Supporting Statement A for 
Paperwork Reduction Act Submission

Hunting and Fishing Application Forms and
Activity Reports for National Wildlife Refuges
50 CFR 25.41, 25.43, 25.51, 26.32, 26.33, 27.42, 30.11, 31.15, 32.1 to 32.72

OMB Control Number 1018-0140

Terms of Clearance.  None

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

The National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee), as amended (Administration Act), and the Refuge Recreation Act of 1962 (16 U.S.C. 460k-460k-4) (Recreation Act) govern the administration and uses of national wildlife refuges and wetland management districts.  The Administration Act consolidated all the different refuge areas into a single "Refuge System."  It also authorizes us to permit public uses, including hunting and fishing, on lands of the Refuge System when we find that the activity is compatible and appropriate with the purpose for which the refuge was established.  The Recreation Act allows the use of refuges for public recreation when the use is not inconsistent or does not interfere with the primary purpose(s) of the refuge.  

We make provisions in our general refuge regulations (50 CFR 25.41, 25.43, 25.51, 26.32, 26.33, 27.42, 30.11, 31.15, 32.1 to 32.72) for public entry for specialized purposes, including hunting and fishing.  These regulations provide the authorities and procedures for allowing hunting and fishing on national wildlife refuges and wetland management districts outside the State of Alaska. We collect the information to assist us in administering these programs in accordance with statutory authorities that require that recreational uses be compatible with the primary purposes for which the areas were established. .

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

Many refuges offer hunting and fishing activities without collecting any information. Those refuges that do collect hunter and angler information do so seasonally, usually once a year at the beginning of the hunting or fishing season. Some refuges may elect to collect the identical information via a nonform format (letter, email, or through discussions in person or over the phone).  Some refuges provide the form electronically over the internet. In some cases, because of high demand and limited resources, we often provide hunt opportunities by lottery, based on dates, locations, or type of hunt.  We do not make the information we collect available to the public, except perhaps for final season summaries of the information.

We have made the following minor changes to the forms based on comments from our outreach:

•	On each of the application forms, we added a longer signature line for the guardian to print and sign.  
•	On each form, we added language in the Notice to state: “It is our policy not to use your name or email for any other purpose."

Hunting Applications/Permits

We have five forms for our national wildlife refuges to use for hunting applications.  Not all species are hunted at each refuge, and some refuges are open to fishing while others are not.  To avoid confusion to hunters and to simplify the process, we have separate applications for refuges to use depending on what opportunities are available.  At some refuges, the forms may also serve as hunting permits.  
•	FWS Form 3-2354 (Quota Deer Hunt Application).
•	FWS Form 3-2355 (Waterfowl Lottery Application).
•	FWS Form 3-2356 (Big Game Hunt Application).
•	FWS Form 3-2357 (Migratory Bird Hunt Application).
•	FWS Form 3-2358 (Fishing/Shrimping/Crabbing Application)

We collect information from individuals seeking hunting and fishing experiences.  We ask for the following information: 

•	Name of the refuge:  Determines what field station will receive and process the information. 
•	Date of application:  We often have application deadlines and this information helps staff determine the order in which applications were received. It also ensures that the information is current.  
•	Applicant information:  We collect name, address, phone number, and email so we can contact the applicant/permittee either during the application process or after receiving a permit. 
•	Hunt Date:  We ask hunters for their preferences for hunt dates.
•	Hunt Location:  We ask hunters for their preferences for hunt units, areas, or blinds. 
•	Hunt methods:  Some refuges hold multiple types of hunts, i.e. archery, shotguns, primitive weapons, etc.  We ask for this information to identify which opportunity a hunter is applying for. 
•	Special hunts:  Some refuges hold special hunts for youth, hunters who are disabled, or other underserved populations.  We ask hunters to identify if they are applying for these special hunts. For youth hunts, we ask for the age of the hunter at the time of the hunt. 
•	Species:  Some refuges allow only certain species, such as moose, elk, or bighorn sheep to be hunted.  We ask hunters to identify which species hunt they are applying for. 
•	Activity: On fishing permits, we ask what type of activity (crabbing, shrimping, etc.) is being applied for. 
•	Signature and date:  To confirm that the applicant understands the terms and conditions of the permit. 

Harvest/Fishing Activity Reports

We have four activity reports, depending on the species.  We ask users to report on their success after their experience so that we can evaluate hunt quality and resource impacts.  We use the following activity reports, which we distribute during appropriate seasons, as determined by State or Federal regulations: 

•	FWS Form 3-2359  (Big Game Harvest Report).
•	FWS Form 3-2360  (Fishing Report).
•	FWS Form 3-2361 (Migratory Bird Hunt Report).
•	FWS Form 3-2362  (Upland/Small Game/Furbearer Report).

We collect the following information:

•	Name of refuge and location:  We ask this to track responses by location, which is important when we manage more than one refuge or activity area from one office. 
•	Date:  We ask when the hunter/angler participated in the activity.  This helps us identify use trends so we have resources available. 
•	Hours/Time in/out:  We ask this to determine how long the hunter/angler participated in the activity.  We also use this to track use so we can allocate resources appropriately.
•	Name, City, State:  We ask for a name so we can identify the user.  We ask for residence information to help establish use patterns (if users are local or traveling).  
•	Number harvested/caught based on species:  
•	Species harvested/caught:  We ask this to determine the impacts on wildlife/fish populations, relative success, and quality of experience. 
Comments:  We provide hunters/anglers an opportunity for comments, recommendations, and information for refuge staff.

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.].

The hunting and fishing application forms and report forms are available online in a fillable format.  Most refuges use postmarks to determine eligibility deadlines; therefore, we expect that most will require users to fill out the form and return it by mail. In some cases, the application and permit are on the same form, so review and approval by a refuge official is necessary. Individuals can return activity reports by email, mail, fax, or drop box.  A few refuges with complex hunting programs prefer to use a third party online permit provider.  

4.	Describe efforts to identify duplication.  

There is no duplication with other information collection activities.  The information is specific to the applicant and the use or activity and is not available from any other source.  We limit the information requested to the minimum necessary to establish eligibility, resource protection, and to demonstrate the applicants are aware of information they need to know to participate safely and within refuge regulations.

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

This collection of information affects only individuals participating in hunting and fishing opportunities on national wildlife refuges.  Commercial guides for hunting and fishing are administered through Special Use Permits (FWS Form 3-1383-R, 3-1383-C, and 3-1383-G), which are approved under OMB Control No. 1018-0102.

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.

Without the information requested in the hunting and fishing applications, we would be unable to effectively manage and implement hunting and fishing programs on refuges. Refuges often have more potential hunters and anglers interested in opportunities that space and resources allow.  Using a quota or lottery system is the only fair way to administer these programs.  In other circumstances, permit applications allow refuge staff to identify use trends, determine needs, and enhance public safety.  Harvest/creel reports allow refuge staff to determine hunter/angler success, evaluate resource impacts, and improve customer service as use trends are identified.  Information is usually collected on either an as-needed basis (one-time or one-season event) or an annual basis. 

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.

No special circumstances exist 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 February 2, 2015, we published a notice in the Federal Register (80 FR 5572) announcing our intent to request that OMB approve this information collection.  We solicited public comment for 60 days, ending on April 2, 2015.  We received one comment in response to this notice.  The commenter opposed the issuance of any hunting permits, but did not address the information collection requirements. We did not make any changes to our requirements.

In addition to the Federal Register notice, we contacted the following individuals involved in State hunting and fishing programs to obtain their views on the clarity of instructions, length of time to make application, burden hours, etc.:

Tim Keough
Accela (Online Permit Provider)
tkeough@accela.com	John Long 
Local Resident
Starkville, MS	
Christian Barefoot
Local Resident
Louisville, MS	Unidentified 
Local Resident
Brooksville, MS	

Based on their input, minor revisions to the forms were made. One respondent suggested adding language to clarify that email addresses will be used for ‘official purposes’ only, as well as adding a second line above the signature lines for the printed name. There were no comments on costs and burden hours. The maximum amount of time to fill out an application is still 30 minutes. 

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. 

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 that 789,800 respondents will each complete a hunting application and/or a hunting/fishing activity report each year.  The total annual burden for this information collection is 264,025 hours.  We have included nonform information collection in these burden estimates.

•	Applications.  We estimate that on the 335 national wildlife refuges with hunting and 271 refuges with fishing programs, we will receive 266,300 application forms each year.  We estimate that each form will take 30 minutes to complete for a total of 133,150 annual burden hours.

•	Hunting/Fishing Activity Reports.  We estimate that 557,000 hunters and anglers will fill out activity reports each year.  Each form will take approximately 15 minutes to complete for a total of 130,875 annual burden hours.  

We estimate the total dollar value of the burden hours for this collection to be $8,372,233 ($4,222,187 for applications and $4,150,046 for activity reports).

Hunters and anglers represent a variety of professions and income levels. We used the BLS Bulletin USDL-15-0386 released March 11, 2015 (http://www.bls.gov/news.release/pdf/ecec.pdf) to estimate hourly wages and calculate benefits. Table 1 lists an hourly wage of $22.65 for all workers. We multiplied the hourly rate by 1.4 to account for benefits, resulting in an hourly rate of $31.71. 
  Activity	Annual Number of Responses	Completion Time per response	Total Annual BurdenHours	Total $ Value of Burden Hours 
($31.71/hr)	
FWS Form 3-2354	169,200 	30 minutes	84,600 	$2,682,666 	
FWS Form 3-2355	87,400 	30 minutes  	43,700 	$1,385,727	
FWS Form 3-2356 	2,400 	30 minutes	1,200 	$38,052 	
FWS Form 3-2357	4,900	30 minutes	2,450	$77,690 	
FWS Form 3-2358 	2,400	30 minutes	1,200	$38,052	
Subtotal Applications	266,300		133,150	$4,222,187 	
FWS Form 3-2359 	82,700	15 minutes	20,675	$655,604 	
FWS Form 3-2360 	387,300	15 minutes	96,825	$3,070,321 	
FWS Form 3-2361	29,100	15 minutes	7,275 	$230,690  	
FWS Form 3-2362	24,400	15 minutes	6,100 	$193,431	
Subtotal Activity Reports	523,500		130,875	$4,150,046	
        Totals: 	789,800		264,025	$8,372,233	

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

We estimate the nonhour burden cost to respondents to be $60,000. We charge fees for hunting applications at approximately 20 of the 408 refuges that are open for hunting or fishing.  Fees range from $1.00 to $10.00 per application.  Each year, approximately 10,000 individuals pay an average hunting application fee of $6.00.

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

We estimate the total annual cost to the Federal Government to administer this information collection to be $18,980,122 ($18,180,122 for salary/benefits and $800,000 for overhead (printing, copying, postage, etc.)).  See tables below for salary/benefit information.  We used the Office of Personnel Management’s Salary Table 2015-GS to determine the hourly wages.  We multiplied the hourly wages by 1.5 to account for benefits (Bureau of Labor Standards news release USDL-15-0386 released March 11, 2015).

Applications:  For each application, we will receive forms; process information; determine permittees by lottery, drawing, or other method; and advise applicants of their success. We will spend about 1 hour per application, or a total of 266,300 hours.  

Position	Grade	Hourly pay rate 	Hourly rate including benefits	Percent of time spent on collection	Weighted average ($/hr)	
Clerical, unskilled (i.e. receptionist, office asst.)	GS 7 step 5	$18.82	$28.23	60%	$16.94	
Professional and technical staff (biologist, outdoor recreation planner)  	GS-11 step 5	$27.86	$41.79	30%	$12.54	
Management (Refuge Manager)	GS 13 step 5	$39.70	$59.55	10%	$5.96	
Weighted Avg
($/hr)					$35.44	

Estimated salary/benefits cost to Federal Government to process applications is $9,437,672 ($35.44 weighted average $/hr x 266,300 hours).

Activity Reports:  We will consolidate and process the information and evaluate management implications.  Processing time for activity reports is approximately 30 minutes each or a total of 261,750 hours.
Position	Grade	Hourly pay rate 	Hourly rate including benefits	Percent of time spent on collection	Weighted average ($/hr)	
Clerical, unskilled (i.e. receptionist, office asst.)	GS 7 step 5	$18.82	$28.23	75%	$21.17	
Professional and technical staff (biologist, outdoor recreation planner)  	GS-11 step 5	$27.86	$41.79	15%	$6.27	
Management (Refuge Manager)	GS 13 step 5	$39.70	$59.55	10%	$5.96	
Weighted Average $/hr)					$33.40	

Estimated salary/benefits cost to Federal Government to process activity reports is $8,742,450 ($33.40 weighted average $/hr x 261,750 hours).

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

We are estimating 789,800 responses totaling 264,025 annual burden hours for this collection.  This is an adjustment decrease of 50,600 responses and 16,925 annual burden hours.  Adjustments in hour and cost burden are due to an estimated 6 percent decrease in hunting and fishing visits since 2011. 

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

We do not plan to publish this information.  

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 approval number and expiration date.

18.  Explain each exception to the certification statement. 

There are no exceptions to the certification statement.