Justification for Submission

DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

JUSTIFICATION FOR SUBMISSION UNDER THE
“DOI PROGRAMMATIC CLEARANCE FOR
CUSTOMER SATISFACTION SURVEYS”

See Page 5 for Instructions on Completing This Form
1. Bureau/Office

2. Date Submitted

FWS/Division of Migratory Birds

06/27/2019

3. Survey Title

Assessment of Black Vulture Pilot Permitting Program in Kentucky and Tennessee
4. Abstract (Not to exceed 150 words)

The U.S. Fish and Wildlife Service’s (Service) Division of Migratory Bird Management is conducting
phone interviews and public meetings with constituents to address questions regarding the best
method to handle permitting conflicts with an overabundant bird species. The current policy is to
issue take permits to individual landowners on a case-by-case basis. However, the intensity of
complaints about black vultures from cattle producers in Kentucky in 2015 and Tennessee in 2016
overwhelmed the Program’s ability to issue permits in a timely manner.
To address the conflict, the Service implemented a pilot program to issue a “blanket permit” to the
Kentucky and Tennessee Farm Bureau Federations, which then issued individual take permits to
landowners. The pilot is justified biologically; however, customers have raised questions about the
permitting processes which need to be investigated. The Service requests OMB approval to solicit
information from customers on the management and administration of the Black Vulture Pilot
permitting processes to determine if the pilot program should be implemented as a standard practice
in other states or discontinued altogether.

5. Bureau/Office Point-of-Contact Information
First Name

Last Name

Laurel

Barnhill

Title

Bureau/Office

Chief, Migratory Bird Program

FWS/R4 Migratory Bird Program

Mailing Address

City

1875 Century Blvd

Atlanta

Phone
404-679-7188

■

Work
Cell

Fax
NA

Last Name

Title

Bureau/Office

Mailing Address

City

Work
Cell

Fax

GA

Zip Code
30345

Email
[email protected]

6. Principal Investigation (PI) Point-of-Contact Information
First Name
Same as #5

Phone

State

State

Zip Code

Email

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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

7. Name of Program or Office Conducting Survey

Migratory Bird Program
8. Description of Customers and Services Provided
Three groups of respondents have been identified: (1) agricultural producers who have and have not participated in the pilot program; (2)
Kentucky and Tennessee Farm Bureau Federations who are administering the program; and (3) Federal and state agencies; specifically, USDA
APHIS Wildlife Services (providers of necessary forms for permit issuance), USFWS (permit issuer), and Tennessee and Kentucky State Wildlife
Agencies (providers of technical assistance).

9. Survey Dates
(mm/dd/yyyy)

7/7/2019

(mm/dd/yyyy)
7/7/2020

to

10. Type of Information Collection Instrument (Check ALL that Apply)
Intercept

Telephone

Mail

Web-based

Comment Cards

Other: (Explain)
Focus Groups
11. Survey Development (Who assisted in survey content development statistics? Was the survey pretested? How did you
integrate improvements? Which of the six topic areas did you address?)

DJ Case & Associates (www.djcase.com) developed the assessment methodology. The interview guide
addresses three of the six topic areas: 1-Delivery, quality and value of products, information and services;
2-Management practices; and 4-Rules, regulations, policies.
12. Survey Methodology (Use as much space as needed; if necessary, include additional explanation on separate page.)
12A. Respondent Universe

Agricultural producers seeking relief from depredation by overabundant black vultures, federal and state natural resources
agencies (provide permits and technical assistance), and Tennessee and Kentucky Farm Bureau Federations.
12B. Sampling Plan/Procedure

See attached sampling plan
12C. Instrument Administration

Contractor will contact selected participants by telephone in Kentucky and Tennessee.
12D. Expected Response Rate and Confidence Levels
We expect participation rate in phone interviews to be high, because affected producers are eager to maximize efficiency of the permitting process. Confidence levels are not
applicable because we are not attempting to apply numerical results to a larger population. Our interviews will nearly be a census of the small respondent universe.

12E. Strategies for dealing with potential non-response bias

Not applicable. We are not attempting to apply numerical results to a larger population.
12F. Description of any pre-testing and peer review of the methods and/or instrument (recommended)

The interview guide was developed by contractor's PhD social scientists (in consultation with USFWS biologists), and
reviewed by USFWS social scientists in the Human Dimensions Branch.
13. Burden Hours Calculations
Number of Annual
Respondents

Category of Respondent

Number of
Responses Each

Total Annual
Responses

Time per
Response

Total Burden
Hours

Initial Contact
24

Completion of Survey Instrument

11

264

60 min

264

Totals:

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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

14. Federal Enterprise Architecture (FEA) Business Reference Model (Check only one “Line of Business” and one
“Subfunction.” Refer to OMB guidance “FEA Consolidated Reference Model Document Version 2.3”)
Line of Business
Subfunction
Line of Business
Subfunction
Community and
Social Services
Defense and
National Security
Economic
Development

(Select One)

Correctional
Activities
Disaster
Management

(Select One)

(Select One)

Education

(Select One)

Energy

(Select One)

Environmental
Management

(Select One)

General Science
and Innovation

(Select One)

Health

(Select One)

Homeland Security

(Select One)

(Select One)

(Select One)

Income Security

(Select One)

Intelligence
Operations

(Select One)

(Select One)

Law Enforcement

(Select One)

International Affairs
and Commerce
Litigation and
Judicial Activities

Natural Resources

Conservation, Marine and Land ManagementTransportation

Workforce
Management
15. Reporting Plan

(Select One)

(Select One)

(Select One)

The reporting plan will consist of a summary of the interviewee responses to the survey questions group by
common themes.
16. Justification, Purpose, and Use
16A. Survey Justification and Purpose
USFWS implemented a pilot program to try to meet the needs of agricultural producers impacted by overabundant black vultures. Phone interviews with affected
producers as well as the agency staff who serve them are needed to determine if the pilot program is meeting these needs and should be implemented as a
standard practice in other states or discontinued.

16B. Survey Goals

The Service has determined that the pilot is justified biologically but needs to determine if sub-permitting cattle
producers to take black vultures should be implemented as a standard practice in other states or discontinued.
16C. Utility to Managers
Results will address questions regarding the regulatory and administrative burden of the pilot program and if future expansion is justified. Specifically, is there a loss of
permit/technical assistance revenue by USFWS or USDA WS, what is impact of reduced technical assistance to producers by USDA WS, ability of permit holder to
assume liability, and reduction in burden/increased efficiency for applicants. Information will improve the Service's administration of permitting for black vulture take.

16D. How will the results of the survey be analyzed and used?
The contractor will compile interview results and insights by stakeholder type. These results will be presented in public meetings/focus groups in TN and KY,
where additional potentially affected producers will have the opportunity to comment. Based on all results, the contractor will identify the pros and cons of the pilot
program and provide recommendations to the Service regarding future use of the pilot.

16E. How will the data be tabulated? How What Statistical Techniques will be used to generalize the results to the entire
customer population? How will limitations on use of data be handled? If the survey results in a lower than anticipated
response rate, how will you address this when reporting the results? (Use as much space as needed; if necessary, include
additional explanation on separate page.)
We will not be using statistical techniques to generalize results across a large population. The agency staff and their customers in this pilot
program are a small group. We seek qualitative results to give insights into issues, concerns and problems that may affect utility of the pilot.

16F. Is this survey intended to measure a Government Performance and Results Act (GPRA) performance measure? If
yes, please include an excerpt from the appropriate document. (Use as much space as needed; if necessary, include additional
explanation on separate page.)

No.

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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

17. Federal Cost: (Consult your Bureau/Office Information Collection Clearance Officer for assistance, if necessary)
The estimated annual cost to the Federal government is $ 2,996.40

, based on: (provide details below)

If the contractor contacts 24 producers and agency personnel and it takes 60 minutes for each phone interview, then the total burden
is 24 hours. Work to be conducted by a mid-level facilitator with a per hour labor rate of $124.85 as indicated in the contract.
Sample Response:
“If we receive 20 submissions and it takes 30 minutes to process and implement each one, then the total burden is $322.40
assuming a GS-7 step 5 is processing the submissions. This custom form is a tool meant to accept submissions in a standard format
rather than through the freeform submissions that would otherwise come in by personal email. The existence of this form actually
saves the government money by standardizing submissions and decreasing the workload of processing each one.”
18. The survey methodology presented in form DI-4010 includes a specific description of:
The respondent universe,
The sampling plan and all sampling procedures, including how respondents will be selected,
How the instrument will be administered,
Expected response rate and confidence levels,
Strategies for dealing with potential non-response bias,
A description of any pre-testing and peer review of the methods and/or the instrument is highly recommended,
The burden hours reported in the Justification include the number of burden hours associated with the initial contact of all
individuals in the sample (i.e., including refusals), if applicable, and the number of burden hours associated with individuals
expected to complete the survey instrument, and
The package is properly formatted (using MS Word) and submitted to the Office of Policy Analysis (through the Bureau/Office
Information Collection Clearance Officer).
19. The approval package includes:
A completed and signed Form DI-4010, Generic Clearance for Customer Satisfaction Surveys.
A copy of the survey instrument.
Other supporting materials, such as:
• Cover letters to accompany mail-back questionnaires,
• Introductory scripts for initial contact of respondents,
• Necessary Paperwork Reduction Act and Estimated Burden compliance language, and/or
• Follow-up letters/reminders sent to respondents.
20. Checklist for Submitting a Request to Use DOI Programmatic Clearance for Customer Satisfaction Surveys
All questions in the survey instrument are within the scope of one of the DOI Programmatic Clearance for Customer
Satisfaction Surveys topic areas.
A qualified statistician has reviewed and approved your request (see question 21A).
Your Bureau/Office Information Collection Clearance Officer receives your package for review/approval at least 75 days
prior to the first day the PI wishes to administer the survey to the public.
21. Required Certifications for Submission Under OMB Control Number 1040-0001
Certification is required to submit a collection of information for approval under the DOI Programmatic Clearance for Customer
Satisfaction Surveys. If the collection does not satisfy the requirements of the Programmatic Clearance, you should follow the
regular PRA clearance procedures described in 5 CFR 1320.
21A. Bureau/Office Statistician
Signature
Date
Recommend

Not Recommended

NATALIE SEXTON

Digitally signed by NATALIE SEXTON
Date: 2019.06.26 08:55:26 -06'00'

21B. Bureau/Office Program or Subgroup

Bureau/Office Point-of-Contact

FWS/Migratory Bird Program

FWS/R4 Chief Migratory Bird Chief

Title (Please be specific)

Signature

DEAN DEMAREST

Acting Chief, R4 Migratory Bird Program

Date
Digitally signed by DEAN DEMAREST
Date: 2019.06.27 09:38:49 -04'00'

FOR PROGRAM USE ONLY
Required certifications: The information collection requested by this submission meets the requirements of OMB Control No. 1040-0001

Bureau/Office ICCO
Recommend

Signature
Not Recommended

DOI Office of Policy Analysis
Recommend
Approved

Signature

Not Recommended

DOI PRA Program Lead
Not Approved

MADONNA BAUCUM

Date
Digitally signed by MADONNA BAUCUM
Date: 2019.07.12 08:39:36 -04'00'

DOI Tracking No.

BENJAMIN SIMON

Date
Digitally signed by BENJAMIN SIMON
Date: 2019.07.17 18:15:21 -04'00'

Signature

2019-FWS-CS6 JEFFREY PARRILLO

7/12/19

7/17/19
Date

Digitally signed by JEFFREY PARRILLO
Date: 2019.07.18 08:12:30 -04'00'

7/18/19

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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

Instructions for Completing Form DI-4010,
Justification for Submission Under the
“DOI Programmatic Clearance for Customer Satisfaction Surveys”
OMB Control Number 1040-0001
1.

Bureau/Office: Insert the name of the bureau/office conducting the survey.

2.

Date Submitted: Date you submit the package to the Bureau/Office Information Collection Clearance Officer (ICCO) for review.

3.

Survey Title: Insert title for the proposed survey.

4.

Abstract: Summarize the proposed study with an abstract not to exceed 150 words.

5.

Bureau/Office Point of Contact Information: Complete the bureau/office contact information. PPA will communicate with the
point of contact listed here throughout the entire approval process.

6.

Principal Investigator (PI) Conducting the Survey: Complete information about the PI who will be conducting the survey, if
different from Point of Contact listed in #4. Otherwise note: Same as #4.

7.

Name of Program Office Conducting Survey: Provide the name of the bureau program, office, or organizational unit conducting
the survey.

8.

Description of Customers and Services Provided: Provide a brief description of the customers you will survey, the services
provided by the program conducting the survey, and customers receive these services.

9.

Survey Dates: List the time-period in which you will conduct the survey, including specific starting and ending dates. The starting
date should be at least 75 days after the date you submit the package to your bureau/office Information Collection Clearance
Officer (ICCO).

10. Type of Information Collection Instrument: Check the type(s) of information collection instrument(s) you will use. If other,
please explain.
11. Survey Development: Explain how the survey was developed. With whom did you consult during the development of the survey
on content? On statistics? Did you pretest the survey? What actions did you take to improve the survey? What suggestions did
you receive for improving the survey? Which of the six topic areas will the collection address? (Note: A description of any pretesting and peer review of the methods and/or instrument is highly recommended.)
12. Survey Methodology: Explain how you will conduct the survey. Provide a description of the survey methodology including:
•
Question 12A – The respondent universe,
•
Question 12B – The sampling plan and all sampling procedures;
•
Question 12C – How the instrument will be administered;
•
Question 12D – Expected response rate and confidence levels;
•
Question 12E – Strategies for dealing with potential non-response bias; and,
•
Question 12A – Description of any pre-testing and peer review of the methods and/or instrument (recommended, but not
required).
Note: Web-based surveys are not an acceptable method of sampling a broad population. Web-based surveys must be limited to
services provided by the web site.
13. Burden Hours Calculations: Provide an estimated total of the following for each category – initial contact and completion of
survey instrument:
•
Number of annual respondents – Enter the number of unique respondents who will complete the information collection;
•
Number of responses per respondent – Enter the total number of responses per unique respondent;
•
Total annual responses – Enter the number of unique respondents multiplied by the total number of responses each;
•
Time per response – Estimate the time to complete the initial contact and the time to complete the survey instrument (in
minutes), and
•
Total burden hours –The total burden hours should account for the amount of time required to instruct the respondents in
completing the survey, and the amount of time required for the respondent to complete the survey.
14. Federal Enterprise Architecture (FEA) Business Reference Model: Using the drop-down menus provided, select ONE “Line of
Business” and ONE corresponding Subfunction that most accurately describes your information collection.
15. Reporting Plan: Provide a brief description of the reporting plan for the data you will collect.
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DI-4010 (Rev. 07/2018)
U.S. Department of the Interior

OMB Control. No. 1040-0001
Expiration Date 10/31/2021

16. Justification, Purpose and Use: For questions 16A through 16F, provide a brief justification for the survey, its purpose, goals,
and utility to managers. Specifically, describe how you will tabulate the data and what the statistical techniques you will use to
generalize the results to the entire customer population. Describe how you will use the data from the survey. Describe how you
will acknowledge any limitations related to the data, particularly in cases where we obtain a lower than anticipated response rate.
Note whether you intend the survey to measure a Government Performance and Results Act (GPRA) performance measure.
17. Federal Cost: Provide the cost estimate for the Federal government to administer the information collection, along with a
description of how you calculated the cost estimate (sample response provided). Contact your bureau/office ICCO for more
information or for assistance.
18. Survey Methodology Checklist: Carefully review each item and check each box to indicate your submission provides
the required description of each item.
19. Checklist for Submitting a Request to Use DOI Programmatic Clearance for Customer Satisfaction Surveys: Carefully
review each item and check each box to indicate your understanding and concurrence of each requirement.
20. Approval Package Content: Carefully review each item and check each box to indicate your package contains each of the
requirement elements listed.
NOTE: Your survey instrument document must show the OMB Control Number 1040-0001 and Expiration Date ##/##/###, and it
MUST include the following Statements somewhere on the instrument document (preferably at the bottom of page 1 or at the end
of the document):
Paperwork Reduction Act Statement: We are collecting this information subject to the Paperwork Reduction Act
(44 U.S.C. 3501) to [insert brief justification for collection of information]. Your response is voluntary and results we
will not share them publicly. We may not conduct or sponsor and you are not required to respond to a collection of
information unless it displays a currently valid OMB Control Number. OMB has reviewed and approved this survey
and assigned OMB Control Number 1040-0001, which expires ##/##/####.
Estimated Burden Statement: We estimate the [insert type of instrument] will take you ## minutes to complete,
including time to read instructions, gather information, and complete and submit your response. You may submit
comments on any aspect of this information collection to the Information Collection Clearance Officer, [Insert
Bureau/Office], [Insert mailing address].
21. Required Certifications: Completion of all information in this section is required before forwarding your approval
package to your bureau/office ICCO for review and processing.
Question 21A – Ensure the bureau/office statistician reviewing your information collection certifies the request satisfies
the requirements of the DOI Programmatic Clearance for Customer Satisfaction Surveys under OMB Control No. 10400001.
Question 21B – Ensure the requestor provides the requested contact information needed by the bureau/office and/or
Departmental ICCO to resolve questions or concerns.

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