Supporting Statement A for 
Paperwork Reduction Act Submission

Annual Certification of Hunting and Sport Fishing Licenses Issued
50 CFR 80, Subpart D

OMB Control Number 1018-0007

Terms of Clearance.  None

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

The Federal Aid in Wildlife Restoration Act (16 U.S.C. 669 et seq.) and the Federal Aid in Sport Fish Restoration Act (16 U.S.C. 777 et seq. except 777e-1) provide Federal assistance to the States for management and restoration of fish and wildlife.  These Acts and our regulations at 50 CFR 80, Subpart D--Certification of License Holders, require that States and territories annually certify hunting and sport fishing license sales in order for the Fish and Wildlife Service (we, Service) to apportion funds under formulas provided in the Acts.

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

Annually, States, the Commonwealths of Puerto Rico and the Northern Mariana Islands, the District of Columbia, and the territories of Guam, the U.S. Virgin Islands, and American Samoa (State grantees) complete FWS Form 3-154b to indicate the total hunting and fishing licenses issued and the dollar amounts involved.  This summary includes all paid and nonpaid licenses, tags, stamps, and permits issued for hunting (both firearm and bow) and for sport or recreational fishing.  

Grantees then take the data from FWS Form 3-154b, eliminate all duplicates, and use FWS Form 3-154a to certify the number of paid hunting and fishing license holders.

Our Division of Administration and Information Management uses this information to apportion funds to State fish and wildlife agencies under the Acts.  During Fiscal Year 2012, we apportioned $371,274,752 under the Wildlife Restoration Program and $349,763,692 under the Sport Fish Restoration Program.  

States, nonprofit organizations, and commercial entities use the information to track statistics and identify economic and participatory trends and anomalies.  The information is available to the public on the Wildlife and Sport Fish Restoration Program Internet site at http://wsfrprograms.fws.gov/.

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.].

FWS Forms 3-154a and 3-155b are available online at http://www.fws.gov/forms/ in a fillable format.  Respondents can complete the forms online, and then must mail or email the form to us.  Until the collections for the FY 2013 apportionments, grantees could also submit electronically through iFAIMS the Federal Aid Information Management System Internet site.  These forms were fillable, fileable and signable.  Historically, we have received approximately 50% of the information electronically.  The iFAIMS system has been decommissioned after the collection of the information for the FY 2013 apportionment.  We expect to have our new electronic submission site up and running by the time the next certification for FY 2014 is due.  We expect the new system to have the same functionality as iFAIMS for collecting license certification information.  The new system will also have some reporting capability.  We will be seeking OMB approval for the new system through a separate information collection request.

4.	Describe efforts to identify duplication.  

There are no other forms that collect similar information.

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

We collect the data from State grantees only; therefore, there is no impact on 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.

Failure to submit these certifications may result in grant funds being partially or totally withheld pending receipt of this certification.

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 special circumstances that require us to collect this 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 August 29, 2012, we published in the Federal Register (77 FR 52344) a notice requesting public comment on this information collection.  The comment period ended on October 29, 2012.  We received one comment in response to this notice.  The respondent objected to the Wildlife Restoration Act, but did not address the information collection requirements.  We did not make any changes to our requirements.  Additionally, we conducted a public outreach and solicited input from:

	Melinda Sturgess-Streich, State of Oklahoma, msturgess@odwc.state.ok.us
	Gary Armstrong, State of Indiana, garmstrong@dnr.in.gov
	Stacey Norris, State of Alabama, Stacey.Norris@dcnr.alabama.gov
	Kris McCarthy, State of Massachusetts, kris.mccarthy@state.ma.us
	Kim Molesworth, State of North Dakota, kmolesworth@nd.gov

We asked:

•	Is it necessary to collect the information, and will the information have practical purpose;
•	Is our estimate of the burden for this collection of information accurate; 
•	In what ways could we enhance the quality, utility, and clarity of the information to be collected; and 
•	In what ways could we minimize the burden of the collection of information on respondents? 

All of those we contacted believed that the information was necessary and that it has a practical purpose.  Three of the respondents said that the estimated time was adequate or more than enough.  One of the respondents said it took a little more time to collect the information for the 3-154a, but the estimate for the 3-154b was adequate.  One of the respondents reported that the 3-154a and the 3-154b both took more time, but said that the estimate would be accurate for them when they implement their automated system.  Due to these responses we feel our estimates are reasonable.  There were no suggestions on how to enhance the quality, utility, and clarity of the information to be collected.  As for ways to minimize the burden, two respondents reported we should revise 50 CFR to clarify which licenses should be counted.  These comments do not impact the forms, but we will review the guidance in the regulations.  One respondent suggested that we “get the on-line submission process working again.”  As mentioned in item 3, we expect to have our new electronic submission site up and running by the time the next certification for FY 2014 is due.  

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

We do not provide any gifts or payments to respondents.

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

There is no assurance of confidentiality.  Once submitted, this form becomes public information and is not protected under the Privacy Act. 

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.  

None of the information collected on FWS Forms 3-154a and 3-154b is sensitive.

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

We estimate that 56 respondents will submit 112 annual responses totaling 1,792 burden hours.

The hour burden associated with the information collection varies with each respondent and depends significantly on whether or not the State has an automated process for issuing hunting and fishing licenses.  We believe our estimates are reasonable and represent an average time to complete the forms.  We based the hourly wage rate on the Employer Costs for Employee Compensation News Release, USDL 12-2404, December 11, 2012.  We used the professional and related category from Table 4 for State and local government workers, which stated an hourly rate of $33.98.  To calculate benefits, we multiplied the hourly rate by 1.5.  The hourly rate including benefits is $50.97.  The total dollar value of the annual burden hours is $91,338.

Table 12.1 – Annual Burden Estimates

ACTIVITY	TOTAL ANNUAL RESPONSES	COMPLETION TIME PER RESPONSE	ANNUAL BURDEN
HOURS	$ VALUE OF ANNUAL BURDEN HOURS (rounded)	
FWS Form 3-154a	56	12 hours	  672 	$34,252	
FWS Form 3-154b	56	20 hours	1,120 	$57,086	
TOTALS	112 		1,792 	$91,338	

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 to respondents; there are no filing fees.

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

We estimate that the total annual cost to Federal Government for processing these forms is $2,031.  We used the hourly rate of a Washington area GS-13 step 5 (from SALARY TABLE 2012-DCB at http://www.opm.gov/oca/12tables/pdf/dcb_h.pdf).  To calculate benefits, we multiplied the hourly rate by 1.5.  We will receive 112 responses annually, each of which takes approximately 15 minutes to process.

Table 14.1 – Fish and Wildlife Salary/Benefits

Action	Position and Grade	Hourly Rate	Hourly Rate including Benefits	Total Annual Hours	Annual Cost
(rounded)	
Review and process  forms	Accountant
GS 13/5	48.35	72.53	28	    2,031	
Total	$  2,031	

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

There are no program changes or adjustments.  

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

The information collected is for grant administration purposes, and we do not formally publish the results.  However, we do make the license data available on the Wildlife and Sport Fish Restoration Program Web site for use by the States and others.  

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 FWS Forms 3-154a and 3-154b.

18.  Explain each exception to the certification statement. 

There are no exceptions to the certification statement.