NASS_comments_PART_A_2009_0319

The Supporting Statement for OMB 0596-0201

Role of Communities in Stewardship Contracting Projects.

Note, throughout this docket, there is some odd formatting with hyphens or similar marks appearing in the middle of words. It’s not a big deal, but the docket will look better if you clean that up.

Terms of Clearance

BLM may participate in this survey provided that they do not undertake the NAU (Northern Arizona University) survey, which is duplicative of this effort.

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.

Section 323 of Public Law 108-7 (16 U.S.C. 2104 Note) requires the Forest Service (FS) and Bureau of Land Management (BLM) to report to Congress annually on the role of local communities in the development of agreement or contract plans through stewardship contracting. To meet that requirement, the Forest Service plans to conduct a survey to gather the necessary information for use by both the FS and BLM in developing their annual report to Congress. A copy of the law is attached.

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.

The survey will collect information on the role of local communities in the development of agreement or contract plans through stewardship contracting. This is a renewal of an existing collection of information. Information will be collected annually, through a phone survey conducted by the Pinchot Institute for Conservation and its sub-contractors. All people interviewed as part of the survey have been involved in a stewardship contracting project – either as a Forest Service or Bureau of Land Management project manager, as an external participant in the project planning, or as a contractor involved in project implementation. The phone survey consists of 16 questions (You’ve numbered them 1 – 16, but some have multiple parts, so can you really still call it 16 questions?) and will be administered to a stratified random sample annually. As information is collected during the interview process, it will be entered into a uniform report format and sent to Michigan State University (MSU) for analysis. Following receipt of the data, MSU researchers will code questions and responses for entry into software programs used for qualitative and quantitative analyses. The results from these analyses will then be delivered to the Pinchot Institute for inclusion into its final reports to the managing agencies. The information will be used by both the Forest Service and the Bureau of Land Management to inform the agencies’ yearly report to Congress on stewardship contracting implementation. The survey responses will not be shared with other organizations inside and or outside the government but the results of the analysis of the survey responses, through its inclusion in the FS and BLM report to Congress, will be available for use by organizations both inside and outside the government.

You did not address the actual use the agency has already made of the information. Yes, you can infer it issued previous reports to Congress, but it would be better to make it clear.

1. What information will be collected - reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)

The survey will collect information on the role of local communities in the development of agreement or contract plans through stewardship contracting. This is a renewal of an existing information collection. Information will be collected annually, through a phone survey conducted by the Pinchot Institute for Conservation and its sub-contractors. All people interviewed as part of the survey have been involved in a stewardship contracting project – either as a Forest Service or Bureau of Land Management project manager, as an external participant in the project planning, or as a contractor involved in project implementation. The phone survey consists of 16 questions and will be administered to a stratified random sample annually.

2. From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.

All people interviewed as part of the survey have been involved in a stewardship contracting project – either as a Forest Service or Bureau of Land Management project manager, as an external participant in the project planning, or as a contractor involved in project implementation. The phone survey consists of 16 questions and will be administered to a stratified random sample annually. As information is collected during the interview process, it will be entered into a uniform report format and sent to Michigan State University (MSU) for analysis. Following receipt of the data, MSU researchers will code questions and responses for entry into software programs used for qualitative and quantitative analyses. The results from these analyses will then be delivered to the Pinchot Institute for inclusion into its final reports to the managing agencies.

Table 1 (response to items a and b)

Information Collected	Description	Information Provided to:	Prepared by
Phone survey of 16 questions regarding the role of local communities in the development of agreement or contract plans through stewardship contracting	Forest Service project manager involved in a stewardship contracting project	Michigan State University (analysis) and Pinchot Institute for Conservation (receive results of the analysis)	Michigan State University
Phone survey of 16 questions regarding the role of local communities in the development of agreement or contract plans through stewardship contracting	BLM project manager involved in a stewardship contracting project	Michigan State University (analysis) and Pinchot Institute for Conservation (receive results of the analysis)	Michigan State University
Phone survey of 16 questions regarding the role of local communities in the development of agreement or contract plans through stewardship contracting	Contractor involved in stewardship contracting project implementation	Michigan State University (analysis) and Pinchot Institute for Conservation (receive results of the analysis)	Michigan State University

You may want an extra row in the table above that lists external participant since you mention that as a separate category from Contractor. You may be able to collapse the two project management rows.

3. What will this information be used for - provide ALL uses?

The information will be used by both the Forest Service and the Bureau of Land Management to inform the agencies’ yearly report to Congress on stewardship contracting implementation. The survey responses will not be shared with other organizations inside and or outside the government but the results of the analysis of the survey responses, through its inclusion in the FS and BLM report to Congress, will be available for use by organizations both inside and outside the government.

4. How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)? Does the respondent have multiple options for providing the information? If so, what are they?

Information will be collected annually, through a phone survey conducted by the Pinchot Institute for Conservation and its sub-contractors. All people interviewed as part of the survey have been involved in a stewardship contracting project – either as a Forest Service or Bureau of Land Management project manager, as an external participant in the project planning, or as a contractor involved in project implementation. The phone survey consists of 16 questions and will be administered to a stratified random sample annually. As information is collected during the interview process, it will be entered into a uniform report format and sent to Michigan State University for analysis. Following receipt of the data, MSU researchers will code questions and responses for entry into software programs used for qualitative and quantitative analyses. The results from these analyses will then be delivered to the Pinchot Institute for inclusion into its final reports to the managing agencies.

5. How frequently will the information be collected?

Information will be collected annually, through a phone survey conducted by the Pinchot Institute for Conservation and its sub-contractors.

6. Will the information be shared with any other organizations inside or outside USDA or the government?

As information is collected during the interview process by the Pinchot Institute for Conservation and its sub-contractors, it will be entered into a uniform report format and sent to Michigan State University (MSU) for analysis. Following receipt of the data, MSU researchers will code questions and responses for entry into software programs used for qualitative and quantitative analyses. The results from these analyses will then be delivered to the Pinchot Institute for inclusion into its final reports to the managing agencies. The information will be used by both the Forest Service and the Bureau of Land Management to inform the agencies’ yearly report to Congress on stewardship contracting implementation. The survey responses will not be shared with other organizations inside and or outside the government but the results of the analysis of the survey responses, through its inclusion in the FS and BLM report to Congress, will be available for use by organizations both inside and outside the government.

7. If this is an ongoing collection, how have the collection requirements changed over time?

Attached are both the original approved survey and the revised survey for this renewal process. There is no change in burden estimate between the original and revised surveys:; between 30 to a maximum of 45 minutes. Both the original and revised surveys contain 16 questions. Revisions to the original survey are being made to reflect minor word changes for clarity, minor format changes for clarity and or analysis purposes, and to add response categories based on feedback from interviewers and/or the scientist who designed the statistical aspects of the survey. These changes are designed to make it easier for both the interviewer and interviewee. Revisions are described in detail, as outlined below.

Question 1a. Response categories have been added based upon responses received over the past several years.

Question 1b. Response categories have been added based upon responses received over the past several years.

Question 2. Two response categories have been added based upon responses received.

Question 3. A format change has been made regarding the “scale of involvement” column to make it easier for both the interviewer and interviewee. A “regionalstate” response category has been added based upon responses received.

Question 4. The original question 4 has been reformatted into questions 4a and 4b. Minor word changes were made to 4a for clarification purposes. For example, the category “NEPA analysis” role was subject to very wide interpretation in the original survey and this category has been clarified as “participation in NEPA process”. Question 4b was added to ensure meaningful use and understanding of the responses received regarding question 4a (role of local community).

Question 5. This question was reworded slightly for clarification purposes. Response categories were reworded and/or added based on past responses and at the suggestion of the interviewers. For example, the “meetings” category was split into “traditional public meetings” and “collaborative process meetings”.

Question 6. The original question had two parts which have been renumbered 6a and 6b for clarity. Response categories were added, to both parts 6a and 6b, based on responses from years past.

Question’s 7a and 7b. The original questions have been combined (into question 7) as they tended to produce the same answers. Also, response categories were added based on responses from years past.

Question 8a. No changes have been made to this question.

Question 8b. A scale of involvement was added for meaningful analysis purposes (which also coincides with format changes to question 3).

Question 9. This question was reworded and the table reformatted for clarification purposes.

Question 10. This question was reworded for clarity and a scale of response added (rather than a simple check list) for a more meaningful analysis of responses.

Question 11. This question was reworded for clarity and a scale of response added (rather than a simple check list) for a more meaningful analysis of responses.

Question 12. The original survey had two “supported” response categories but only one “opposed” response categories; both categories now have “widely” and “somewhat” responses available for more meaningful analysis purposes.

Question 13. The original survey had two “supported” response categories but only one “opposed” response categories; both categories now have “widely” and “somewhat” responses available for more meaningful analysis purposes.

Question 14. No changes were made to this question.

Question 15. A response category titled “maybe” was added based on responses from years past.

Question 16. No changes have been made to this question.

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.

The survey will be conducted by phone so it will not involve the use of automated, electronic, mechanical, or other technological collection techniques. (In the questionnaire, it appeared that the advance letter/ questionnaire were being sent by email? Shouldn’t that be addressed here? Also, do you want to make provisions for allowing people to fill out the form by email and return it?)

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.

Currently, the Forest Service and Bureau of Land Management have no other approved surveys that address the role of local communities in stewardship contracting. The FS and BLM stewardship contracting project managers frequently work with external groups that are interested in stewardship contracting. As far as these program managers are aware, there are no similar information collections currently conducted by other government sources or other outside sources. What about the exception listed at the top: “BLM may participate in this survey provided that they do not undertake the NAU (Northern Arizona University) survey, which is duplicative of this effort.”

5. If the collection of information im­pacts small businesses or other small entities¹,describe any methods used to mini­mize burden.

The collection of information should not impact small businesses. There may be some small businesses within the survey pool. However, the phone survey was purposefully limited to a maximum of 45 minutes in order to decrease the effect on small businesses and other contractors. Additionally, the survey is voluntary, which will accommodate those that don’t have time to respond.

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.

Without the information from this annual collection of data, the Forest Service and Bureau of Land Management will not be able to provide the annual report to Congress on the role of local communities in the development of agreement and contract plans.

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;

There would be no special circumstances requiring respondents to report information to agencies 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;

There would be no special circumstances 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;

There would be no special circumstances 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;

There would be no special circumstances 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;

There would be no special circumstances 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;

There would be no special circumstances requiring the use of 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

There will be no assurances of confidentiality. However, the names of people interviewed will not be associated with the interviewer’s notes from the phone survey, and the names of those interviewed will not be retained, ensuring some measure of privacy.

• Requiring respondents to submit propri­etary trade secret, 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 would be no special circumstances requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentially to the extent permitted by law.

There are no special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.

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.

“Information Collection: Role of Communities in Stewardship Contracting Projects” was published in the Federal Register, Vol. 73, No. 241, p. 75996, on Monday, December 15, 2008. A copy of the Federal Register notice is attached.

RESPONSE TO COMMENTS RECEIVED:

Three letters were received and are attached. Comments made and Forest Service responses are discussed below.

Comment: Request was made to be included as a “Community in the Stewardship Contracting Projects;” specifically, a reviewing entity for the forest lands under the Caja del Rio Grant administered by the Espanola Ranger District of the U.S. Forest Service’s Southwest Region.

Response: This request is beyond the scope of the information collection. However, the comment letter was forwarded to the Forest Service’s Southwest Region (R3) regional stewardship coordinator, for their information and use as appropriate.

Comment: Comment made regarding “(1) whether this collection of information is necessary for the stated purposes and the proper performance of the functions of the agency, including whether the information will have practical or scientific utility.” The commenter stated “It appears that the collection of this information is necessary for the stated purposes and the proper performance of the functions of the agency…the information appears to have practical utility.”

Response: A response is not necessary.

Comment: Comment made regarding “(2) the accuracy of the agency’s estimate of the burden of the collection of information, including the validity of the methodology and assumptions used.” The commenter stated “The validity of the methodology and assumptions used appear to be sound. We do not feel [it] is in our scope to comment on the agency’s estimate of the burden of the collection of information.”

Response: A response is not necessary.

Comment: Comment made regarding “(3) ways to enhance the quality, utility, and clarity of the information to be collected.” The commenter stated “it would be helpful to compare information collected in previous years with subsequent years. In addition, it may provide beneficial to report the results by region in conjunction with reporting the results nationally.”

Response: The survey was designed as a national programmatic monitoring effort and annual reporting as required by Congress (section 323 of Public Law 108-7 (16 U.S.C. 2104 Note)). The legislation provides that the agencies establish a programmatic multiparty monitoring and evaluation process, specifically designed to assess the use of new and expanded contracting authorities and the roles local communities are playing in the development of stewardship agreements or contracts. The Pinchot products annual reports to each agency; the Forest Service’s reports are available on the Forest Service website [http://www.fs.fed.us/forestmanagement/projects/stewardship/reports/index.shtml] and persons may make their own comparisons with previous year data. To help determine regional trends among projects and foster the multiparty aspect of monitoring/evaluation, the Pinchot Institute utilizes a series of regional teams. Summaries of regional team findings by the Pinchot Institute have been included in their 2007 and 2008 final reports to each agency.

Comment: Comment made regarding “(4) ways to minimize the burden of the collection of information on respondents, including the use of automated, electronic, mechanical or other technological collection techniques or other forms of information technology.” The commenter stated “ways to minimize the burden of the collection of information on respondents should be asked of the respondents during surveys”.

Response: The survey is completely voluntary. Additionally, survey participants are asked for any additional comments they may wish to make.

Comment: Comment made regarding “(4) ways to minimize the burden of the collection of information on respondents, including the use of automated, electronic, mechanical or other technological collection techniques or other forms of information technology.” The commenter stated “the quality of information through the various collection techniques should also be evaluated. For example, is it possible to obtain the same quality of information from an email than a phone call?

Response: The survey instrument is shared with respondents prior to the telephone interview. The intent of the telephone interview is to more accurately capture the nature of the local community involvement in stewardship contracting, rather than via a written survey or other monitoring method. The survey is utilized to guide interviews and collect information in a uniform manner.

Comment: Section 323 of Public Law 108-7 requires the Forest Service (FS) and Bureau of Land Management (BLM) to report to Congress annually on the role of local communities in the development of agreement or contract plans through stewardship contracting. However, the purpose and use for these reports is not well defined.

Response: Section 323 of Public Law 108-7 (16 U.S.C. 2104 Note) requires the Forest Service (FS) and Bureau of Land Management (BLM) to report to Congress annually on the role of local communities in the development of agreement or contract plans through stewardship contracting. To meet that requirement, the Forest Service through a contract with the Pinchot Institute for Conservation conducts a survey to gather the necessary information for use by both the FS and BLM in developing their annual report to Congress. A copy of the law is attached.

Comment: The information collected through telephone interviews with stewardship participants is difficult to evaluate because it is not connected to a specific project or compiled in comparable form from one year to the next. While an OMB-approved protocol for survey collection is used, when it is anonymous and not specific to a project it is difficult to know if direct participants, indirect participants, leaders, followers or associates were contacted. If there is no reference for other measures of success or difficulty, such as timely completion, the size and budgets, community involvement, and ecological value, it is difficult to understand the context for the respondents points of view. A summary of the project, written by agency representatives and contractors or community participants, could frame the scale and scope of the project, providing a way to consider what was done and what was intended. The current survey methods make it difficult to compare projects by similar types, across regions, and from year-to-year.

Response: The agency collects programmatic rather than individual project level monitoring information, regarding the role of communities in development of stewardship contracting projects, as required by Section 323 of Public Law 108-7 (16 U.S.C. 2104 Note).

Comment: There are a lot of well-intentioned and useful responses in the surveys and the monitoring team reports. However, the information is also scattered and individualized without a clear direction for application. The use of these reports and surveys is also not clear. Important lessons are being learned about stewardship contracting, but they are not adequately shared either within or outside the agency. Improving the usefulness of the information collected to allow cross-comparison and identify how stewardship contracting can be improved is critical to the “proper performance of the functions of the agency” if the agency goal is to maintain this tool and improve its use. Should the information collection be improved, we believe it would have practical and scientific utility.

Response: As addressed above, the agency collects programmatic monitoring information regarding the role of communities in development of stewardship contracting projects, and reports that information to Congress as required per Section 323 of Public Law 108-7. The reports are also posted on the Forest Service’s internet at http://www.fs.fed.us/forestmanagement/projects/stewardship/reports/index.shtml

Comment: The commenter referenced a GAO audit (2008) which recommended the Forest Service “implement improvements in the availability, accuracy, comparability, and accessibility of data on the extent, purposes, and outcomes of stewardship contracts. The commenter stated “we believe that improvements in consistent collection of information as well as its accessibility to the public and the agency will help improve stewardship accounting.”

Response: This purpose of this information collection is to determine the role of local communities in the development of agreement or contract plans through stewardship contracting, on a programmatic level. The survey information collected utilizes the exact same methods on an annual basis, via a phone survey conducted by the Pinchot Institute for Conservation and its sub-contractors. As information is collected during the interview process, it is entered into a uniform report format and sent to Michigan State University (MSU) for analysis. Following receipt of the data, MSU researchers code questions and responses for entry into software programs used for qualitative and quantitative analyses. The results from these analyses are delivered to the Pinchot Institute for inclusion into its final reports to the managing agencies. The information is used by both the Forest Service and the Bureau of Land Management to inform the agencies’ yearly report to Congress on stewardship contracting implementation. The survey responses are not shared with other organizations inside and outside the government but the results of the analysis of the survey responses, through their inclusion in the FS and BLM reports to Congress, will be available for use by organizations both inside and outside the government.

Comment: The commenter stated “we share the GAO’s (2008) recommendation to the USFS improve the quality and accessibility of information on stewardship contracts.” The commenter also stated “we have sometimes been frustrated in our attempts to obtain basic information on stewardship contracts….for example, even the number of active and/or completed contracts in the state of Idaho was not available recently on the Forest and Rangeland website…Beyond such basic information, it would also be useful to obtain a consistent description of each stewardship contract.” “…As researchers and policy analysts, we believe that the case for or against the use of stewardship contracting will be made, in part, by detailed analyses of stewardship contracts.” “Summary information on stewardship projects is not consistently provided to the monitoring teams or to the public on a website or other public database.

Response: As already stated above, the purpose of this information collection is only to determine the role of local communities in the development of agreement or contract plans through stewardship contracting, on a programmatic level, and report that information to Congress, per the public law. Listings of approved and awarded stewardship projects are available to the public at http://www.fs.fed.us/forestmanagement/projects/stewardship/projects/index.shtml. As interviews are completed, resulting data is formatted into uniform reports and shared immediately with Michigan State University for analysis. Following receipt of the data, questions and responses are coded for applications in a software program used for quantitative and qualitative analyses. Summarized results from these analyses are forwarded to the Pinchot Institute for use at the Regional Team meetings and inclusion in the programmatic-level monitoring report to the agencies.

Comment: The burden of the collection of information should be reassessed after changes are made to ensure that comparable, consistent information is collected and easily accessible. The agency would be well served by a) improving the utility of the information collected to increase cross-comparison and b) improving its accessibility. These changes alone may ease the burden on respondents.

Response: See response to comment immediately above.

Comment: ultimately, the goal of collecting information should be to improve stewardship contracting: the use of the authority, the geographic breadth of its use, the amount and breadth of work accomplished with it and the role of communities in creating and accomplishing projects in concert with the agency. The lack of training in how to engage communities in collaborative planning is an impediment to more extensive use of stewardship contract. The agency should examine the questions asked of respondents during information collection efforts to assure that its surveys are assessing the state of collaboration and ways to improve it. Questions centered on whether collaborative training was provided to the group (agency employees and members of the public) at the beginning of project planning leading to stewardship contracts, and follow-up questions as to its usefulness would help the agency to assess how best to respond to this problem.

Response: Survey questions 2 through 14 are directly related to community involvement and collaboration, and include questions 8, 9, and 14 which are specifically regarding improvement of community involvement and collaboration.

Comment: An impediment to increasing the role of communities in stewardship contracting resides in the agency relationship to NEPA compliance. The agency has long had a NEPA compliance course taught by a roving cadre of employees. A companion course in collaboration, with a focus on engaging communities at the beginning of the project planning process would be useful.

Response: Comment is noted, but the actual provision of training is beyond the scope of this immediate information collection. However, the survey does seek information from participants regarding identifying resources that community members need to facilitate their participation in the project, which could potentially include, for example, training on collaborative processes and/or NEPA (reference survey question 9). The information collected is shared with the agencies.

Comment: The Federal Register Notice states that the type of request is an “extension with revision: (Supplementary Information section). But no details are provided on what exactly is being revised. Is it the information collected itself or merely the calculations of the burden? Please clarify.

Response: There is no change in burden estimate between the original and revised surveys; between 30 to a maximum of 45 minutes. Both the original and revised surveys contain 16 questions. Revisions to the original survey are being made to reflect minor word changes for clarity, minor format changes for clarity and or analysis purposes, and to add response categories based on feedback from interviewers and/or the scientist who designed the statistical aspects of the survey. These changes are designed to make it easier for both the interviewer and interviewee. Revisions are described in detail, as outlined in item 2g above.

Comment: More information is needed on other facets of the request. The information collection is congressionally mandated, but how is it used? Have members of Congress sought changes in the information collected or commented on its usefulness? How has the agency used this information internally? More context for the information collection would be useful.

Response: Comment is noted. All comments received regarding the information collection are included in this section (8) and none came from members of Congress. The information is used by the agency in its annual report to Congress as discussed in comment responses above. The actual use of the information by Congress is beyond the scope of this information collection.

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 record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

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.

Persons Consulted

The following people were contacted to ascertain if the requested information collection and burden estimate are reasonable.

James Bowmer, Stewardship Contracting Coordinator, Bureau of Land Management, 202.452.5081 was consulted on survey protocol and questions/revisions.

Bob Schrenk, Rocky Mountain Elk Foundation, (406) 829-9149 (3/25/2009)

Mr. Schrenk stated that he often hears from folks who are contacted that they do appreciate the call as they want to tell the Forest Service what they think about stewardship contracting. However, he also stated that he often hears there’s a lack of feedback to those folks providing the information; the Forest Service needs to work better at getting the monitoring reports out to the public.

Dave Wilson, National Wild Turkey Federation, (803) 637-7515

Mr. Wilson stated: “I like the revised questionnaire. The changes will make the interview more user friendly and will generate better information, particularly from individuals not fully involved in the process.”

Third Commenter:

What does “third commenter” refer to? It seems out of place. Is it left over from a draft?

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

There will be no payments or gifts to respondents, other than remuneration of contractors or grantees.

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

There will be no assurances of confidentiality. However, the names of people interviewed will not be associated with the interviewer’s notes from the phone survey, and the names of those interviewed will not be retained, ensuring some measure of privacy.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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.

There are no questions in the proposed survey of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form.

a) Description of the collection activity

b) Corresponding form number (if applicable)

c) Number of respondents

d) Number of responses annually per respondent,

e) Total annual responses (columns c x d)

f) Estimated hours per response

g) Total annual burden hours (columns e x f)

The estimated number of respondents is 350. The estimate of annual burden is 0.75 hours. The estimated annual number of responses per respondent is one. Therefore, the estimated total annual burden is 263 hours.

The Pinchot Institute for Conservation and its’ subcontractors have determined, based on their professional experience, that the survey will usually take 0.5 hours and no longer than 0.75 hours.

Table 2

(a) Description of the Collection Activity	(b) Form Number	(c) Number of Respondents	(d) Number of responses annually per Respondent	(e) Total annual responses (c x d)	(f) Estimate of Burden Hours per response	(g) Total Annual Burden Hours (e x f)
Phone Survey	None – Info. collection # 0596-0201	350 people	one	350	0.75	263
Totals	---	350	---	350	---	263

Record keeping burden should be addressed separately and should include columns for:

a) Description of record keeping activity: None

b) Number of record keepers: None

c) Annual hours per record keeper: None

d) Total annual record keeping hours (columns b x c): Zero

Table 3

(a) Description of record keeping activity	(b) Number of Record keepers	(c) Annual hours per record keeper	(d) Total annual record keeping hours (b x c)
None	None	None	Zero
Totals	0	---	0

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

Table 4

(a) Description of the Collection Activity	(b) Estimated Total Annual Burden on Respondents (Hours)	(c)* Estimated Average Income per Hour	(d) Estimated Cost to Respondents
Phone Survey	263 hours	$21	$5,523
Totals	263 hours	---	$5,523

To determine the estimated income per hour, the Bureau of Labor Statistics, “Table 1 Summary: mean hourly earnings and weekly hours for selected worker and establishment characteristics” was reviewed. The table is located at http://www.bls.gov/ncs/ocs/sp/nctb0298.pdf. Average mean hourly civilian earnings are $19.88; private industry workers are $19.21, and state and local government workers are $24.15. Averaging the three totals $21.08 (rounded to $21).

A copy of Table 1 is attached.

13. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information, (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates 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.

There are no capital operation and maintenance costs.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The response to this question covers the actual costs the agency will incur as a result of implementing the information collection. The estimate should cover the entire life cycle of the collection and include costs, if applicable, for:

• Employee labor and materials for developing, printing, storing forms

• Employee labor and materials for developing computer systems, screens, or reports to support the collection

• Employee travel costs

• Cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information

• Employee labor and materials for collecting the information

• Employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information

A contract has been awarded to Pinchot Institute for collecting information on the role of local communities in the development of stewardship contracting plans, analyzing the data, and writing the final reports for both the BLM and the Forest Service. Assuming that two-thirds of the effort each year of the contract goes to collecting and analyzing the information, the cost per year is approximately $161,700 (based on total FY 2008 contract costs) and $153,800 (based on total FY 2007 contract costs).

15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB form 83-I.

The estimate in item 14 was originally $110,000. However, estimated costs for collecting and analyzing the information shown for both FY 2007 and FY 2008 are based on actual contract costs (i.e. an estimated two-thirds of contract costs for FY 2007 and FY 2008). One reason for total contract costs increasing is they are based, in part, on the total number of active stewardship projects supplied annually by the Forest Service and BLM to the contractor. The contractor provides their estimate based, in part, on the total number of active stewardship projects provided to them.

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

The results of the collection of information will be included in the agencies’ annual Report to Congress on stewardship contracting. Ideally, information collection from participants not employed by the federal government will begin in early July. The information collection and analysis will be done by the Pinchot Institute between July and September. The Pinchot Institute will provide a report to the FS and BLM by December 31 each year, and these agencies will provide their report to Congress by spring. After inclusion in the Report to Congress, the analysis of the data may be used in other reports created both internally and externally by the FS and BLM. No complex analytical techniques will be used.

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 Forest Service and Bureau of Land Management will display the expiration date for OMB approval of the information collection.

18. Explain each exception to the certification statement identified in item 19, "Certification Requirement for Paperwork Reduction Act."

There are no exceptions to the certification statement identified in Item 19.

1 Small business. A small business is a concern that:

(1) Is organized for profit with a place of business in the United States, operates primarily within the United States, or makes a significant contribution to the U.S. economy by paying taxes or using American products, materials, or labor. 

 (2) Is not dominant in its field on a national basis. 

 (3) Meets or is below an established size standard. The Small Business Administration’s (SBA) Web site has detailed information on size standards for U.S. businesses. The following table shows the general size standards by industry. (For a more detailed definition, see 5 U.S.C. 601(3).)

 IndustryStandardMeasured by Number of EmployeesManufacturing and mining500 or fewerWholesale trade100 or fewerMeasured by Average Annual RevenueRetail and service$6.5 million or lessGeneral and heavy construction$31 million or lessSpecial trade contractors$13 million or lessAgricultural$0.75 million or less Small government agency. A small government agency is a government of a city, county, town, township, village, school district, or special district with a population of less than 50,000. (For a more detailed definition, see 5 U.S.C. 601(5).)

 Small not-for-profit organization.  A small not-for-profit organization is an enterprise that is independently owned and operated and is not dominant in its field.  (For a more detailed definition, see 5 U.S.C. 601(4).)

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