DRAFT Supporting_statement 1004 0119

9

Supporting Statement A

Permits for Recreation on Public Lands

(43 CFR Part 2930)

OMB Control Number 1004-0119

Terms of Clearance: None.

General Instructions

A completed Supporting Statement A must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses, or employ statistical methods?” is checked "Yes," then a Supporting Statement B must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The Bureau of Land Management (BLM) is required to manage commercial, competitive and organized group recreational uses of the public lands, and individual use of special areas. The BLM must assess, evaluate and authorize (permit) activities that are proposed to be conducted on public land. The BLM has the following authorities for collecting the required information to authorize and collect fees for recreation use on public lands:

A. Federal Land Policy and Management Act (43 U.S.C. 1701 – 1787);

B. Federal Lands Recreation Enhancement Act (16 U.S.C. 6801 - 6814);

C. Wilderness Act (16 U.S.C. 1131 - 1136);

D. National Trails System Act (16 U.S.C. 1241 – 1251);

E. National Wild and Scenic Rivers Act (16 U.S.C.1271 - 1287); and

F. Title 43 CFR Subpart 2930 – Special Recreation Permits, Other than on Developed

Recreation Sites

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

The BLM needs the information to:

1. Determine whether proposed recreation use is environmentally acceptable;

2. Calculate the amount of fees that will be assessed if the activity or event is authorized;

3. Determine qualifications and capability of the applicant to offer the proposed services; and

4. Tabulate recreation use data for the Triennial Report to Congress required by the Federal Lands Recreation Enhancement Act.

The respondent must file with the BLM Form 2930-1, Special Recreation Permit Application, to obtain approval of the requested recreation use. The BLM needs this information to approve or reject the application.

We request the following information on Form 2930-1:

Item 1: Indicate if this form is a new application or renewal of an existing permit. The BLM uses this information to determine if the applicant has a file with the BLM so we can review the background history.

Item 2: Indicate the name of the business or organization. The BLM uses this information for identification and communication purposes.

Items 3 through 10: Indicate the following information:

• Applicant’s Name;

• E-mail address;

• Address;

• Telephone Number;

• FAX Number

• Website

• Type of Business; and

• Name and telephone numbers of those individuals authorized to conduct business with BLM concerning the permit.

The BLM uses this information to review the application and communicate with the applicant.

Item 11: Indicate the type of permit applying for such as (commercial, competitive, organized group, individual, or vending use). The BLM uses this information to determine how to help the applicant and give guidance on completing the process.

Items 12 through 15: Indicate the following information:

• Name and legal description of land to be used;

• Purpose and description of activity or use;

• Dates activity will begin and end;

• Indicate the applicant’s history and prior use of SRPs and bonds. The BLM uses this information to build a profile on the use of permits.

Item 16: Indicate the certification information. The BLM uses this information to ensure that the application is correct and to inform the applicant of the conditions and stipulations that may be imposed when we issue the permit.

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 Special Recreation Permit Application (Form 2930-1) is electronically available to the public in fillable, printable format on BLM’s Forms Web site at http://www.blm.gov/noc/st/en/business/eForms.html. A respondent who chooses to submit the form electronically may do so by scanning and then emailing it to the appropriate BLM office.

At this time, the BLM is developing an online geospatially enabled application system that will include Form 2930-1. This will enable the public to fill out and submit the application in a secure online environment, and allow electronic review of the application and any associated materials by the Agency.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

No duplication occurs in the information we collect. The requested information is unique to the applicant and is not available from any other data source. No similar information is available or able to be modified. The information is required to receive a benefit.

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

We do not collect information on whether the respondents are small businesses or small entities. We believe virtually all of the respondents are small businesses or other small entities. The information we require from all respondents is limited to the minimum necessary to authorize recreation use on the public lands.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If we did not collect the information, we could not manage the recreation uses on the public lands, thereby resulting in potential damage to resources and loss of revenue. This information is needed to allocate and track individual use in areas with sensitive resources. Without a permit, many commercial, competitive, and group events could take place on public lands without sufficient oversight, and those lands could be subject to unauthorized use violations and trespass. Less frequent collection of the information would mean no collection of the information at all.

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 the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5.

8. If applicable, provide a copy and identify 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 and in response to the PRA statement associated with the collection over the past three years, and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

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.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every three years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

On August 22, 2019 the BLM published the required 60-day notice in the Federal Register (84 FR 43818), and the comment period ended on October 19, 2019. The BLM received no comment(s) in response to the notice.

The BLM consulted with seven individuals from the following cities:

• Grants Pass, Oregon

• Prineville, Oregon

• Moab, Utah

• Golden, Colorado

• Hood River, Oregon

• Socorro, New Mexico

• Reno, Nevada

All of the respondents thought the form was easy to read and the required data was readily available. One respondent thought the collection frequency was too often, however this respondent has since been issued a 10-year permit. The BLM recognizes that first time applicants will often change their operations in the second year, and have to submit a new application. Five of the respondents indicated the data elements are appropriate, and two did not have a comment.

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 the respondents.

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

We protect the respondent’s confidentiality to the extent consistent with the Freedom of Information Act (5 U.S.C. 552).

Under the privacy provisions of the E-Government Act of 2002, individuals/respondents were informed as to whether or not providing the information is required to obtain a benefit.

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. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

We do not require respondents to answer questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here.

Table 12-1, below, shows the BLM’s estimates of the hourly cost burdens for respondents. The mean hourly wages for Table 12-1 were determined using national Bureau of Labor Statistics data at: http://www.bls.gov/oes/current/oes_nat.htm.

The benefits multiplier of 1.4 is supported by information at http://www.bls.gov/news.release/ecec.nr0.htm.

Table 12-1 — Hourly Cost Calculation

Position and Occupation Code	Hourly Pay Rate ($/hour)	Hourly Rate with Benefits ( x 1.4)
Travel Guides 39-7012	$14.25	$19.95

Table 12-2, below, shows the BLM’s estimates of respondents’ annual hour burdens, and the dollar equivalents of those hour burdens. These estimates take into account time spent for researching, preparing, and submitting information. The estimated hourly wage associated with this information collection is shown at Table 12-1, above.

The frequency of response for each component of this information collection is “on occasion.”

Table 12-2 – Estimated Hour and Cost Burdens

Type of Response 43 CFR 2930 Citation	A. Number of Responses Annually	B. Hours per Response	C. Annual Hour Burden (Column A x Column B)	D. Hourly Wage	E. Dollar Equivalent (Column C x Column D)
Special Recreation Permit Applications 43 CFR 2932.20 Form 2930-1	1,323	4	5,292	$19.95	$105,575

13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)

* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information (including filing fees paid for form processing). Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

Respondents are not required to purchase additional computer hardware or software to comply with this information collection. There is no filing fee associated with this information collection. There are no capital or start-up costs involved with this information collection.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

The hourly cost to the Federal Government shown in Table 14-1, below, is based on data at:https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/GS_h.pdf. The benefits multiplier of 1.6 is implied by information at http://www.bls.gov/news.release/ecec.nr0.htm.

Table 14-1 — Hourly Cost Calculation

A. Position and Pay Grade	B. Hourly Pay Rate	C. Hourly Rate with Benefits (Column B x 1.6)	D. Percent of time spent on these collections	E. Weighted Avg. (Column C x Column D)
Clerical GS-7/1	$17.42	$27.87	10%	$2.79
Technical GS-11/1	$25.78	$41.25	80%	$33.00
Managerial GS-13/1	$36.75	$58.80	10%	$5.88
Totals				$41.67

Estimated Annual Cost to the Government: The estimated annual cost to the government includes time spent for processing the information provided by the respondents. The average hourly wage is shown at Table 14-1, above. Table 14-2, below, shows the annualized Federal costs for this collection of information. The estimated time spent to process the information collections is based on the BLM’s experience.

The frequency of response for each of the information collections is “on occasion.”

Table 14-2 — Estimated Annual Cost to the Government

A. Type of Response and 43 CFR 2930 Citation	B. Number of Responses Annually	C. Hours Per Response	D. Total Hours (Column B x Column C)	E. Dollar Equivalent (Column D x $41.67)
Special Recreation Permit Applications 43 CFR 2932.20 Form 2930-1	1,323	1	1,323	$55,090

15. Explain the reasons for any program changes or adjustments.

The number of annual responses has remained steady from the previous period from 1,376 to 1,323. This is within normal year to year variation.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The BLM will publish the tabulated recreation use data in the Public Land Statistics, as required by the Federal Lands Recreation Enhancement Act (16 U.S.C. 6808).

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.

The BLM will display the expiration date of the OMB approval on the form included in this information collection.

18. Explain each exception to the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions to the certification statement.