Grazing Draft supporting statement 5 20 2010

15

Supporting Statement for Paperwork Reduction Act Submission

43 CFR Subpart 4120

Grazing Management: Range Improvement Agreements and Permits

OMB Control Number 1004-0019

Terms of Clearance: None.

1. 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.

This submission pertains to range improvements on public lands managed by the Bureau of Land Management (BLM). Range improvements may be nonstructural (e.g., seedings or prescribed burns) or structural (e.g., fences, wells, or water pipelines). Many structural range improvements are considered permanent, as they are not easily removable from the land.

Range improvements enhance or improve livestock grazing management, improve watershed conditions, enhance wildlife habitat, or serve similar purposes. At times, the BLM may require holders of grazing permits or grazing leases (henceforth, “operators”) to install range improvements to meet the terms and conditions of their permits or leases. Operators may also come to the BLM with proposals for range improvements. Often the BLM, operators, and other interested parties work together and jointly contribute to construction of range improvements in order to facilitate improved grazing management or enhance other multiple uses. Cooperators may include lenders which provide the funds that operators contribute for improvements.

The BLM collects both form and non-form information under this control number. Forms 4120-6 and 4120-7 document contributions to range improvements. A Cooperative Range Improvement Agreement or a Range Improvement Permit. A Cooperative Range Improvement Agreement (Form 4120-6) is an agreement between an operator and/or other cooperating parties and the United States that documents contributions of the cooperator(s) toward the initial construction of the improvement. Contributions may be in the form of funds, labor, or materials. Regulations that have been in effect since 1995 require a Cooperative Range Improvement Agreement in order to authorize new permanent water developments such as spring developments, wells, reservoirs, stock tanks, and pipelines.

In a Range Improvement Permit (Form 4120-7), an operator agrees to fund 100 percent of the construction costs. Regulations that have been in effect since 1995 limit Range Improvement Permits to removable or temporary range improvements. Examples of removable range improvements include corrals, creep feeders, and loading chutes. An example of a temporary range improvement is a trough for hauled water.

In these forms, the BLM documents operators’ and cooperators’ contributions of funds, labor, and materials to ensure proper credit in the event that an assignment or removal of range improvements becomes necessary, or if an operator is temporarily authorized to use forage for which another operator holds a permit or lease.

The non-form information collection under this control number consists of opportunities for consultation and coordination with the interested public.

The following statutory provisions pertain to range improvements on public lands managed by the BLM:

• Section 4 of the Taylor Grazing Act (43 U.S.C. 315c) authorizes the BLM to enter into cooperative agreements, and to issue permits, to construct fences, wells, reservoirs, and other improvements necessary for the management and care of domestic livestock that are authorized to use grazing allotments managed by the BLM. Section 6 of the Public Rangeland Improvement Act (43 U.S.C. 1901) provides that each year, either half of the grazing fees paid by operators or $10 million (after it is appropriated through the Federal budget process), whichever is greater, will be provided to the BLM to fund range improvements.

• Section 402(g) of the Federal Land Policy and Management Act (FLPMA) (43 U.S.C. 1752(g)) provides that whenever a permit or lease for grazing domestic livestock is cancelled in whole or in part, in order to devote the lands covered by the permit or lease to another public purpose, including disposal, the permittee or lessee shall receive from the United States a reasonable compensation for the adjusted value, to be determined by the Secretary concerned, of his interest in authorized permanent improvements placed or constructed by the permittee or lessee on lands covered by such permit or lease, but not to exceed the fair market value of the terminated permittee’s or lessee’s interest therein.

• The Public Rangelands Improvement Act (PRIA) (43 U.S.C. 1901-1908) establishes a national policy and commitment to improve the conditions on public rangelands, requires a national inventory and consistent federal management policies, and provides funds for range improvement projects. Section 5 of PRIA (43 U.S.C. 1904) is most pertinent to range improvements:

  • No less than 80 percent of funds appropriated for PRIA must be used for on-the-ground range rehabilitation, construction and maintenance of range improvements (including project layout, project design, and project supervision). No more than 15 percent of such funds may be used to hire and train such experienced and qualified personnel as are necessary to implement on-the-ground supervision and enforcement of land use plans and such allotment management plans as may be developed.

  • Such funds may be distributed as the Secretary deems advisable after careful consultation and coordination with district grazing advisory boards, advisory councils, range user representatives, and other interested parties.

  • An environmental assessment record must be prepared for each range improvement. If the environmental assessment record indicates that the range improvement will have a significant impact on the quality of the human environment, an environmental impact statement must be prepared, pursuant to the National Environmental Policy Act (42 U.S.C. 4321 et seq.).

2. Explain how, by whom, how frequently, and for what purpose the information is used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. [Be specific. If this collection is a form or a questionnaire, every question needs to be justified.]

The BLM implements the statutory authorities described above in accordance with regulations at 43 CFR part 4100, subpart 4120. The information collected under the regulations enables the BLM to make decisions regarding proposed range improvement projects and documents agreements and responsibilities for constructing and maintaining specified projects.

Under 43 CFR 4120.3-1(b), the BLM requires that an operator enter into a Cooperative Range Improvement Agreement, or obtain a Range Improvement Permit, before installing, using, maintaining, and/or modifying a range improvement. Cooperative range improvement agreements are addressed at 43 CFR 4120.3-2. The BLM uses Form 4120-6, Cooperative Range Improvement Agreement, to document cooperative range improvement construction arrangements with grazing operators. The following information is required by Form 4120-6:

• Project Name and Number allows BLM to identify the project;

• Location of Project distinguishes the project from similar projects and allows the BLM to provide adequate analysis of the effects of implementing the project;

• Names of Cooperators documents the parties to whom responsibility for maintenance will be assigned, and to whom compensation will be provided when appropriate;

• Contributions made by Cooperators and Value of the Contribution (contributions may be labor, materials or equipment use) provides the BLM with information needed to properly distribute compensation when appropriate;

• Signature(s) of Cooperator(s) and Date provides documentation of when all the cooperators have agreed to the terms of the Agreement.

Range improvement permits are addressed at 43 CFR 4120.3-3. The BLM uses Form 4120-7, Range Improvement Permit, to authorize grazing operators to develop removable or temporary rangeland improvement projects. The following information is required by Form 4120-7:

• Name and Address of Applicant allows BLM to identify the owner of the improvement and to contact the Applicant when it is necessary to remove the project;

• Whether project will be constructed and maintained or just maintained by the applicant identifies the level of responsibility the Applicant assumes for the project;

• The Purpose and Need for the Project allows BLM to decide if the project is appropriate in a multiple-use context;

• Location of Project distinguishes the project from similar projects and allows BLM to provide adequate analysis of the effects of implementing the project;

• Cost and Value of Improvement (Labor, materials or equipment use) allows BLM to oversee and ensure accurate compensation for improvement interest if the permittee transfers the permit;

• Signature(s) of Applicant(s) and Date provides documentation of when applicant has agreed to the terms of the Agreement.

Non-form information collection under this control number is in accordance with the regulations at 43 CFR 4120.5, which provide for opportunities for cooperation. Under 43 CFR 4120.5-1, the BLM is required, to the extent appropriate, to cooperate with Federal , State, Indian tribal and local governmental entities, institutions, organizations, corporations, associations and individuals to achieve the objectives of 43 CFR part 4100. Under 43 CFR 4120.5-2, the BLM is required to cooperate with permittees, appropriate Federal and State agencies, Indian tribes and local government entities, organizations, corporations and individuals, to the extent consistent with applicable laws, in the administration of laws and regulations relating to livestock, livestock diseases, sanitation, and noxious weeds, including:

• State cattle and sheep sanitary or brand boards in control of stray and unbranded livestock, to the extent such cooperation does not conflict with the Wild Free-Roaming Horse and Burros Act (16 U.S.C. 1331, et seq.);

• County or other local weed control districts in analyzing noxious weed problems and developing control programs for areas of the public lands and other lands administered by the BLM; and

• Tribal, state, county, or local government-established grazing boards in reviewing range improvements and allotment management plans on public lands.

This cooperation is often accomplished through NEPA processes, collection of monitoring data, and development of evaluation reports. No specific information is required, but these entities may voluntarily submit information that they consider relevant to the project and which they wish the BLM to consider in the decision making process.

In summary, the collection of information under this control number takes place for each range improvement project or project modification. The information is used to maintain records of improvements on the public lands; make decisions on proposed rangeland improvement projects; oversee and ensure accurate compensation for improvement interest if the permittee transfers the permit; and determine the amount we must compensate the permittee if the public lands associated with the range improvement become devoted to another purpose that precludes livestock grazing.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological 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.].

In accordance with the Government Paperwork Elimination Act (GPEA), the public can fill out and download forms. They cannot submit the forms to BLM electronically at this time.

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.

No duplication of information occurs in the information we collect. The requested information is unique to the applicant or cooperator and is not available from any other data source. No similar information is available or able to be modified. The information is required in order for the applicant or cooperator to receive a benefit.

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

While the BLM does not collect information on whether the respondents are small businesses or small entities, we estimate 299 respondents that may qualify as a small business in ROCIS. The information we require from all respondents is limited to the minimum necessary to authorize and conduct grazing operations on the public lands.

6. Describe the consequence to the 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 the burden.

If we did not collect the information, we could not administer the construction and maintenance of projects placed or constructed by private parties or organizations on the public lands. Anyone, including a rancher, who places improvements on public lands without a permit or an agreement is subject to unauthorized use violations. Also, we could not maintain land records or locate the physical facilities. Less frequent collection of the information would mean no collection of the information at all.

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 the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secrets, 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 are no special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5. (A response may be required in less than 30 days if an applicant wants to place temporary water facilities in response to drought conditions.)

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 in response to the PRA statement associated with the collection over the past three years] 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 the 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.

As required in 5 CFR 1320.8(d), the BLM published the 60-day notice in the Federal Register on January 25, 2010 (75 FR 3914) soliciting comments from the public and other interested parties. The comment period closed on March 26, 2010. The BLM did not receive any comments from the public in response to this notice.

During the approval period, we consulted with the following respondents to solicit comments on the burden hour and cost estimates, availability of data, frequency of collection, and clarity of instructions. The burden estimates in Question 12 reflect these consultations.

Name	Affiliation	Phone Number
Gary Snow, Owner	Gary Snow Livestock and Grain	775- 423-7521
Chuck Hall, Authorized Representative	Hall Family Trust	208-845-2266
Ash Corlett, Ranch Manager	Miller Estates	307-710-4700
Marty Landrum, Permittee		907-876-2242
James Ray Evrage, Permittee		575-963-2340
Joe David Yates, Permittee		325-247-5711
Patti Owens, Permittee		435-644-2051

We sought comments on the forms included in this information collection. The majority of the respondents told us that they found the forms’ instructions are straightforward and clear and reasonable as to information requirements. The majority of respondents indicated that BLM completes most of the forms for them, and they review and sign it. One respondent said that the township/range/section portion is the most confusing/difficult but the BLM fills out that section for him. Some respondents indicated a range of times needed to complete the form, the low being 15 minutes and the high being 2 hours for more complex projects or if the information had to be collected. Form 4120-7, Range Improvement Permit, generally takes less time to complete than Form 4120-6, Cooperative Range Improvement Agreement, because it is used to document range improvement construction arrangements for removable or temporary rangeland improvement projects. Form 4120-6, Cooperative Range Improvement Agreement is used to document range improve construction arrangements that are for more long-term projects. One respondent said that the forms are usually filled out in advance (sometimes it has been up to a year) so the Total Cost/Value is only an estimate and may not reflect the actual costs.

One respondent suggested that the forms should more clearly identify which portions of the form are for BLM use only.

The hour burden for each form was estimated as indicated in Item 12 for reviewing instructions, gathering and maintaining data, time for travel involved to complete these tasks, coordination and consultation with the BLM and other parties to prepare information, and completing and reviewing these forms.

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

We do not provide payments or gifts to the respondents.

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

We protect the respondent’s confidentiality to the extent consistent with the Freedom of Information Act (5 U.S.C. 552).

Under the privacy provisions of the E-Government Act of 2002, individuals/respondents were informed as to whether or not providing the information is mandatory to obtain a benefit. The BLM provides no promises that the application will be protected under the Privacy Act.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, or other matters that are commonly considered private. The justification should include the reasons why the agency considers the question necessary, the specific uses to be made of the information, the explanation to be given to persons from when the information is requested, and any steps to be taken to obtain their consent.

We do not require respondents to answer questions of a sensitive nature.

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.

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 14.

The tables summarize the estimated burden hour and cost for the form and non-form information.

Tables 12-1 and 12-2 Hourly Cost Calculations: As shown at Table 12-1, below, the average respondent hourly cost for Cooperative Range Improvement Agreements, Range Improvement Permits, and Affected Public / Individuals and Households is $33.07. We assumed that individuals and households participating in opportunities for cooperation under this control number face hourly costs that are similar to those experienced by operators applying for Range Improvement Permits and by operators who enter into Cooperative Range Improvement Agreements.

The hourly wage for Table 12-1 was determined using national Bureau of Labor Statistics data at: http://www.bls.gov/oes/current/oes_nat.htm. The benefits multiplier of 1.4 is supported by information in Table A of Bureau of Labor Statistics News Release USDL 10-0283, March 10, 2010, at http://www.bls.gov/news.release/ecec.nr0.htm.

Table 12-1 — Hourly Cost Calculation for Cooperative Range Improvement Agreement, Range Improvement Permit, and Affected Public / Individuals and Households

Position	Hourly Pay Rate ($/hour)	Hourly Rate with Benefits (x 1.4)
Farmers and Ranchers (11-9012)	$23.62	$33.07

As shown at Table 12-2, below, the average respondent hourly cost for Affected Public / State, Local, and Tribal Governments is $45.59. The hourly wage for Table 12-2 was determined using national Bureau of Labor Statistics data at: http://www.bls.gov/oes/2008/may/naics4_999200.htm. The benefits multiplier of 1.5 is supported by information in Table A of Bureau of Labor Statistics News Release USDL 10-0283, March 10, 2010, at http://www.bls.gov/news.release/ecec.nr0.htm.

Table 12-2 — Hourly Cost Calculation for Affected Public / State, Local, and Tribal Governments

Position	Hourly Pay Rate ($/hour)	Hourly Rate with Benefits (x 1.5)
Farm, Ranch, and other Agricultural Managers (11-9011)	$30.39	$45.59

Tables 12-3 and 12-4 Estimates of Hour and Cost Burdens: Hour and cost burdens to respondents include time spent for researching, preparing, and submitting information. The average hourly wage associated with these information collections is shown at Tables 12-1 and 12-2, above. The BLM’s estimate of the time it takes a respondent to supply the information was verified by consultations with several respondents (see Item 8, above).

The frequency of response for each of the information collections is “on occasion.” As shown below, the total number of responses is 1,216, the total hour burden is 1,799 hours, and the total wage cost burden is $66,792.

Table 12-3 Cooperative Range Improvement Agreements, Range Improvement Permits, and Affected Public / Individuals and Households

(a) Type of Response	(b) Number of Responses	(c) Hours Per Response	(d) Total Hours (b x c)	(e) Total Wage Cost (d x $33.07)
43 CFR part 4100, subpart 4120 Cooperative Range Improvement Agreement Form 4120-6 and related non-form information	573	2	1,146	$37,898
43 CFR part 4100, subpart 4120 Range Improvement Permit Form 4120-7 and related non-form information	10	2	20	$661
43 CFR part 4100, subpart 4120 Affected Public / Individuals or Households	50	1	50	$1,654
Total	633		1,216	$40,213

Table 12-4 Affected Public / State, Local, and Tribal Governments

(a) Type of Response	(b) Number of Responses	(c) Hours Per Response	(d) Total Hours (b x c)	(e) Total Wage Cost (d x $45.59)
43 CFR part 4100, subpart 4120 Affected Public / State, Local, and Tribal Governments	583	1	583	$26,579

13. Provide an estimate of the total annual cost burden to the respondents or record keepers resulting from the information collection. Do not include the cost of the burden hours described 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 [including filing fees paid]. 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 collection services should be a part of this 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.

Respondents are not required to purchase any additional computer hardware or software to comply with these information requirements. There is no filing fee associated with this information collection. There are no capital and start-up costs involved with this information collection.

14. Provide estimates of annualized cost 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 also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

As shown below, the estimated average annualized cost to the Federal Government for this information collection is $38.59.

Table 14-1 Weighted Average Federal Wage Cost: The hourly cost to the Federal Government is based on the U.S. Office of Personnel Management Salary Table 2010-RUS located at http://www.opm.gov/oca/10tables/html/RUS_h.asp. The benefits multiplier of 1.5 is implied by information in Table A of Bureau of Labor Statistics News Release USDL 10-0283, March 10, 2010, at http://www.bls.gov/news.release/ecec.nr0.htm.

Position	Pay Grade	Hourly Pay Rate ($/hour)	Hourly Rate with Benefits (x 1.5)	Percent of time spent on these collections	Weighted Avg. ($/hour)
Range Clerk	GS-7/5	$21.07	$31.61	5%	$1.58
Rangeland Management Specialist	GS-9/5	$25.77	$38.66	94%	$36.34
Field Manager	GS-13/5	$44.43	$66.65	1%	$0.67
Weighted Average Hourly Pay Rate ($/hour) $38.59

Table 14-2 Estimated Annual Cost to the Government: The table below shows the annualized Federal costs for each component of this collection of information. The estimated time spent to process the information collections is based on the BLM's experience. The hourly wage is shown at Table 14-1, above.

Table 14-2 – Estimated Annual Cost to the Government

(a) Type of Response	(b) Number of Responses	(c) Hours Per Response	(d) Total Hours (b x c)	(e) Total Wage Cost (d x $38.59)
43 CFR part 4100, subpart 4120 Cooperative Range Improvement Agreement Form 4120-6 and related non-form information	573	8	4,584	$176,897
43 CFR part 4100, subpart 4120 Range Improvement Permit Form 4120-7 and related non-form information	10	9	90	$3,473
43 CFR part 4100, subpart 4120 Affected Public / Individuals or Households	50	2	100	$3,859
43 CFR part 4100, subpart 4120 Affected Public / State, Local, and Tribal Governments	583	1	583	$22,498
TOTALS	1,216		5,357	$206,727

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

Burden	Previous Collection	This Collection	Difference
Responses	712	1,216	+504
Burden hours	4,348	1,799	-2,549

Adjustments:

Cooperative Range Improvement Applications

BLM expects a significant increase in the number of responses due to increased public use.

Range Improvement Permit

The BLM expects fewer applications because the current economy is discouraging projects funded by livestock grazing permittees.

Affected Public (Individuals and Households)

Because of the current economy, the BLM expects a decrease in the number of responses and burden hours for the Range Improvement applications from livestock operators.

Affected Public (State, Local, and Tribal Government)

The BLM increase in responses and burdens are based on the interest in range improvement proposals and effects on soil, water and wildlife resources with the resulting increase in coordination and consultation with State, Local and Tribal governments.

Program Adjustment

Affected Public (Federal Government)

We removed this information collection that pertained to collecting information from the Federal Government. Section 3502 of the Paperwork Reduction Act, does not require that we include information collected amongst government agencies. The program adjustment reflects the removal of 27 responses and 162 burden hours for this collection.

A reestimate in respondent burden and number or respondents has resulted in a burden reduction for this collection as an adjustment. There was also an increase in the amount of time it takes to complete the forms for this collection. It now takes 2 hours to complete both forms.

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.

The BLM will not publish the results of this information collection.

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 BLM will display the expiration date of the OMB approval on the forms included in this information collection.

18. Explain each exception to the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions to the certification statement.