Document
Supporting Statement A
ICR 202603-1029-001 · OMB 1029-0113 · Object 170297700.
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
|---|---|
| File Title | Supporting Statement A |
| Author | Frankel, William L |
| Last Modified By | Writer |
| File Modified | 2026-05-18 |
| File Created | 2026-06-19 |
| Conversion State | complete |
Extracted Text
Supporting Statement A
for paperwork reduction act submission
30 CFR Part 874 - General Reclamation Requirements
OMB Control Number 1029-0113
Terms of Clearance: None
Justification
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
Title IV of the Surface Mining Control and Reclamation Act of 1977 (SMCRA), 30 U.S.C. § 1201 et seq., authorizes the Abandoned Mine Land (AML) program and establishes eligibility criteria and priorities for reclamation expenditures. The information collection is necessary to document and support eligibility determinations and project approvals required under SMCRA and its implementing regulations at 30 CFR Part 874, including:
1. Eligibility of coal lands and waters under 30 U.S.C. § 1234 and 30 CFR § 874.12; and
2. Required statutory findings for certain Unreclaimed post-1977 sites under 30 U.S.C.
§ 1232(g)(4)(B)(i)–(ii).
The collected information supports oversight of reclamation activities, compliance with applicable environmental and program requirements, and verification that reclamation obligations are fulfilled in accordance with SMCRA and 30 CFR Part 874.
In addition, Part 874 includes information-collection requirements for reclamation projects involving the incidental extraction of coal, conducted under SMCRA authority and subject to specific statutory and regulatory conditions and safeguards. SMCRA limits the use of AML funds to sites that meet specific eligibility criteria and requires sufficient documentation to support eligibility determinations, funding decisions, and program oversight.
Statutory Authority:
• 30 U.S.C. § 1234 – Eligibility of coal lands and waters adversely affected by past coal mining or processing and Unreclaimed prior to August 3, 1977, with no continuing responsibility under State or Federal law.
• 30 U.S.C. § 1232(g)(4)(B)(i) – Certain sites mined between August 4, 1977, and the date of State program approval, where available funds are insufficient for reclamation.
• 30 U.S.C. § 1232(g)(4)(B)(ii) – Certain sites mined between August 4, 1977, and November 5, 1990, where the surety became insolvent and available funds remain insufficient.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.
The information collected under 30 CFR part 874.17 is used by OSM and State and Tribal AML agencies with approved programs to support the consultation, evaluation, and documentation required when considering an abandoned mine land reclamation project as government-financed construction under 30 CFR part 707, where the level Government funding is less than 50 percent of the total project cost because of planned coal extraction.
This information supports:
Review and documentation of AML project proposals subject to § 874.17 procedures.
Consultation with the appropriate Title V regulatory authority, including concurrence on the project boundary and the amount of coal proposed for extraction under the AML project.
Documentation of determinations and controls to ensure coal extraction remains incidental to reclamation, prevent unauthorized mining, and ensure the project is conducted in accordance with SMCRA and applicable implementing regulations. Site inspections and recordkeeping to support oversight, accountability, and compliance.
This information is necessary to determine whether coal may be extracted incidentally to reclamation under the applicable statutory and regulatory framework and to document compliance with required conditions and safeguards.
Where coal is extracted and sold in accordance with these requirements, proceeds may reduce the net cost of the reclamation project, thereby reducing the amount of government funding required.
Historically, OSM and State/Tribal authorities have used this information to evaluate and document AML projects subject to § 874.17, including consultation outcomes, concurrence, determinations, and oversight records.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden and specifically how this collection meets GPEA requirements.
The information collection relies extensively on electronic processes to minimize respondent burden. Most required submissions, including analyses, project documentation, consultation records, concurrences, inspection reports, and related materials, are prepared, transmitted, and maintained in electronic format. Respondents may submit information using secure electronic systems or other electronic means commonly used by Federal, State, and Tribal AML programs, thereby reducing paper handling and improving efficiency.
Additionally, OSM uses e-AMLIS (Abandoned Mine Land Inventory System) to manage and track Abandoned Mine Land projects. To further improve efficiency and accuracy, advanced analytical tools, including artificial intelligence (AI), assist in identifying potential sites. This approach enhances data quality, accelerates project evaluation, and supports informed decision-making while complying with the Government Paperwork Elimination Act (GPEA) by enabling electronic submission and review.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The information collected under 30 CFR § 874.17 is project-specific and collected only once per affected AML reclamation project. Existing information from other AML or regulatory programs cannot be used because § 874.17 requires unique, project-specific, determinations and documentation. As a result, the collection is limited in scope and not duplicative.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This information collection does not impact small businesses or other small entities. The
respondents are State agencies and federally recognized Indian Tribes administering
approved Abandoned Mine Land programs, which are not considered small entities
under the Paperwork Reduction Act.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
If the information were not collected or were collected less frequently, OSM and State and Tribal AML agencies would be unable to make or document the determinations required under 30 CFR § 874.17, which would impede approval and oversight of AML reclamation projects involving incidental coal extraction. This would limit the ability to ensure compliance with statutory and regulatory requirements and could delay reclamation of sites that pose risks to public health and safety. Because the information is project-specific and collected only when applicable, the frequency cannot be reduced without compromising program implementation.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
* requiring respondents to report information to the agency more often than quarterly;
* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
* requiring respondents to submit more than an original and two copies of any document;
* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
* in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study;
* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
* requiring respondents to submit proprietary trade secrets, or other confidential information, unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
This collection complies with 5 CFR 1320.5(d)(2). No exceptional circumstances apply.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and in response to the PRA statement associated with the collection over the past three years, and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every three years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
A 60-day Federal Register Notice soliciting public comment on this information collection was published in accordance with 5 CFR 1320.8(d) on March 11, 2026, at 91 FR 11987.
At the close of the public comment period, OSM reviewed the comments received in response to the notice. The public did not submit any comments for the 60-Day Federal Register Notice.
OSM previously consulted with State and Tribal Abandoned Mine Land program officials, who are the primary respondents to this information collection, through routine program coordination and outreach to obtain their views on the availability of data, frequency of collection, clarity of instructions and recordkeeping requirements, and reporting formats. No changes are necessary based on their responses.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts are provided to respondents in connection with this information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
No assurances of confidentiality are provided. This information collection does not solicit confidential or personally identifiable information. No confidential information is solicited.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
This information collection does not include questions of a sensitive nature, such as those concerning sexual behavior or attitudes, religious beliefs, or other matters commonly considered private.
12. Provide estimates of the hour burden of the collection of information. The statement should:
* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.
* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here.
Number of responses in this information collection package were updated to reflect estimates from current projects in e-AMLIS. Burden hours and costs are reflective of prior estimated from the State of Pennsylvania.
Contacts:
Pennsylvania Bureau of Abandoned Mine Reclamation
P.O. Box 8461
Rachel Carson State Office Building
Harrisburg, PA 17105-8461
Estimated Information Collection Burden
a. Burden Hour Estimates for Respondents
Based on information from historical projects, the estimated burden per project remains 90 hours. These hours include time spent reviewing information during consultation, inspecting the project area, reviewing documentation, and determining environmental and reclamation requirements.
Estimated Respondent Burden
Role
Hours per Response
Total Hours (1 Project)
Physical Scientists
85
85
Managers
5
5
Total
90
90
It is estimated that there will be 1 project (or response) annually, resulting in a total of 90 hours. The estimate was reduced from 3 annual projects to 1 to reflect the currently limited inventory of AML projects involving incidental coal recovery (only 2 in Virginia).
Estimates above reflect one respondent, one response annually.
b. Estimated Annual Wage Cost to Respondents
OSM estimated that State reclamation and regulatory specialists performed the activities associated with this information collection, including consultation, site inspections, determination of environmental and site reclamation requirements, and preparation of required documentation. These staff were classified as Physical Scientists for wage estimation purposes.
Annualized Cost to Respondents
Role
Base Wage ($/hr.)*
Cost/hr w/ Benefits (×1.62)**
Total Hours (1 project)
Total Cost ($)
Physical Scientists
$51.99
$84.22
85
$7,158.70
Managers
$64.87
$105.01
5
$525.05
Total
90
$7,683.75
* Hourly wage rates were derived from the Occupational Employment and Wage Statistics (OEWS), Occupational Employment and Wages—May 2025 (https://www.bls.gov/news.release/pdf/ocwage.pdf).
** Benefits were calculated using a factor of 1.62, consistent with the U.S. Bureau of
Labor Statistics’ Employer Costs for Employee Compensation report (December 2025,
USDL‑26‑0505): https://www.bls.gov/news.release/ecec.nr0.htm.
Therefore, the total estimated annual respondent burden was 90 hours, with an associated annualized wage cost of $7,683.75.
13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)
* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation, 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.
Total Annual Non-Wage Cost Burden to Respondents — $0
The information collection associated with 30 CFR § 874.17 did not impose any annual non-hour cost burdens on respondents or
recordkeepers beyond those attributable to customary and usual business or governmental administrative practices.
a. Annualized Capital and Start-Up Costs — $0
The information collection requirements of § 874.17 did not require respondents to incur any capital or start-up costs, such as the
purchase of equipment, software, or record storage systems, beyond those normally associated with the routine administration of State
and Tribal AML programs.
b. Operation and Maintenance Costs — $0
No non-wage operation and maintenance costs were incurred by respondents to comply with the information collection requirements
of § 874.17.
14. Provide estimates of annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
Estimate of Annualized Cost to the Federal Government
Oversight
OSM conducts routine oversight of AML procedures and projects. AML projects
receiving less than 50 percent government funding requires an additional review to
ensure that State agencies fulfill the consultation, concurrence, and documentation
elements of 30 CFR § 874.17.
Method Used to Estimate Cost
OSM estimated the annualized Federal cost by calculating:
• the number of projects requiring additional oversight review,
• the average Federal staff hours required per project, and
• the fully loaded hourly cost (salary plus benefits) for the reviewing staff.
No incremental equipment, printing, contractor, or additional support staff costs were incurred beyond normal agency operations. Accordingly, the estimate reflects labor costs only.
Hours and Wage Rate Assumptions
• Number of projects reviewed annually: 1 (consistent with the annual response
estimate)
• Additional oversight time per project: 5 hours
• Total annual Federal hours: 1 projects × 5 hours/project = 5 hours
OSM used the hourly rate for a GS-12, step 5 reclamation specialist of $48.61 per hour
(Rest of U.S. locality, effective January 2026) as published by the U.S. Office of
Personnel Management salary tables. (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2026/GS_h.pdf).
To estimate fully loaded labor costs, OSM applied a benefits multiplier of 1.62,
consistent with the Bureau of Labor Statistics’ Employer Costs for Employee
Compensation framework.
• Fully loaded hourly rate: $48.61× 1.62 = $78.75 per hour
Estimated Annualized Federal cost
• Total hours: 5
• Fully loaded hourly rate: $78.75
• Annualized Federal cost: 5 hours × $78.75= $393.74
Operational and Other Non-Labor Costs — $0
OSM anticipated no additional non-labor costs (including equipment, printing,
Overhead beyond normal operations, or contractor/support staff costs) that would not
otherwise have been incurred without this information collection.
15. Explain the reasons for any program changes or adjustments in hour or cost burden.
Previously, OSM estimated three projects annually, for a total annual burden of 270 hours (90 hours × 3 responses). Based on updated program data to account for variability and uncertainty, OSM now anticipates one project annually, resulting in a total annual burden of 90 hours (90 hours × 1 response). The per-project burden remains at 90 hours.
This change reflects an adjustment to burden estimates, not a program change, and is based on more accurate, experience-based estimates of the time required to complete the information collection.
Summary of Burden Adjustment
270 Previously approved annual burden
- 180 Reduction due to adjustment
90 Total annual burden requested
16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
OSM had no plans to tabulate or publish the information collected under this information collection. The information was collected and used solely for internal program oversight, consultation, and compliance determinations on a project-specific basis. No statistical or complex analytical techniques were used.
The information collection occurred on an as-needed basis in conjunction with the review and oversight of individual Abandoned Mine Land reclamation projects have no fixed project time schedule.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
OSM is not requesting approval to waive the requirement to display the OMB expiration date for this information collection.
18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."
There are no exceptions to the certification statement for this information collection.