Agency Comment Response

OMB Number: 0596-New.
https://www.federalregister.gov/documents/2017/01/06/2017-00061/information-collectionsignificant-cave-nomination
Respondent:
Raymond C. Keeler
President
Central Arizona Grotto and Arizona Region of the
National Speleological Society
NSS #23245
[email protected]
623-523-1760
Respondent Comments and Agency Responses
Associated Respondent Burdens:
(1) Whether this collection of information is necessary for the stated purposes and the proper
performance of the functions of the agency, including whether the information will have
practical or scientific utility;
• The collection of information is critical to the management of the interconnected
surface/subsurface relationships. This is a primary function of the agency.
Agency Response: The collection of information is critical to the management of
caves, directed by the Federal Cave Resources Protection Act of 1988.
•

Practical use of significant cave information gathered should directly affect the area
access, and surface management above the cave.
Agency Response: The practical utility of this information collection is in fulfilling the
requirements of the Federal Cave Resources Protection Act of 1988, to nominate and
designate significant caves.

•

There are several scientific disciplines associated. Subsurface water direction and
movement, cave microbe communities identification, biota, archeology, paleontology.
Agency Response: The information collection can provide initial scientific information
about the nominated cave.

(2) The accuracy of the agency’s estimate of the burden of the collection of information,
including the validity of the methodology and assumptions used;
•

It appears that the burden statement of an estimated 10 submissions at 11 hours each
assumes all of the field work has been completed, is retrievable, and only filling out the
form is being included. This number grossly under estimates the total time and
resources necessary to acquire the information.

Agency Response: This estimate is based on consultation with National Speleological
Society members and the Department of the Interior Bureau of Land Management. It
is important to consider that this is a) an estimate and b) only cursory information is
required for the nomination of a significant cave, including a visit to the cave itself and
initial inventory data. This takes into account approximately a one-day field visit and
time to send information about the potential significant cave. Full cave mapping and
comprehensive inventories can be included in the significant cave file at a later date.
More time might be required for evaluation of the cave for significance after
nomination. It is also important to consider that in many cases, information about
inventoried caves already exists and so time to collect and send the currently available
information on the potentially significant cave is all that is required for the
nomination. We find the estimate to be appropriate for the nomination of a
significant cave.
•

The burden statement per response appears to be too large (11 hours) assuming this is
for just filling out the form. A form taking 11 hours to fill out will be rejected by most.
seems the annual burden is directed towards new responses. The 11 hour burden per
response is too large. It recommended an average of two hours burden to fill out each
response (the length of most major movies.)
Agency Response: Please see the response to the previous comment, above. This is
an estimate taking into account potential information collection in the field for the
response.

•

The total number of responses (10) is low. There has been a 20+ year lull since the last
set of submissions.
Agency Response: This estimate takes into account the current and past submission of
nomination information only from the general public. Over the past 20 years there
have been few, if any, submissions from the general public for significant caves
through this information collection. However, the lack of submissions has only been
from the general public. Many new significant caves have been nominated and
designated over the past 20 years, but almost all nominations were submitted
internally from Forest Service personnel, contractors, or volunteers. With no
evidence that submissions from the general public will increase, the estimate of
responses from the general public using this form is adequate based on historical and
current data.

(3) Ways to enhance the quality, utility, and clarity of the information to be collected; and
• An electronic, recoverable form would standardize the information received.
• The form needs to be simple, straight forward and not too long. This is not a research
paper.
• The form needs the ability to include attachments (photos, maps, scans)
• Posting a couple of examples will be helpful.
• If a standardized form is used, this would be an excellent opportunity to resubmit
currently accepted significant caves to get them into the standard form format.

Agency Response: Thank you for your suggestions on ways to enhance the quality, utility, and
clarity of the information to be collected. An opportunity to comment on the method of
information collection developed will occur before the process is finalized.
(4) ways to minimize the burden of the collection of information on respondents, including the
use of automated, electronic, mechanical, or other technological collection techniques or other
forms of information technology.
• The respondents need a simple tracking mechanism for each submission. The submitter
needs to be able to follow the progress from submission through to signing by the
Forest Supervisor.
• The respondents need to be able to print the information submitted.
• The respondents need to be able to download a file of the information submitted so
they do not have to retype the information.
• The respondents need to be able to modify the information as needed. For example,
unclear statements can be modified and additional information can be added.
Agency Response: Thank you for your suggestions on ways of minimizing the burden of collection.
They will be considered in relation to current agency capabilities and technology in the development
of the method of information collection.
Associated USFS burdens that need to correspond to the Responses. This is not the Federal
Register request but is closely related. There is some overlap from the above, but the
perspective is from the USFS view.
(1) Whether this collection of information is necessary for the stated purposes and the proper
performance of the functions of the agency, including whether the information will have
practical or scientific utility;
• The collection of information is critical to the management of the interconnected
surface/subsurface relationships. This is a primary function of the agency.
• Practical use of significant cave information gathered should directly affect the area
access, and surface management above the cave.
• There are several scientific disciplines associated. Subsurface water direction and
movement is one example. Cave microbe communities are another example.
Agency Response: Please see the response to (1), above.
(2) The accuracy of the agency’s estimate of the burden of the collection of information,
including the validity of the methodology and assumptions used;
• The burden statement does not state if the estimated 10 submissions at 11 hours each
are by District, Forest, Region, or National. If the submissions are a national annual
total, the number will be low due to the improved reporting form being implemented,
and the associated visibility. If the number is by Forest, the numbers will vary widely
from zero to many. Let us assume the intent is the national form is used, and the
information is forwarded to individual Forests. The problem arises when there is no one
available at the Forest level to process the submission. See the next bullet.
• The burden statement appears to be incomplete. It seems the annual burden is directed
towards new responses. However, there is an annual burden that is needed to address
management of previous years of nominations. The 11 hour burden per response

•

appears too small. It does not include local field confirmation, or equipment or vehicles.
Is this number intended to include review time by the Forest/District officer for each
FCRPA category included for significance? Does this include Supervisor review time and
signing?
The total number of responses (10) is low. There has been a 20+ year lull since the last
set of submissions.

Agency Response: Please see responses to (2), above. Again, the burden statement is
specifically addressing the time it would take a member of the general public to fill out a new
nomination form. This does not include agency personnel time in processing nominations or
any other agency personnel time, equipment, or resources in any other aspect of this process.
The comments relating to agency time and resources are outside the scope of this request for
comment.
(3) Ways to enhance the quality, utility, and clarity of the information to be collected; and
• Here is an area where huge improvements can be made. From the Forests I have talked
with, each Forest is creating their own GIS cave layer for data management, if it has
been done at all over the last 20+ years. Further, there is little desire to implement a
cave GIS layer by the Forest GIS person who already has too many items on his/her
plate. If a cave GIS template were created at a national level that could be implemented
at the Forest level then the reluctance to implement would go down and the
information quality would go up.
• The issue is for those forests with a current cave GIS layer needing to convert to a
standardized format.
• If the standardized GIS layer can be modified as needed at a regional level, it will allow
for regional/forest variations.
• If the standardized form has exportable fields to a cave a standardized GIS layer, there
will be a huge USFS savings at the Forest and District levels. Much of their background
work will already be included. For example, Environmental Assessment preparation.
Agency Response: These comments are outside the scope of the request for comment. These
comments do not address significant cave nomination by the general public.
(4) ways to minimize the burden of the collection of information on respondents, including the
use of automated, electronic, mechanical, or other technological collection techniques or other
forms of information technology.
• There needs to be a simple tracking mechanism for submissions. The submitter needs
to be able to follow the progress of the submission through to the signing by the Forest
Supervisor.
• The responsible Forest officer needs to be able to print the information submitted.
• The responsible Forest officer needs to be able to download a file of the information
submitted.
• The responsible Forest officer needs to be able to modify that information.
Agency Response: Please see the response to item (4), above.