1004-0119 Supporting_statement

11

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION

OMB CONTROL NUMBER 1004-0119

PERMITS FOR RECREATION ON PUBLIC LANDS (43 CFR PART 2930)

Form 2930-1

Terms of Clearance: In our last renewal, OMB included terms of clearance asking us to expand our submission capability to include electronic submission. In response and in accordance with the Government Paperwork Elimination Act (GPEA), we have made Form 2930-1 available electronically through Forms Central at www.blm.gov/blmforms/Forms/index.htm. The form can be downloaded and completed electronically. The completed application can be emailed directly to the field office that will process the application. The contact information for each field office is available on the BLM website.

SECTION A

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Bureau of Land Management (BLM) is required to manage commercial, competitive and organized group recreational uses of the public lands, and individual use of special areas. The BLM must assess, evaluate and authorize (permit) activities proposed to be conducted on public land. The BLM has the following authorities for collecting the required information to authorize and collect fees for recreation use on public lands:

A. Federal Land Policy and Management Act (43 U.S.C. 1701 – 1782);

B. Federal Lands Recreation and Enhancement Act (16 U.S.C. 6801 - 6814);

C. Wilderness Act (16 U.S.C. 1131 - 1136);

D. National Trails System Act (16 U.S.C. 1241 – 1251);

E. National Wild and Scenic Rivers Act (16 U.S.C.1271 - 1287); and

F. Title 43 CFR, Subpart 2930 – Special Recreation Permits, Other than on Developed

Recreation Sites

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 needs the information to:

1. Determine whether proposed recreation use is environmentally acceptable;

2. Calculate the amount of fees that will be assessed if the activity or event is authorized;

3. Determine qualifications and capability of the applicant to offer the proposed services; and

4. Tabulate recreation use data for the annual Federal Recreation Fee Report required by the Land and Water Conservation Fund Act.

The respondent must file with the BLM Form 2930-1, Special Recreation Permit Application, to obtain approval of the requested recreation use. The BLM needs this information to approve or reject the application. The BLM is revising Form 2930-1 (Special Recreation Application and Permit) to be used only as a Special Recreation Application.

In this information collection renewal, we are replacing the combined Special Recreation Application and Permit, Form 2930-1, with two forms:

• a Special Recreation Permit Application (Form 2930-1), for which OMB approval will be required (and requested); an

• a Special Recreation Permit (Form 2930-2) for which OMB approval will not be required

When the requested use is approved, BLM will issue a Special Recreation Permit (SRP), Form 2930-2. Because Form 2930-2 will be completed by the agency and not by the applicant, OMB approval is not required for Form 2930-2. A more detailed explanation is in item 15.

We request the following information on Form 2930-1:

Item 1: Indicate if this form is a new application or renewal of an existing permit. The BLM uses this information to determine if the applicant has a file with the BLM so we can review the background history.

Item 2: Indicate the name of the business or organization. The BLM uses this information for identification and communication purposes.

Items 3 through 10: Indicate the following information:

• Applicant’s Name;

• E-mail address;

• Address;

• Telephone Number;

• FAX Number

• Website

• Type of Business; and

• Name and telephone numbers of those individuals authorized to conduct business with BLM concerning the permit.

The BLM uses this information to review the application and communicate with the applicant.

Item 11: Indicate the type of permit applying for such as (commercial, competitive, organized group, individual, or vending use). The BLM uses this information to determine how to help the applicant and give guidance on completing the process.

Items 12 through 15: Indicate the following information:

• Name and legal description of land to be used;

• Purpose and description of activity or use;

• Dates activity will begin and end;

• Indicate the applicant’s history and prior use of SRPs and bonds. The BLM uses this information to build a profile on the use of permits.

Item 16: Indicate the certification information. The BLM uses this information to ensure that the application is correct and to inform the applicant of the conditions and stipulations that may be imposed when we issue the permit.

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. In our last renewal, OMB included terms of clearance asking us to expand our submission capability to include electronic submission. In response, we have made Form 2930-1 available electronically through Forms Central at www.blm.gov/blmforms/Forms/index.htm. The form can be downloaded and completed electronically. The completed application can be emailed directly to the field office that will process the application. The contact information for each field office is available on the BLM website.

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

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

We do not collect information on whether the respondents are small businesses or small entities. We estimate that 3,000 respondents may qualify as a small business. The information we require from all respondents is limited to the minimum necessary to authorize recreation use 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 manage the recreation uses on the public lands, thereby resulting in potential damage to resources and loss of revenue. Without a permit, many competitive off-highway vehicle events could take place on public lands without sufficient oversight, and those lands could be subject to unauthorized use violations and trespass. 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.

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 a 60-day notices in the Federal Register (75 FR 14458) on March 25, 2010, soliciting comments from the public and other interested parties. The comment period closed on May 24, 2010. One comment was received. The comment did not address, and was not germane to, this information collection; rather, it was a general invective about the Department of the Interior, and the BLM. Therefore, we have no response to the comment.

During the approval period, we consulted with three respondents to solicit comments on the burden hour and cost estimates, availability of data, frequency of collection, and clarity of instructions. The names, titles, addresses and phone numbers of the respondents are available from the agency, by request. The respondent’s personal information is protected by the Privacy Act. Because this document will be made available to the public, the respondent’s information will not be included in this document. The three respondents stated that the required data are readily available, the frequency of collection is reasonable, and the instructions are clear. One respondent commented that the form is very simple to complete. One respondent commented that she likes having the form available on-line. There were no additional comments about the data elements. Based on these consultations, the burden estimates in Question 12 have been revised to reflect their input.

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 required 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.

Hourly Cost Calculations: As shown at Table 12-1, below, the estimated average respondent hourly cost is $22.41 for this information collection

The basic hourly pay rate 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 10-0774, June 9, 2010, at http://www.bls.gov/news.release/ecec.nr0.htm.

Table 12-1 — Hourly Cost Calculation

Position	Hourly Pay Rate ($/hour)	Hourly Rate with Benefits ( x 1.4)
Travel Guides 39-6022	$16.01	$22.41
Total		$22.41

Estimated Hour and Cost Burdens: The estimated hour and cost burdens shown in Table 12-2, below, include time spent for researching, preparing, and submitting information. The average hourly wage associated with these information collections is $22.41, as shown at Table 12-1, above. The BLM’s estimate of the time it takes a respondent to supply the information was verified by consultations with respondents (see Item 8, above).

The frequency of response for this information collection is “on occasion.” As shown below, the total number of responses is 3,694, the total hour burden is 14,776 hours, and the dollar equivalent of the hour burden is $331,130.

Table 12-2 – Estimated Hour and Cost Burdens

Type of Response	A. Number of Responses Annually	B. Hours per Response	C. Annual Hour Burden (B x C)	D. Hourly Wage	E. Annual Cost (D x E)
Special Recreation Permit Applications 43 CFR 2932.20 Form 2930-1 and related non-form information	3,694	4	14,776	$ 22.41	$331,130

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 additional computer hardware or software to comply with this information collection. 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 to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Hourly Cost Calculation: As shown at Table 14-1, below, the average government hourly cost is $40.14 for this information collection. 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 10-0774, June 9, 2010, at http://www.bls.gov/news.release/ecec.nr0.htm.

Table 14-1 — Hourly Cost Calculation

A. Position	B. Pay Grade	C. Hourly Pay Rate	D. Hourly Rate with Benefits (C x 1.5)	E. Percent of time spent on these collections	F. Weighted Avg. (D x E)
Clerical	GS-7/1	$18.59	$27.89	15%	$4.18
Technical	GS-11/1	$27.51	$41.27	80%	$33.02
Managerial	GS-13/1	$39.21	$58.82	5%	$2.94
Totals				100%	$40.14

Estimated Annual Cost to the Government: The estimated annual cost to the government includes time spent for processing the information provided by the respondents. The average hourly wage is shown at Table 14-1, above. Table 14-2, 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 frequency of response for each of the information collections is “on occasion.” As shown below, the total number of responses is 3,694, the total Federal hour burden is 3,694 hours, and the total wage cost burden is $148,277.

Table 14-2 — Estimated Annual Cost to the Government

Type of Response and 43 CFR 3809 Citation	A. Number of Responses	B. Hours Per Response	C. Total Hours (B x C)	D. Total Wage Cost (D x $40.14)
Special Recreation Permit Applications 43 CFR 2932.20 Form 2930-1 and related non-form information	3,694	1	3,694	$148,277

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

Burden	Previous Collection	Program Decrease	Adjustment Increase	This Collection
Responses	365,845	364,395	2,244	3,694
Hours	375,995	364,395	3,176	14,776

The BLM has removed from this submission two forms, Recreation Fee Permit Envelope Form 1370-036 and the combined Special Recreation Application and Permit (Form 2930-1).

Recreation Fee Permit Envelope

The Recreation Fee Permit Envelope (Form 1370-036, 43 CFR subpart 2933) combines an application for a recreation use permit with an envelope in which to enclose a fee. Applicants may obtain a permit at self-service pay stations, from the BLM at a recreation site, or at other specified locations. The form asks respondents to supply the following information: (a) campsite number, (b) dates of camping, (c) number in party, (d) ZIP Code, (e) fee paid, (f) vehicle license number, and (g) primary purpose of visit.

OMB approved Form 1370-036 prior to 2007 under OMB control number 1004-0133. In 2007, the BLM submitted an Information Collection Request (ICR) asking for consolidation of control numbers 1004-0133 and 1004-0119. On September 2, 2008, the BLM issued Information Bulletin (IB) No. 2008-104 instructing employees to “cross out all three lines of text in the OMB approval block.” The IB also indicated that the BLM had determined that Form 1370-036 no longer requires OMB approval. The IB is available in ROCIS.

For purposes of this ICR, we have determined that the regulations at 43 CFR subpart 2933 entail no information collection burden other than that necessary to identify the respondent, the respondent’s address, the date and the nature of the instrument. Therefore, in reliance on 5 CFR 1320.3(h), we have decided not to include in this ICR the collection of information requirements in 43 CFR subpart 2933.

Special Recreation Application and Permit

In this ICR, we are proposing to replace the combined Special Recreation Application and Permit (Form 2930-1) with two forms:

• a Special Recreation Permit Application (Form 2930-1), for which OMB approval will be required (and requested); and

• a Special Recreation Permit (Form 2930-2) for which OMB approval will not be required

When the OMB approves the Special Recreation Permit Application, 2930-1, the respondent will not be required to complete the Special Recreation Permit, Form 2930-2. The BLM will complete the Special Recreation Permit, Form 2930-2 for the respondent.

Summary

The total estimated burden for this information collection request is 3,694 responses and 14,776 hours, compared to 365,845 responses and 375,995 hours for the previous request. There is a net decrease of 362,151 responses and 361,219 hours.

The net decrease is due in part to our removal of Form 1370-036 from this ICR. The previously approved burdens for Form 1370-036 were 364,395 responses and 364,395 hours. (The estimated time per response was one hour.)

A portion of this decrease is offset by an upward adjustment in our estimated number of responses for Form 2930-1, from 1,450 (previous estimate) to 3,694 (current estimate). However, we are adjusting downward our estimate of the hours per response (from 8 hours to 4 hours) because respondents will no longer be required to complete the Permit portion of the form.

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 publish the tabulated recreation use data in the Public Land Statistics, as required by the Federal Lands Recreation Enhancement Act (16 U.S.C. 6808).

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 form 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.