0596-0022_2015_renewal_suptstmt 2015-01-28

The Supporting Statement for OMB 0596-0022

36 CFR part 228, Subpart A-Locatable Minerals

January 2015

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.

Pertinent Laws and Regulations

• Organic Act of 1897

• 1872 Mining Law

• 36 CFR 228, Subpart A

The United States General Mining Laws, as amended, govern prospecting for and appropriation of metallic and most nonmetallic minerals on National Forest lands set up by proclamation from the public domain. These laws give individuals the right to search for and extract valuable mineral deposits, and secure title to the lands involved. A prospector may locate a mining claim upon the discovery of a valuable mineral deposit. Recording that claim in the local county courthouse and with the appropriate BLM State Office affords protection to the mining claimant from subsequent locators. A mining claimant is entitled to reasonable access to the claim for further prospecting, mining, or necessary related activities, subject to other applicable laws and regulations. Locatable mineral regulations are specific rules and procedures for use of the surface of National Forest System lands, in connection with mineral operations authorized by the United States mining laws, to minimize adverse environmental impacts to surface resources.

This is a request for renewal of OMB approval for three different collections of information that have been an integral part of the regulations since they were first published on August 28, 1974. Two of the information requirements are described in 36 CFR 228.4, Plan of Operations – Notice of Intent – Requirements. The third information collection requirement is described in 36 CFR 228.10, Cessation of Operations, removal of structures and equipment. Current approval for these three information collections expires December 31, 2011.

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.

1. What information will be collected - reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)

The information requirements for a Notice of Intent include:

• The information to identify the area involved;

• The nature of the proposed operations;

• The route to the area of operations; and

• The method of transport.

The information requirements for a Plan of Operations include:

• The name and legal mailing address of the operators. If the claimant and the operator differ, the name and legal mailing address of the lessees, assigns, or designees;

• A map/sketch of the proposed area of operations, existing/proposed roads or access routes, and the approximate location/size of disturbance;

• A description of the type of operations proposed

• A description of how the operation would be conducted

• A description of the type and standard of existing/proposed roads/access routes;

• A description of the means of transportation to be used;

• A description of the period during which the proposed operation will take place; and

• Mitigation and monitoring measures to meet the environmental protection requirements of the following:

  • Air quality

  • Water quality

  • The Federal Water Pollution Control Act;

  • Solid wastes;

  • Tailings, dumpage and other waste;

  • Scenic values;

  • Fisheries and wildlife habitat;

  • Roads;

  • Reclaim disturbed area; and

  • Removal of structures, equipment and other facilities and site clean-up.

The information requirements for a cessation of operations include:

• Verification to maintain the structures, equipment and other facilities;

• Expected reopening date;

• Estimate of extended duration of operations; and

• Maintenance of the site, structures, equipment and other facilities during non-operating periods.

2. From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.

Forest Service employees collect the required information from either the mineral operator or the mining claimant.

2. What will this information be used for - provide ALL uses?

In order for the Forest Service to determine the appropriate mitigation measures for a given locatable mineral operations, Agency personnel must gather a certain amount of fundamental information in order to evaluate the proposed operation. This gathering of information and the subsequent evaluation prior to occupancy minimizes to the extent practicable, the surface resource impacts and the necessary reclamation performance bond. However, once there is a proposal to modify an approved mining operation, then new additional information has to be submitted. A modification is considered a new plan of operations, and for each operation, the Forest Service only gathers the required information once.

2. How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)? Does the respondent have multiple options for providing the information? If so, what are they?

There is no particular format required for the three different information collections associated with the locatable mineral regulations.

For mineral operations which require a plan of operations, the most common format used is the Plan of Operations form FS-2800-5 developed by the Forest Service. However, the use of this form is optional and the information is collected from the operator in whatever format or type of medium that the operator chooses.

There is no specific form for either a Notice of Intent or a Cessation of Operations, but the operator is still required to furnish the information identified in the regulations.

2. How frequently will the information be collected?

On average, the information is collected once annually for each of the following:

• Plan of Operations

• Notice of Intent

• Cessation of Operations

2. Will the information be shared with any other organizations inside or outside USDA or the government?

The information will be shared with several western states. All western states (SD,CA,AZ,NM,CO,UT,WY,OR,WA,ID,MT,AK,NV) may also require some kind of permit for larger scale exploration and mining activities. The Forest Service has a Memorandum Of Understanding (MOU) with most western states where the Forest Service and the States share information about Plans of Operation and Cessation of Operations.

2. If this is an ongoing collection, how have the collection requirements changed over time?

The collection requirements have not changed since the last renewal of this information collection.

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.

The operator/claimant has the option to choose the method/form most convenient for them when submitting the required information. They may submit a paper copy of FS-2800-5 provided by the Forest Service, may submit by Fax, or by face-to-face meeting.

In an effort to reduce burden, the form is also available be downloaded from the Minerals and Geology website and filled out and submitted electronically by email.

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 Forest Service has signed Memorandums of Understanding with Idaho, Washington, Wyoming, Montana, Utah, Colorado, South Dakota, Nevada, Oregon, and California. The intent of these memos is to reduce the amount of administrative duplication between all of the States that have similar requirements and the Forest Service, and achieve a more efficient use of personnel and appropriations, and eliminate duplicate requirements to the operator/claimant.

To avoid duplication of effort, the Forest Service works closely with county and state officials to ensure, as practicable, that conditions required of operators in minimizing adverse environmental impacts conform to applicable local, state, and federal regulations. The Forest Service may accept functional equivalents to its requirements of documents relating to operating plans, reclamation plans, and environmental studies, when such plans and studies meet or exceed the minimum standards set by USDA requirements.

5. If the collection of information im­pacts small businesses or other small entities, describe any methods used to mini­mize burden.

The regulations at 36 CFR Part 228, Subpart A, provide the Forest Service and the mining community with the means of meeting mutual environmental responsibilities to protect the surface resources of National Forest System lands. One passage from the regulations at 228.4(b) states: “any person conducting operations on the effective date of these regulations that would have been required to submit a plan of operations under 228.4(a) may continue operations…” Nothing in the mineral regulations suggests that small business entities should be able to conduct mineral operations under different environmental standards than large corporations. A plan of operations is evaluated on its own merits, and the required mitigation measures are based on the projected disturbance to surface resources. Whether the operator is a large corporation or a small business, and whether the proposed plan of operations is for a routine operation or for a complex one, the evaluation is based on the merits of the specific plan that was submitted.

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.

Without prior notification, and without an established procedure for joint Forest Service and operator planning, serious, long-lasting, and avoidable adverse impacts on surface resources could become a common occurrence. Access roads improperly located and constructed would most likely result in aesthetic damage, soil loss, and water pollution. Soil loss, water pollution, and adverse impacts to plants and animals and their habitat will also probably occur with the unplanned disposal of waste rock and mill tailings, inadequate water drainage controls in disturbed areas, ill conceived or careless bulldozer prospecting, and the failure to reclaim disturbed areas after operations are completed. Public safety to national forest users would also be a major concern if operators were allowed to leave shafts, cuts, and adits uncovered, unfenced, or unmarked.

Forest managers collect this information to ensure that:

• The mineral operations are conducted in an environmentally sensitive manner;

• Mineral operations are integrated with the planning and management of other resources;

• Lands disturbed by mineral operations are reclaimed using the best scientific knowledge and principles;

• Lands disturbed by mineral operations are reclaimed and returned to other productive uses;

• The mineral operations are in accordance with our legal and regulatory authority; and

• Mineral operations conducted in congressionally designated or other withdrawn areas are supported by valid existing rights.

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;

• The Forest Service does not initiate Notices of Intent, Plans of Operation or Cessation of Operations. Under the Mining Law the public has the right of self-initiation to search for and develop locatable mineral resources.

• 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.

If an operator is required to submit proprietary data such as trade secrets because of the potential surface disturbance, then that information would be locked up for security reasons, and it would be immediately returned to the operator when no longer needed. This is further described in answer #10 regarding the treatment of information under the Freedom of Information Act.

There are no other special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.

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 describe actions taken by the agency in response to these comments. Specifically address com­ments received on cost and hour burden.

The Forest Service published a notice in the Federal Register on October 10, 2014 in Volume 79, page 61281 and invited public comments on the extension of the information collection for locatable mineral operations. No public comments were received.

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 record keeping, 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 3 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.

The following locatable mineral operators were contacted and asked for their views on the availability of data, frequency of collection, the clarity of instructions, record keeping, disclosure, or reporting form, and on the data elements to be recorded, disclosed, or reported to the Forest Service authorized officer. The miners interviewed represent a wide geographic range. Three people were contacted to get their views on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

• Christy Woodward, Dennison Mines, Phone (303) 389-4136

• Dave McPherson Phone (541) 938-6229

• John Chakarun Phone (541) 523-1670

Summary of Comments: All thought the form and information requested was reasonable and at the right level of detail. It took between 30 minutes and 4 hours to fill out a Notice of Intent. It took between 2 hours and several days to fill out a Plan of Operations. Cessation of Operation usually took about an hour.

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

The Forest Service does not provide any kind of payment or gift to the respondents or grantees regarding information collection requirements of 36 CFR Part 228, Subpart A, for locatable mineral operations.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Evaluation of impacts on surface resources from Plans of Operations may, in some cases, require obtaining data considered proprietary by operators, and as such, may affect their competitive interests if it is released. Such data are usually not requested. However, when requested, it is only released with the operator’s consent. When the data is kept, it is Forest Service practice to keep such data secured in locked storage. When the requested data is not retained, the information is usually examined and immediately returned to the operator.

All information and data submitted by an operator pursuant to the regulations at 36 CFR Part 228, Subpart A, shall be available for examination by the public at the office of the District Ranger in accordance with the provisions of the Freedom of Information Act and the Privacy Act. We have included the specific wording found in Section 228.6 of the locatable mineral regulations that pertains to the confidentiality of the information provided by respondents. It is as follows:

“Except as provided herein, all information and data submitted by an operator pursuant to the regulations in this part shall be available for examination by the public at the Office of the District Ranger in accordance with the provisions of 7 CFR 1.1-1.6 and 36 CFR 200.5-200.10. Specifically identified information and data submitted by the operator as confidential concerning trade secrets or privileged commercial or financial information will not be available for public examination. Information and data to be withheld from public examination may include, but is not limited to, known or estimated outline of the mineral deposits and their location, attitude, extent, outcrops, and content, and the known or planned location of exploration pits, drill holes, excavations pertaining to location and entry pursuant to the United States mining laws, and other commercial information which relates to competitive rights of the operator.”

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 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 kind of information is not required from the mining claimant/operator.

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.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form.

a) Description of the collection activity

b) Corresponding form number (if applicable)

c) Number of respondents

d) Number of responses annually per respondent,

e) Total annual responses (columns c x d)

f) Estimated hours per response

g) Total annual burden hours (columns e x f)

Table #1 – Burden Estimate

Description of Collection Activity	Form Number	Annual Number of Respondents	Number of Responses Annually per Respondent	Total Annual Responses	Estimated Hours per Response	Total Annual Burden Hours
Plan of Operations	FS-2800-5 (optional)	111	1	111	12	1,332
Notice of Intent	None	169	1	169	2	338
Cessation of Operations	None	3	1	3	1	3
Totals	---	283	---	283	---	1,673

Each year, the Forest Service gathers information from field offices to determine how many Plans of Operation and Notices of Intent were received during the previous year. The latest figures indicate that 111 Plans of Operations and 169 Notices of Intent were received.

• Record keeping burden should be addressed separately and should include columns for:

a) Description of record keeping activity: None

b) Number of record keepers: None

c) Annual hours per record keeper: None

d) Total annual record keeping hours (columns b x c): Zero

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

The United States Geological Survey (USGS) published earnings information pertaining to locatable mineral operations. That information can be found in the Mineral Commodity Summaries 2014. The USGS disclosed that the estimated “Average weekly earnings of production workers” data for metal mining in 2009 it was $1,093. However, these data are no longer available for 2010, 2011, 2012 and 2013 because of changes to U.S. Department of Labor reports. Without this information, the agency took the previous average hourly wage of $27.32 and increased it by 10% for the last three years. This calculates an estimate of weekly earnings of $1,202. Based on 40 hours a week and on an 8-hour workday, the average hourly salary in the locatable mineral arena would be about $30.05. The total annual cost to respondents is $50,274.

Table #2 – Cost to Respondents

Information Collection	Total Burden Hours		Cost per Hour		Total Annualized Cost to Respondents
Plan of Operations		1,332		$30.05	$40,027
Notice of Intent		338			$10,157
Cessation of Operations		3			$90
Total					$50,274

13. Provide estimates of the total annual cost burden to respondents or record keepers 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 are no capital operation and maintenance costs.

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 response to this question covers the actual costs the agency will incur as a result of implementing the information collection. The estimate should cover the entire life cycle of the collection and include costs, if applicable, for:

• Employee labor and materials for developing, printing, storing forms

• Employee labor and materials for developing computer systems, screens, or reports to support the collection

• Employee travel costs

• Cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information

• Employee labor and materials for collecting the information

• Employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information

The following assumptions were used to create tables 3-6:

• Each individual was a Step 5 pay grade; and

• The 2015 General Pay Schedule for the Federal Government was used.

Table #3 shows how the estimated cost was calculated for the Forest Service to prepare and environmental assessment and then conduct the associated project administration.

Table #3: Est. Cost to Prepare an Environmental Assessment and do Project Administration

ACTION ITEM	PERSONNEL	GS LEVEL	HOURLY RATE	HOURS	SALARY
Plan reviewed, questions and deficiencies noted, call(s) to operator, new changes drafted, on-the-ground meeting w/operator scheduled.	Technician	9	$28.60	2	$57.20
Cultural resource survey conducted	Archeologist	11	$34.60	10	$346.00
Meet w/operator in the field	Technician	9	$28.60	8	$228.80
Meet w/District Ranger to discuss operation and designate ID team	Technician District Ranger	9 13	$28.60 $49.32	1 1	$ 28.60 $ 49.32
Send synopsis of plan to ID team, set up ID team meeting and T&E survey	Technician	9	$28.60	2	$ 57.20
ID team meeting in office and field	Technician District Ranger Hydrologist Geologist Engineer Biologist Soil Scientist Botanist Forester Fisheries Bio IDT Leader District Ranger	9 13 11 11 11 11 11 11 11 11 11 13	$28.60 $49.32 $34.60 $34.60 $34.60 $34.60 $34.60 $34.60 $34.60 $34.60 $34.60 $49.32	13 4 8 12 12 8 8 44 8 40 40 2	$371.80 $197.28 $276.80 $415.20 $415.20 $276.80 $276.80 $1,522.40 $276.80 $1,384.00 $1,384.00 $98.64
Public scoping letters	Technician Clerical	9 4	$28.60 $16.87	5 4	$143.00 $67.48
Fisheries/wildlife/botany surveys conducted and report prepared	Biologist	11	$34.60	18	$622.80
Make changes based on issues/concerns from field visit, discuss with operator	Technician Geologist	9 11	$28.60 $34.60	8 8	$228.80 $276.80
Make copies, send Plan to ID team and interested parties.	Geologist Clerical Technician	11 4 9	$34.60 $16.87 $28.60	1 1 2	$ 34.60 $16.87 $57.20
Compile public scoping and ID team comments, develop changes, calculate reclamation bond.	Technician Engineer	9 11	$28.60 $34.60	4 1	$114.40 $34.60
Office/on-site ID team meeting with operator, discuss changes, explain bonding, discuss surface disturbance	Technician Geologist Engineer Hydrologist Biologist Forester Soil Scientist Botanist	9 11 11 11 11 11 11 11	$28.60 $34.60 $34.60 $34.60 $34.60 $34.60 $34.60 $34.60	10 8 8 4 4 4 4 4	$286.00 $276.80 $276.80 $138.40 $138.40 $138.40 $138.40 $138.40
Prepare cultural resource survey report	Archeologist	11	$34.60	4	$138.40
Prepare draft Environmental Assessment	Technician	9	$28.60	12	$343.20
Hold public meeting	Technician District Ranger Geologist	9 13 11	$28.60 $49.32 $34.60	4 1 1	$114.40 $49.32 $34.60
Consultation with specialists, Environmental Assessment finalized	Technician Clerical Geologist	9 4 11	$28.60 $16.87 $34.60	16 4 1	$457.60 $67.48 $34.60
Respond to comments received, specialists review the Environmental Assessment, minor changes made, Environmental Assessment finalized, news release prepared, District Ranger signs authorization, operator notified when to begin work, publish notice in the local newspaper.	Technician Hydrologist Geologist Engineer Biologist Forester District Ranger	9 11 11 11 11 11 13	$28.60 $34.60 $34.60 $34.60 $34.60 $34.60 $49.32	26 1 2 1 1 1 1	$743.60 $34.60 $69.20 $34.60 $34.60 $34.60 $49.32
Cost Estimate to Prepare Environmental Assessment					$13,031.11
Project administration	Technician Hydrologist Geologist Engineer Biologist Forester	9 11 11 11 11 11	$28.60 $34.60 $34.60 $34.60 $34.60 $34.60	60 4 8 24 4 4	$1,716.00 $ 138.40 $ 276.80 $ 830.40 $ 138.40 $ 138.40
Cost Estimate to Conduct Project Administration					$3,238.40
Total Cost to Process/Administer a Plan of Operations					$16,269.51

Table #4 shows how the estimated cost to process a Notice of Intent is calculated.

Table #4: Estimated Cost to Process a Notice of Intent

ACTION ITEM	PERSONNEL	GS LEVEL	HOURLY RATE	HOURS	SALARY
Specialist Input	Geologist Biologist	11 11	$34.60 $34.60	0.5 0.5	$17.30 $17.30
Review Notice of Intent, prepare response, and one field check.	Technician	7	$23.38	4.0	$93.52
Review Notice of Intent and sign	District Ranger	13	$49.32	0.5	$24.66
Total Cost to Process a Notice of Intent					$152.78

Table #5 shows how the estimated cost to process a Cessation of Operations was calculated.

Table #5: Estimated Cost to Process a Cessation of Operations

ACTION ITEM	PERSONNEL	GS LEVEL	HOURLY RATE	HOURS	SALARY
Review Cessation of Operations, prepare response, and one field check	Technician	7	$23.38	4.0	$93.52
Review Cessation of Operations and sign	District Ranger	13	$49.32	0.5	$24.66
Total Cost to Process a cessation of operations					$118.18

Table #6 shows how the total estimated cost to deal with the information collection requirements in 36 CFR Part 228, Subpart A, was calculated. The costs do not include:

• Conducting a Surface Use Determination

• Preparation of this justification

• Litigation

• Table #6: Total Estimated Cost for Information Collection under 36 CFR Part 228, Subpart A

INFORMATION COLLECTION	NUMBER OF RESPONDENTS	COST PER ACTION ITEM	TOTAL COST
Plan of Operations	111	$16,269.51	$1,805,916
Notice of Intent	169	$ 152.78	$ 25,820
Cessation of Operations	3	$ 118.18	$ 355
Total Cost			$1,832,091

The total estimated annual cost to the Government for this Information Collection Request is $1,832,091.

15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB form 83-I.

Since the last submission there has been a reduction in the number of exploration and mining proposals submitted to Forest Service. This renewal submission reflects an adjustment decrease of 879 respondents, 879 responses and 5,348 burden hours.

Table #7

Information Collections	Year			Hour Burden of Collection			Total Burden Hours
	2008	2009	2010	2008	2009	2010	2008	2009	2010
Plan of Operations	1,728	5,640	470	8.0	12.0	12.0	13,824	67,680	5,640
Notice of Intent	1,400	1,378	689	2.0	2.0	2.0	2,800	2,656	1,378
Cessation of Operations	0	3	3	1.0	1.0	1.0	0	3	3
Total Burden							16,624	70,339	7,021

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

There are no plans to publish the results of this information collection.

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.

As in previous renewals, the Forest Service is requesting approval to not display the expiration date on form FS-2800-5.

Displaying the OMB approval expiration date has in the past caused some confusion with many operators and Forest Service personnel, particularly when the expiration date has elapsed and the request for the next information collection cycle has not yet been approved. Operators are reluctant to fill out a form that has expired or will expire in the near future. Many Forest Service employees are confused about that period of time when the expiration date has lapsed and the new information collection is still at OMB waiting approval.

18. Explain each exception to the certification statement identified in item 19, "Certification Requirement for Paperwork Reduction Act."

There are no exceptions to the certification statement identified in item 19 of form 83-I, “
Certification Requirement for Paperwork Reduction Act.”

B. Collections of Information Employing Statistical Methods

The Forest Service does not employ statistical methods regarding the information collected.

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