Supporting Statement A for
Paperwork Reduction Act Submission
Migratory Bird Surveys, 50 CFR 20.20
OMB Control Number 1018-0023
Terms of Clearance. This is an early revision of OMB Control Number 1018-0023 to request approval of a 3-year pilot study with the development of a mobile application that hunters will use to take photos of the birds they harvest to be uploaded to our database. Additionally, biologists will use a web-based interface to examine and identify birds from the photos. Changes to this document since OMB’s last approval on May 26, 2023, are highlighted in yellow.
Migratory Bird Harvest Information Program: Under 50 CFR 20.20, migratory bird hunters must register for the Migratory Bird Harvest Information Program (HIP) in each state in which he or she hunts each year. State natural resource agencies are required to send names and addresses of all migratory bird hunters to the USFWS. The U.S. Fish and Wildlife Service (Service, we) sends surveys to selected hunters to estimate the magnitude and composition of migratory bird species harvest.
Migratory Bird Hunter Survey and Parts Collection Surveys: Under the Migratory Bird Treaty Act (16 U.S.C. 703-712), the Department of the Interior is designated as a key agency responsible for the wise management of migratory bird populations frequenting the U.S. and for the setting of hunting regulations that allow appropriate harvests of magnitudes that will allow for the populations' well-being. These responsibilities dictate the gathering of accurate data on various characteristics of migratory bird harvests of a temporal and geographic nature. The Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j) authorizes collection of such information as is necessary to determine the status of wildlife resources, which is necessary to develop appropriate hunting regulations. Information required for effectively governing harvests of migratory birds includes not only knowledge of the harvest's magnitude but also information of the species, age, and sex composition within that harvest, including the geographic and chronologic distribution of these components as they relate to various hunting regulations.
Sandhill Crane Harvest Survey: The cooperative management guidelines for mid-continent sandhill cranes (included are three currently recognized subspecies: lesser, Grus canadensis canadensis; Canadian, G. c. rowani; and greater, G. c. tabida) are aimed at providing optimum diverse recreational opportunity consistent with the welfare of the species and within the provisions of international treaties and socio-economic constraints. Beginning in 1960 and continuing to date, hunting seasons have been allowed for sandhill cranes in Alaska and all or part of eight Midwestern states (Colorado, Montana, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, and Wyoming) during specified time periods. In addition, Kansas allows a sandhill crane hunting season since 1993 and in northwest Minnesota since 2010. Prior to the initiation of the sandhill crane harvest questionnaire in 1975, little information was available on the number of individuals who annually hunt sandhill cranes or the number of harvested cranes. This lack of information was a major information gap in management of the species. Annual crane hunter activity and harvest information were readily available for Canada through uniform nationwide surveys conducted by the Canadian Federal Government. Lack of comparable information from the United States precluded ascertaining the total annual hunter harvest from this migratory bird resource shared by the two countries.
We collect data via various survey forms that are specific to the type of information being collected (e.g., online or mail survey form for Migratory Bird Hunter Survey, envelope for Parts Collection Survey). Data are collected by state natural resource agencies (Migratory Bird Harvest Information Program) and the Service (Migratory Bird Harvest Survey, Parts Collection Survey, and Sandhill Crane Harvest Survey). We collect all data each year because there is a reasonable expectation of significant changes in key statistics between collections. This is because:
(1) hunters change addresses over time;
(2) hunter success is dependent upon bird populations and migration chronology that can vary from year to year depending on weather and habitat conditions; and,
(3) research has indicated that there is substantial turnover in the hunters that participate each year.
Both Federal and state authorities use the collected information to monitor the effects of various hunting regulations on the harvest of individual migratory bird species. The information has been particularly useful in evaluating the effects of changes in daily bag limits, hunting season length, and hunting season dates on harvest. Information obtained also gives the Service a great deal of insight into the status of the many species involved.
We post annual reports on the Division of Migratory Bird Management’s (DMBM) website. Promulgation of annual hunting regulations by the Service relies on a well-defined process of monitoring data collection and scientific assessment. At key points during that process, Flyway technical committees, Flyway Councils (state agencies), consultants, and the public (and in some instances international regulatory agencies) review and provide valuable input on data collection and technical assessments. We deemed all assessments pertaining to the setting of annual harvest regulations “highly influential;” however, they are exempted from strict application of IQA peer-review guidelines due to the compressed time schedule associated with the regulatory process. Therefore, we do not post peer-review plans for technical assessments that influence annual hunting regulations decisions on the DMBM webpage. The DMBM has a long history of subjecting applicable portions of such technical assessments to formal peer-review through submission to scientific journals, or other means, in addition to the review received as part of the annual regulatory process. Information from each survey contributes towards a national program to monitor the harvest of all migratory game bird species in the U.S.
The Migratory Bird Harvest Information Program (MBHIP), developed by state natural resource agencies and the Service, allows each state to provide lists of all migratory bird hunters licensed by the state on an annual basis. Each migratory bird hunter is required to register in each state in which he/she hunts by providing his/her name, address, and date of birth, and other ancillary information (described below). States also collect and send us the email address of hunters who provide them. We request the date of birth in order to identify duplicate records and assess the quality of the data provided. The state includes the date the hunter registered with the record. We use both email and postal address to invite hunters to take the survey.
This ancillary information allows the Service to stratify the sample, investigate sources of bias, calculate bias correction factors, and identify duplicate records. Each state collects the information in a way that is most appropriate for that state, but all states ask some variation of the following questions that are appropriate in that state:
Will you hunt migratory birds this year?
How many ducks did you bag last year?
How many geese did you bag last year?
How many doves did you bag last year?
How many woodcock did you bag last year?
Did you hunt coots or snipe last year?
Did you hunt rails or gallinules last year?
Will you hunt sandhill cranes this year?
Will you hunt band-tailed pigeons this year?
Will you hunt brant this year?
Will you hunt sea ducks this year?
Because the distributions of these birds vary across the country and hunters vary in terms of what species they choose to hunt, the answers to these questions allow us to increase the efficiency of sampling by allowing us to concentrate sampling effort on the most appropriate hunters in each state.
We use the Parts Collection Surveys (PCS) to estimate the species, sex, and age composition of the harvest, and the geographic and temporal distribution of the harvest. Randomly selected successful hunters who responded to the Migratory Bird Hunter Survey the previous year are asked to complete and return a letter (Form 3-165B [waterfowl], Form 3-165C [woodcock, band-tailed pigeon, rail, gallinule], or Form 3-165D [mourning dove]) if they are willing to participate in the Parts Collection Surveys. We also ask those who answer “Yes” to report approximately how many birds they harvest in an average season. We need this information to determine how many of Forms 3-165, 3-165A, or 3-165E to send each participant at the beginning of the hunting season.
Respondents to Forms 3-165B, 3-165C, and 3-165D are provided postage-paid envelopes before the hunting season and asked to send in a wing or the tail feathers from each duck or goose (Form 3-165) they harvest, a wing from each woodcock, band-tailed pigeon, rail, or gallinule (Form 3-165A) they harvest, or a wing from each dove (Form 3-165E) they harvest. Dove managers are interested in estimates of local recruitment, so dove wings are requested from only the first 2 hunts during the first week of the dove season, to limit the sample to local birds. We use the wings and tail feathers to identify the species, age, and sex of the harvested sample.
We also ask respondents to report on the envelope:
Hunter name, to allow identification of the hunter if the barcode sticker is damaged or destroyed;
Location (state, county and nearest town) the bird was harvested, because this enables us to estimate the geographic distribution of the harvest of each species (nearest town enables us to identify county if county was unknown);
Month and day the bird was harvested, because this provides information on the temporal distribution of the harvest of each species that enables us to evaluate the effects of hunting season dates on species-specific harvest;
The band number of any leg-banded bird, because this enables us to estimate band reporting rates (Form 3-165 only, because we only band waterfowl in significant numbers).
We based the Migratory Bird Harvest Survey (MBHS) on the sample frame provided by the Migratory Bird Harvest Information Program. Randomly selected migratory bird hunters are sent one of the following forms and asked to report their harvest of those species: a waterfowl questionnaire (Form 3-2056J), a dove and band-tailed pigeon questionnaire (Form 3-2056K), a woodcock questionnaire (Form 3-2056L), or a snipe, rail, gallinule, and coot questionnaire (Form 3-2056M). We combine the resulting estimates of harvest per hunter with the complete list of migratory bird hunters, which serves as the expansion factor to provide estimates of the total harvest of those species or species groups.
On survey Form 3-2056J-M, we ask hunters to identify the following information:
Whether or not they hunted (waterfowl: ducks, geese, sea ducks or brant[Form 3-2056J]; doves and/or band-tailed pigeons [Form 3-2056K]; woodcock [Form 3-2056L]; or snipe, rails, gallinules and/or coots [Form 3-2056M]) this season. We need this information to estimate the number of active hunters of that species or species group. If they did hunt those species, we ask for:
Month and day of hunt, because this provides information on the temporal distribution of the harvest that enables us to evaluate the effects of hunting season dates on harvest;
County and state of hunt, because this enables us to estimate the geographic distribution of the harvest;
Number of birds bagged, because this provides us with information on daily hunting success that enables us to evaluate the impacts of daily bag limits on harvest; and
Season totals (days hunted, birds bagged, and birds knocked down but not retrieved), because this allows people who do not record their daily hunts to still provide us with data that enable us to estimate total days of hunting, total harvest, and mortality due to crippling loss.
We use the Sandhill Crane Harvest Survey to estimate annually the magnitude, geographical distribution, and temporal distribution of the sandhill crane harvest in Alaska, Colorado, Kansas, Minnesota, Montana, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, and Wyoming. Although we do not currently survey crane hunters in Kentucky and Tennessee, the recent additions of crane seasons in these states may require us to sample from these registered hunters in our survey in the future. It has also been possible for us to estimate the portion of the sandhill crane’s total population taken during harvest. This information has been particularly useful in determining the effects on harvests of daily bag limits and changes in hunting dates and the areas (counties) of states open to hunting. Based on information from the U.S. and Canadian surveys, we can adjust hunting regulations as needed to optimize harvest at levels that provide a maximum of hunting recreation while keeping populations at desired levels.
On survey Form 3-2056N, we ask hunters to identify the following information:
Whether or not they hunted sandhill cranes this season. We need this information to estimate the number of active crane hunters.
If they did hunt cranes, we ask for:
Month and day of hunt, because this provides information on the temporal distribution of the harvest that enables us to evaluate the effects of hunting season dates on harvest;
County and state of hunt, because this enables us to estimate the geographic distribution of the harvest;
Number of birds bagged, because this provides us with information on daily hunting success that enables us to evaluate the impacts of daily bag limits on harvest; and
Season totals (days hunted, birds bagged, and birds knocked down but not retrieved), because this allows people who do not record their daily hunts to still provide us with data that enable us to estimate total days of hunting, total harvest, and mortality due to crippling loss.
In the fall of 2019, we implemented a new, online platform for the Migratory Bird Hunter Survey. It is optimized for use on multiple device types (computer, tablet, or phone; Android or Apple operating systems). Unlike the paper survey form, the online survey platform walks a participant through the process of entering their harvest for a single day, asking for one piece of information at a time, which reduces confusion and the likelihood that the hunter will provide incorrect information. The online system improves data quality and prevents errors (e.g., reporting harvest of the wrong species, or in the wrong State). We continued to conduct the full paper survey through 2022, in order to ensure that data collected through the online platform is sound, and to provide a side-by-side comparison of harvest estimates that can be used to calibrate the old survey to the new one. This is particularly important for maintaining a continuous time series of harvest estimates, despite changing methodology. From the fall of 2022-on, we are conducting the full survey using the online application but provide a paper survey by mail to those hunters who request them (we provide our toll-free number in the invitation we send the hunter). NOTE: We removed the separate IC for the online submission and provided screenshots of the online system for each IC in ROCIS.
PROPOSED REVISION
Pilot Digital Photo Survey – We propose to revise our Parts Collection Survey over the next 3 years (2023-2026) to replace or substantially augment bird wings and tails collection with photos of harvested birds, in order to reduce survey costs and perceived risk of disease transmission through the handling of wild bird parts. Preliminary assessments have indicated that photos taken by hunters of harvested waterfowl can be used to determine species, age, and sex of birds, without requiring examination of bird parts “in the hand.”
We propose to conduct a 3-year pilot study with the development of a mobile application that can be used by hunters to take photos of the birds they harvest and upload them to our database, and a web-based interface for expert biologists to use to examine and identify birds from photos. We propose to conduct the pilot study with up to 600 hunters each year, which allows us to (1) evaluate the potential of using photo identification for other species in the Parts Collection survey, including doves, band-tailed pigeons, woodcock and rails, (2) achieve sample sizes sufficient to assess the limitations of photo identification for all waterfowl species, (3) develop methods to enhance the quality of hunter-supplied photos, and (4) amass an annotated set of photos to provide to researchers investigating the potential of machine-learning based image classification methods for automated identification of species, age, and sex.
In addition, there is the potential for introducing other biases in data collection when transitioning to a photo survey; to assess these biases and provide uninterrupted information on annual harvest, we intend to conduct the full parts survey during this 3-year period to provide a comparison of results between the two surveys. If photo identification proves difficult for some species, we may continue a limited sample of parts collection to ensure harvest estimates can be calculated.
We have developed an online survey response platform to allow hunters to respond to our season-long survey over the internet, as an alternative to a paper form. This change to our survey platform became operational in in full deployment during the 2022-2023 harvest season. Testing with the new online survey indicates that total response time decreases with implementation of this online form because of the following changes: (1) hunters will not need to return the survey in the mail; (2) the step-by-step question and response format of the online survey reduces confusion and provides drop-down prepopulated menus for county names, bird species, and number harvested; and (3) the system is optimized for mobile application, allowing hunters to respond at their convenience, even while they are hunting, which reduces the additional need to keep notes on harvest). In addition, we will be inviting the majority of hunters to participate in the survey via email, rather than through mailed letters, and will also be sending reminders via email.
We also receive hunter information from states that are collected electronically. On average, we receive the name and addresses of about 3,800,000 migratory bird hunters. Almost all of these are now collected electronically by the states, either online (through electronic licensing systems) or by telephone. We no longer receive hunter records via paper forms.
Finally, we have implemented 2 electronic methods for hunters to communicate with us: two email addresses ([email protected], for the Parts Collection Survey, and [email protected], for the online survey).
The envelopes (Forms 3-165, 3-165A, 3-165E) for the migratory bird wing/feather parts are large and most standard printers are incapable of printing them. Furthermore, we could not guarantee envelopes printed on personal printers would comply with U.S. Postal Service regulations, thus we do not anticipate putting those envelopes online. We believe the burden currently placed on cooperators and the cost to the Federal government to be at a minimum level consistent with the information required.
We do not print out paper copies of our reports for distribution. We post annual reports on the Division of Migratory Bird Management’s (DMBM) website.
Proposed Revision
We are currently collaborating on a pilot project with USGS to develop a photo-based Parts Collection Survey to supplement (and possibly eventually replace) the mailing of migratory bird parts through the mail. Increased awareness of the potential for disease transmission through bird parts, as well as increasing postage and printing costs, have led to interest in developing an alternative survey where hunters submit photos of harvested birds that are identified to species, age and sex, either by experienced biologists or possibly in an automated process using machine-learning algorithms. To determine the efficacy of a photo-based alternative to sending wings through the mail, during the 2021-22 hunting season we began a pilot project to identify the species, age and sex of hunter-harvested duck and goose species from photos submitted by hunters. Although sample size was small (801 birds) during the first year, the results suggest that for most birds, species and sex identification could be accomplished to the same degree as with a wing in the hand, despite often poor photo quality (Table 2). Exceptions included the identification of mottled ducks, black ducks, and greater scaup (albeit from only one bird), both USFWS focal species, as well as species for which very few photos were submitted (e.g., geese, black ducks, scaup; Table 2). Age identification was problematic for several species, and appeared to be more difficult than ageing birds from a wing in the hand. No photos were collected during this pilot study for doves, band-tailed pigeons, woodcock, or rails, so the efficacy of photo identification was not explored for these species. The results suggest that (1) a photo survey may provide species and sex identification for most ducks and geese, but may be difficult for some species of interest, including those suffering from declining population trends; (2) increased photo quality may improve identification; and (3) age identification may not be reliable for some species from a photo survey. Therefore, we propose that 2 more years of the pilot study be conducted, with approximately 600 hunters each year, using a custom-built Survey123 app and photo storage on ArcGIS online. This would allow us to evaluate the potential of using photo identification for doves, band-tailed pigeons, woodcock and rails, to achieve sample sizes sufficient to assess the limitations of photo identification for all waterfowl species, and to develop methods to enhance the quality of hunter-supplied photos. In addition, there is the potential for introducing other biases in data collection when transitioning to a photo survey, making it advisable to conduct the wing and photo surveys side by side for several years for comparison of results. Because our current budget does not have sufficient funding for this project, we propose to reinstate the pilot project in the 2025-26 hunting season.
The components of a photo-based Parts Collection Survey consist of (1) a mobile-based Survey123 app hosted by ESRI (Environmental Systems Research Institute) in ArcGIS Online, (2) a database system on ArcGIS Online linked to databases and photo storage on the USFWS computer network, and (3) a group of expert biologists who view photos and determine species, age and sex of harvested birds (or, alternatively, a system of automated image classification using machine-based algorithms to model identification based on a set of training photos). The Survey123 app collects the same information from hunters as the current Parts Collection Survey: hunter name, location and date where the bird was harvested (the app also allows for hunters to record the precise location using a mapping application or by recording the hunter’s latitude and longitude), the species of bird (if known), and various photos of the bird in different positions including (1) a view of the head, (2) a dorsal (back) view of the bird with one wing outstretched, and (3) a ventral (front) view of the bird with one wing outstretched. This information is transmitted via the app to a database in ArcGIS online, where it can be downloaded to a storage database on the USFWS network. An internet-based interface will be used to allow USFWS biologists to view photos and record information on species, age, sex, as well as additional information about photo quality and confidence in their assessment that can be used to estimate accuracy and uncertainty in identification.
Preliminary information from the first year of the pilot photo project indicates that the photo survey app reduces the burden of response time of hunters participating in the survey by (1) removing the need to cut and dry a wing or tail from each bird harvested and (2) removing the need to place parts in envelopes and put in the mail. While hunters are asked to take at least 3 photos of the bird in different positions, this can be done in the field when birds are harvested, and the mobile app makes it possible to automate the process, further reducing the time needed to submit information.
Many state wildlife agencies collect some information on migratory bird harvest within their state, and we examine a number of state hunter surveys. States generally collect information secondarily in harvest surveys of game other than migratory birds and is not adequate for Federal regulatory responsibilities primarily because: (1) not every state conducts surveys to estimate harvest of migratory birds and hunter activity, and (2) survey methodologies vary among those states who do conduct harvest surveys. Information from state surveys is often insufficiently detailed or imprecise, or has weaknesses in sampling design that can result in bias (e.g., failing to contact non-respondents; having no verification of species identification). Furthermore, many state survey results are not available in time to be useful for promulgating regulations. Some states eliminated migratory birds from their harvest surveys when we began conducting the Migratory Bird Harvest Survey; thus, reducing duplication of effort between state and Federal surveys since implementation of the Migratory Bird Harvest Information Program.
Within the USFWS, we do not select a hunter for more than one survey each year. We have implemented computer algorithms to identify exact duplicate Migratory Bird Harvest Information Program registrations across all data files. We eliminate these duplicate records prior to drawing our sample, thus improving the efficiency of our survey while avoiding asking a single hunter to fill out more than one survey. We are also investigating the cost-effectiveness of implementing address hygiene software to identify probable duplicates across all data files to further decrease the probability that a hunter will be selected for more than one survey each year.
This collection does not significantly impact small entities. We only collect this information from individual migratory bird hunters and state agencies.
If we did not collect this information, it would greatly weaken the Service's ability to promulgate regulations allowing controlled hunting of migratory birds. Agencies participating in determining appropriate hunting regulations, and making use of survey results, include the Department of the Interior, the Canadian Wildlife Service, state conservation agencies, and various private conservation organizations. Additionally, researchers often use these data to investigate biological phenomena such as range expansion, migration chronology, and species presence/absence.
The Service would not be able to estimate annual hunter take of migratory birds, or assess our ability to manage populations through harvest regulation. The continued health of migratory bird populations demands that harvests be commensurate with population size and status. If we did not conduct these surveys, the lack of accurate assessment of migratory bird harvests would dictate restrictive hunting regulations, which could result in lost hunting recreation. Loss of hunting opportunity due to lack of monitoring would not be acceptable to the hunting public, state natural resource agencies (many of whom rely on revenue from hunting licenses for funding and USFWS harvest surveys to set state-level hunting regulations), and some Non-Governmental Organizations (NGOs; e.g., Ducks Unlimited). Allowing hunting opportunity without monitoring would not be acceptable to conservationists, much of the hunting public, non-hunting public, and some NGOs (e.g., Humane Society).
The Service needs to conduct surveys annually because the number of birds harvested can change substantially between years. Harvests fluctuate with the size of the hunted and hunter population, as well as climatic conditions such as drought, flood, extreme warm or cold temperatures, and annual fluctuations in species distribution. Annual harvest estimates are required to allow us to adequately measure these changes in harvest. Furthermore, states and some NGOs are interested in creating increased hunting opportunity for hunters and are experimenting with hunting regulations (e.g., different license types, special seasons, season length, bag limit, opening and closing dates, zoning). The utility of these approaches needs to be monitored annually to determine efficacy.
* requiring respondents to report information to the agency more often than quarterly;
* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
* requiring respondents to submit more than an original and two copies of any document;
* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
* in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study;
* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
* requiring respondents to submit proprietary trade secrets, or other confidential information, unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
There are no special circumstances that require we collect the information in a manner inconsistent with OMB guidelines.
On June 2, 2023, we published in the Federal Register (88 FR 36328) a notice of our intent to request that OMB approve this information collection. In that notice, we solicited comments for 60 days, ending on August 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-2023-0085) 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). We received the following comments in response to that notice:
Comment 1: Electronic comment received via Regulations.gov (FWS-HQ-MB-2023-0085-0002) on June 3, 2023 from Jean Public:
“this dept shows no evidence atall of wise management. none.the mgtis slanted, biased, prejudiced, conflict of interest and should be criminally investigated for the poor way they protect nature. fact is hunters shoot at anything that moves. they have proved this by endless killing of people.hunters show they lie. this is proven by teh reports of conservation park officers who exibit a hunter shooting and killing and then when they ask the hunters about it the hunter lies all of the time. when the vifence is produced to the hunter, then the hunter tells the truth. over and over we have seen this over 25 years in the reports of conservation officers. they lie like fishermen.so then how is this collection of fake information meaningfjull at all.it is not. it is full of lies and you bas management on it. horrific. you waste taxpayer dollars to collect hunter lies. the bird population is declining precipitously. becaue hunters kill anything that moves. they dont care if its endangered. why shoudl taxpaeyrs fund this for 3 years. when its a waste. one year more and we need to see what information you get. you hide the ionformation you get from teh us public who pays taxes for this crap you collect.stop all hunting and trapping and let the birds populate and live. that is the way to go now. just stop the insanity of allowing human being to kill for their fun at killing. they get enough freebies from welfare to buy the food they eat so there is no fake reason that they need to kill an animal to eat. that is fake. and stop allwoing inoto this country all those citizens who eat dogs and cat and other animals. we want to save and protect animals and we feel strongly about that. we are sickof the abuse and insanity that is gonig on. this is not l860. this is 2023. we shoudl be intelligent enough to stop this horror. carying on shows the worse part of humanity, the devil side.this agency is not wise. itis carrying on insanity.”
Agency Response to Comment 1: The commenter did not address the information collections; therefore, no response is required.
Comment 2: Anonymous electronic comment received via Regulations.gov (FWS-HQ-MB-2023-0085-0003) on June 4, 2023:
“Equal Opportunity”
Agency Response to Comment 2: The commenter did not address the information collections; therefore, no response is required.
Comment 3: Anonymous electronic comment received via Regulations.gov (FWS-HQ-MB-2023-0085-0004) on June 4, 2023:
“Need Help”
Agency Response to Comment 3: The commenter did not address the information collections; therefore, no response is required.
Comment 4: Anonymous electronic comment received via Regulations.gov (FWS-HQ-MB-2023-0085-0005) on July 31, 2023:
“Please don't allow anymore the killing of these poor migratory birds. These birds should be protected, not killed. And these birds are being killed just for recreation, for the fun of it. It doesn't make sense wanting to protect these animals, but then tolerating them being killed just for fun. No, these birds must be protected. They are most beautiful when they are alive and free. Please protect all the migratory birds.”
Agency Response to Comment 4: The commenter did not address the information collections; therefore, no response is required.
In addition to the Federal Register notice, we consulted with the nine (9) individuals identified below who familiar with this collection of information in order to validate our time burden estimate and asked for comments on the questions below:
Organization Title
CT Dept of Energy and Environmental Protection Migratory Bird Program Leader
Private Citizen Hunter
Private Citizen Hunter
Private Citizen Hunter
Private Citizen Hunter
Private Citizen Hunter
Private Citizen Hunter
Private Citizen Hunter
Private Citizen Hunter
“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: Most respondents agreed that the information collected by the harvest survey is necessary and critical for management of migratory gamebird populations at state and national levels, to measure and track changes in harvest. They agreed it is useful to states, federal government (including other agencies that USFWS) and non-governmental organizations. They thought that hunters also are interested in the harvest estimates because they allow comparison of harvest from different regions of the country and is a source of information that is “enjoyed by hunters everywhere.” Two respondents mentioned that the age information collected in the Parts Collection Survey was important for understanding the age ratios in the harvest. One respondent expressed uncertainty about what the data are used for, other than to provide a snapshot of migration at a given time, but appreciated receiving reports after the survey of the wings they submitted, and one respondent suggested a greater investment into studying the effects of potential bias in the survey.
Agency Response/Action Taken: None required.
“The accuracy of our estimate of the burden for this collection of information”
Comments: Seven respondents said that our estimate of the burden was accurate, and three respondents said the estimate was nominal, reasonable, appropriate, or manageable. One respondent said that the burden was 1-2 minutes per day of hunting, for an overall average of 10-20 minutes for the hunting season. One respondent commented that there was limited to no perceived burden based on their 40 years of management experience.
Agency Response/Action Taken: None required.
“Ways to enhance the quality, utility, and clarity of the information to be collected”
Comments: One hunter replied that they did not see any way to enhance the quality or utility of information, but that any effort to improve the quality of the HIP information collected from states would greatly improve the reliability of the information, and thought the electronic option would make things better for many younger hunters. One respondent commended USFWS for improving the clarity and communication of the importance of the survey, and finding ways for stakeholders to view and utilize the survey data. Hunters commented that increasing the sample size of wings in the Parts Collection Survey by accepting all birds taken in group hunts might be worthwhile, as well as using the wings to spot possible diseases. One hunter stated that if they knew better how the data were used, they could make suggestions on how to improve the entire process.
Agency Response/Action Taken: Although sample size is an important consideration for the Parts Collection Survey, the design of the survey requires a random sample, so accepting wings from all members of a hunting party would not meet that requirement. Also, we have recently initiated outreach efforts (hunter focus group, website, communications plans with partners) to increase public understanding of the survey and how the data are used, in order to boost public acceptance and participation in the surveys.
“Ways to minimize the burden of the collection of information on respondents”
Comments: One hunter replied that they did not believe participation in the Parts Collection survey was a “burden.” Three hunters replied that the development of a web-based application will save hunters time in participating in the survey. Two hunters stated that development of a cellphone based app or mobile platform using artificial intelligence or image recognition could reduce the burden by allowing hunters to take photos of birds and get locations. One hunter thought most hunters are more than willing to participate in these surveys. Two hunters commented that if hunters could send all their wings from a day’s hunt in one envelope it would reduce preparation time and save money on mailing costs.
Agency Response/Action Taken: We have implemented the online survey to decrease the burden of participating in the survey, and we are working to develop the technology to identify species, age and sex of birds from photos taken in the field, and will also be working to incorporate this technology in a mobile application. We are currently evaluating photos received during a pilot project to determine the feasibility of this type of application, but due to the significant research effort required to develop the technology for automated image recognition, we believe that the timeline for producing a mobile application will be several years.
Additional comments received during the outreach:
Comments: One hunter commented that they would encourage OMB to embrace the modernization of the critically important harvest survey including encouraging the DOI/FWS examiner to work with agency leadership to adequately fund modernization efforts.
Agency Response/Action Taken: No response required.
We provide no payments or gifts to respondents. As incentive, we provide participants in the Parts Collection Survey with a report at the end of the hunting season. This report lists the species, age, and sex of each wing that hunter submitted during the past hunting season.
We do not provide assurance of confidentiality. Information hunters provide may be disclosed pursuant to the Freedom of Information Act (FOIA), the Privacy Act of 1974, and the routine uses listed in the System of Records Notice (SORN) INTERIOR/FWS-26, Migratory Bird Population and Harvest Surveys (published May 12, 2015, 80 FR 27183; modification published March 16, 2023, 88 FR 16277).
There are no questions of a sensitive nature.
* 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 estimate that we will receive 192,657 responses totaling 126,968 annual burden hours for this information collection with an estimated total dollar value of the annual burden hours of approximately $7,198,168 (rounded). Response data are estimated as average from 2020-2022 survey data.
Table 12.1
We used Table 1 from the of Bureau of Labor Statistics (BLS) News Release USDL-23-1971, September 12, 2023, Employer Costs for Employee Compensation—June 2023, to calculate the cost of the total annual burden hours:
Individuals – the hourly rate for all workers is $43.26, including benefits.
Government – the hourly rate for all workers is $58.25, including benefits.
Average Average Average Average Estimated
Number of Number of Number of Completion Annual $ Value of
Annual Responses Annual Time per Burden Hourly Annual
Requirement Respondents Each Responses Response Hours* Rate Burden Hours
Migratory Bird Harvest Information Program (State Governments)
49 18 882 129 hours 113,778 $ 58.25 $ 6,627,568.50
Migratory Bird Hunter Survey (Individuals)
Form 3-2056J 31,900 1 31,900 4 minutes 2,127 $ 43.26 $ 92,014.02
Form 3-2056K 16,900 1 16,900 3 minutes 845 43.26 36,554.70
Form 3-2056L 8,500 1 8,500 3 minutes 425 43.26 18,385.50
Form 3-2056M 10,200 1 10,200 2 minutes 340 43.26 14,708.40
Subtotals: 67,500 67,500 3,737 $ 161,662.62
Parts Collection Survey (Individuals)
Form 3-165 4,700 22 103,400 5 minutes 8,617 $ 43.26 $ 372,771.42
Form 3-165A 770 5.5 4,235 5 minutes 353 43.26 15,270.78
Form 3-165B 3,540 1 3,540 1 minute 59 43.26 2,552.34
Form 3-165C 260 1 260 1 minute 4 43.26 173.04
Form 3-165D 770 1 770 1 minute 13 43.26 562.38
Form 3-165E 750 1.5 1,125 5 minutes 94 43.26 4,066.44
Subtotals: 10,790 113,330 9,140 $ 395,396.40
Sandhill Crane Harvest Survey (Individuals)
Form 3-2056N 5,900 1 5,900 1.5 minutes 148 $ 43.26 $ 6,402.40
Pilot Digital Photo Survey (Individuals)
Form 3-165 200 22 4,400 2 minutes 147 $ 43.26 $ 6,359.22
Form 3-165A 60 5.5 330 2 minutes 11 43.26 475.86
Form 3-165B 150 1 150 1 minute 3 43.26 129.78
Form 3-165C 60 1 60 1 minute 1 43.26 43.26
Form 3-165D 60 1 60 1 minute 1 43.26 43.26
Form 3-165E 30 1.5 45 2 minutes 2 43.26 86.52
Subtotals: 560 5,045 165 $ 7,137.90
TOTALS: 84,799 192,657 126,698 $ 7,198,167.82
*Numbers rounded to match ROCIS
Migratory Bird Harvest Information Program: Although State licensing authorities are collecting the name and address information needed to provide a sample frame of all licensed migratory bird hunters, Federal regulation requires collection of the information. Therefore, we provide the reporting burden associated with that information collection here. The Service estimates that the 49 states will collect the required information from approximately 3,500,000 individuals annually. States are using a variety of methods to collect the required information, and the amount of time required for an individual respondent to provide the information varies from less than 1 minute to up to 4 minutes, depending upon the method employed by the state. We estimate that the overall average time per response is 2 minutes.
The states then compile a list of migratory bird hunters in their state and send it to the Service. States send their first list of hunter names to the service in August and continue to send updated entries at 2-week intervals until the end of the migratory bird hunting seasons in their state. The number of hunters on each list varies, depending on the time of year and the number of migratory bird hunters in the state. On average, the lists contain 3,870 records and we receive an average of 18 lists per state per year. The total annual burden estimate for the Migratory Bird Harvest Information Program is 113,778 hours. This estimate is lower than 2017—19 due to a decrease of approximately 300,000 in the number of hunters registering for the Harvest Information Program.
Migratory Bird Hunter Survey: From the 2022-23 hunting season onward, almost all hunters will take the Migratory Bird Hunter Survey online (we offer the paper survey as an alternative but very few (~ 100, or 0.14%) hunters have requested one. The online application was designed to decrease response time by hunters by (1) requesting one piece of information at a time, resulting in the need for fewer instructions, (2) providing drop down lists for choosing inputs, such as a calendar for days, county lists for location, and species lists for birds harvested. Most hunters receive email invitations to take the survey, and may report that they did not hunt the species for which we survey them by clicking on a button in the email, which also reduces response time. We estimate that these differences between the online survey and the paper form result in a decrease in the amount of time it takes to fill out the survey by 1 minute. The online application is identical for each species survey; thus, the difference in response time among surveys is due to differences in the average number of hunts entered for each species type.
About 31,900 hunters respond to Form 3-2056J (waterfowl harvest survey) each year; the number of hunting trips reported ranges from zero to as many as 100, with an average of 3 trips reported per respondent. Recording and summarizing the trips requires an average of 1 minute per trip (2,658 total burden hours). Despite a decrease in the number of hunters in the sample frame, this is about the same number as in 2017--19 because we increased sampling rates in some states to ensure a sufficient sample of hunters.
About 16,900 hunters respond to Form 3-2056K (dove-pigeon harvest survey), with the number of trips reported ranging from zero to about 30. The number of trips reported averages 2, and the time required to report and summarize the trips averages 1 minute per trip (1,127 total burden hours). This number is similar to that from 2017--19.
About 8,500 hunters respond to Form 3-2056L (woodcock harvest survey) each year, with response burden averaging 1 minute per trip and respondents averaging 2 trips (567 total burden hours). This number is similar to that from 2017--19..
About 10,200 respondents are also expected for Form 3-2056M (snipe, coot, rail, and gallinule harvest survey) each year, with response burden again averaging 1 minute per trip and respondents expected to average 1 trip (510 total burden hours). This number is similar to that reported in 2017--19.
The total annual burden estimate for all 4 paper forms used for the Migratory Bird Hunter Survey is 4,862 hours, which is about the same as reported in 2017--19.
Parts Collection Survey: About 4,760 respondents provide waterfowl parts in Form 3-165 (waterfowl wing envelope). Response frequency for Form 3-165 varies from once to up to 200 times annually dependent on the amount and success of hunting by individuals, averaging about 22 times per individual. The estimated time required to complete form 3-165 is 5 minutes, and we receive about 104,720 completed forms annually (8,726 total burden hours). This is a slight decrease from the 2017--19 average of 8,928 burden hours, due to a decrease in hunter participation in the survey.
About 830 respondents will provide wings using Form 3-165A (woodcock, rail, gallinule, and band-tailed pigeon wing envelope), averaging 5.5 responses per individual annually. The estimated time to complete Form 3-165A is 5 minutes, and we receive about 4,565 forms annually (380 total burden hours). This is a decrease from the 2017-19 estimate of 458, due to a drop in participation in the survey.
Approximately 3,600 hunters will respond to Form 3-165B (request to provide waterfowl parts). Response frequency is once annually, and completion of the form requires about 1 minute (60 total burden hours).
About 320 hunters will respond to Form 3-165C (request to provide wings from woodcock, rails, gallinules, and band-tailed pigeons). Response frequency is once annually, and completion of the form requires about 1 minute (5 total burden hours). This number is similar to the actual 2017-19 average, but was reported in error as 900 in the last information collection request.
Approximately 800 respondents will respond to Form 3-165D (request to provide wings from mourning doves). The response frequency is once annually, and completion of the form requires about 1 minute (13 burden hours). This is a decrease from the 2017-19 estimate, due to a decrease in hunter participation in the survey.
Approximately 780 hunters will provide mourning dove wings using Form 3-165E (mourning dove wing envelope), averaging 1.5 responses per individual annually. The estimated time to complete Form 3-165E is 5 minutes, and we receive about 1,170 forms annually (98 total burden hours). This is a decrease from 138 burden hours in 2017-19, due to a decrease in hunter participation in the survey.
Thus, the total annual burden estimate for the Parts Collection Survey is 9,282 hours.
Sandhill Crane Harvest Survey: About 5,900 hunters respond to form 3-2056N; the number of hunting trips reported ranges from zero to as many as 20, with an average of 1.5 trips reported per respondent. Recording and summarizing the trips requires an average of 1 minute per trip totaling 245 burden hours. This is an increase in the number of responses from 4,300 in 2017-19, due to an increase in the number of sandhill crane harvest permits being issued by states.
Pilot Digital Photo Survey: In the second and third year of the pilot photo survey, we estimate that approximately 560 hunters will respond to the request to provide photos via the photo survey app. We estimate that the time for uploading photos of harvested birds will be reduced from the 5 minutes it took to cut wings/tails, dry, and place in envelopes to mail, to 2 minutes per response. During the pilot project, this burden will be additional to the burden from the Parts Collection Survey, but once the photo survey becomes operational, it will result in an overall reduction due to the replacement of, or reduction in, the Parts Collection Survey with the photo survey.
* 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 dollar cost burden to respondents. There is no fee for completing the survey or any other costs associated with responding to this survey.
The total estimated annual cost to the Federal Government is $1,933,984 (rounded) ($1,038,584 (rounded) for salaries and $895,400 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. The Patuxent Wildlife Research Center in Laurel, MD conducts most work so we used the DC area salary table to calculate salaries and benefits.
Table 1 – Salaries and Benefits: $1,038,584 (average grades/steps with 100% of time dedicated to program).
2023-DCB Total Salary, # of Total Salary
Position Grade/Step Annual Salary Incl. Benefits* Positions Costs*
Branch Chief GS-14/05 $ 150,016 $ 238,525 1 $ 238,525
Biologist GS-13/05 126,949 201,849 1.5 302,774
Database Manager GS-13/05 126,949 201,849 0.75 151,387
Administrative Assistant GS-07/05 60,185 95,694 1 95,694
Biologist/Speciator GS-07/05 60,185 95,694 1 95,694
Survey Clerk GS-05/05 48,588 77,255 2 154,510
Subtotal - Table 1: $ 1,038,584
*Rounded
Table 2 - Operating Costs: $547,750 (printing and mailing survey forms, packing and mailing wing envelopes, processing incoming data, producing reports, coordinating with state agency partners, and implementing modernizations).
Contracts, Total
Supplies, & Operating
Activity/Survey Travel Postage Printing Equipment Costs
Parts Collection Survey $ 37,000 $ 358,300 $ 78,000 $ 28,000 $ 503,300
Photo Pilot Survey 57,000 57,000
Online Harvest Surveys 245,200 40,900 22,000 308.100
Harvest Surveys Support and Ops 5,000 10,000 14,000 29,000
Subtotal – Table 2: 42,000 613,500 118,900 121,000 $ 895,400
(Corrected mathematical errors from prior submission)
With the replacement of the paper survey with the online survey application, the number of staff needed to conduct the survey has changed. A Database Manager is now required (75% of FTE) to manage the online survey database, schedule email invitations, assemble the sample frame, and export data for harvest estimation, and takes the place of 0.5 of one biologist position. In addition, one biologist position (HIP liaison with states) is now a GS-13 position. The lead survey clerk is no longer required because many clerical tasks associated with the paper survey are no longer needed for the online survey. The survey contractor and Half-time Speciators have been replaced with two Biologist/Speciators each of whom contribute 0.5 of their annual time to the surveys. These changes have resulted in a slight increase in staff cost from $931,995 in 2017-19. Also, for the pilot photo survey, a database architect is needed to build and connect the relational databases and photo storage, which requires 6 months funding through an existing contract ($57,000).
Implementation of the online survey application has reduced printing costs for the Migratory Bird Harvest Survey because forms no longer need to be printed, and the number of invitations sent is lower than for the paper survey. However, paper shortages and increases in printing costs have resulted in higher printing costs for the Parts Collection Survey. Return (business reply mail) costs for the Harvest Surveys have decreased substantially because hunters are no longer returning survey forms in the mail, but these costs have increased for the Parts Collection Survey because USPS has increased rates for business reply mail. The overall operating costs for the surveys above in 12.2 ($838,400; minus the $57,000 contract funding for the pilot photo survey) represents a decrease from the $889,350 costs provided in our 2020 submission (covering years 2017-2019).
We are reporting a discretionary burden change (increase) of 5,045 annual responses and 165 annual burden hours, as well as a change in agency estimate (decrease) of 1,845 annual responses and 143 annual burden hours, associated with the revisions described in question 2 and 12 of this Supporting Statement A.
We plan to continue the Migratory Bird Harvest Surveys annually as long as the U.S. offers migratory bird hunting seasons.
Schedule for Migratory Bird Harvest Information Program: The schedule for the Migratory Bird Harvest Information Program varies among states and is dependent upon the license structure used in that state. States have differing hunting license structures, including license that are valid from 1 January-31 December, 1 September-31 August, 1 April – 31 March, and 365-days from date of purchase. States generally send these data from August-February, but some states send data year-round. We receive migratory bird hunter names and addresses rom the states, either in the form of electronic databases or on paper forms from which the data are compiled in a database.
Schedule for the Migratory Bird Hunter Survey
Sep-Feb We send invitations to the sampled migratory bird hunters asking them to keep track of their hunting trips throughout the hunting season and fill out the online survey when they have completed their hunting season, or periodically throughout the season.
Dec-Apr Following a staggered schedule based on the closing date of the hunting season in each state, we send sent reminder letters to sampled hunters who have not registered for the online survey. We accept responses until the end of June.
Apr-May Editing, compilation in a database, and analysis of response data.
Jun-Jul The report on non-waterfowl species must be prepared and distributed by early June, in time for the public meeting on hunting regulations for those species and publication in the Federal Register and various status reports. The report on waterfowl must be prepared and distributed by early July, in time for the public meeting on waterfowl hunting regulations and publication in the Federal Register. The complete harvest report is distributed both internally and externally and made available on our website: https://fws.gov/library/collections/migratory-bird-hunting-activity-and-harvest-reports
Schedule for the Parts Collection Survey
Jun We mail letters soliciting participation in the survey to the public from the Service in Laurel, Maryland. Respondents return the letter to the Service in Laurel, Maryland. We compile names and addresses of respondents in a database.
Jul-Aug Employees prepare the parts envelopes for mailing.
Aug-Oct Because they must be in the possession of survey participants at the start of the hunting season, we send parts envelopes to participants about 2 weeks before the hunting season begins in each state. Hunting seasons open as early as September 1 in many states, and as late as early November.
Sep-Mar Hunters mail parts to collection points in each Flyway throughout the hunting season, which continues to mid-March in some states.
Nov-May Federal and state biologists assemble at one of six collection points to identify the species, age, and sex of each part between late November and mid-March. They forward late arriving parts to Laurel in early April and they are identified there. We accept parts until May.
Feb-May Shipment of completed data slips (form #s) to Laurel, where we compile the data in a database. We analyze data in combination with information derived from the Migratory Bird Hunter Survey to generate species-specific estimates of harvest.
Aug-Sep We publish status reports containing estimates of annual dove, woodcock, band-tailed pigeon, and sandhill crane by August 20. The Service’s Division of Migratory Bird Management must receive harvest estimates used in harvest strategies driven by population models internally for model input by early-July. The complete harvest report is available by the end of August and is distributed both internally and externally and accessible on our website. https://fws.gov/library/collections/migratory-bird-hunting-activity-and-harvest-reports
Schedule for Sandhill Crane Harvest Survey: In all states but Alaska, participating states issue permits to sandhill crane hunters in mid-July. States send electronic copies of issued permits (showing names and addresses of permittees) to the Division of Migratory Bird Management, Laurel, Maryland, following the end of the crane-hunting season in each state. Upon receipt of name and address information, we produce computer records of each name/address, select hunters, and email (and mail) invitations for the online survey. We email these invitations to permittees approximately two weeks after the close of the respective hunting seasons. We email and mail follow-up invitations to non-respondents approximately one month later. In recent years, the latest crane season has closed in early February. Thus, we complete distribution of follow-up invitations in early April and the analysis of data commences in May. The sample frame for estimating sandhill crane harvest from Alaska is provided from the Migratory Bird Harvest Information Program. Survey procedures are the same as for the other states, except that the survey can be sent out before the close of the sandhill crane hunting season because of earlier receipt of sample frame information. An annual report is available by August on our website: https://fws.gov/media/status-and-harvests-sandhill-cranes-2021
The Service does not include the expiration date on the envelopes currently approved under OMB Control No. 1018-0023 (Forms 3-165, 3-165A, and 3-165E). The Service prints the envelopes in bulk from the Government Printing Office. Funding availability dictates the quantity of envelopes printed. At times, when the Service is in a position to print a higher quantity of envelopes, they may not be used before the current expiration date. Omitting the expiration date is advisable in order to avoid confusion and anxiety on the part of the public, who may fear that the envelope is no longer valid if it displays a date that is expired. We will continue to display the current expiration date on the survey invitation, as well as on all other forms approved in this collection.
There are no exceptions to the certification statement.
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| 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 | 2023-12-12 |