1018-0022 SSA w attachment

Supporting Statement A for
Paperwork Reduction Act Submission
OMB Control Number 1018-0022
Federal Fish and Wildlife Permit Applications and Reports-Migratory Birds and Eagles
50 CFR 10, 13, 21, and 22
Note: This information collection includes four permit application and report forms that
are currently approved under OMB Control Number 1018-0136. Once OMB takes action
on this IC, we will discontinue OMB Control No. 1018-0136.
Terms of Clearance: None.
1. Explain the circumstances that make the collection of information necessary.
We collect information on application forms and in reports to determine if applicants for permits
meet the requirements mandated by:



Migratory Bird Treaty Act (MBTA, 16 U.S.C 703-712; 50 CFR 21).
Bald and Golden Eagle Protection Act (Eagle Act, 16 U.S.C. 668-668d; 50 CFR 22).

U.S. Fish and Wildlife Service (we, Service) regulations implementing these statutes are in
Chapter I, Subchapter B of Title 50, Code of Federal Regulations. These regulations stipulate
general and specific requirements that when met allow us to issue permits to authorize activities
that are otherwise prohibited.
2. Indicate how, by whom, how frequently, and for what purpose the information is to
be used. If the information collected will be disseminated to the public or used to
support information that will be disseminated to the public, explain how the
collection complies with all applicable Information Quality Guidelines.
All Service permit applications are in the 3-200 series of forms, each tailored to a specific
activity based on the requirements for specific types of permits. We collect standard identifier
information for all permits, such as the name of the applicant and the applicant’s address,
telephone and fax numbers, social security or tax identification number, and e-mail address.
Standardizing general information common to the application forms will make filing of
applications easier for the public as well as expedite our review of applications.
The information that we collect on applications and reports is the minimum necessary for us to
determine if the applicant meets/continues to meet issuance requirements for the particular
activity. Respondents submit application forms periodically, as necessary. Submission of
reports is generally on an annual basis, although some are dependent on specific transactions.
We examined applications in this collection, focusing on questions frequently misinterpreted or
not addressed by applicants. This ICR includes modifications to the format and content of the
currently approved applications so that they (a) are easier to understand and complete and (b)
will accommodate future electronic permitting.

We developed two new application forms (3-200-81, 3-200-82) and one new report form (3-20217) to simplify the application and reporting process for respondents:
FWS Form 3-200-81 (Special Purpose – Utility)
This application is specifically tailored for utilities (e.g., electric, communications, wind) to
request permits to salvage migratory birds on their property and rights-of-way. Currently utility
applicants apply for permits using either the Special Purpose – Miscellaneous application form
(3-200-10f) or, improperly, the Special Purpose – Salvage application form (3-200-10a). The
new form 3-200-81 requests essentially the same information as the 3-200-10f, but it is clearly
tailored to apply to utilities. This form requests information about measures the utility has taken
to avoid, reduce, or minimize migratory bird fatalities that may be caused by the facility. This
relates to our policy to work with utilities to develop best management practices to reduce
avoidable take.
FWS Form 3-200-82 (Eagle Transport into and out of the United States)
This application enables us to administer permits under the Bald and Golden Eagle
Protection Act to transport dead eagle specimens into and out of the country temporarily for
scientific or exhibition purposes, such as for museum exhibits. Currently applicants wishing to
transport eagles into and out of the United States submit FWS 3-200-69 (Eagles, International
Transport for Scientific or Exhibition Purposes) (approved under OMB Control No. 1018-0093).
Since the Bald Eagle was downlisted from Appendix I to Appendix II under the Convention on
International Trade in Endangered Species (CITES), this form is no longer appropriate because
only Eagle Act authorization (i.e., not a CITES import permit) is required to transport eagle
specimens into the United States. The new form 3-200-82 requests much of the same
information as the 3-200-69, but is clearly tailored only to the Eagle Act. Applicants will submit
their applications to the Regional Migratory Bird Permit Offices instead of the Division of
Management Authority in the Washington Office.
FWS Form 3-202-17 (Special Purpose – Utility Annual Report)
This is a standardized annual report form for Special Purpose – Utility permits to report
salvage of specimens. This information may be submitted either electronically or in written
form. This information will assist both the utilities and the Service to work together to identify
problem or structures or vulnerable species and develop best management practices to avoid or
reduce future bird mortalities. The report requests basic information such as:
 Species name.
 Date specimen was collected.
 Location where specimen was found including State, county, city/nearest town, and GPS
coordinates in decimal degrees.
 Type of equipment or structure potentially causing the mortality of the migratory bird.
 Weather conditions when the mortality likely occurred.
 Final disposition of specimens (i.e., were they are buried or retained).
 Measures employed to reduce future mortality.

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In addition to the new forms, we made substantive changes to two currently approved forms:
FWS Form 3-202-4 (Rehabilitation Annual Report)
We eliminated a section that requests information on birds held over at the facility from
the prior calendar year. We no longer track this information. We reduced another section that
requests information on birds held over at the end of the calendar year to only request
information on birds held over at the end of the calendar year that the permittee has held for
longer than 180 days. We added a new section to the form to collect information on the results
of birds admitted to rehabilitation centers that the permittee had tested for contaminants and
disease and that were confirmed victims of infectious disease or contaminants. Providing this
information is optional on the part of the permittee. We are expanding our avian disease
monitoring programs and will use this information to aid in identifying trends in avian infectious
disease, such as West Nile virus and Avian Influenza, and contaminants such as lead and
carbofuran.
FWS Form 3-200-77 (Native American Eagle Take)
We revised this form because we have received applications where the applicant has
provided no information to support or legitimize the religious need to take (kill) eagles from the
wild. We have a statutory obligation under the Bald and Golden Eagle Protection Act to weigh
the religious needs of practitioners with the need to protect eagles, so a requirement that
applicants demonstrate this need is warranted.
We removed the following from the currently approved form:



Name the religious ceremony for which the eagle(s) is required, if doing so will
not violate your religious beliefs.
Does the religious ceremony proposed require the take of an eagle(s) from the
wild?

Those questions were replaced with the following:



The name of your religion (item E6).
Please explain why take of a live eagle(s) from the wild is necessary and why an
eagle carcass, parts, or feathers from another source will not suffice (item E7).

Answers to these questions will not be voluntary. The name of the tribal religion may
provide information on the types of ceremonies the applicant’s tribe traditionally practices. The
explanation of why take of a live eagle from the wild is necessary is intended to not be overly
intrusive by avoiding any requirement that the applicant disclose details about the actual
ceremonial activities. However, it is important that an applicant justify a legitimate religious
need to kill eagles.
In order to continue to try to limit take of live eagles to situations where it is truly a
religious necessity, we need some information on which to base that decision. Under the
current application process, an individual is able to certify that take of a wild eagle is necessary
and the inquiry ends there. Because we found that applicants’ responses to the questions often
did not yield accurate information as to the actual necessity of taking eagles from the wild, we
revised the form as noted above to ensure that any take we authorize is necessary, in keeping
with our mandate to preserve eagles.

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We also revised the application to require co-signature or other written approval by a
tribal government official when individuals, as opposed to a tribe, are requesting a permit. This
is to ensure that the request is consistent with tribal interests. This will assist with situations
where tribal members apply to take eagles when, tribal laws prohibit the killing of eagles. why an
eagle carcass, parts, or feathers from another source will not suffice.
3. Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology; e.g., permitting electronic submission of
responses, and the basis for the decision for adopting this means of collection. Also
describe any consideration of using information technology to reduce burden [and
specifically how this collection meets GPEA requirements.].
Forms in this collection will be available to applicants in a fillable format on our forms and
permits websites, by mail, or by fax. Applicants may complete the fillable application online, but
must send the application form with an original signature and the applicable processing fee by
mail. Applicants may send supporting information by e-mail or fax, if we already have their
application and they are able to reference an application number. At this time, we do not have a
system for electronic submission of permit application forms or reports; however, we are actively
developing the system and are pilot testing two Service application forms that have current
OMB approval.
4. Describe efforts to identify duplication.
The information that we collect is unique to the applicant and is not available from any other
source. Other than the general identifying information standard for each application, collection
of duplicate information is minimal.
Many permittees renew permits for ongoing activities. We retain information from their original
application so they do not have to duplicate information that is unchanged for the new permit. If
an existing permittee requests a new type of permit (such as a rehabilitator who applies for an
education permit), applicants may reference existing permit files for information relevant to the
new application. This allows the applicant to submit only the additional information necessary to
meet the requirements of a new type of permit.
We developed an electronic permit issuance and tracking system that greatly improves
retrieval of file information, further reducing duplicate information requests for use in
renewals, extensions, and repeat applications. Ongoing development of our permit issuance
and tracking system will ensure that no duplication arises among Service offices.
5. If the collection of information impacts small businesses or other small entities,
describe the methods used to minimize burden.
This collection will not have a significant impact on small entities. Small businesses or small
entities must provide the same information required of individual applicants. We collect only the
minimum information necessary to establish eligibility and to assess the effect of the permit
program.
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.

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If we do not collect the information or if we collect the information less frequently, we could
not implement many wildlife protection programs that are mandated by law. Further, we could
not issue applicants a permit since the collected information is either required on the permit or
authorization itself or is needed to make the necessary biological and legal findings under
applicable statutes and treaties. If we were not able to satisfy the information requirements
necessary to issue a permit, the public would not be able to conduct otherwise prohibited
activities, such as possession of migratory birds and eagles.
7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:
*
*
*
*
*
*
*

*

requiring respondents to report information to the agency more often than
quarterly;
requiring respondents to prepare a written response to a collection of information
in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any
document;
requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records, for more than three years;
in connection with a statistical survey, that is not designed to produce valid and
reliable results that can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been reviewed and
approved by OMB;
that includes a pledge of confidentiality that is not supported by authority
established in statute or regulation, that is not supported by disclosure and data
security policies that are consistent with the pledge, or which unnecessarily
impedes sharing of data with other agencies for compatible confidential use; or
requiring respondents to submit proprietary trade secrets, or other confidential
information unless the agency can demonstrate that it has instituted procedures
to protect the information's confidentiality to the extent permitted by law.

Permit regulations (50 CFR 21.27(c)(5), 21.28(d)(4), and 21.30(d)(6)) require that Special
Purpose Game Bird, Falconry, and Raptor Propagation permit holders file an FWS Form 3-186A
(Migratory Bird Acquisition and Disposition Report) with the Service within 5 days of a
transaction (take from the wild, buy, sell, or transfer). Permit regulations (50 CFR 21.25(c)(5))
require that Waterfowl Sale and Disposal permit holders file an FWS Form 3-186 with the
Service by the end of the month during which a waterfowl sale is conducted. The MBTA, which
was enacted to protect migratory birds from market hunting, strictly regulates commerce. These
are the only four permits that authorize sale and purchase. Current information regarding
commercial activity under the permits is necessary to enforce the regulations.
Permit regulations (50 CFR 13.46) require that records of any taking, possession,
transportation, sale, purchase, barter, export or import of wildlife pursuant to a permit be
maintained for 5 years from the expiration date of the permit. The statute of limitations for
enforcement is 5 years.
8. Provide the date and page number of publication in the Federal Register of the
agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the
information collection prior to submission to OMB. Summarize public comments
received in response to that notice (or in response to a PRA statement) and describe
actions taken by the agency in response to these comments.
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Describe efforts to consult with persons outside the agency to obtain their views on
the availability of data, frequency of collection, the clarity of instructions and
recordkeeping, disclosure, or reporting format (if any), and on the data elements to be
recorded, disclosed, or reported. [Please list the names, titles, addresses, and phone
numbers of persons contacted.]
On April 7, 2010, we published in the Federal Register (75 FR 17757) a notice of our intent to
request that OMB approve this information collection. In that notice, we solicited comments for
60 days, ending on June 7, 2010. We did not receive any comments.
We contacted the individuals and groups listed below that consistently use our forms and
solicited comments on the applications and report forms. We targeted two applications and one
annual report form for comments. FWS Forms 3-200-15A and 3-200-15B are applications for
first and second order, respectively, for Native Americans to obtain a permit and receive parts
for Indian Religious Purposes. We did not receive any comments on those forms. The
comments received pertained to revisions we proposed to FWS Form 3-202-4 (Rehabilitation
Annual Report). We deleted one section of the report form, reduced another section, and added
one new section to gather information on the results of birds tested for contaminants and
disease. Thousands of migratory birds are admitted each year into wildlife rehabilitation
centers, which represent an untapped source of information on disease and contaminants
demographics. We are only requesting data on birds that the centers voluntarily chose to have
tested by a professional diagnostics laboratory. This represents a small fraction of birds
admitted, but the data are reliable.
Peggy Whitford of Blackfeet
[email protected]
Phone: 406-338-7207.

Dody Wyman, President
International Wildlife Rehabilitation Council
[email protected]

Monica Terkildsen
Member of federally recognized tribe
[email protected]

Wendy Fox, President
National Wildlife Rehabilitators Association
[email protected]

Steven Emery
Member of federally recognized tribe
[email protected]
Scott Aiken
Bureau of Indian Affairs
Portland, OR
via Tami TateHall/RO/R1/FWS/DOI@FWS

Edward E. Clark, Jr., President
Wildlife Center of Virginia
www.wildlifecenter.org

We received three comments, all pertaining to FWS Form 3-202-4. None of the comments
pertained to the burden estimates.
Necessity of Collection.


Two commenters generally supported collecting the disease and contaminants
information, but recommended several clarifications to the instructions (see below).



One commenter did not support the proposed new section on disease and
contaminants. He felt that the Service does not use the rehabilitation annual report
information it already collects and that collecting additional information on disease and
contaminants will have limited value.

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Response: We generally disagree with the commenter. We use annual report
information to monitor permit compliance. These reports are reviewed as they come in
and when a permittee requests renewal. We also use species-specific information
submitted in the course of assessing species population status. However, until these
reports can be submitted online by permittees, we have to enter reported data into the
permits database. With the exception of data on eagles and certain other high priority
species, staff do not always have time to enter this data into the system. However,
recent programming changes facilitate that data entry and we are working on a system
that will allow permittees to submit reports online.


This commenter also questioned whether the Service has the authority to require
permittees to provide the information on disease diagnoses because (1) this information
may be considered proprietary without permission of the permittee and (2) the
rehabilitation permits do not require advanced diagnostic testing—it is optional.
Response: We believe the commenter has raised two valid points. As a result, we will
retain the disease and contaminants section on the annual report, but make the section
voluntary.

Clarity


One commenter suggested revisions to column heading and the instructions to clarify
the data being requested. For instance, it needed to be clarified and emphasized that
the Service is not asking rehabilitators to test birds—which is very expensive--but only to
report those that the rehabilitator chose to test and for which they obtained a confirmed
cause of death. Another suggested that we clarify which infectious diseases and
contaminants we want information on. For instance clarify whether we want information
on internal parasites and external contaminants, such as oil.
Response: We agree with the commenters and have made the recommended
clarifications.

9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
We do not provide payments or gifts to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
We do not provide any assurance of confidentiality. The information collected is subject to the
requirements of the Privacy Act and the Freedom of Information Act as explained in the
notices portion of all applications.
11. Provide additional justification for any questions of a sensitive nature, such as
sexual behavior and attitudes, religious beliefs, and other matters that are commonly
considered private.
FWS Form 3-200-77 (Native American Eagle Take) is the application for a permit for Native
Americans to take bald or golden eagles from the wild for Indian religious purposes. Typically
the eagles are killed. The form includes a question asking the applicant to explain why the take
of live eagle(s) from the wild is necessary. We ask that they describe the aspect of the religious
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ceremony or other religious practice that makes the take of a live eagle(s) from the wild
necessary as a central part of the religious ceremony and belief system, and why an eagle
carcass, parts, or feathers from another source, such as the National Eagle Repository, will not
suffice. We only ask for as much information as we need to evaluate in order to weigh the
religious need against our statutory obligation under the Bald and Golden Eagle Protection Act
to conserve eagles.
12. Provide estimates of the hour burden of the collection of information.
We estimate that there will be approximately 57,260 non-Federal respondents annually for the
applications and reports included in this ICR. We anticipate receiving approximately 57,260
responses annually, totaling 93,402 burden hours. The completion times vary substantially
(from 15 minutes to 40 hours) depending on the activity. See Attachment A for a breakdown of
burden hours for each information collection.
We estimate the total dollar value of the annual burden hours for this collection to be $2,858,354
(see Attachment A). We used the Bureau of Labor Statistics news release USDL 10-1241,
September 8, 2010, Employer Costs for Employee Compensation—June 2010
(http://www.bls.gov/news.release/pdf/ecec.pdf), to estimate average hourly wages and calculate
benefits for:


Individuals - We used the wage and salary costs for all workers from Table 1 ($20.55)
and multiplied by 1.4 to calculate benefits, resulting in an hourly rate of $28.77.



Private Sector - We used the wage and salary costs for all workers from Table 5
($19.53) and multiplied by 1.4 to calculate benefits, resulting in an hourly rate of $27.34.



State/local/tribal Government - We used the wage and salary costs for all State workers
from Table 3 ($26.13) and multiplied by 1.5 to calculate benefits, resulting in an hourly
rate of $39.20.

13. Provide an estimate of the total annual [non-hour] cost burden to respondents or
record keepers resulting from the collection of information.
We estimate the nonhour cost burden to respondents for this information collection to be
$1,049,925 (see Attachment A). These costs are primarily for application processing fees, which
range from $0 to $1,000. Substantive amendments to certain permit types cost from $50 for
rehabilitation permits to $500 for amendments to programmatic eagle take permits. There are
no processing fees for reports. Federal, tribal, State, and local government agencies and those
acting on their behalf are exempt from processing fees. When there is more than one applicable
fee, such as for an original permit or an amendment, we have used the higher fee to calculate
costs.
14. Provide estimates of annualized costs to the Federal Government.
We estimate the total cost to the Federal Government to administer this information collection
will be $2,618,429 (see Attachment A).
Service biologists (GS-11/13) and permit examiners (GS-9/12), with support of GS-7 staff, will:



Review and determine the adequacy of the information an applicant provides.
Conduct any internal research necessary to verify information in the application or
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evaluate the biological impact of the proposed activity.
Assess the biological impact of the proposed activity on the bald or golden eagle.
Evaluate whether the proposed activity meets the issuance criteria.
Prepare or review NEPA documentation.
Prepare either a permit or a denial letter for the applicant.
When necessary to evaluate the impact of the proposed activity, visit the location to
examine site-specific conditions.
 Monitor reports.







Permits are processed in our eight Regional Offices, which are located in major cities across the
United States. Therefore, we used Office of Personnel Management Salary Table 2010-DCB
http://www.opm.gov/oca/10tables/html/dcb_h.asp to determine average hourly wages. We
multiplied the hourly rate by 1.5 to account for benefits in accordance with BLS news release
USDL 10-1241, September 8, 2010.
The table below shows Federal staff and grade levels performing various tasks associated with
this information collection.
POSITION/GRADE

Clerical - GS-7/step 5
(Receptionist, Office Asst.)
Legal documents examiner–GS9/step 5 (Permit examiner)
Legal documents examiner-GS11/step 5 (Permit examiner)
Biologist - GS-11/step 5
Supervisor – GS-12/step 5
(Permit Chief)
Management - GS-13/step 5
(Branch/Division Chief, Solicitor)
Weighted Average
($/hr)

HOURLY
RATE
$22.92

HOURLY
RATE
INCLUDING
BENEFITS
$34.38

28.04

42.06

30% 12.62

33.92

50.88

30% 15.27

33.92
40.66

55.88
60.99

10%
20% 12.20

48.35

72.53

5% 3.63

TIME SPENT ON
INFORMATION
COLLECTION
5%

WEIGHTED
AVERAGE
$/HOUR
$ 1.72

5.59

$51.03

15. Explain the reasons for any program changes or adjustments.
We are requesting 57,260 annual responses, 93,402 burden hours, and $1,049,925 nonhour
burden costs. This is a net increase of 1,586 responses, 46,071 annual burden hours, and
$343,625 in nonhour costs from our previous request.
We are reporting as a program change an increase of 1,921 responses, 44,771 burden hours,
and $241,625 nonhour costs associated with the applications and reports currently approved
under OMB Control No. 1018-0136 and the two new applications and one new report proposed
in this ICR.
The remaining net decrease of 335 responses and net increases of 1,300 burden hours and
$102,000 nonhour burden costs are the result of adjustments to our estimated number of
responses and/or burden hours. We made these adjustments based on our experience in
administering this collection over the past years.

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16. For collections of information whose results will be published, outline plans for
tabulation and publication.
There are no plans for publication of the results of these information collections.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
We will display the OMB control number and expiration date.
18. Explain each exception to the certification statement.
There are no exceptions to the certification statement.

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Cost to Govt
($51/hr)

Avg Time (hrs)
per response
for Govt review

Attachment A

Total Annual
Nonhour Burden
Cost

Average
Nonhour Burden
Cost Per
Response

Dollar Value of
Annual Burden
hours

Hourly Labor
Costs including
Benefits

Hourly Labor
Costs

Annual Burden
Hours

Completion Time
per Response
(hours)

Annual
Responses

Regulation/
Activity

OMB 1018-0022
BURDEN HOURS, NONHOUR COSTS, AND FEDERAL COSTS

3-200-6 - application
Import/Export
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-7 - application
Scientific Collecting

36
20
20
76

1
1
1

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 8 - application
Taxidermy

50
60
100
210

5
5
5

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 9- application
Waterfowl Sale/Disposal

0
690
0
690

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 10a - application
Special Purpose Salvage

70
300
0
370

1.5
1.5

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-10b - application
Rehabilitation

110
150
40
300

1.5
1.5
1.5

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 10c - application
Education - Live

20
150
5
175

12
12
12

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 10d - application
SP Education - Dead

75
175
0
250

4.5
4.5

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-10e - application
Game Bird Propagation

35
30
0
65

2.5
2.5

5
10
0
15

1.5
1.5
0

Individuals/Households
Private Sector
State/Local/Tribal
Total

2

36
20
20
76

$20.55
19.53
26.13

250
300
500
1050

$20.55
19.53
26.13

0
1380
0
1380

$20.55
19.53
26.13

0
105
450
0
555

$20.55
19.53
26.13

165
225
60
450

$20.55
19.53
26.13

240
1800
60
2100

$20.55
19.53
26.13

338
788
0
1126

$20.55
19.53

88
75
0
163

$20.55
19.53
26.13

8
15
0
23

$20.55
19.53
26.13

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$1,036
$547
$784

$7,193
$8,202
$19,600

$0
$37,729
$0

$3,021
$12,303
$0

$4,747
$6,152
$2,352

$6,905
$49,212
$2,352

$75
$75
$0

$100
$100
$0

$100
$100
$0

$75
$75
$0

$75
$75
$0

$50
$50
$0

$2,700
$1,500
$0
1

$0
$0
$0
$3,876

2.5

$0
$0
$0
$26,775

1

$0
$0
$0
$35,190

1

$0
$0
$0
$18,870

1.5

$0
$0
$0
$22,950

4

$0
$0
$0
$35,700

4

$0
$0
$0
$51,000

3

$0
$0
$0
$9,945

1

$0
$0
$0
$765

$5,000
$6,000
$0

$0
$69,000
$0

$5,250
$22,500
$0

$8,250
$11,250
$0

$1,000
$7,500
$0

SP

$28.77
$27.34

$28.77
$27.34
$39.20

$9,724
$21,544
$0

$2,532
$2,051
$0

$75
$75
$0

$75
$75
$0

$5,625
$13,125
$0

$2,625
$2,250
$0

SP

$28.77
$27.34
$39.20

$230
$410
$0

$75
$75
$0

$375
$750
$0

3-200- 10f - application
Miscellaneous

20
25
5
50

2.5
2.5
2.5

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 12 - application
Raptor Propagation

700
0
0
700

1.25

5
50
0
55

4
4

850
1050
800
2700

1.75
3.5
3.5

0
100
20
120

5.5
5.5
5.5

1345
0
0
1345

1

895
0
0
895

0.5

0
3
3
6

3.5
3.5
3.5

4
0
0
4

3.25

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-13 - application
Depredation
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-14 - application
Eagle Exhibition
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-15a - application
Eagle Indian Religious
Application & First Order
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-15b - application Eagle
Indian Religious Reorder

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-17 - application
Eagle Falconry
Individuals/Households
Private Sector
State/Local/Tribal
Total

Cost to Govt
($51/hr)

Avg Time (hrs)
per response
for Govt review

Total Annual
Nonhour Burden
Cost

Average
Nonhour Burden
Cost Per
Response

Dollar Value of
Annual Burden
hours

Hourly Labor
Costs including
Benefits

Hourly Labor
Costs

Attachment A

SP

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 11 - application
Falconry

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 16 - application
of Depredating Eagles

Annual Burden
Hours

Completion Time
per Response
(hours)

Annual
Responses

Regulation/
Activity

OMB 1018-0022
BURDEN HOURS, NONHOUR COSTS, AND FEDERAL COSTS

50
63
13
126

$20.55
19.53
26.13

875
0
0
875

$20.55
19.53
26.13

20
200
0
220

$20.55
19.53
26.13

1488
3675
2800
7963

$20.55
19.53
26.13

0
550
110
660

$20.55
19.53
26.13

1345
0
0
1345

$20.55
19.53
26.13

448
0
0
448

$20.55
19.53
26.13

0
11
11
22

$20.55
19.53
26.13

13
0
0
13

$20.55
19.53
26.13

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$1,439
$1,722
$510

$25,174
$0
$0

$575
$5,468
$0

$42,795
$100,475
$109,760

$0
$15,037
$4,312

$38,696
$0
$0

$12,889
$0
$0

$100
$100
$0

$100
$100
$0

$100
$100
$0

$50
$100
$0

$75
$75
$0

$0
$0
$0

$0
$0
$0

$2,000
$2,500
$0
2

$0
$0
$0
$5,100

2

$0
$0
$0
$71,400

2

$0
$0
$0
$5,610

2.5

$0
$0
$0
$344,250

4

$0
$0
$0
$24,480

2

$0
$0
$0
$137,190

0.5

$0
$0
$0
$22,823

2

$0
$0
$0
$612

2

$0
$0
$0
$408

$70,000
$0
$0

$500
$5,000
$0

$42,500
$105,000
$0

$0
$7,500
$0

$0
$0
$0

$0
$0
$0

Take

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$0
$287
$412

$374
$0
$0

$100
$100
$0

$100
$100
$0

$0
$300
$0

$400
$0
$0

3-200- 18 - application Take
of Golden Eagle Nests
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-67 - application
Special State Canada Goose
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-68 - application
Renewal of Permit
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-71 - application Eagle
Take (Disturb)
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 72 - application
Eagle Nest Take
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 71 & 72 - application
Eagle/Nest Take Amendment
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 71 & 72 - application
Eagle Take Programmatic
Permit
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200- 71 & 71 - application
Eagle Programmatic Permit
Amdt.
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-77 - application
Native American Eagle Take
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-78 - application Native
American Eagle Aviary

0
4
0
4

0
0
1
1

6.5

7

1300
2750
1000
5050

1.5
1.5
1.5

100
300
100
500

16
16
16

10
20
20
50

16
16
16

5
20
15
40

6
6
6

0
16
10
26

40
40
40

0
7
3
10

5
0
5
10

20
20

2.25
2.25

0
26
0
26

$20.55
19.53
26.13

0
0
7
7

$20.55
19.53
26.13

1950
4125
1500
7575

$20.55
19.53
26.13

0
1600
4800
1600
8000

$20.55
19.53
26.13

160
320
320
800

$20.55
19.53
26.13

30
120
90
240

$20.55
19.53
26.13

0
640
400
1040

$20.55
19.53
26.13

0
140
60
200

$20.55
19.53
26.13

11
0
11
22

$20.55
19.53
26.13

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$0
$711
$0

$0
$0
$274

$56,102
$112,778
$58,800

$46,032
$131,232
$62,720

$4,603
$8,749
$12,544

$863
$3,281
$3,528

$17,498
$15,680

$0
$3,828
$2,352

$316
$0
$431

$100
$100
$0

$0
$0
$0

$100
$100
$0

$500
$500
$0

$500
$500
$0

$150
$150
$0

$1,000
$1,000
$0

$500
$500
$0

$0
$0
$0

$0
$400
$0

Cost to Govt
($51/hr)

Avg Time (hrs)
per response
for Govt review

Attachment A

Total Annual
Nonhour Burden
Cost

Average
Nonhour Burden
Cost Per
Response

Dollar Value of
Annual Burden
hours

Hourly Labor
Costs including
Benefits

Hourly Labor
Costs

Annual Burden
Hours

Completion Time
per Response
(hours)

Annual
Responses

Regulation/
Activity

OMB 1018-0022
BURDEN HOURS, NONHOUR COSTS, AND FEDERAL COSTS

2

$0
$0
$0
$408

5

$0
$0
$0
$255

1.5

$0
$0
$0
$386,325

20

$0
$0
$0
$510,000

27

$0
$0
$0
$68,850

10

$0
$0
$0
$20,400

102

$0
$0
$0
$135,252

25

$0
$0
$0
$12,750

8

$0
$0
$0
$4,080

$0
$0
$0

$130,000
$275,000
$0

$50,000
$150,000
$0

$5,000
$10,000
$0

$750
$3,000
$0

$0
$16,000
$0

$0
$3,500
$0

$0
$0
$0

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-79 - application
Special Purpose Abatement
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-81 - application
Special Purpose Utility
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-200-82 - application Eagle
Transport
Individuals/Households
Private Sector
State/Local/Tribal
Total

0
0
5
5

5
5
5

0
25
0
25

2.5
2.5
2.5

0
30
0
30

0
5
5
10

4.5

1
1

0
0
25
25

$20.55
19.53
26.13

0
63
0
63

$20.55
19.53
26.13

0
135
0
135

$20.55
19.53
26.13

0
5
5
10

$20.55
19.53
26.13

100
130
350
580

$20.55
19.53
26.13

50
450
0
500

$20.55
19.53
26.13

450
1200
200
1850

$20.55
19.53
26.13

1050
3750
150
4950

$20.55
19.53
26.13

240
1500
0
1740

$20.55
19.53
26.13

18
30
0

$20.55
19.53
26.13

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$0
$0
$980

$0
$1,722
$0

$0
$3,691
$0

$0
$137
$196

$0
$0
$0

$100
$100
$0

$100
$100
$0

$75
$75
$0

$0
$0
$0

Cost to Govt
($51/hr)

Avg Time (hrs)
per response
for Govt review

Attachment A

Total Annual
Nonhour Burden
Cost

Average
Nonhour Burden
Cost Per
Response

Dollar Value of
Annual Burden
hours

Hourly Labor
Costs including
Benefits

Hourly Labor
Costs

Annual Burden
Hours

Completion Time
per Response
(hours)

Annual
Responses

Regulation/
Activity

OMB 1018-0022
BURDEN HOURS, NONHOUR COSTS, AND FEDERAL COSTS

6

$0
$0
$0
$1,530

2

$0
$0
$0
$2,550

2

$0
$0
$0
$3,060

1

$0
$0
$0
$510

1

$0
$0
$0
$29,580

0.25

$0
$0
$0
$12,750

0.25

$0
$0
$0
$23,588

0.5

$0
$0
$0
$42,075

0.5

$0
$0
$0
$29,580

$0
$2,500
$0

$0
$3,000
$0

$0
$375
$0

REPORTS
3-202-1 - report - Scientific
collecting
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202-2 - report Waterfowl
Sale and Disposal
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202-3 - report - Special
Purpose Salvage
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202-4- report Rehabilitation
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202-5- report - Possession
for Education
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 6 - report - Special
Purpose Game Bird
Individuals/Households
Private Sector
State/Local/Tribal

100
130
350
580

1
1
1

100
900
0
1000

0.5
0.5
0.5

450
1200
200
1850

1
1
1

350
1250
50
1650

3
3
3

160
1000
0
1160

1.5
1.5

35
60
0

0.5
0.5
0.5

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$2,877
$3,554
$13,720

$1,439
$12,303
$0

$12,947
$32,808
$7,840

$30,209
$102,525
$5,880

$6,905
$41,010
$0

$518
$820
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

Total
3-202-7 - report - Special
Purpose Miscellaneous
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 8 - report - Raptor
Propagation
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 9 - report Depredation
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 10 - report - Special
State Canada Goose
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 11 - report Eagle
Depredation
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 12 - report Acquisition and Transfer
Request
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 13 - report - Eagle
Exhibition
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 14 - report - Native
American Eagle Aviary
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 15 - report - Eagle
Take Monitoring & Reporting
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 16 - report - Eagle
Nest Take & Monitoring

95

48

20
75
30
125

0.5
0.5
0.5

125
300
0
425

1
1
1

765
825
630
2220

1
1
1

0
0
18
18

1
1
1

5
30
5
40

1
1
1

200
500
100
800

1.5
1.5
1.5

0
500
200
700

1
1
1

0
0
10
10

0.5
0.5
0.5

150
520
450
1120

30
30
30

10
38
15
63

$20.55
19.53
26.13

125
300
0
425

$20.55
19.53
26.13

765
825
630
2220

$20.55
19.53
26.13

0
0
18
18

$20.55
19.53
26.13

5
30
5
40

$20.55
19.53
26.13

300
750
150
1200

$20.55
19.53
26.13

0
500
200
700

$20.55
19.53
26.13

0
0
5
5

$20.55
19.53
26.13

4500
15600
13500
33600

$20.55
19.53
26.13

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$288
$1,039
$588

$3,596
$8,202
$0

$22,009
$22,556
$24,696

$0
$0
$706

$144
$820
$196

$8,631
$20,505
$5,880

$0
$13,670
$7,840

$0
$0
$196

$129,465
$426,504
$529,200

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

Cost to Govt
($51/hr)

Avg Time (hrs)
per response
for Govt review

Attachment A

Total Annual
Nonhour Burden
Cost

Average
Nonhour Burden
Cost Per
Response

Dollar Value of
Annual Burden
hours

Hourly Labor
Costs including
Benefits

Hourly Labor
Costs

Annual Burden
Hours

Completion Time
per Response
(hours)

Annual
Responses

Regulation/
Activity

OMB 1018-0022
BURDEN HOURS, NONHOUR COSTS, AND FEDERAL COSTS

0.25

$1,211

0.5

$0
$0
$0
$3,188

0.3

$0
$0
$0
$6,503

0.75

$0
$0
$0
$84,915

1.5

$0
$0
$0
$1,377

0.3

$0
$0
$0
$612

0.5

$0
$0
$0
$20,400

0.5

$0
$0
$0
$17,850

0.5

$0
$0
$0
$255

0.5

$0
$0
$0
$28,560

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

Individuals/Households
Private Sector
State/Local/Tribal
Total
3-202- 17 - report - Special
Purpose Utility
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-186 - report - Notice of
Transfer & Sale of Migratory
Waterfowl
Individuals/Households
Private Sector
State/Local/Tribal
Total
3-186a - report - Migratory
Bird Acquisition & Disposition
Individuals/Households
Private Sector
State/Local/Tribal
Total
Grand Total

6
17
17
40

16
16
16

0
100
0
100

2
2
2

300
12600
0
12900

0.25
0.25

18640
0
0
18640
57,260

0.25
0.25
0.25

96
272
272
640

$20.55
19.53
26.13

0
200
0
200

$20.55
19.53
26.13

75
3150
0
3225

$20.55
19.53
26.13

4660
0
0
4660
93402

$20.55
19.53
26.13

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$28.77
$27.34
$39.20

$2,762
$7,436
$10,662

$0
$5,468
$0

$2,158
$86,121
$0

$134,068
$0
$0
$2,858,354
$2,858,354

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0

$0
$0
$0
0.5

$0
$0
$0
$1,020

0.5

$0
$0
$0
$2,550

0.17

$0
$0
$0
$111,843

$0
$0
$0

$0
$0
$0

$0
$0
$0
0.25
$1,049,925

Cost to Govt
($51/hr)

Avg Time (hrs)
per response
for Govt review

Attachment A

Total Annual
Nonhour Burden
Cost

Average
Nonhour Burden
Cost Per
Response

Dollar Value of
Annual Burden
hours

Hourly Labor
Costs including
Benefits

Hourly Labor
Costs

Annual Burden
Hours

Completion Time
per Response
(hours)

Annual
Responses

Regulation/
Activity

OMB 1018-0022
BURDEN HOURS, NONHOUR COSTS, AND FEDERAL COSTS

$0
$0
$0
$237,660
$2,618,429