SS-0335 2013 v1

SUPPORTING STATEMENT

OMB Clearance 0579-0335

National Management Information System

August, 2012

Terms of Clearance: Wildlife Services has conducted initial examination of the feasibility of automation of our collection of information for MIS and are consulting with APHIS concerning such implementation as soon as APHIS has completed its process which will allow digital signing for official documents.  APHIS currently has a working group assigned to identify necessary agency actions to implement digital signing.  The working group is meeting on a regular basis to provide recommended solutions as soon as possible.  When digital signing is authorized by the agency, Wildlife Services will implement a process by which cooperators will have the option to electronically review and sign agreements, work initiation documents and other forms as part of the collection process.

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), Wildlife Services (WS), is a service program that responds to requests by persons and agencies needing help with wildlife damage. Congress has directed APHIS/WS to take a leadership role in managing conflicts that occur between people and wildlife. Assistance is available to all citizens upon request. The primary statutory authority for the APHIS/WS program is the Act of March 1931 (7 U.S.C. 426-426c; 46 Stat. 1468), as amended. Section 426 of the Act authorizes the “Secretary of Agriculture to conduct a program of wildlife services with respect to injurious animal species and take any action the Secretary considers necessary in conducting the program. The Secretary administers the program in a manner consistent with all of the WS authorities in effect on the day before the date of the enactment of the Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2001.” Section 426c States that “hereafter, the Secretary of Agriculture is authorized, except for urban rodent control, to conduct activities and to enter into agreements with States, local jurisdictions, individuals, and public and private agencies, organizations, and institutions in the control of nuisance mammals and birds and those mammal and bird species that are reservoirs for zoonotic diseases…”

In the normal course of business in response to requests for wildlife damage management assistance, WS collects information about organizations, industry, Federal and non-Federal entities, and members of the public as part of its program. That program is usually viewed as having two parts: the cooperative direct control and technical assistance programs. In the cooperative direct control program, WS provides goods, services, and expertise to address wildlife damage. Customers must reimburse USDA for money and time spent by WS to conduct these kinds of programs. In technical assistance programs, WS gives advice in the form of telephone consultations, personal onsite consultations, training sessions, demonstration projects, etc. WS usually provides only technical expertise in these activities and the customer usually conducts whatever activities are likely to resolve or mitigate resource damage by wildlife of concern. These activities are usually free to the public.

Information provided by customers in the WS programs is voluntary so that WS can prepare to help them, and do a good job. For the purpose of understanding, all persons who receive help from WS are referred to as “Cooperators” in this document.

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.

Information collected in most situations is used in routine business communication activities by WS as part of its cooperative programs initiated by request from the Public, and Government entities.

This information is used by the Agency to:

• Uniquely identify and differentiate between Cooperators (i.e., property owners, land managers, or resource owners) who request assistance to manage damage caused by wildlife,

• Identify the land areas where wildlife damage management activities would be conducted,

• Identify the relationship between resources or property and the damage caused by wild animals,

• Evaluate frequency and efficacy of methods or damage management activities WS uses to address wildlife damage,

• Establish a cooperative agreement with a Cooperator,

• Document that permission has been obtained for WS employees to go on the property of the Cooperator to perform activities that are related to the work defined in “Work Initiation Documents for Wildlife Damage Management,” and Work and Financial Plans,

• Record wildlife damage occurrences on the Cooperator property and steps that WS takes to address them,

• Record occurrences which may have affected non-target species or humans during, or related to, WS project actions.

Some of the information collected is used by WS field specialists actively doing business with Cooperators who submitted the information. They use the information to report to supervisors, and to communicate with the Cooperator. WS clerks and program managers, WS budget specialists and analysts who track program progress and budgets at the district, State, and

regional level use some of the collected information to keep a record as part of Agency requirements related to administrative process and budget tracking. WS database managers use

the information to create data links between one element of datum and another about activities conducted on properties of Cooperators. In addition, the information is used by WS supervisors who have some supervisory authority over those working with the project where the information was collected. They use the collected information to assess and track progress regarding projects being performed by field specialists, and to contact the Cooperator when needed for the benefit of the overall program. In addition, part of the collected information is used by both field specialists and supervisors to report to appropriate regulatory Federal and State agencies about WS use of restricted-use pesticides, or for reporting animal incidents that might be part of the responsibility of such an Agency or regulatory authority. Other uses of information collected are in accordance with “routine uses” as described in WS’ Privacy Act Notice. All information collections are itemized below with additional information about each.

Also, all forms associated with developing and maintaining cooperative program activities with customers are discussed below. Please note that all forms, except surveys, are completed by WS field employees with information available from public sources (i.e., county and State land records) and through interviews with cooperators.

WS FORM 12A (Work Initiation Document for Wildlife Damage Management)

This form authorizes WS to enter premises, apply certain methods, tools, or strategies to address damage being caused by certain species, and to conduct direct control activities on private, non-private, or adjacent landowner property, and/or conduct aerial operations on certain premises. A completed Form 12A contains the Cooperator’s name, address, telephone number, and signature in addition to the class of land involved in the work authorized by the work initiation document.

WS FORM 12A Addendum (Addendum to a Work Initiation Document for Wildlife Damage Management)

This form is an additional page for the WS Form 12A, to be used to record additional species or components associated with the work initiation document that it becomes a part of. The form requires the signature of the Cooperator.

WS FORM 12B (Work Initiation Document for Wildlife Damage Management - Multiple Resource Owners)

This form documents that WS will enter certain premises by authorization from a primary Cooperator, use certain techniques, and conduct direct control activities on the property for the protection of resources located on that property that may be owned or managed by different individuals, companies, or organizations (i.e., multiple resource owners). For example, if several ranchers are grazing their cattle on the same allotment that is managed by the Department of Interior, Bureau of Land Management, then this form must be completed. This form enables WS to capture information about all resource owners involved in an agreement.

WS FORM 12B Addendum (Addendum to a Work Initiation Document for Wildlife Damage Management - Multiple Resource Owners)

This form is an additional page for the WS Form 12B, to be used to record additional species or components associated with the work initiation document that it becomes a part of. The form requires the signature of the Cooperator.

WS FORM 12C (Work Initiation Document for Management of Wildlife Damage on Urban Properties)

This form collects information specific to WS Cooperative Service Agreements conducted in urban settings. Information collected includes landowner names, addresses, telephone numbers, types of property, and signatures.

WS FORM 14 (Project Report)

This form collects information about damage to resources of different types. Information collected includes the name, address, and telephone number of the resource owner.

WS FORM 17 (Pocatello Supply Depot Order Form)

This form is used by State Directors to place orders for supplies carried by Pocatello Supply Depot. These forms are completed when something is ordered for a specific State program, or for a requester who may be a non-WS entity or individual. In cases where the order is placed for supplies for the latter, the name, address, telephone number, and the pesticide applicator license number of an individual may be recorded.

WS FORM 18 (Control Materials Sales Record)

This form captures information about a customer who purchases control materials from WS. This information includes the buyer’s land class, name, address, certified pesticide applicator’s license or certificate number, and signature.

WS FORM 30 (WS Assistance Request)

This form is used to record data from a request by an individual for assistance with a wildlife damage problem. This completed form captures the name, address, and phone number of the Cooperator; the location where the damage is occurring; and may collect information about the resource being damaged and the lost value of the resource.

WS FORM 35 (Report of Injury or Death of Nontarget Animal)

This form collects information about a nontarget animal which was injured or killed during a WS Wildlife Damage Management activity. Information captured includes the name, address, and phone number of the owner of the animal being reported (if applicable), and location of the occurrence.

WS FORM 37 (Migratory Bird Damage Project Report)

This form collects information about damage being caused by a migratory bird species for the purpose of assisting a requester to obtain a depredation permit from the U.S. Fish and Wildlife Service in order to take some action to reduce damage. Information collected includes the Cooperator’s name, address, telephone number, and location of the damage occurring. This information is voluntarily sent to the U.S. Fish and Wildlife Service by the Cooperator in an application package requesting a permit.

WS FORM 66 (Nuisance Wildlife Permit [Louisiana])

This form is used to assist requesters in Louisiana to obtain a nuisance wildlife permit from the Louisiana Department of Wildlife and Fisheries (DWF). Information captured is used by WS and DWF to provide services to the requester and to process the permit. Information includes the name, address, phone number, and property location where the protected resource is located.

WS Form 68 (WS Abatement Program Assignment of U.S. Government Property)

This form captures information about equipment sales or rental to the Cooperators in State wildlife damage abatement programs. Information collected includes name, address, telephone number, and social security number of participating cooperators.

WS Form 45 (Resource Values Survey)

This form is used to obtain prices for various resources which are listed in the WS database but are not available through the internet or other forms of open advertising used by various businesses. Information collected will include current prices on marketed items that individual companies offer for sale. Other information recorded on this form such as name of business and contact information about the business is acquired by WS employees from the internet or other advertisements. This survey will not employ statistical methods because it is conducted for the sole purpose of obtaining an average wholesale or retail value of selected resources (products) to populate resource values in the WS database. This survey will query an average of 50 business entities per year.

Cooperative Agreement Forms (SF 424, 424a, 424b, and LLL)

WS enters into agreements with States, local jurisdictions, individuals, public and private agencies, organizations, and institutions in the control of nuisance mammals and birds and those mammal and bird species that are reservoirs for zoonotic diseases.

** All forms, except the WS Form 45, are filled out by Individuals, Private Sector, and State, Local or Tribal Groups. The WS Form 45 is only filled out by the Private Sector.

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. Also describe any consideration of using information technology to reduce burden.

Almost all information collection activities (estimated 98%) are currently performed through non-electronic, non-automated, mechanical collection methods. Forms are usually completed through collaboration between Cooperators and WS employees by telephone or in person. This process is most often used because hard copy documents are kept which have the signature or name of the WS employee or the Cooperator, or both.

Most collection instruments listed in Question 2 are connected with agreements for management of wildlife damage, and require the Cooperators’ signatures. So, if direct contact with the person who signs for the cooperating entity is not convenient or possible, WS mails documents through Federal Express or the U.S. Postal Service to them for signature. In some instances (5% or less), field managers may generate electronic documents which are e-mailed to Cooperators who electronically or manually complete them. They are then printed by the Cooperator, manually signed (when required), and returned to the originating WS office where they are signed by WS representatives and executed copies are then returned by mail or are hand-delivered to the Cooperator. A similar procedure is used for a small percentage of facsimile copies sent to Cooperators upon request.

4. Describe efforts to identify duplication. Show specifically why any similar information

already available cannot be used or modified for use for the purpose described in Item 2 above.

APHIS is the only Federal agency acquiring authorization to conduct wildlife damage management activities in agreement with the Cooperator, and for tracking the progress and results of such activities. The information APHIS is collecting is its only source for the information and is not being collected through other forms or reports.

5. If the collection of information impacts small businesses or other small entities (Item 5 on OMB Form 83-I), describe any methods used to minimize burden.

WS perceives the information collection impact to be negligible for small businesses or other small entities. Over 70 percent of all respondents is in the collection are considered small business. As described in Question 3, however, WS is initiating development of electronic forms which can be e-mailed to such entities for signature when this helps to reduce the burden.

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.

The service that WS provides helps to minimize the negative impacts of wildlife on agriculture, property, natural resources, and human health and safety. Without the methods of collection, the mission of WS would be negatively impacted. WS would be unable to carry out business procedures with its Cooperators or measure annual Agency progress against performance objectives. Without this information collection, program managers would be unable to monitor and track data, refine program policies, or implement new programs.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

• 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 secret, or other confidential information unless the agency can demon­strate that it has instituted procedures to protect the information's confidentiality to the extent permit­ted by law.

No special circumstances exist that would require this collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

8. 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 form, and on the data elements to be recorded, disclosed, or reported. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency’s notice, soliciting comments on the information collection prior to submission to OMB.

WS engaged in productive consultations with the following individuals in 2012:

Peter Orwick, Executive Director

American Sheep Industry Association (ASI)

9785 Maroon Circle Suite 360

Centennial, CO 80112

(303) 771-3500 ext. 33

Email: porwick@sheepusa.org

Barbara Decaro, Resource Conservation Coordinator

Seattle Parks and Recreation, Natural Resources Management Unit

1600 S. Dakota St.

Seattle, WA 98108-1546

Ph. (206) 615-1660

Email: Barbara.DeCaro@seattle.gov

Henry Bierlink, Executive Director Whatcom Farm Friends 

1796 Front Street Lynden, WA 98264 

Ph. 360‐354‐1337    

Email: hbierlink@wcfarmfriends.com 

The Agency’s notice of information collection activity was announced in the Federal Register on Tuesday, December 4, 2012, pages 71774 – 71775. During this time APHIS received one comment from interested members of the public. The comment did not deal with paperwork burden.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There are no plans to provide any payments 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.

No additional assurance of confidentiality is provided with this information collection. Any and all information obtained in this collection shall not be disclosed except in accordance with

5 U.S.C. 552a.

Confidentiality is ensured under the conditions prescribed by WS in the Privacy Act Notice (attached) provided to respondents in the collection of information.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private.

This information collection activity asks no questions of a personal or sensitive nature.

12. Provide estimates of the hour burden of the collection of information.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

• Provide estimates of annualized cost to respondents for the hour burdens for collection of information, identifying and using appropriate wage rate categories.

See APHIS Form 71 for burden estimates. The cost to the public was determined by multiplying the total number of burden hours (5,448) x the wage per hour ($21.74) which equals $118,429.52.

$21.74 is the hourly rate derived from the U.S. Department of Labor, Bureau of Labor Statistics Report - National Compensation Survey: Occupational Wages in the United States, May, 2012. See http://www.bls.gov/news.release/ocwage.t01.htm.

13. Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates 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.

There is zero annual cost burden associated with capital and start-up, operation and maintenance, and purchase of services in connection with this program.

14. Provide estimates of annualized cost to the Federal Government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The estimated cost to the Federal Government is $175.661.58 (See APHIS Form 79.)

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

ICR Summary of Burden:

	Requested	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate	Change Due to Potential Violation of the PRA	Previously Approved
Annual Number of Responses	117,772	0	0	26,706	0	91,066
Annual Time Burden (Hr)	5,448	0	0	1,285	0	4,163
Annual Cost Burden ($)	0	0	0	0	0	0

There is an adjustment increase due to the following: the number of respondents has increased by 26,706; annual responses have increased by 26,706; and the total burden hours have increased by 1,285. These increases are due to an increase in the number of respondents which also impacted the annual responses and total burden hours. This collection is conducted for the purpose of initiating and conducting wildlife damage management programs with Cooperators.

In the last submission, the common form – SF-424 was listed but the burden associated with the number of respondents, annual responses, and burden hours were not accounted for. Now the burden for the SF-424 has been included in this submission.

The burden for the SF-424 is 4 respondents, 4 total annual responses, and 3 total hours.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

APHIS has no plans to tabulate or publish the information it is collecting.

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.

APHIS has no plans to seek approval for not displaying the OMB expiration date on its forms.

18. Explain each exception to the certification Statement identified under “Certification for Paperwork Reduction Act.”

APHIS certifies compliance with all provisions of the Act.