md.us
Stewart Michels, Delaware Department of Fish and Wildlife, stewart.michels@state.de.us
Mark Thompson, South Carolina Department of Natural Resources

Yearly contact is made with individuals/organizations who tag crabs.  For the renewal process, we contacted the following individuals to verify that tagging instructions are easy to understand.  They agreed that our estimate of time burden was accurate and instructions were straightforward.

Dr. David Hata, Virginia Polytechnic Institute, 540-231-7683
Kathleene Sterling, Lonza Corporation, 410-677-0389
Drs. Jennifer Mattei and Mark Beekey, Sacred Heart University, 203-365-7577

We also solicited comments from the following individual who reported tagged crabs.  She stated that the questions were easy to understand and agreed that our estimates of time burden were accurate.

Amy Roe, 19 Sunset Road, Newark, DE  19711, 302-731-4978

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

Individuals who report information about previously tagged horseshoe crabs receive a reward package for each crab they report.  The reward package contains a letter explaining the tagging program, a certificate that lists the individual’s name, information regarding the crab reported, educational fact sheets on shorebirds and horseshoe crabs, and a pewter lapel pin in the shape of a horseshoe crab.  The lapel pin is an inexpensive item ($2.50 each) that we use as incentive for individuals to report tagged crabs.  

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; however, we do not release any personal information from individual tag reporters to tagging agencies or the public.  The confidentiality of this information is protected by 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.  

We estimate there will be 980 annual burden hours associated with this information collection:

Activity	Number of Respondents	Number of annual responses 	Average time required per response	Total annual burden hours	
FWS Form 3-2310 – recapture report	500	1,500 (avg 1 to 40 per respondent)	10 minutes	250 	
FWS Form 3-2311 – tagging report	10	10	73 hours*	730	
Totals	510	1,510		980 	

*Average time required per response is dependent on the number of tags applied by an agency in 1 year.  Agencies tag between 25 and 9,000 horseshoe crabs annually, taking between 2 to 5 minutes per crab to tag.  Each agency determines the number of tags it will apply.

We estimate the dollar value of the annual burden hours to be $27,179.36.  Using the National Compensation Survey:  Occupational Wages in the United States, June 2006, published by the U.S. Bureau of Labor Statistics (www.bls.gov), we estimate wages as follows:

•	Individuals.  Average hourly wage is $19.29 multiplied by 1.4 to account for benefits ($27.01).  
•	Private sector.  Average hourly wage is $18.56 multiplied by 1.4 to account for benefits ($25.98).  
•	States/tribal/local governments.  Average hourly wage is $23.99 multiplied by 1.5 to account for benefits ($35.99).  
(Benefits were calculated in accordance with BLS news release USDL 07-1883, 
December 11, 2007)

Respondent	No of Responses	Time per response	Total Annual Burden Hours*	$ Value of Burden Hour	Total $ Value of Annual Burden Hours	
Individuals	1,500	10 min	250	$27.01	$  6,752.50  	
Private sector	       8	73 hrs	584	$25.98	  15,172.32	
State/Local/Tribal Govts	       2	73 hrs	146	$35.99	    5,254.54 	
Total					$27,179.36	

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 burden for individuals.  They can report tags via a toll-free phone number or online at the MFRO website.  We provide tags to agencies that use less than 500 annually.  Tagging does result in some costs to participants, depending on the number of tagged crabs they release.  However, agencies would tag crabs and have the same costs if the Service did not coordinate the program.

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

We estimate the annual cost to the Federal Government to be $14,905 as outlined below.  

Salary Costs
Federal
Staff	Activity	Salary
(including)
Benefits)*	Hours 	Total
Cost	
GS-11/5	•	Coordinate with tagging agencies
•	Send out tagging materials
•	Key punch paper tagging data and recapture reports and format electronic data
•	Collect recapture reports via telephone
•	Assemble reward packages
•	Computer programming
•	Provide data to tagging agencies	$47.42	182	$8,630.44	
GS-4/5	Collect recapture reports via telephone	$23.12	 40	    924.80	
			222	$9,555.24	
*For salary costs, we used the Office of Personnel Management Salary Table 2008-DCB to determine the hourly wage and multiplied by 1.5 to account for benefits.  (Benefits were calculated in accordance with BLS news release USDL 07-1883, December 11, 2007)

Nonsalary Costs 

Activity	Cost	
Tags	$ 1,000	
Printing reward packages	      100	
Reward Incentive (pewter crab pin)	   2,750	
Mail costs, postage	$ 1,500	
TOTAL	$ 5,350	

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

There are no program changes or adjustments.

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

The Fish and Wildlife Service does not publish information regarding the horseshoe crab tagging program.  Upon request, we release data to tagging agencies and fishery management agencies.  The respective tagging agencies may publish portions of the tagging and recapture data to address specific research questions.  We do not release any personal information from individual tag reporters to tagging agencies or the public.

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 on the forms.

18.  Certification. 

There are no exceptions to the certifications required by 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).