Document
Supporting Statement A
ICR 202608-1018-001 · OMB 1018-0174 · Object 171857600.
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
|---|---|
| File Title | Supporting Statement A |
| Author | Hilla-Custodio, Andrea |
| Last Modified By | Writer |
| File Modified | 2026-08-19 |
| File Created | 2026-09-15 |
| Conversion State | complete |
Extracted Text
Supporting Statement A for
Paperwork Reduction Act Submission
U.S. Fish and Wildlife Service Preliminary Land Acquisition Processes
OMB Control Number 1018-0174
Terms of Clearance: None
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
Information collected by the U.S. Fish and Wildlife Service (in support of the Pre-Acquisition Tracking System (PATS) database) is required under applicable statutes, Department of Justice regulations, Departmental and Service policies, and best business practices. In addition, the PATS database facilitates Secretarial Orders 3356 and 3366 by tracking land acquisitions that have potential to support public hunting, fishing, and other forms of outdoor recreation, and access related thereto. The collection of realty-related information is required and supports the following authorities:
• Regulations of the Attorney General Governing the Review and Approval of Title for Federal Land Acquisitions (2016);
• Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (42 U.S.C. § 4601 et al.);
• National Wildlife Refuge Administration Act of 1966 (16 U.S.C. § 668dd);
• Migratory Bird Hunting and Conservation Stamp Act (16 U.S.C. § 718d);
• Migratory Bird Conservation Act (16 U.S.C. § 715-715r, as amended);
• Land and Water Conservation Fund Act of 1965, as amended (54 U.S.C. § 200301 et seq.);
• Endangered Species Act of 1973, as amended (16 U.S.C. § 1534);
• Emergency Wetlands Resources Act of 1986 (16 U.S.C. § 3901); and,
• Fish and Wildlife Act of 1956, as amended (16 U.S.C. § 742a).
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 Service tracks information collected from landowners as part of the preliminary land acquisition process. Information collected by the Service as part of the preliminary land acquisition process may include the following:
Initial Requests - Initial request to consider property, to include such items as:
• Identifying information for the legal property owner(s), such as:
◦ Name of primary property owner, along with spouse and/or co-owner(s) whose names appear on the current deed to the property under review;
◦ Marital status;
◦ Other names used; and
◦ Contact information to include telephone numbers, personal email addresses, and mailing/home addresses.
• Financial information, to include Social Security Numbers (necessary for final payment transaction). (NOTE: We collect as part of the process, but do not store within the system. The information stored securely within Interior’s Federal Business Management System.)
• Property description, to include such information as:
• Property name,
• Location,
◦ Legal description, and
• Introductory information.
Permission to Inspect and Appraise (Form 3-2471) – Collects information about the property owner and location, and grants permission to enter and inspect the property for real estate acquisition purposes. We do not use Form 3-2471 in projects that are under Memoranda of Understanding (MOU), Memoranda of Agreement (MOA), Cooperative Agreements, some donation partnerships, and other special cases.
Inspection may include, but is not limited to:
• Appraisal valuations;
• Boundary survey;
• Hazardous materials examination (contaminant survey); and
• Physical examination of any structures on the property.
We do not use Form 3-2471 in projects that are under Memoranda of Understanding (MOU), Memoranda of Agreement (MOA), Cooperative Agreements, some donation partnerships, and other special cases.
Waiver of Appraisal Requirement (Form 3-2461) – Per 49 CFR 24.102(c)(2), a willing-seller landowner may release the Service from the obligation of obtaining an appraisal for:
(1) Land donations, and
(2) Certain land acquisitions where the anticipated value is low and the valuation problem is uncomplicated.
Unless delivered in person, both the Permission to Inspect and Appraise (Form 3-2471) and the Waiver of Appraisal Requirement (Form 3-2461) will contain a cover letter referred to as the Access Permission Letter. The Access Permission Letter does not request any information but is used to explain the form or waiver process.
PROPOSED REVISION
The Service proposes to rescind Form 3-2471, “Permission to Inspect and Appraise” and Form 3-2461, “Waiver of Appraisal Requirement” forms. Service staff retrieve the necessary information from the internal PATS database prior to completing the forms and obtaining the signature of the property owner. The same data is submitted by applicants and also retrieved by Service staff from public realty records. All information is prepopulated by the Service, and the property owner signs only to verify and approve the information. Therefore, since the property owners are not required to resubmit this information, the forms do not require OMB approval under the PRA.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden and specifically how this collection meets GPEA requirements.
Currently, most landowners submit documents to the Service in paper format by either submitting the request by email attachment, in person or by post. We estimate receiving approximately 50-75% of submissions electronically.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The information that we collect is unique to each landowner conducting realty transactions with the Service and is not available from any other source.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This collection will not have a significant impact on small entities. We collect only the minimum information necessary to establish the identity of the landowner, to conduct the realty transaction, and to finalize electronic payment to the landowner.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
If we do not collect the information or if we collect the information less frequently, we would be unable to complete the realty transaction. Further, we would be unable to comply with Internal Revenue Service requirements to prepare the required Forms 1099 or process electronic payments.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
* requiring respondents to report information to the agency more often than quarterly;
* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
* requiring respondents to submit more than an original and two copies of any document;
* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
* in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study;
* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
* requiring respondents to submit proprietary trade secrets, or other confidential information, unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
There are no special circumstances that require us to collect this information in a manner inconsistent with OMB guidelines.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and in response to the PRA statement associated with the collection over the past three years, and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every three years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
On March 13, 2026, we published in the Federal Register (91 FR 12437) 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 12, 2026. We also published the Federal Register notice on Regulations.gov (Docket No. FWS-R3-NWRS-2025-1496). We received one comment in response to that notice:
Comment 1: Anonymous electronic comment received via Regulations.gov (FWS-HQ-NWRS-2025-1496-0004) on May 4, 2026. The commenter requested the Service protect all animals and end hunting, fishing, and trapping.
Agency Response to Comment 1: The commenter did not address the information collection requirements; therefore, no response is required.
In addition to the Federal Register notice, we contacted nine (9) private landowners who are familiar with this collection of information in order to validate our time burden estimate and asked for comments on the questions below:
“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: The information requested is necessary for those who wish to convey land to the Service. Since the Service's policy is to work exclusively with willing sellers, it is presumed that those being asked have entered willingly into a relationship with the Service and the questions are to provide basic information necessary to appropriately plan for land acquisition.
Agency Response/Action Taken: No action necessary
“The accuracy of our estimate of the burden for this collection of information”
Comments: 30 minutes is a reasonable estimate of time needed to verify basic land and landowner information. Much of the basic data can be obtained through public sources, so in many cases the Service is asking for verification in addition to obtaining necessary data that is not in the public record.
Agency Response/Action Taken: No action necessary
“Ways to enhance the quality, utility, and clarity of the information to be collected”
Comments: The requested information is very basic and straightforward. No further suggestions.
Agency Response/Action Taken: No action necessary
And
“Ways to minimize the burden of the collection of information on respondents”
Comments: As noted above, some basic land information is publicly available but it is important for landowners to concur and verify information collected buy other means.
Agency Response/Action Taken: No action necessary
Additional comments received during the outreach:
Comments: In my experience, information collection as part of the land acquisition planning process by the U.S. Fish and Wildlife Service is appropriate, is not an undue burden and serves to allow the land acquisition process to move forward expeditiously to the benefit of the landowner and the government.
Agency Response/Action Taken: No action necessary
Despite multiple attempts to solicit feedback, we only received comments from 1 of the 9 individuals contacted
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
We do not provide payment or gifts to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
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 maintained the information in a secure System of Records (FWS-11 – Real Property Records, 71 FR 68635 (November 27, 2006); modification published 88 FR 16277 (March 16, 2023).
In addition to personally identifiable information needed to identify property owners, we gather Social Security Numbers and banking information to assist with electronic payments and preparation of the required Internal Revenue Service Form 1099.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
We do not ask questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information. The statement should:
* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.
* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here.
We estimate that we will receive 669 responses totaling 495 annual burden hours. We estimate the dollar value of the annual burden hours to be $21,224 (rounded).
We used Table 1 from the Bureau of Labor Statistics (BLS) News Release USDL-26-0287, February 24, 2026, Employer Costs for Employee Compensation—September 2025, to calculate the cost of the total annual burden hours:
• Individuals – the hourly rate for all workers is $41.86, including benefits.
• Private Sector – the hourly rate for all workers is $39.61, including benefits.
• Government – the hourly rate for all workers is $57.02, 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
Initial Requests
Individuals 415 1 415 .5 208 $ 41.86 $ 8,706.88
Private Sector 221 1 221 1 221 39.61 8,753.81
Government 33 1 33 2 66 57.02 3,763.32
Permission to Inspect and Appraise (FWS Form 3-2471)
Individuals 0 0 0 0 0 0 0
Private Sector 0 0 0 0 0 0 0
Government 0 0 0 0 0 0 0
Waiver of Appraisal Requirement (FWS Form 3-2461)
Individuals 0 0 0 0 0 0 0
Private Sector 0 0 0 0 0 0 0
Government 0 0 0 0 0 0 0
TOTALS: 669 669 495 $ 21,224.01
*Rounded to match ROCIS
13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)
* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information (including filing fees paid for form processing). Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.
* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
There is no non-hour cost burden to respondents associated with this information collection.
14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
We estimate the total annual cost to the Federal government to administer this information collection is $14,328.
To determine average annual salary costs, we used the Office of Personnel Management Salary Tables identified in Table 14.1 to determine the annual salary costs for staff involved in reviewing and processing the information collected as shown below. In accordance with BLS News Release USDL-26-0287, we multiplied the annual salaries by 1.62 to account for benefits:
Table 14.1 – Salaries and Benefits:
Annual Salary* % of Time
Annual (Inc. Benefits) Spent on Position Grade OPM Table Salary* (Salary x 1.62) Collection Total Costs*
Realty Specialist (R1) GS-12/05 OR 2026-POR $ 109,303 177,071 1% $ 1,771
Realty Specialist (R2) GS-12/05 NM 2026-AQ 102,544 166,121 1% 1,661
Realty Specialist (R3) GS-12/05 MN 2026-MSP 110,594 179,162 1% 1,792
Realty Specialist (R4) GS-12/05 GA 2026-ATL 107,275 173,786 1% 1,738
Realty Specialist (R5) GS-12/05 MA 2026-HAR 114,459 185,424 1% 1,854
Realty Specialist (R6) GS-12/05 CO 2026-DEN 113,107 183,233 1% 1,832
Realty Specialist (R7) GS-12/05 AK 2026-AK 114,702 185,817 1% 1,858
Realty Specialist (R8) GS-12/05 CA 2026-SAC 112,449 182,167 1% 1,822
*Rounded TOTAL: $ 14,328
15. Explain the reasons for any program changes or adjustments in hour or cost burden.
We are reporting a discretionary burden change of -187 annual responses and -46 annual burden hours associated with the discontinuation of Forms 3-2461 and 3-2471, as explained in question 2 above.
We are also reporting a change in agency estimate of 294 annual responses and 179 annual burden hours.
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.
This information collection is not subject to statistical analysis, and we will not publish the results.
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.
We will display the OMB control number and expiration date.
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.