1004-0132 Supporting Statement (2023 Renewal) OMB

2023 Renewal

U.S. DEPARTMENT OF THE INTERIOR

BUREAU OF LAND MANAGEMENT

PAPERWORK REDUCTION ACT REQUEST

SUPPORTING STATEMENT A

GEOTHERMAL RESOURCE LEASING AND GEOTHERMAL RESOURCES UNIT AGREEMENTS

(43 CFR PARTS 3200 AND 3280)

OMB Control Number 1004-0132

Terms of Clearance: Not applicable. The Office of Management and Budget (OMB) provided no Terms of Clearance when it last approved the collections of information under this OMB Control Number (see OMB Notice of Action dated July 23, 2020).

Abstract: The Bureau of Land Management (BLM) uses this information to issue geothermal leases in BLM-managed lands, and in national forests and other lands managed by the U.S. Forest Service (USFS). In this request, the BLM is requesting that OMB renew this OMB Control Number for additional three years.

Justification

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

The Geothermal Steam Act (30 U.S.C. 1001-1028) and regulations at 43 CFR parts 3200 and 3280 authorize the Bureau of Land Management (BLM) to collect information from those who wish to participate in the exploration, development, production, and utilization of geothermal resources on BLM-managed public lands, and geothermal resources on lands managed by other surface management agencies.

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 required information to approve lease activities for geothermal resources and unit agreements, process nominations for geothermal lease sales, and monitor compliance with granted approvals.

The BLM uses a database called the Mineral and Land Records System (MLRS) to track information on geothermal operations. This database includes the information covered under this control number involving exploration, development, production, and utilization of geothermal resources on BLM-managed public lands, and geothermal resources on lands managed by other surface management agencies. The previous system known as the Geothermal Resources Automated Support System (GRASS) has been decommissioned.

Lessee Qualifications 43 CFR Subpart 3202

Under 43 CFR 3202.11, an applicant for a geothermal lease must submit proof of qualifications within 30 days after receipt of a request from the BLM to provide additional information regarding an application for a geothermal lease. The BLM needs this information to verify that the respondent meets all the lessee qualification requirements.

Nomination of Lands for Competitive Leasing 43 CFR Subpart 3203

Under 43 CFR 3203.5(a)(1)(i), 3203.10, 3203.11(a), and 3203.12, a qualified company or individual may nominate lands for geothermal development by submitting BLM Form 3203-1, Nomination of Lands for Competitive Geothermal Leasing. The BLM uses this information to determine whether or not to offer nominated parcels as a block in response to a Nomination of Lands for Competitive Geothermal Leasing. If the BLM decides to offer the nominated lands for leasing, it also uses the information to prepare a Notice of Competitive Geothermal Lease Sale. A processing fee is required.

Specific information we request on Form 3203-1:

1. The name and address of the company or individual submitting the nomination. We require this information to identify the company or individual submitting the nomination, to determine whether the company or individual is qualified to submit a nomination, and to correspond with that company or individual.

2. The name of the surface managing agency if other than the BLM. We require this information to correspond and consult with that agency.

3. The unit or project. We require this information if the nomination includes a request that the BLM offer the lands as a block under 43 CFR 3203.11. Such a request must specify that the lands will be associated with a project or unit.

4. Separate descriptions of public-domain and acquired lands that are nominated, by township, range, section, meridian, state, and county. We require this information to determine what lands are nominated.

5. A check mark if the nomination is part of a block nomination. We require this information to determine if the nomination includes a request that the BLM offer the lands as a block under 43 CFR 3203.11.

6. The total acres nominated. We require this information to determine if the total acreage nominated is in compliance with 43 CFR 3203.10(b).

7. Amount remitted. We require this information to determine if the nominator has submitted a filing fee in compliance with 43 CFR 3203.12.

8. Printed name and signature of nominator or attorney-in-fact. We require this information as proof of the authenticity of the nomination.

Noncompetitive Leasing Other Than Direct Use Leases 43 CFR Subpart 3204

The respondent may file a noncompetitive lease application for lands that were not sold at a competitive lease sale. The BLM needs this information to process noncompetitive lease applications.

Direct Use Leasing 43 CFR Subpart 3205

The respondent may file an application for lease for direct use (i.e., direct use of the geothermal heat and not for electricity generation) for any lands on which the BLM manages geothermal resources. The BLM needs this information to process the application for a direct use lease.

Lease Issuance 43 CFR Subpart 3206

The respondent must accept all lease stipulations; make all required payments to the BLM; sign a unit joinder or waiver, if applicable; and comply with the maximum limit on acreage holdings before the BLM issues a lease. The BLM needs this information to decide whether or not to issue a lease.

Lease Terms and Extensions 43 CFR Subpart 3207

The respondent must perform development activities that provide geologic or reservoir information during the lease term and extension. The BLM needs this information to approve the various development activities during the lease term.

Lease Consolidation 43 CFR Subpart 3210

The respondent must submit a request in writing to the BLM to consolidate two or more adjacent leases that have the same ownership and same lease terms, if the combined leases do not exceed the size limitation in 43 CFR 3206.12. The BLM may consolidate leases that have different stipulations if all other lease terms are the same. A processing fee in accordance with the fee schedule at 43 CFR 3000.12 must accompany a request to consolidate leases.

Lease Suspensions and Royalty Rate Reductions 43 CFR Subpart 3212

The respondent must submit a request in writing to the BLM to:

(1) Suspend the operations and production for a producing lease;

(2) Suspend, reduce, or waive royalty or rental; and

(3) Apply for a production incentive.

The BLM needs this information to determine if the respondent qualifies for these actions.

Lease Relinquishment, Termination, and Cancellation 43 CFR Subpart 3213

The respondent must submit a request in writing to the BLM if it wants to relinquish, terminate, or cancel a lease. The BLM needs this information to determine if the respondent qualifies for one of these actions.

Lease Reinstatement 43 CFR Subpart 3213

The respondent must submit a request in writing to the BLM in order to request reinstatement of a lease. Along with such a request, the respondent must pay any past-due rent. The BLM needs both elements in order to determine if the respondent qualifies for reinstatement.

Cooperative Agreements 43 CFR Subpart 3217

The respondent must submit to BLM an application and the information under this subpart to establish a cooperative agreement for any lands the BLM manages the geothermal resources. The BLM needs this information to process the application for a cooperative agreement.

Notice of Intent to Conduct Geothermal Exploration Activities 43 CFR Subpart 3251

The respondent must file Form 3200-9, Notice of Intent to Conduct Geothermal Resource Exploration Operations, along with required nonform information under this subpart to obtain approval of operations on BLM-managed lands. The BLM needs this information to determine whether or not to approve the application.

Specific information we request on Form 3200-9:

(1) The name(s) and address(es) of the Applicant(s), Operator, and Contractor(s) and the telephone number of the Operator. We require this information to identify all persons who will be conducting operations on the lands and to correspond with them.

(2) Description of lands by township, with map or maps showing lands to be entered or affected. We require this information to determine the area to be entered or disturbed by the proposed exploration operations.

(3) Type of operations to be conducted. We require this information to determine whether the applicant/operator/contractor is complying with the provisions of the regulations.

(4) Exploration operations will be conducted during the period (date) of commencement and completion. We require this information to determine how long the applicant/operator/contractor intends to conduct exploration operations on the land.

(5) Amount and type of financial assurance to be supplied: Surety bond, Rider to Nationwide bond, Rider to Statewide bond, Bond to be furnished. We require the applicant to indicate the type of bond coverage that will cover the exploration operations.

(6) Signatures. We require signatures to demonstrate that the applicant/operator/contractor understands that he/she must comply with the provisions of the notice of intent.

Geothermal Sundry Notice 43 CFR Subpart 3252

The respondent must file Form 3260-3, Geothermal Sundry Notice, to obtain approval of operations on BLM-managed lands. The BLM needs this information to approve the application.

Specific information we request on Form 3260-3:

Items 1-14 provide location of the well, its status, the responsible operator, the appropriate surface management agency, and the type of work requested. Item 15 provides for the current conditions of the well (hole size, casing, perforations, etc.) along with all proposed additions and/or changes. Item 16 allows for identification of associated engineering forms and specifications. Item 17 certifies the agreement between the operator and the BLM. The subsequent report would provide a record of what was done and the results. We use this information to assess the feasibility of future work.

Reports: Exploration Operations 43 CFR 3253

The respondent must submit to the BLM a complete exploration operations report within 30 days after:

• Completing any geophysical exploration operations;

• Completing the drilling of temperature gradient well(s) approved under the notice of intent to conduct exploration;

• Plugging and abandon a temperature gradient well; and

• Plugging shot holes and reclaim all exploration sites.

The BLM needs this information to ensure compliance with the conditions specified by the BLM at the time of approving a Notice of Intent to Conduct Geothermal Resource Exploration Operations.

Exploration Operations Relief and Appeals 43 CFR Subpart 3256

The respondent must submit a request in writing for a variance from the BLM requirements for exploration operations. The BLM needs this information to determine if the respondent qualifies for the variance.

Geothermal Drilling Permit 43 CFR Subpart 3261

The respondent must file Form 3260-2, Geothermal Drilling Permit, and comply with the requirements of this subpart to obtain approval of operations on BLM-managed lands. The BLM needs this information to determine whether or not to approve the application for a drilling permit.

Specific information we request on Form 3260-2:

Items 1-17 identify the lessee/operator, well location, approximate starting dates, and lease numbers. Items 18-21 provide for the altitude of the ground and derrick floor above sea level and how it was determined, along with the associated drilling and casing programs containing size and weight of casing, setting depth of each string, and the amount of cement to be used. Item 22 provides a summary of the associated requirements for a drilling permit, e.g., blowout prevention diagram and access road maps. Item 23 certifies the agreement between the operator and the BLM.

Geothermal Well Completion Report 43 CFR Subpart 3264

The respondent must file Form 3260-4, Geothermal Well Completion Report, within 30 days after completion of a well. The BLM needs this information to approve all aspects of the activities related to drilling operations.

Specific information we request on Form 3260-4:

Items 1-12 identify the operator, well type and location, and type of completion. Items 13-23 provide technical information covering the depth, direction, core sizes, and dates of completion. Items 24-28 provide data on the casing, liner, tubing, workover, or completion activity (cement squeeze, fracture, etc.), and the perforation records. Item 29 provides information on past drilling and completion reports. Items 30-31 indicate the current status of the well and whether or not it is commercially viable. Item 32 certifies the agreement between the operator and the BLM. Items 33-37 provide important well test data.

Utilization Plans and Facility Construction Permits 43 CFR Subpart 3272

The respondent must file an application for a utilization plan and facility permit in accordance with the requirements in this subpart for any lands where the BLM manages the geothermal resources. The BLM needs this information to process the application for a utilization plan and facility permit.

Site License Application 43 CFR Subpart 3273

The respondent must file an application for a site license and the information under this subpart for any lands where the BLM manages the geothermal resources. The BLM needs this information to process the application for a site license.

Relinquishment, Assignment, or Transfer of a Site License 43 CFR Subpart 3273

Under 43 CFR 3273.25, a holder of a site license may request approval to relinquish the site license by sending the BLM a written notice requesting relinquishment review and approval. Under 43 CFR 3273.26, a holder of a site license may apply for assignment or transfer of the site license in whole or in part by sending the BLM a completed and signed transfer application and the filing fee for assignment or transfer found in the fee schedule at 43 CFR 3000.12. The application must include a written statement that the transferee will comply with all license terms and conditions, and that the lessee accepts the transfer.

Commercial Use Permit 43 CFR Subpart 3274

The respondent must file an application for a commercial use permit and the information under this subpart for any lands where the BLM manages the geothermal resources. The BLM needs this information to process the application for a commercial use permit.

Monthly Report of Geothermal Operations 43 CFR Subpart 3276

Subpart 3276 requires operators to file Form 3260-5, Monthly Report of Geothermal Operations, each month beginning with the month in which commercial production and operation begins. The BLM needs this information to evaluate the amount and quality of production received from geothermal resources on Federal lands. The information that is required depends on the type of operation.

Under 43 CFR 3276.10, the following information is required:

• A lessee or unit operator supplying Federal geothermal resources to a utilization facility on Federal land leased for geothermal resources must submit a monthly report of well operations for all wells on the lease or unit.

• An operator of a utilization facility (e.g., for electrical generation or direct use) on Federal land leased for geothermal resources must submit a monthly report of facility operations.

• Any person or entity that is both a lessee or unit operator and the operator of a utilization facility on Federal land leased for geothermal resources is allowed to combine the first two requirements in a single monthly report.

Unless the BLM grants a variance, the monthly reports must be received by the BLM by the end of the month following the month that the report covers. For example, the report covering the month of July is due by August 31.

Under 43 CFR 3276.11, the monthly report of well operations must include the following information:

• Any drilling operations or changes made to a well;

• Total production or injection in thousands of pounds (klbs);

• Production or injection temperature in degrees Fahrenheit;

• Production or injection pressure in pounds per square inch (psi), and whether this is gauge pressure (psig) or absolute pressure (psia);

• The number of days the well was producing or injecting;

• The well status at the end of the month;

• The amount of steam or hot water lost to ventage or leakage, if the amount is greater than 0.5 percent of lease production (the BLM may modify this standard by a written order describing the change);

• The lease number or unit name where the well is located;

• The month and year to which the report applies;

• The respondent’s name, title, signature, and a phone number where the BLM may contact the respondent; and

• Any other information that the BLM may require.

The monthly reporting requirements for electrical generation facilities are at 43 CFR 3276.12 and 3276.13. Under 43 CFR 3276.12(a), the monthly report of facility operations for all electrical generation facilities must include the following information:

• Mass of steam and/or hot water, in klbs, used or brought into the facility (for facilities using both steam and hot water, the mass of each must be reported);

• The temperature of the steam or hot water in degrees Fahrenheit;

• The pressure of the steam or hot water in psi, and whether this is psig or psia;

• Gross generation in kilowatt hours (kwh);

• Net generation at the tailgate of the facility in kwh;

• Temperature in degrees Fahrenheit and volume of the steam or hot water existing the facility;

• The number of hours the plant was on line;

• A brief description of any outages; and

• Any other information the BLM may require.

Under 43 CFR 3276.12(b), a monthly report of facility operations for electrical generation facilities where Federal royalty is based on the sale of electricity to a utility must include the following additional information:

• Amount of electricity delivered to the sales point in kwh, if the sales point is different from the tailgate of the facility;

• Amount of electricity lost to transmission;

• A report from the utility purchasing the electricity documenting the total number of kwh delivered to the sales point during the month, or monthly reporting period if it if not a calendar month, and the number of kwh delivered during diurnal and seasonal pricing periods; and

• Any other information the BLM may require.

In addition to the information required under 43 CFR 3276.12, the following information is required under 43 CFR 3276.13 for flash and dry steam facilities:

• Steam flow into the turbine in klbs (for dual flash facilities, the steam flow must be separated into high pressure steam and low pressure steam);

• Condenser pressure in psia;

• Condenser temperature in degrees Fahrenheit;

• Auxiliary stem flow used for gas ejectors, steam seals, pumps, etc., in klbs;

• Flow of condensate out of the plant (after the cooling towers) in klbs; and

• Any other information the BLM may require.

Under 43 CFR 3276.14, the monthly report of operations for direct-use facilities must include the following information:

• Total monthly flow through the facility in thousands of gallons of klbs;

• Monthly average temperature in degrees Fahrenheit;

• Number of hours that geothermal heat was used; and

• Any other information the BLM may require.

Unit Agreement 43 CFR Subpart 3281

The respondent must submit to the BLM an application and the information required under this subpart to establish a unit agreement or area for any lands the BLM manages the geothermal resources. The BLM needs this information to process the application for a unit agreement or area.

Participating Area 43 CFR Subpart 3282

The respondent must submit to the BLM an application and the information required under this subpart to establish a unit agreement or area for any lands the BLM manages the geothermal resources. The BLM needs this information to process the application for a unit agreement or area.

Unit Agreement Modifications 43 CFR Subpart 3283

The respondent must submit to the BLM a request in writing to revise a unit agreement or area for any lands where the BLM manages the geothermal resources. The BLM needs this information to process the request to revise the unit agreement or area.

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 forms in this collection are 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 one of the forms electronically may do so by scanning and then emailing it to the appropriate BLM office.

As discussed above in Item # 2, the BLM’s GRASS database is undergoing a major update to allow for greater program efficiency and user interface by the geothermal industry.  GRASS II will incorporate changes to information collected using the forms authorized by this control number.  This update is expected to be completed within the next 12 months including any necessary revisions to these forms.  Changes to these forms now would likely not be consistent with changes resulting from this ongoing program review and GRASS II update. Accordingly, the BLM plans to submit an information collection request within approximately 12 months to revise the forms for this control number.

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 of information occurs in the information we collect. The requested information is unique to the operator/operating rights owner and the lease and is not available from any other data source. No similar information is available or able to be modified. The information is required to obtain or retain a benefit.

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

The BLM is not required to collect information on whether the respondents qualify as small businesses or small entities. The percentage of respondents that are small businesses or other small entities varies depending on the type of response. The information we require from all respondents is limited to the minimum necessary to authorize and manage geothermal operations on 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, or collected it less frequently, geothermal resources leasing activities and operations could not occur on Federal lands in accordance with applicable statutes and other authorities.

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.

The regulations at 43 CFR subpart 3276 require operators to file Form 3260-5, Monthly Report of Geothermal Operations, each month beginning with the month in which commercial production and operation begins. The BLM needs this information more often than quarterly in order to evaluate adequately the amount and quality of production received from geothermal resources on Federal lands.

There are no other 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 January 27, 2023, the BLM published the proposed rule in the Federal Register providing interested parties and the general public 60 days to comment on the proposed renewal of this OMB Control Number. (88 FR 5373), and the comment period ended on March 28, 2023. The BLM received no comments in response to this notice.

Additionally, as required by 5 CFR 1320.5(a)(1)(iv), BLM will publish a notice in the Federal Register announcing the submission of this request to OMB, and allowing the public 30 days to send comments on the proposed extension of this OMB number to OMB.

The BLM has consulted with the following respondents to obtain their views on the availability of data; frequency of collection; the clarity of instructions; the recordkeeping, disclosure, and reporting formats; and on the data elements to be recorded, disclosed, or reported:

• Land & Lease Manager, Ormat Technologies Inc., Reno, NV;

• Landman, Cyrq Energy, LLC, Salt Lake City, UT; and

• PLS Environmental, LLC, On behalf of Davenport Newberry Holdings, LLC, Seattle, WA.

The BLM did not receive any feedback from this outreach effort.

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.

The BLM handles any proprietary data submitted under 43 CFR part 3200 or part 3280 in accordance with the regulations at 43 CFR part 2 (Records and Testimony; Freedom and Information Act) and 43 CFR subpart 3255 (Confidential, Proprietary Information). These regulations provide that data will be subject to disclosure under the Freedom of Information Act unless:

• Each page of data that the respondent believes is confidential is clearly marked, and

• The operator submits such data to the BLM separately from other materials.

The BLM will keep information marked in this manner confidential to the extent allowed by the Freedom of Information Act (5 U.S.C. 552) and 43 CFR part 2. Material not so marked will not be withheld from disclosure to the public.

The Indian Mineral Development Act (25 U.S.C. 2101 - 2108) and 43 CFR 3255.13 authorize the withholding from disclosure of the following information of Indians and Indian tribes:

• All findings forming the basis of the Secretary’s intent to approve or disapprove any Minerals Agreement under the Indian Mineral Development Act; and

• All projections, studies, data, or other information concerning a Mineral Agreement under the Indian Mineral Development Act, regardless of the date received, related to:

• The terms, conditions, or financial return to the Indian parties;

• The extent, nature, value, or disposition of the Indian mineral resources; or

• The production, products, or proceeds thereof.

Regulations at 43 CFR 3255.14 and 3255.15 address, respectively, how the BLM manages information submitted under the Indian minerals not covered by 43 CFR 3255.13, and consultations with Indian mineral owners when information concerning their minerals is the subject of a request under the Freedom of Information Act. The gist of these two regulations is that the BLM will comply with the Freedom of Information Act and the regulations at 43 CFR Part 2 in those situations.

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.

The estimated hourly cost for respondents is shown at Table 12-1. The hourly wage for Table 12-1 was determined using national Bureau of Labor Statistics data at: http://www.bls.gov/oes/current/oes_nat.htm. The benefits multiplier of 1.3 is supported by information at http://www.bls.gov/news.release/ecec.nr0.htm.

Table 12-1: Estimated Weighted Average Hourly Costs

Position	Mean Hourly Pay Rate	Hourly Rate with Benefits (Hourly Pay Rate x 1.3)	Percent of Collection Time	Weighted Average Hourly Cost
General Office Clerk (43-9061)	$18.16	$23.61	10%	$2.36
Engineer (17-2199)	$51.47	$66.91	80%	$53.53
Engineering Manager (11-9041)	$76.01	$98.81	10%	$9.88
Totals:			100%	$65.77

Hour and cost burdens to respondents include time spent for researching, preparing, and submitting information. The weighted average hourly wage is shown at Table 12-1, above. The BLM’s estimate of the time it takes a respondent to supply the information was verified by consultations with several respondents (see Item 8, above).

The frequency of response for most aspects of this collection is “on occasion.” The sole exception is for file Form 3260-5, Monthly Report of Geothermal Operations (which is filed once a month).

Table 12-2: Estimated Hour and Cost Burdens

Collection of Information	Number of Responses	Hours Per Response	Annual Hours	Hourly Cost	Total Wage Cost
43 CFR subpart 3202 Lessee Qualifications	125	1	125	$65.77	$8,221
43 CFR subpart 3203 Nomination of Lands for Competitive Leasing Form 3203-1	1,245	1	1,245	$65.77	$81,884
43 CFR subpart 3204 Noncompetitive Leasing Other Than Direct Use Leases	24	4	96	$65.77	$6,314
43 CFR subpart 3205 Direct Use Leasing	10	10	100	$65.77	$6,577
43 CFR subpart 3206 Lease Issuance	125	1	125	$65.77	$8,221
43 CFR subpart 3207 Lease Terms and Extensions	16	1	16	$65.77	$1,052
43 CFR subpart 3210 Lease Consolidation	1	1	1	$65.77	$66
43 CFR subpart 3212 Lease Suspensions and Royalty Rate Reductions	2	40	80	$65.77	$5,262
43 CFR subpart 3213 Lease Relinquishment, Termination, and Cancellation	7	40	280	$65.77	$18,416
43 CFR subpart 3213 Lease Reinstatement	1	1	1	$65.77	$66
43 CFR subpart 3217 Cooperative Agreements	1	40	40	$65.77	$2,630
43 CFR subpart 3251 Notice of Intent to Conduct Geothermal Exploration Activities Form 3200-9	8	8	64	$65.77	$4,209
43 CFR subpart 3252 Geothermal Sundry Notice Form 3260-3	100	8	800	$65.77	$52,616
43 CFR subpart 3253 Reports: Exploration Operations	1	8	8	$65.77	$66
43 CFR subpart 3256 Exploration Operations Relief and Appeals	1	8	8	$65.77	$66
43 CFR subpart 3261 Geothermal Drilling Permit Form 3260-2	12	8	96	$65.77	$6,314
43 CFR subpart 3264 Geothermal Well Completion Report Form 3260-4	12	10	120	$65.77	$7,892
43 CFR subpart 3272 Utilization Plans and Facility Construction Permits	1	10	10	$65.77	$657
43 CFR subpart 3273 Site License Application	1	10	10	$65.77	$657
43 CFR subpart 3273 Relinquishment, Assignment, or Transfer of a Site License	1	1	1	$65.77	$66
43 CFR subpart 3274 Commercial Use Permit	10	10	100	$65.77	$6,577
43 CFR subpart 3276 Monthly Report of Geothermal Operations Form 3260-5	120	10	1200	$65.77	$78,924
43 CFR subpart 3281 Unit Agreements	1	10	10	$65.77	$657
43 CFR subpart 3282 Participating Area	1	10	10	$65.77	$657
43 CFR subpart 3283 Unit Agreement Modifications	1		10	$65.77	$657
Totals:	1,827	_----	4,556	----	$298,724

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.

Since this information collection has been in place for many years, respondents incur no annual capital or start-up costs in order to comply with this information collection. We estimate a total non-hour cost burden of which comes from processing fees.

Processing fees are for some, but not all, of the activities in this collection. These fees are set and are updated annually in accordance with 43 CFR 3000.12. The most recent updates were published at 87 FR 57641 (Sept. 21, 2022).

All of the regulations pertaining to these processing fees were promulgated in accordance with FLPMA Section 304 (43 U.S.C. 1734), and the Independent Offices Appropriation Act (31 U.S.C. 9701), which authorize the BLM to charge processing costs. Moreover, OMB Circular No. A-25, titled “User Charges,” provides that the Federal policy is to assess a charge against each identifiable recipient for special Federal benefits beyond those received by the general public.

The estimated non-hour cost burdens for this information collection are shown below in Table 13.

Table 13: Non-Hour Cost Burdens

Collection of Information	Number of Responses	Processing Fee	Annual Cost Burden
43 CFR subpart 3203 Nomination of Lands for Competitive Leasing	1,245	$135 plus $0.13 per acre = $4991	$621,255
43 CFR subpart 3204 Noncompetitive Leasing Other Than Direct Use Leases	24	$475	$11,400
43 CFR subpart 3210 Lease Consolidation	1	$525	$525
43 CFR subpart 3213 Lease Reinstatement	1	$90	$90
43 CFR subpart 3273 Site License Application	1	$70	$70
43 CFR subpart 3273 Relinquishment, Assignment, or Transfer of a Site License	1	$70	$70
Totals:	1,273		$633,410

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 estimated hourly cost to the Federal Government is shown in Table 14-1 and is based on the U.S. Office of Personnel Management Salary Table at: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/23Tables/html/RUS_h.aspx. The benefits multiplier of 1.6 is implied by information at: http://www.bls.gov/news.release/ecec.nr0.htm.

Table 14-1: Weighted Average Hourly Cost

Position and Pay Grade	Hourly Pay Rate ($/hour)	Benefits Multiplier	Hourly Rate with Benefits	Percent of Collection Time	Weighted Average
Clerical GS-5, step 5	$20.47	1.6	$32.75	10%	$3.28
Professional GS-9, step 5	$31.02	1.6	$49.63	80%	$39.70
Managerial GS-13, step 5	$53.49	1.6	$85.58	10%	$8.56
Totals:				100%	$51.54

The Table below shows the annualized Federal costs for each collection. The estimated time spent to process the information collections is based on the BLM's experience. The weighted average hourly wage is shown at Table 14-1, above.

Table 14-2: Estimated Annual Cost to the Government

Collection of Information	Number of Responses	Staff Hours Per Response	Total Staff Hours	Hourly Staff Cost	Total Wage Cost
43 CFR subpart 3202 Lessee Qualifications	125	1	125	$51.54	$6,443
43 CFR subpart 3203 Nomination of Lands for Competitive Leasing Form 3203-1	1,245	1	1,245	$51.54	$64,167
43 CFR subpart 3204 Noncompetitive Leasing Other Than Direct Use Leases	24	4	96	$51.54	$4,948
43 CFR subpart 3205 Direct Use Leasing	10	10	100	$51.54	$5,154
43 CFR subpart 3206 Lease Issuance	125	1	125	$51.54	$6,443
43 CFR subpart 3207 Lease Terms and Extensions	16	1	16	$51.54	$825
43 CFR subpart 3210 Lease Consolidation	1	1	1	$51.54	$52
43 CFR subpart 3212 Lease Suspensions and Royalty Rate Reductions	2	40	80	$51.54	$4,123
43 CFR subpart 3213 Lease Relinquishment, Termination, and Cancellation	7	40	280	$51.54	$14,431
43 CFR subpart 3213 Lease Reinstatement	1	4	4	$51.54	$206
43 CFR subpart 3217 Cooperative Agreements	1	40	40	$51.54	$2,062
43 CFR subpart 3251 Notice of Intent to Conduct Geothermal Exploration Activities Form 3200-9	8	8	64	$51.54	$3,299
43 CFR subpart 3252 Geothermal Sundry Notice Form 3260-3	100	8	800	$51.54	$41,232
43 CFR subpart 3253 Reports: Exploration Operations	1	8	8	$51.54	$412
43 CFR subpart 3256 Exploration Operations Relief and Appeals	1	8	8	$51.54	$412
43 CFR subpart 3261 Geothermal Drilling Permit Form 3260-2	12	8	96	$51.54	$4,948
43 CFR subpart 3264 Geothermal Well Completion Report Form 3260-4	12	10	120	$51.54	$6,185
43 CFR subpart 3272 Utilization Plans and Facility Construction Permits	1	10	10	$51.54	$515
43 CFR subpart 3273 Site License Application	1	10	10	$51.54	$515
43 CFR subpart 3273 Relinquishment, Assignment, or Transfer of a Site License	1	1	1	$51.54	$52
43 CFR subpart 3274 Commercial Use Permit	10	10	100	$51.54	$5,154
43 CFR subpart 3276 Monthly Report of Geothermal Operations Form 3260-5	120	10	1,200	$51.54	$61,848
43 CFR subpart 3281 Unit Agreements	1	10	10	$51.54	$515
43 CFR subpart 3282 Participating Area	1	10	10	$51.54	$515
43 CFR subpart 3283 Unit Agreement Modifications	1	10	10	$51.54	$515
Totals:	1,827		4,559		$234,971

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

There are no program changes. There is an estimated adjustment of +914 responses (from 913 to 1,827) and -853 hours (from 5,409 to 4,556). These adjustments are a result to updating burden estimates based on current program data. There is also an adjustment of +$548,425 in non-hour cost burden (from $84,985 to $633,410). This adjustment results from inflation-adjusted cost of certain reporting requirements.

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 not publish the results of this collection.

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 forms included in this information collection. Additionally, the OMB number and expiration are available at www.reginfo.gov

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 requirements outlined in 5 CFR 1320.9.

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1 On average, a nomination covers 2,800 acres. Thus, on average, the processing fee includes an “acreage surcharge” of $336.00.

1