Supporting Statement A for
Paperwork Reduction Act Submission
North American Woodcock Singing Ground Survey
OMB Control Number 1018-0019
Terms of Clearance: None
The Migratory Bird Treaty Act (MBTA; 16 U.S.C. 703–712) requires the Secretary of the Interior, delegated to the U.S. Fish and Wildlife Service (we, Service, FWS), to implement a viable and ongoing program for the protection and conservation of various migratory birds. The MBTA designates the Department of the Interior as the primary agency responsible for:
Management of migratory bird populations frequenting the United States, and
Setting hunting regulations that allow for the well-being of migratory bird populations.
These responsibilities dictate that we gather accurate data on various characteristics of migratory bird populations. The North American Woodcock Singing Ground Survey is an essential part of the migratory bird management program. State, local, Tribal, U.S. Federal, and Canadian Provincial conservation agencies conduct the survey annually to provide the data necessary to determine the population status of the American woodcock. In addition, the information is vital in assessing the relative changes in the geographic distribution of the species.
The Service’s Division of Migratory Bird Management (DMBM) uses the information to assess the status of woodcock populations and to develop recommendations for hunting regulations. The Service, State, and Canadian Provincial conservation agencies, university associates, and other interested parties also use the information for various research and management projects. The Canadian Wildlife Service, Provinces, and States rely on the Service to administer and coordinate this survey.
State, local, Tribal, U.S. Federal, and Canadian Provincial conservation agencies, as well as other participants, use FWS Form 3-156 to conduct annual field surveys. Instructions for completing the survey and reporting data are on the reverse of the form or within the data collection application. Observers can utilize the data collection application with a mobile device in the field to collect/report survey data or scan/email the paper version of Form 3-156 to their assigned coordinator who will then enter the data via the data collection application.
We collect observer information (name, email address, and agency they work for) so that we can contact the observer if questions or concerns arise. Observers provide information on:
Sky condition, temperature, wind, and precipitation.
Survey date.
Stop number.
Stop location.
Mileage accrued.
Time at each stop.
Number of American Woodcock males heard peenting.
Disturbance level.
Comments concerning the survey.
We use the information that we collect to analyze the survey data and prepare reports. Assessment of the population's status serves to guide the Service, the States, and the Canadian Government in the annual promulgation of hunting regulations.
The latest results from the survey collection are available to the public over the Internet at https://fws.gov/library/collections/american-woodcock-population-status-reports or by contacting the Service to receive in a summarized, tabular format.
Proposed Revisions
We request OMB approval to revise our American Woodcock Singing-ground Survey data collection and data entry process over the 2023-2024 period. We plan to develop and implement a new mobile application, along with a new web browser data entry method. The yet-to-be-developed application will operate on portable electronic devices while conducting field surveys (see question 3 below). The data entry feature would still be collecting data on all the same fields within the survey form.
While we still plan to administer the paper-based survey form to every observer, the observer is not required to submit the paper-based results unless the observer does not utilize the data collection mobile application in the field. Instead, data entry will occur through the application’s web browser after the survey is complete. A mapping feature within the new application will allow observers to see each stop location along the route and keep track of their current location. This will assist in stop location verification efforts and help maintain a verified spatial reference for the survey.
Initially, we expect the burden time to be higher as respondents adjust to the new method to collect and enter data, and for reviewing the updated instructions and completing the training. However, once observers are trained in using the application, the estimated burden will decrease in subsequent years.
The reporting procedure requires that observers/respondents fill out FWS Form 3-156 either by pen or pencil on a paper version or by using a data collection application on a mobile device in the field or after they return to the office. A PDF version of FWS Form 3-156 (pre-printed with unique individual route information) is distributed to every assigned observer before the survey season begins and an updated blank version is available on our website each spring (https://migbirdapps.fws.gov/woodcock/trainingtooldocs.htm). If respondents choose to complete the paper form in the field, they can voluntarily submit data via the data collection application using a secure login method that is accessible via a computer or mobile device. Survey forms are only collected by designated State and province coordinators if the respondent chooses not to submit data via the data collection application themselves. The State or province coordinator would then report the results on behalf of the respondent/observer using the data collection application’s offline feature. If respondents choose to utilize the data collection application while conducting the survey, results are reported as soon as they fill out the electronic form in its entirety and submit their data. This method will streamline data processing steps and increase data accuracy.
Respondents will access the data collection application through a secure login method. Respondents will need to download the application to their mobile device and register before being able to use it or they may access it through a secure login method via the web. Much of the electronic form is pre-filled with specific variables that helps reduce data entry time and ensures data accuracy.
Proposed Revisions
At this time, the Service has not finalized the new application which will allow for mobile and web browser data entry. The Service will partner with the Canadian Wildlife Service and Birds Canada to develop these two features through NatureCounts.
The Service will provide OMB with updated screenshots and details for the new system prior to the system going live. We chose to include this proposed revision with the regular renewal of this collection to ensure we provided the public with an opportunity to comment on the proposed revisions prior to requesting OMB approval change from the current web collection method to the new web browser collection method and mobile application. We anticipate the web browser application will be ready by early spring 2024. While some observers may be able to utilize the mobile application in the spring of 2024, we do not anticipate it being fully operational until the spring of 2025.
We are not aware of any duplication. Within the Federal government, the DMBM is the sole organizational unit charged with monitoring the population status of migratory game birds. Also, the realm of migratory bird management is small. If similar sources of information were available or even possible, DMBM would be aware of them.
The survey does not impact small businesses or other small entities.
Migratory game bird populations are dynamic and can change in size and status from year to year. For this reason, the promulgation of hunting regulations has traditionally been an annual activity, and, thus, annual assessments of the population status of the more important species, including woodcock, are desirable. Without information on the population's status, we might promulgate hunting regulations that are:
Not sufficiently restrictive, which could cause harm to the woodcock population, or
Too restrictive, which would unduly restrict recreational opportunities afforded by woodcock hunting.
Another consequence of not conducting the surveys is that we could be vulnerable to litigation charging mismanagement and failure to fulfill treaty and other obligations.
* 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.
No special circumstances exist that require us to conduct this collection in a manner inconsistent with OMB guidelines.
On February 28, 2023, we published in the Federal Register (88 FR 12695) a notice of our intent to request that OMB approve this information collection. In that notice, we solicited comments for 60 days, ending on May 1, 2023. In an effort to increase public awareness of, and participation in, our public commenting processes associated with information collection requests, the Service also published the Federal Register notice on Regulations.gov (Docket No. FWS-HQ-MB-2023-0003) to provide the public with an additional method to submit comments (in addition to the typical [email protected] email and U.S. mail submission methods).
On August 9, 2023, we published in the Federal Register (88 FR 53902) a notice reopening the comment period to provide the public with an opportunity to comment on the proposed revisions to this information collection that we planned to submit to OMB for approval. In that second notice, we solicited comments for 60 days, ending on October 10, 2023. In an effort to increase public awareness of, and participation in, our public commenting processes associated with information collection requests, the Service also published the Federal Register notice on Regulations.gov (Docket No. FWS-HQ-MB-2023-0003) to provide the public with an additional method to submit comments. We received one comment in response to that second notice, but it did not address the information collection requirements. Therefore, no response is required.
In addition to the Federal Register notice, we consulted with the nine (9) individuals identified below who were familiar with this collection of information in order to validate our time burden estimate and asked for comments on the questions below:
Organization Title
Maryland Department of Natural Resources Game Bird Biologist
Michigan Department of Natural Resources Senior Wildlife Technician
New Jersey Division of Fish and Wildlife Upland Game Biologist
New York State Department of Environmental Conservation Small Game Unit Leader
Ohio Department of Natural Resources Wildlife Research Technician
West Virginia Division of Natural Resources Migratory Game Bird Coordinator
Connecticut Department of Energy and Environmental Protection Wildlife Biologist
Maine Department of Inland Fisheries and Wildlife Environmental Specialist
Volunteer Observer Volunteer
“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: Responses to this question indicated that all were necessary, concise, relevant, has utility, and is appropriate for woodcock management. It is necessary for the administrative Migratory Bird Flyways to select annual hunting regulatory hunting season alternatives. States and Provinces also use the information gathered from this survey for their own monitoring efforts of local population status. This survey has used the same methodology for many years, so it is important to keep the same format and procedures to maintain consistency.
Agency Response/Action Taken: There was no action taken by the Service since all thought there was practical utility, and it is necessary.
“The accuracy of our estimate of the burden for this collection of information”
Comments: Responses to this question were mostly in line with the accuracy of our estimated burden. One respondent did indicate it takes him an additional 15 minutes to pre-dive the route. Another respondent indicated it takes her longer to drive to and from the route location than Service estimates.
Agency Response/Action Taken: The pre-drive is not required for the survey, only recommended, thus why the Service doesn’t calculate it into the burden estimate. We have no measurable way of knowing exactly how many people do this each year and so we can't accurately calculate it into the estimate. A pre-drive is done by some observers so can they familiarize themselves with the route path and locate any obstacles ahead of conducting the survey during the time window. We calculate an average over all observers to obtain the estimated time it takes to drive to and from the route location. So, the actual time it takes may vary from one observer to another with some taking considerably more or less time to travel to and from the route’s location.
“Ways to enhance the quality, utility, and clarity of the information to be collected”
Comments: Responses included the following:
My only suggestion would be to print the county and omit the county code on the survey form to help avoid confusion.
There always seems to be an issue with a few observers each year trying to calculate the appropriate start time, but the coordinator wasn’t sure how to fix that.
The form is as good as it can be.
Use a platform like Survey123 that automatically records each stop's exact location, when we started listening at each point, and the associated data at each stop. The exact starting time would still need to be calculated, and as an administrator, I like to review the data before it is entered and add the data to my own local data bank.
Agency Response/Action Taken: The Service has already begun to switch over from using a county code system to the actual county or district name. Within the new application that is being created for data entry, our long-term goal is for it to have the ability to calculate the start time based on the observer's input if they select that they are collecting the data in the field during the survey. Once the app has the date of survey, sky code, and of course the route info, the start time would be generated for them. Additionally, the Service plans to provide each stop location on an interactive map that allows participants to see where they are in relation to the corresponding stop. Unfortunately, the coordinators’ ability to review the data before it gets submitted would not occur if observers chose to use this mobile application in the field. That being said, the Service is looking at adding a reporting feature that would allow state or province coordinators the ability to review the data, if they so choose to do so. We'd also look into having a reporting feature that lets the coordinator download their state/province's raw data once the survey has been completed and the data has been through the Service review process. However, due to staffing and resources, these reporting features will most likely not be available at first, but hopefully in subsequent years.
“Ways to minimize the burden of the collection of information on respondents”
Comments: Responses included the following:
If the form was in a format that could be completed on a cell phone, I might use it only because it is dark by the end of the survey which makes it a little more challenging to fill out paperwork. However, it would only be helpful if the form was easy to manage because the survey has to be completed quickly.
In my case, this has been a family tradition for many years so it is a welcome event. We do not consider it a burden at all and believe this is a value added program.
Respondent prefers to fill out a paper survey form and enter results online after the fact.
None at this time. My surveyors who volunteered for the trial run of the new method of survey data collection in 2023 gave me positive feedback and we’re looking forward to using this method in the future.
Agency Response/Action Taken: The Service is already developing a mobile application that can be used for data entry in the field. We are trying to make it as user friendly as possible knowing there are time constraints to completing the survey. The Service is still providing a survey form to each observer so they may use this in the field, if they prefer this method of data collection. A web version of the application will be available to enter data after the survey has been completed.
Additional comments received during the outreach:
Comments: Responses included the following:
It would be kind of interesting if you could create an electronic form that captured the time, set a timer and then had a drop down for # birds, check box for disturbance and a place to add notes.
The Service does a great job with the woodcock SGS.
My comment is that I believe this a great program and it is a pleasure to be a part of it. Both State and Federal staff have been wonderful to work with over the years. Anytime I have had questions or made requests they have been handled promptly. Thanks to all involved for doing such a great job!
I think the information that is collected now as part of the SGS is essential and the process is streamlined as much as it can be.
Agency Response/Action Taken: Within the planning phase for the mobile application we have incorporated a way to capture the time and provided a way for observers to record the number of birds and disturbance at each stop. There is also a place to add notes for each stop and a place to add notes before the survey even begins. There are also plans to incorporate a timer into the application.
Despite multiple attempts to solicit feedback, we did not receive responses from 3 of the 9 individuals contacted as part of the targeted outreach.
We do not provide payments or gifts to respondents.
We do not provide any assurance of confidentiality. Information is collected and protected in accordance with the Privacy Act (5 U.S.C. § 552a) and the Freedom of Information Act (5 U.S.C. 552). We will maintain the information in a secure System of Records (Migratory Bird Population and Harvest Surveys – Interior, FWS-26, 80 FR 27183, published May 12, 2015; modification published 88 FR 16277, March 16, 2023).
We do not ask sensitive questions.
* 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.
We are providing first year and subsequent year burden estimates; however, we are reporting the subsequent year burden estimates in ROCIS.
First Year Breakdown: We estimate there will be 820 annual responses totaling 2,928 annual burden hours associated with this information collection, with a total annualized cost burden of $155,541 (rounded).
Approximately 820 non-Federal observers conduct the survey and submit data annually. For each response, we estimate it will take observers from Canada and the United States an average of 1.92 hours to supply the needed information. This includes time for:
Reviewing instructions, map and training presentation (20 minutes)
Gathering data during survey stops (30 minutes)
Completing and reviewing the survey form (5 minutes)
Driving time to and from the survey site (1 hour)
Approximately 392 Canadian and United States observers (48% percent) will voluntarily choose to submit data electronically using an application in the field rather than use the survey form, which will add an additional 100 minutes to the response time, or a total of 3.58 hours per response. The additional time includes additional instructions and training (70 minutes) on using the new application and another 30 minutes to download the application and register as a new user.
Approximately 390 Canadian and United States observers (47%) will voluntarily choose to submit data electronically using an application after collecting data in the field, which will add an additional 108 minutes to the response time, or a total of 3.72 hours per response. The additional time includes additional instructions and training (70 minutes) on using the new application, another 30 minutes to download the application and register as a new user, and another 8 minutes to enter the data after collecting the data in the field.
Subsequent Year Breakdown:
We estimate there will be 820 annual responses totaling 1,626 annual burden hours associated with this information collection, with a total annualized cost burden of $86,128 (rounded).
Approximately 820 non-Federal observers conduct the survey and submit data annually. For each response, we estimate it will take observers from Canada and the United States an average of 1.92 hours to supply the needed information. This includes time for:
Reviewing instructions, map and training presentation (20 minutes)
Gathering data during survey stops (30 minutes)
Completing and reviewing the survey form (5 minutes)
Driving time to and from the survey site (1 hour)
Approximately 392 Canadian and United States observers (48% percent) will voluntarily choose to submit data electronically using an application in the field rather than using the survey form, which we estimate will take the same amount of time, an average of 1.92 hours to supply the needed information.
Approximately 390 Canadian and United States observers (47%) will voluntarily choose to submit data electronically using an application after collecting data in the field, which will add an additional 8 minutes to the response time, or a total of 2.05 hours per response.
Table 12.1 – Annual Response and Burden Hour Calculations
NOTE: We have a web browser application (app submission) and the mobile app (in the field app collection and submission). Respondents would use the web browser application if they collected their results on the paper form in the field and then went back to their computer after the survey to enter the results into the web browser application. We also now provide a breakdown between submissions in the U.S. and those in Canada.
Table 1 – Burden Estimates: First Year
Requirement |
Average No. of Annual Respondents |
Average No. of Responses Each |
Average No. of Annual Responses |
Average Completion Time per Response (Hours) |
Estimated Annual Burden Hours * |
Hourly Rate |
$ Value of Annual Burden Hours |
Survey – US (App Submission) REVISED |
|
|
|||||
Government |
290 |
1 |
290 |
3.72 |
1,079 |
56.21 |
60,650.59 |
Survey – CAN (App Submission) NEW |
|||||||
Foreign Gov. |
100 |
1 |
100 |
3.72 |
372 |
44.95 |
16,721.40 |
Survey – US (In the Field App Collection & Submission) NEW |
|||||||
Government |
291 |
1 |
291 |
3.58 |
1,042 |
$ 56.21 |
$ 58,570.82 |
Survey – CAN (In the Field App Collection & Submission) NEW |
|||||||
Foreign Gov. |
101 |
1 |
101 |
3.58 |
362 |
44.95 |
16,271.90 |
Survey – US |
|||||||
Government |
2 |
1 |
2 |
1.92 |
4 |
56.21 |
224.84 |
Survey – CAN NEW |
|||||||
Foreign Gov. |
36 |
1 |
36 |
1.92 |
69 |
44.95 |
3,101.55 |
TOTALS: |
820 |
|
820 |
|
2,928 |
|
$ 155,541.10 |
*Rounded
Table 2 – Burden Estimates: Subsequent Years
Requirement |
Average No. of Annual Respondents |
Average No. of Responses Each |
Average No. of Annual Responses |
Average Completion Time per Response (Hours) |
Estimated Annual Burden Hours * |
Hourly Rate |
$ Value of Annual Burden Hours |
Survey – US (App Submission) REVISED |
|
|
|||||
Government |
290 |
1 |
290 |
2.05 |
595 |
56.21 |
33,444.95 |
Survey – CAN (App Submission) NEW |
|
|
|||||
Foreign Gov. |
100 |
1 |
100 |
2.05 |
205 |
44.95 |
9,214.75 |
Survey – US (In the Field App Collection & Submission) NEW |
|
|
|||||
Government |
291 |
1 |
291 |
1.92 |
559 |
$ 31,421.39 |
|
Survey – CAN (In the Field App Collection & Submission) NEW |
|
|
|||||
Foreign Gov. |
101 |
1 |
101 |
1.92 |
194 |
44.95 |
8,720.30 |
Survey – US |
|
|
|||||
Government |
2 |
1 |
2 |
1.92 |
4 |
56.21 |
224.84 |
Survey – CAN NEW |
|
|
|||||
Foreign Gov. |
36 |
1 |
36 |
1.92 |
69 |
44.95 |
3,101.55 |
TOTALS: |
820 |
|
820 |
|
1,626 |
|
$ 86,127.78 |
*Rounded
We calculated the benefits for both U.S. and Canadian observers in accordance with Bureau of Labor Statistics (BLS) News Release USDL- 23-1971, September 12, 2023, Employer Costs for Employee Compensation—June 2023. We used the Occupational Employment and Wages, May 2022 (19-1023 Zoologists and Wildlife Biologists) from the Bureau of Labor Standards website to determine the dollar value of the U.S. burden hours [$34.91 (mean hourly labor cost for a State government zoologist/wildlife biologist) multiplied by 1.61 to account for benefits for State government employees, resulting in an annual cost factor of $56.21 per hour].
We used the Statistics Canada website, Table 14-10-0340-01 Employee wages by occupation, annual on October 23, 2023 to determine labor cost information for Canadian observers (average hourly wage rate for natural and applied sciences and related occupations). We obtained 2022 labor cost information for full time (15 years and over) biologists in each Province (Ontario, Nova Scotia, New Brunswick, Quebec, Prince Edward Island, and Manitoba) participating in the survey, and then averaged all the Provinces together. We estimate the average dollar value of a Canadian burden hour to be $38.24 CAD (see Table 12.3). Using the exchange rate in effect on October 23, 2023 (1.00 CAD = 0.73 USD), we estimate the dollar value of a Canadian burden hour to be $27.92 USD, which we multiplied by 1.61 to account for benefits ($44.95 USD).
Table 12.2 – Calculation of Canadian Burden Hour Average
Average Hourly Overall
Location Wage ($) Average
Ontario $ 43.23
Nova Scotia 36.62
New Brunswick 37.88
Quebec 39.87
Prince Edward Island 33.85
Manitoba 38.00
Subtotal: $ 229.45 $ 38.24
* 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 are no nonhour burden costs to respondents.
The total estimated annual cost to the Federal Government is $82,450 (rounded), which includes $82,350 (rounded) for salaries and $100 for operating costs.
We used Office of Personnel Management Salary Table 2023-DCB to determine the annual wages and multiplied the hourly wage by 1.61 to account for benefits in accordance with BLS News Release USDL- 23-1971.
Table 14.1 - Salary Costs
Hourly Hourly Rate Total Total Salary
Position Grade/Step Rate (Incl. Benefits) Hours Costs
Wildlife biologist GS-12/05 $ 51.15 $ 82.35 1,000 $ 82,350
Table 14.2 - Operating Costs
Activity/Survey Costs
Materials $ 100
With this revision, we are reporting a discretionary burden change (increase) of 40 annual responses and 159 annual burden hours, as well as a change in estimate (reduction) of 38 annual responses and 66 annual burden hours.
Analytical techniques are in the annual American Woodcock Population Status Report under METHODS. We distribute this status report both internally and externally.
Form 3-156 sent to observers Early spring
Survey April – May
Collection of data April – June
Data analysis July
Report writing July – August
Publication date August
Service Regulations Committee Meeting (recommendations on hunting season) October
We will display the OMB control number and expiration date.
There are no exceptions to the certification statement.
-
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement for Paperwork Reduction Act Submission |
| Author | Anissa Craghead |
| File Modified | 0000-00-00 |
| File Created | 2023-11-21 |