Supporting Statement A for 
Paperwork Reduction Act Submission

Horseshoe Crab Tagging Program
OMB Control Number 1018-0127

Terms of Clearance.  None.

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

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

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

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

In 1998, the Commission released the first fishery management plan for horseshoe crabs (Fishery Management Report No. 32).  This tagging study has been used to address some of the research and data needs in the fishery management plan, including determining beach fidelity, spawning frequency, timing of migrations, and population boundaries along the Atlantic Coast to determine management units.  

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

2.	Indicate how, by whom, and for what purpose the information is to be used.  

Since 1999, the tagging program has provided essential information to fishery managers about the life history, population size, and migratory patterns of horseshoe crabs on the Atlantic coast.  State and Federal fishery managers use the information to more effectively manage crab populations to sustain the dependent resources, including the commercial fishery, biomedical industry, and ecologically dependent bird species.  Researchers also use tagging information to describe important life history characteristics of horseshoe crabs.

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

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

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

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

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

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

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

•	Capture method:  Hand collection or collection in some kind of fishing gear.  To better protect the crab population, we need to know to which types of fishing gear crabs are most susceptible.

•	Capture location:  Body of water, beach or location and nearest city.  We need this information so that we can determine migratory patterns and coastal population structure of crabs.

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

•	Comments.  Miscellaneous information provided by reporter.

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

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

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

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

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

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

•	Capture site.  

•	Latitude (optional).

•	Longitude (optional).

•	Waterbody.

•	State. 

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

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

3.	Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology; e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection.  Also describe any consideration of using information technology to reduce burden [and specifically how this collection meets GPEA requirements.].

All tags are printed with a toll-free phone number and a mailing address.  The public may report finding tagged crabs using either of those methods or by completing an online form at the Maryland Fishery Resources Office (MRFO) website.  We will advertise the availability of the online form at beaches where tagged crabs are frequently encountered and also in reward package mailings to the public.  We estimate that 85 percent of the public who find tagged crabs will report via the toll free number, 15 percent via online form, and less than 1 percent via mail.  We expect 80 percent of the tagging agencies to submit electronic files of tagging data by email and 20 percent to send completed paper datasheets to the MRFO.  At this time, the results of the information collection are not available to the public on the internet.  There are no immediate plans to make the information available to the public on the internet, however cooperating individuals and agencies receive information about the program.  Summary reports can be provided to individuals with a request to the tagging program coordinator.  Individuals who provide information on a horseshoe crab tag are sent a package containing information on the individual crab they found.  Agencies that supply tagging data are sent recapture data annually from the tags that they had released.  
4.	Describe efforts to identify duplication.  

Atlantic coast States manage horseshoe crabs under the Atlantic States Marine Fisheries Commission Fishery Management Plan for Horseshoe Crabs.  The Commission encourages all States to use USFWS tags in order to have a coordinated coastwide tagging effort.  At this time, we are not aware of any horseshoe crab tagging programs occurring in our core area of the Atlantic coast from Georgia to Massachusetts.  Any new tagging programs are encouraged to participate in the U.S. Fish and Wildlife Service sponsored program to eliminate any duplication of effort and to increase coastwide coordination.

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

The collection does not significantly impact small entities.  

6.	Describe the consequence to Federal program or policy activities if the collection were not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

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

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.

There are no circumstances that require us to collect the information in a manner inconsistent with OMB guidelines.

8.	If applicable, provide the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB.  Summarize public comments received in response to that notice (or in response to a PRA statement) and describe actions taken by the agency in response to these comments.  

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.  

On September 26, 2011, we published in the Federal Register (76 FR 59422) a notice of our intent to renew our information collection authority from OMB.  In that notice, we solicited comments for 60 days, ending on November 25, 2011.  We received comments from 10 individuals/organizations.  

•	Comment 1- appreciated the opportunity to tag horseshoe crabs and suggested that public outreach is an important component of the program and increased public outreach would be useful.  
•	Comment 2 - public outreach component has been very useful and the tagging program has benefited horseshoe crab management and increased public awareness of management issues.  
•	Comment 3 - both the scientific merit and public outreach components of the program have been very useful.  The tagging program has benefited horseshoe crab management and increased public awareness of management issues.  
•	Comment 4 - discussed the scientific merit of the tagging program and that it has been very useful.  The tagging program has benefited horseshoe crab management and has had impacts on management of associated shorebird species whose population levels are of concern.  The commenter had concerns on the effort of tag recoveries, and suggested that we provide higher incentives to commercial fishermen to report crab tags, increase efforts on spawning beaches to recover tags, record time searching for tags to determine catch-per-unit-effort, that on-line reporting can be done in a batch system, and that we increase efforts to collect tag data from commercial fishermen.  While we recognize that all of these suggestions would make a stronger program with more significant scientific data, some come with substantial cost.  At this time we do not have any additional funds to provide increased incentives to fishermen, increase tag recovery efforts on beaches (done by our cooperators at this time), or increase efforts to solicit tag data from commercial fishermen.  Through our cooperators in the future, we can attempt to get an estimate of catch-per-unit-effort and we will discuss this issue with the Atlantic States Marine Fisheries Commission to determine if those data would be useful.  We will also explore providing a batch-type data entry program on our website to report recaptured tags.  We will explore collecting catch-per-unit-effort and online batch reporting in the future.
•	Comment 5 - supportive of the information collection, and commented that the scientific data provided by the program has been very useful to for horseshoe crab management.  Information was collected efficiently and the burden estimates were accurate. 
•	Comment 6 - opposed the use of horseshoe crabs by biomedical companies and proposed a ban on the use of horseshoe crabs for any purpose. 
•	Comment 7 - tagging program is not necessary and the data generated by the program is not useful. Also opposed the commercial harvest of horseshoe crabs and the use of horseshoe crabs by biomedical companies.  The commenter proposed a ban on the use of horseshoe crabs for any purpose. 
•	Comment 8 - discussed the scientific merit of the tagging program and that it has been very useful for horseshoe crab management purposes.  Suggested that the Fish and Wildlife Service increase efforts in resighting tagged crabs outside the Delaware Bay area. While we recognize that increasing effort for resighting tagged crabs would increase the quality of the scientific data, there is substantial cost associated with increasing that effort.  At this time, we do not have any additional funds to increase tag recovery efforts on beaches (done by our cooperators at this time).  We will encourage our cooperators to increase efforts in tag recovery outside the Delaware Bay area.  The commenter also suggested we develop an application for smart phones in addition to the online reporting system that we currently offer.  We will explore the development of an app for smart phones to provide another method for tag reporting.  
•	Comment 9 - discussed the scientific merit of the tagging program and that it has been very useful to horseshoe crab and shorebird management (whose population levels are of concern).  The commenter suggested that we increase efforts on spawning beaches of Maryland and Virginia to recover tags, record time searching for tags to determine catch-per-unit-effort, and use formal models to determine survival of bled crabs from the Lysate industry.  As with previous comments, we will encourage our cooperators to increase tag recovery efforts on the Maryland and Virginia beaches; however, without increased funding, we will not be able to increase tag recovery efforts without the assistance of cooperators.  Some formal studies are being done by our cooperators using the Service tagging program to evaluate impacts of both tagging and of the Lysate bleeding programs.  We will continue to support the tagging programs that are evaluating crab survival.  The commenter also suggested that we should facilitate batch reporting of crabs on the phone and to encourage tag reporting by commercial fishermen.  At this time we do not have any additional funds to provide increased incentives to fishermen, increase tag recovery efforts on beaches (done by our cooperators at this time), or increase efforts to solicit tag data from commercial fishermen.  We will work with our cooperators to attempt to get better distribution of tag recovery efforts. 
•	Comment 10 - similar in nature to Comments 4 and 9.

We did not make any changes to our information collection requirements based on the above comments.

Yearly contact is made with individuals/organizations who tag crabs (FWS Form 3-2311).  For the renewal process, we contacted the following individuals in July 2011 to verify that tagging instructions are easy to understand.  They agreed that our estimate of time burden was accurate and instructions were straightforward.

Drs. Jennifer Mattei and Mark Beekey, Sacred Heart University, 203-365-7577
Dr. Matthew Sclafani, Cornell University, 631-727-7850 ext. 377 

We also solicited comments in July 2011 from the following individuals who reported tagged crabs (FWS Form 3-2310).  They stated that the questions were easy to understand and agreed that the completion time for FWS Form 3-2310 should be reduced to 5 minutes..

Zach Jasensky, 78 Gros Rd., Bethlehem, CT  06751, 203-232-2441
Allen MacDonald, 688 Quaker Hill Rd., Magnolia, DE  19962, 302-359-9148

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

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

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

We do not provide any assurance of confidentiality.

11.	Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.  

We do not ask questions of a sensitive nature.

12.	Provide estimates of the hour burden of the collection of information.  

We estimate there will be 1,898 annual burden hours associated with this information collection:

Activity	Number of Respondents	Number of annual responses 	Average time required per response	Total annual burden hours	
FWS Form 3-2310 – recapture report	950	2,250 (avg 1 to 40 per respondent)	5 minutes	188	
FWS Form 3-2311 – tagging report	18	18	95 hours*	1,710	
Totals	968	2,268		1,898 	

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

We estimate the dollar value of the annual burden hours to be $59,774.76.  Using the National Compensation Survey:  Occupational Wages in the United States, September 2011, published by the U.S. Bureau of Labor Statistics (USDL 11-1718, December 7, 2011, http://www.bls.gov/news.release/pdf/ecec.pdf), we estimated wages and calculated benefits as follows:

•	Individuals.  Average hourly wage is $20.91 multiplied by 1.4 to account for benefits ($29.27).  
•	
Private sector.  Average hourly wage is $19.91 multiplied by 1.4 to account for benefits ($27.87).  
•	States/tribal/local governments.  Average hourly wage is $26.57 multiplied by 1.5 to account for benefits ($39.86).  

Respondent	No of Responses	Time per response	Total Annual Burden Hours*	$ Value of Burden Hour	Total $ Value of Annual Burden Hours	
Individuals (Form 3-2310)	2,250	5 min	188	$29.27	$  5,502.76	
Private sector (Form 3-2311)	       12	95 hrs	1,140	$27.87	31,771.80	
State/Local/Tribal Govts (Form 3-2311)	       6	95 hrs	570	$39.86	22,720.20	
Total	2,268		1,898		$59,774.76	

13.	Provide an estimate of the total annual [nonhour] cost burden to respondents or recordkeepers resulting from the collection of information.  

There is no nonhour cost burden for individuals.  They can report tags via a toll-free phone number or online at the MFRO website.  We provide tags to agencies that use less than 500 annually.  Tagging does result in some costs to participants, depending on the number of tagged crabs they release.  However, agencies would tag crabs and have the same costs if we did not coordinate the program.

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

We estimate the total annual cost to the Federal Government to be $46,884 as outlined below.  

Salary Costs
Federal
Staff	Activity	Hourly Rate	Hourly Rate
(including)
Benefits)*	Hours 	Total
Cost	
GS-11/7
Fishery
Biologist	•	Coordinate with tagging agencies
•	Send out tagging materials
•	Key punch paper tagging data and recapture reports and format electronic data
•	Collect recapture reports via telephone
•	Assemble reward packages
•	Computer programming
•	Data management
•	Provide data to tagging agencies	$35.92	$53.88	300	$16,164	
GS-3/1
Biological
Technician	•	Collect recapture reports via telephone
•	Key punch paper tagging data and recapture reports and format electronic data	$13.00	$19.50	 480	    9,360	
				780	$25,524	
*For salary costs, we used the Office of Personnel Management Salary Table 2012-DCB to determine the hourly wage and multiplied by 1.5 to account for benefits.  We calculated benefits were calculated in accordance with BLS news release USDL 11-1718, December 7, 2011, Employer Costs for Employee Compensation-September 2011 (http://www.bls.gov/news.release/pdf/ecec.pdf). 

Nonsalary Costs 

Activity	Cost	
Tags	$ 6,380	
Printing reward packages	      900	
Reward Incentive (pewter crab pin)	   7,200	
Mail costs, postage	$ 6,880	
TOTAL	$ 21,360	

15.	Explain the reasons for any program changes or adjustments in hour or cost burden.

We are reporting 2,268 annual responses totaling 1,898 annual burden hours for this information collection.  This is an adjustment net increase of 758 annual responses and 918 burden hours from our last submission.  Demand for horseshoe crabs has increased dramatically since 2008.  Prior to 2008, the FWS was providing an average of less than 10,000 tags to cooperating agencies to be used in horseshoe crab tagging.  The addition of several new cooperating agencies since 2008 has increased the average number of horseshoe crab tags released annually to 25,000.  Based on outreach conducted, we reduced our reporting time for FWS Form 3-2310 from 10 minutes to 5 minutes, which decreased burden hours from 250 to 188.  The increase in number of tags released has significantly increased our total burden hours for FWS Form 3-2311 from 730 to 1,710.  

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

The Fish and Wildlife Service does not publish information regarding the horseshoe crab tagging program.  Upon request, we release data to tagging agencies and fishery management agencies.  The respective tagging agencies may publish portions of the tagging and recapture data to address specific research questions.  

17.	If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We will display the OMB control number and expiration date on the forms.

18.  Explain each exception to the certification statement. 

There are no exceptions to the certification statement.