Request for comments on ICR

Date: April 24, 2013
To:

Marine Mammal Protection Act (MMPA) Authorization Holder

Re:

Request for Information on Your MMPA Incidental Take Authorization

Hello,
The Paperwork Reduction Act of 1995 (PRA) prevents federal agencies from placing undue
burdens on the public when asking for information. To comply with the PRA, we would seek public
comment, through a 60-day Federal Register notice, on the information collection requirements for
a Marine Mammal Protection Act Incidental Take Authorization (ITA).
As a part of this process we must:
•

estimate an applicant’s paperwork and response burden (i.e., time and cost) for an Incidental
Harassment Authorization (IHA) or a Letter of Authorization (LOA) application; and

•

seek input on the clarity of our instructions, the accuracy of previous reported estimates, and
the usefulness of the information collected pre- and post-activity.

We’ll present a summary of this information in the Federal Register notice. If you would like to
submit estimates for time and cost and provide your opinion on our ITA process, please fill out the
enclosed table and answer three quick questions. f a particular activity in the table does not apply to
your situation, please note N/A.
Your organization is not required to complete this survey, but we appreciate your willingness to do
so. Once you’ve finished the survey, please return this table to me at [email protected] by
Friday, May 3, 2013. Also, if you have any questions, feel free to call me at 301.427-8415.
Thank you.

Jeannine Cody

2013 Survey for NMFS, Office of Protected Resources, Incidental Take Program’s Applicants on
Burden of Information Collection Requirements under the Paperwork Reduction Act.

Activity (Please note N/A, if not applicable.)
IHA Application Preparation
Initial LOA Application Preparation for 5-year Regulations
Subsequent Annual/Bi-Annual LOA Application
Environmental Assessment
Preparation of an Interim Report for an IHA
Preparation of a Draft Annual Report for an IHA or LOA
Preparation of a Final Annual Report IHA or LOA
Preparation of a LOA Draft Comprehensive Report
Preparation of a LOA Final Comprehensive Report
Activity
Equipment (computers, software)
Copying / Printing
Faxing / Phone Calls
Postage / Shipping

Time to Complete (Hours)

Estimated Cost (Dollars)

Question 1:
On a scale from 1 to 10, how clear are the instructions for submitting and completing an Incidental
Take Authorization? (0 = Not Clear; 10=Extremely Clear)
Brief Answer:

Question 2:
How accurate are the burden estimates shown in Attachment #1 (Page 3) for your organization?
(e.g., much lower than my estimate, very close to my estimate, much higher than my estimate)
Brief Answer:

Question 3:
What are your thoughts on the utility on the data that we collect from your organization?
Brief Answer:

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Attachment # 1 – Results from the 2010 Survey for NMFS, Office of Protected Resources, Incidental Take
Program’s Applicants on Burden of Information Collection Requirements under the Paperwork Reduction Act.

Table 1 – 2010 Survey Results of Time Spent on ITA Applications and Reports
Information Collection Activity
IHA Application
IHA Interim Draft Report
IHA Draft Annual Report
IHA Final Annual Report
LOA - Initial Application Preparation for Regulations
LOA - Annual LOA Application
LOA - Draft Annual Report
LOA - Final Annual Report
LOA - LOA Draft Comprehensive Report
LOA - LOA Final Comprehensive Report

Estimated Length of Time to Prepare
Hours
Days
399
50
310
39
422
52
163
20
1,100
138
70
9
220
28
65
8
625
78
300
38

* We calculated business days as 8-hour increments.

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