1018-New SSA Sea Lampreys 09082020

Supporting Statement A

for paperwork reduction act submission

Sea Lamprey Control Program

OMB Control Number 1018-New

Terms of Clearance: This is a request for a new OMB control number (existing collection in use without an OMB control number).

Justification

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

Service staff at the Marquette and Ludington biological stations fulfill U.S. obligations under the 1954 Convention on Great Lakes Fisheries between the United States and Canada and the Great Lakes Fishery Act of 1956 (16 U.S.C. 931). The Service works with State, Tribal, and other Federal agencies to monitor progress towards fish community objectives for sea lampreys in each of the Great Lakes, and also to develop and implement actions to achieve these objectives. Activities are closely coordinated with State, Tribal, and other Federal and provincial management agencies, nongovernmental organizations, private landowners, and the public. Our primary goal is to conduct ecologically sound and publicly acceptable integrated sea lamprey control.

The Sea Lamprey Control Program is administered and funded by the Great Lakes Fishery Commission (GLFC) and implemented by two control agents, the U.S. Fish and Wildlife Service and Fisheries and Oceans Canada, who often partner on larger projects. The sea lamprey (Petromyzon marinus), a parasitic fish species native to the Atlantic Ocean, parasitizes other fish species by sucking their blood and other bodily fluids. Having survived through at least four major extinction events, the species has remained largely unchanged for more than 340 million years. The sea lamprey differs from many other fishes, in that it does not have jaws or other bony structures, but instead has a skeleton made of cartilage. Sea lampreys prey on most species of large Great Lakes fish such as lake trout, salmon, lake sturgeon, whitefish, burbot, walleye, and catfish.

In the 1800s, sea lampreys invaded the Great Lakes system via manmade locks and shipping canals. Their aggressive behavior and appetite for fish blood wreaked havoc on native fish populations, decimating an already vulnerable lake trout fishery. The first recorded observation of a sea lamprey in the Great Lakes was in 1835 in Lake Ontario. For a time, Niagara Falls served as a natural barrier, confining sea lampreys to Lake Ontario and preventing them from entering the remaining four Great Lakes. However, in the early 1900s, modifications were made to the Welland Canal, which bypasses Niagara Falls and provides a shipping connection between Lakes Ontario and Erie. These modifications allowed sea lampreys access to the rest of the Great Lakes system. Within a short time, sea lampreys spread throughout the system: into Lake Erie by 1921, Lakes Michigan and Huron by 1936 and 1937, and Lake Superior by 1938. Sea lampreys were able to thrive once they invaded the Great Lakes because of the availability of excellent spawning and larval habitat, an abundance of host fish, a lack of predators, and their high reproductive potential—a single female can produce as many as 100,000 eggs.

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 Sea Lamprey Control Program (SLCP) maintains an internal database. In existence for more than 20 years, it contains information critical to the delivery and evaluation of an integrated control program to manage invasive sea lamprey populations in the five Great Lakes. The storage of data in this database not only documents the history of the SLCP since inception in 1953, but it also provides data to steer assessment and control of invasive sea lamprey populations in the Great Lakes in partnership with the GLFC. We provide annual population data to Federal and State regulatory agencies to inform critical evaluations used to issue permits to allow sea lamprey control actions.

The SLCP database maintains the points of contact for landowners to request landowner permission to access their land for treatment. The Service collects basic contact information from landowners via the “Sea Lamprey Control Landowner Questionnaire”:

• Property address;

• Whether they allow access to their land;

• Landowner contact information (name, home address, contact phone numbers, email address, and preferred contact time);

• Alternate contact information (name and phone number);

• Whether stream water is used for irrigation purposes;

• Methods of transportation allowed on property;

• Whether a gate key or gate combination is needed to access their land; and

• Additional questions the landowner might have about treatment or sea lamprey management.

Our treatment supervisors use this information to plan treatments of streams. With prior permission from the landowners they can decide where the best places are to access the streams. The contact information is used to get in touch with the landowners before the treatment starts and confirm that we still have permission to access their land.

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.

Currently, we expect most landowners will submit information to the Service in paper format by either submitting the request in person or by post. We will also accept documents as an email attachment or via fax. We estimate receiving approximately 5% of submissions electronically.

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.

There is no duplication. The information collected is specific to the SLCP. Due to the unique nature of each program, no other division of the Service or any other Federal agency collects this information from the public.

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

We collect only the minimum information necessary for us to request landowner permission to access their land for treatment. This information collection will not significantly impact small businesses or other small entities.

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, the Service would be unable to keep in touch with landowners and document that permission was obtained to access their land. Stream treatments often require access to streams that cannot be accomplished using only public lands.

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 requiring collection of the information in a manner inconsistent with OMB guidelines.

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 June 1, 2020, we published in the Federal Register (85 FR 33192) a notice of our intent to request that OMB approve this information collection. In that notice, we solicited comments for 60 days, ending on July 31, 2020. We did not receive any comments in response to that notice.

In addition to the Federal Register notice, we consulted with the nine (9) individuals identified in Table 8.1 who familiar with this collection of information in order to validate our time burden estimate and asked for comments on the questions below:

Table 8.1

Organization	Title
Private Citizen	Landowner
Private Citizen	Landowner
Private Citizen	Landowner
Private Citizen	Landowner
Private Citizen	Landowner
Private Citizen	Landowner
Private Citizen	Landowner
Private Citizen	Landowner
Private Citizen	Landowner

“Whether or not the collection of information is necessary, including whether or not the information will have practical utility; whether there are any questions they felt were unnecessary”

Comments: Questions are both necessary and important. Landowners appreciate the treatment letters that are sent based off of the information gathered as it keeps them informed about treatments.

Agency Response/Action Taken: No action required or requested.

“The accuracy of our estimate of the burden for this collection of information”

Comments: Completing the form takes less time than the estimated 15 minutes. The average of reported time burden responses is 5 minutes.

Agency Response/Action Taken: We will adjust our burden estimates to use 5 minutes instead of 15.

“Ways to enhance the quality, utility, and clarity of the information to be collected”

Comments: No suggestions for improvements were given, and no issues with the process were reported.

Agency Response/Action Taken: None needed.

And

“Ways to minimize the burden of the collection of information on respondents”

Comments: One response that was given is that it would be helpful to have a checkbox on the form indicating no changes from the last time the form was submitted.

Agency Response/Action Taken: We will incorporate that into our future forms.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

We will not provide any payment 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 will not provide any assurance of confidentiality. We do not ask for other personal identifiers such as social security numbers, street addresses, or telephone numbers. The Service’s Associate Privacy Act Officer (APAO) determined this collection does not require a Systems of Records Notice or a Privacy Impact Assessment. We completed the required Privacy Threshold Analysis, approved by the Service’s APAO on November 26, 2019. The required Privacy Impact Assessment was completed on January 10, 2020. We provided copies of both to OMB via ROCIS as supplemental documents.

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 will not ask any 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.

Since we have received no responses to this policy, as a placeholder, we will estimate 1 respondent/response for each IC identified in Table 12.1 totaling 440 annual responses and 36 annual burden hours (rounded). The total dollar value of the annual burden hours is approximately $1,368 (rounded).

We used Table 1 from the of Bureau of Labor Statistics (BLS) News Release USDL-20-1232, June 18, 2020, Employer Costs for Employee Compensation—March 2020, to calculate the cost of the total annual burden hours:

• Individuals - the hourly rate for all workers is $37.73, including benefits.

• Private Sector - the hourly rate for all workers is $35.34, including benefits.

• Government - the hourly rate for all workers is $52.45, including benefits.

Table 12.1

Requirement	Average Number of Annual Respondents	Average Number of Responses Each	Average Number of Annual Responses	Average Completion Time per Response	Estimated Annual Burden Hours*	Hourly Rate	$ Value of Annual Burden Hours
Sea Lamprey Control Landowner Questionnaire
Individuals	400	1	400	5 minutes	33	$ 37.73	$ 1,245.09
Private Sector	25	1	25	5 minutes	2	35.34	70.68
Government	15	1	15	5 minutes	1	52.45	52.45
Totals:	440		440		36		$ 1,368.22

^{*Rounded to match ROCIS}

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.

There is no non-hour cost burden associated 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 total estimated cost to the Federal Government for processing and reviewing reports from States as a result of this collection of information is $5,527 (rounded). This estimate includes 100 hours of FWS salary and benefits (100 hours x $55.27). There are no other costs are associated with this information collection.

To determine average annual salary costs, we used the Office of Personnel Management Salary Table 2020-RUS as an average nationwide rate. The salary rate for a GS-11, step 5 is $34.76. In accordance with BLS News Release USDL-20-1232, June 18, 2020, Employer Costs for Employee Compensation—March 2020, we multiplied the hourly rate by 1.59 to account for benefits resulting in a fully burdened rate of $55.27.

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

This is a request for a new OMB control number (existing collection of information in use without an OMB control number).

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 information we will collect will not be published.

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.

Not applicable.

18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."

There are no exceptions to the certification statement.

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