0579-0335 2019 SS (Revised 2)

September 2019
SUPPORTING STATEMENT
NATIONAL MANAGEMENT INFORMATION SYSTEM
OMB NO. 0579-0335
This is a reinstatement of a previously approved information collection with changes.
Terms of Clearance: “... Failure to make electronic signature available for this collection
[during the subsequent approved period] may result in disapproval of this collection. OMB
notes that the burden associated with SF-424 (3 hours) is a violation and should be
reported as such.”
APHIS is currently testing the use of eSign Live and its two factor authentication for obtaining
electronic signatures from the public but its use is currently restricted to pilot applications in
other programs. Another pilot program is testing the use of ezFEDGRANTS to establish an
electronic solution for creating and managing agreements. Wildlife Services is following both
programs’ progress closely for future adaptation by the program.
The use of Standard Forms (SF) in this information collection was discontinued.
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 Secretary of Agriculture is authorized under 7 U.S.C. 8351-8354 to take actions considered
necessary for the control of nuisance mammals and birds, and mammal and bird species that are
reservoirs for zoonotic diseases. These populations, if left unmanaged, may cause tremendous
economic damage to crops, livestock herds, and private property within the United States. The
Wildlife Services (WS) program of the United States Department of Agriculture Animal and
Plant Health Inspection Service is responsible for assisting the public with managing damage
caused by wildlife. WS provides advice or enters into agreements for its services provided
through a technical assistance approach or a direct control approach.
WS collects only information needed to determine appropriate courses of action for providing
effective wildlife damage management services. Information is used by the agency to identify
and differentiate between cooperators (i.e., property owners, land managers, or resource owners)
who request assistance, and to identify land areas on which management activities would be
conducted. Information is also collected to identify the relationship between resources or
property, WS’ protection of such resources or property, the damage caused by wildlife, and the
management methods or activities required to mitigate the damage. Records are maintained of
cooperative service agreements and Work Initiation Documents documenting permissions to
access cooperator property, wildlife damage occurrences on cooperator property and allowable
methods to address wildlife damage, and occurrences which may have affected non-target
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species or humans during, or related to, WS project actions. Finally, information is used to help
WS evaluate, modify, and improve its programs.
APHIS is asking OMB to approve, for 3 years, the use of these information collection activities.
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.
WS collects information from the public to facilitate communication with respondents; assess
the status of mitigation efforts at the local, regional, and national levels; conduct trend and cost
analyses; maintain Federal or State-mandated records of restricted use pesticides and animal
incident reports; and certify respondents’ qualifications to provide services on behalf of WS.
The program uses the following information collection activities to perform these functions.
Work Initiation Document for Wildlife Damage Management (WS Form 12A);
7 U.S.C. 8351; State, Local, or Tribal Group; Private Sector, Individual
WS Form 12A is an agreement between the cooperator and WS authorizing 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 landowner properties, and/or conduct aerial
operations on certain premises. A completed form contains the cooperator’s name, address,
telephone number, and signature in addition to the class of land involved in the work authorized.
Work Initiation Document for Wildlife Damage Management - Multiple Resource Owners
(WS Form 12B); 7 U.S.C. 8351; State, Local, or Tribal Group; Private Sector, Individual
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.
Addendum to a Work Initiation Document (WS Form 12 Addendum); 7 U.S.C. 8351; State,
Local, or Tribal Group; Private Sector, Individual
WS Form 12 Addendum replaces WS Form 12A Addendum and WS Form 12B Addendum. It
is a continuation page for WS Forms 12A and 12B and is used to record additional species or
components associated with the base work initiation document. The form requires the signature
of a primary cooperator.
Work Initiation Document for Management of Wildlife Damage on Urban Properties
(WS Form 12C); 7 U.S.C. 8351; State, Local, or Tribal Group; Private Sector, Individual
WS Form 12C is an agreement between the cooperator and WS authorizing 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 landowner properties in urban settings. A
completed form contains the cooperator’s name, address, telephone number, and signature in
addition to the class of land involved in the work authorized.
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Project Report (WS Form 14); 7 U.S.C. 8351; State, Local, or Tribal Group; Private
Sector, Individual
WS Form 14 is used to collect information about damage to different types of resources.
Information collected includes the name, address, and telephone number of the resource owner.
WS uses the information to conduct trend analyses and assess the types of services it provides.
Pocatello Supply Depot Order Form (WS Form 17); 7 U.S.C. 8352; State, Local, or Tribal
Group; Private Sector, Individual
WS Form 17 is used by State Directors to place orders for supplies carried by the Federal
Pocatello Supply Depot. Order forms are submitted for specific State programs or on behalf of
non-Federal entities. For the latter, information collected includes name, address, telephone
number, and pesticide applicator license number of the individual requiring the supplies.
Control Material Sales Record (WS Form 18); 7 U.S.C. 8352; State, Local, or Tribal
Group; Private Sector, Individual
WS Form 18 is a record capturing information about cooperator purchases of control materials
from WS. This information includes the buyer’s name, address, land class, certified pesticide
applicator’s license or certificate number, and signature.
Wildlife Services Assistance Request (WS Form 30); 7 U.S.C. 8351; State, Local, or Tribal
Group; Private Sector, Individual
WS Form 30 documents a cooperator request for WS assistance in mitigating a wildlife damage
problem. It includes the requester’s name, address, telephone number, and location where the
damage is occurring. It may also include information about the resource being damaged and the
lost value of the resource.
Report of Injury or Death of Non-target Animal (WS Form 35); 7 U.S.C. 8352; State,
Local, or Tribal Group; Private Sector, Individual
WS Form 35 is used to collect information about a non-target animal which was injured or killed
during a WS wildlife damage management activity. Collected information includes the names,
addresses, and telephone numbers of the animal owner and land owner (if applicable), and
location of the occurrence. WS uses the information to assess policies and program efficacy.
Migratory Bird Damage Project Report (WS Form 37); 7 U.S.C. 8353; State, Local, or
Tribal Group; Private Sector, Individual
WS Form 37 is used to collect information about damage being caused by a migratory bird
species, which in turn is used by WS to assist a requester in obtaining a depredation permit from
the U.S. Fish and Wildlife Service authorizing action to mitigate further damage. Collected
information includes the requester’s name, address, and telephone number, and location of the
damage.
Survey for Collecting Prices for MIS Resources Protected (WS Form 45); 7 U.S.C. 8352;
Private Sector
WS Form 45 is used to collect pricing information for various mitigation resources listed in the
WS database but generally not available through the internet or other forms of open advertising.
Collected information includes names of businesses, business contact information not readily
available from public sources, and current prices.
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Permanent Assignment of Pyrotechnics and Repellants (WS Form 49); 7 U.S.C. 8352;
Individual
WS Form 49 is used to issue and account for pyrotechnics and repellants. Collected information
includes the recipient’s name, address, and signature.
Nuisance Wildlife Permit (Louisiana) (WS Form 66); 7 U.S.C. 8352; State, Local, or Tribal
Group; Private Sector, Individual
Residents of Louisiana use WS Form 66 to obtain WS assistance in obtaining nuisance wildlife
permits from the Louisiana Department of Wildlife and Fisheries (DWF). Collected information
is used by WS and DWF to provide services and process permits, and includes name, address,
telephone number, and property location where the protected resource is located.
Livestock Protection Collar (LPC) Accident Report (WS Form 92); 7 U.S.C. 8352; State,
Local, or Tribal Group; Private Sector, Individual
WS Form 92 is used to record information about an instance where a livestock protection collar
has been involved in a contamination or poisoning incident related to any animal or human that
was not the collared animal or a coyote. Collected information includes the address and specific
location of the incident, the name and address of the land owner or lessee, name and address of
the doctor (if one was involved); name, address, age, and occupation of the injured person (if
poisoning/contamination involved a human), and name and address of any person administering
first aid. The information is used by WS to assess policies, procedures, and program efficacy.
Protected Resources Query; 7 U.S.C. 8352; State, Local, or Tribal Group; Private Sector;
Individual
WS may query cooperators for additional descriptive information about the resources being
protected by damage management projects. It uses this information to better describe and justify
the value of WS services.
Fixed Wing Pilot Proficiency Flight Review (WS Form 200); 7 U.S.C. 8354; Private Sector
WS Form 200 is a qualification checklist for confirming fixed-wing contract pilots hired by WS
have completed all necessary flight training and are current on all other necessary qualifications
for their mission. Collected information includes the pilot’s name, mailing address, telephone
number, pilot certificate number, date of most recent medical examination; and type, certificate
type, ratings under such certificates, pilot flight time, and type of aircraft flown; and the pilot’s
signature.
Rotary Wing Pilot Proficiency Flight Review (WS Form 201); 7 U.S.C. 8354; Private Sector
WS Form 201 is a qualification checklist for confirming rotary wing (helicopter) contract pilots
hired by WS have completed all necessary flight training and are current on all other necessary
qualifications for their mission. Collected information includes the pilot’s name, mailing address,
telephone number, pilot certificate number, date of most recent medical examination; and type,
certificate type, ratings under such certificates, pilot flight time, and type of aircraft flown; and
the pilot’s signature.
National Wildlife Service Advisory Committee Self-Nomination (AD 755 and Resume);
5 U.S.C. Appendix: Federal Advisory Committee Act; Individual
OMB approval for the use of AD Form 755 and an associated resume is found in 0505-0001.
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National Wildlife Service Advisory Committee Selection Acknowledgement;
5 U.S.C. Appendix: Federal Advisory Committee Act; Individual
Selected members of the National Wildlife Service Advisory Committee may be notified by
letter requesting signed acknowledgement of the service commitment to the committee.
National Wildlife Service Advisory Committee Travel Reimbursement;
5 U.S.C. Appendix: Federal Advisory Committee Act; Individual
Members of the National Wildlife Service Advisory Committee are reimbursed for travel to,
from, and during the annual National Wildlife Service Advisory Committee Meeting.
Reimbursement is calculated and paid using travel and deposit information provided by the
committee members.
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.
All of the forms in this information collection except WS Forms 92, 200, and 201 are refreshed
versions of previously approved forms and contain the same information or minor adjustments.
The WS Forms 92, 201, and 202 are new for new activities. All of the forms are also in fillable
PDF format.
To reduce response time and minimize errors, WS employees typically complete the forms on
behalf of the respondents and, when necessary, obtain the respondents’ signatures in the most
expeditious manner available. WS continues to assess information management technologies as
resources allow. APHIS is currently testing the use of eSign Live and two factor authentication
for obtaining electronic signatures from the public but its use is currently restricted to pilot
applications in other programs. Another pilot program is testing the use of ezFEDGRANTS to
establish an electronic solution for creating and managing agreements. Wildlife Services is
following both programs’ progress closely for future adaptation.
WS Forms 12A, 12B, 12C, 12 Addendum, 18, 49, 66, 200, and 201 are completed by WS
personnel and presented to cooperators for signature. WS Form 92 may be prepared and signed
by a cooperator. Electronic completion is available but not necessary.
WS Forms 14, 17, 30, 35, 37, and 45 do not require cooperator signatures. Copies may be
provided to them in hard copy or by email if suitable to all parties.
AD Form 755 is available at the USDA website, https://www.ocio.usda.gov/document/ad-755.

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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.
The information WS collects is exclusive to its mission to mitigate the negative impacts wildlife
have on U.S. agriculture, property, natural resources, and human health and safety. The
information WS collects is not available from any other source.
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.
Approximately 90 percent of the business respondents are small entities. The information APHIS
collects from them is the minimum needed to initiate assistance. The impact on respondents to
provide it is negligible.
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.
Large populations of aggressive wildlife species, if left unmanaged, may cause tremendous
amounts of damage to crops, livestock herds, and private property within the United States.
Without mitigation, the damage could result in severe physical and economic losses for States,
tribes, businesses, organizations, and private property owners.
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;
A completed WS Form 92 must be delivered to the WS State Director within 3 days of the
reported accident.
• requiring respondents to submit more than an original and two copies of any document;
• requiring respondents to retain records, other than health, medical, governmental
contract, grant-in-aid, or tax records for more than 3 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;
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• 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 other 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.
a. WS consulted with the following individuals for comment about the activities in this
information collection and no substantial recommendations for changes were received.
Generally, the collection burdens are viewed as business requirements and reasonable for the
services received.
Mr. Jaime Anderson
Vice President, I.F. Anderson Farms, Inc.
4377 Hwy 70 West
Lonoke, AR 72086
Telephone: (501) 676-2716
Email: jande10590@aol.com
Mr. Michael Freeze
Owner, Keo Fish Farms, Inc.
6444 Hwy 164
North Keo, AR 72083
Telephone: (501) 842-2872
Email: Kkeo@centurytel.net
Mr. Peter Orwick
Executive Director, American Sheep Industry Association
9785 Maroon Circle, Suite 360
Centennial, OH 80112
Telephone: (303) 771-3500, ext 33
Email: porwick@sheepusa.org

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b. On Thursday, December 6, 2018, APHIS published in the Federal Register (83 FR 62834) a
60-day notice seeking public comments on its plans to request a reinstatement of approval for
this collection of information. No relevant comments were received from the public.
c. On Wednesday, December 26, 2018, WS published in the Federal Register (83 FR 66239) a
notice of intent to reestablish the National Wildlife Services Advisory Committee.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
This information collection activity involves no 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.
Confidentiality of information is protected under 5 USC 552a. Also, System of Records Notice
APHIS-9, Wildlife Services Management Information System, was published on October 8,
2015 (80 FR 60872) and describes and addresses privacy security controls and routine uses of
information for individual respondents. No additional assurance of confidentiality is provided
nor required with this information collection.
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.
See APHIS Form 71. The 98,926 respondents are private citizens and representatives of State,
local, and tribal governments; private and public organizations, and businesses.
• Provide estimates of annualized cost to respondents for the hour burdens for collection
of information, identifying and using appropriate wage rate categories.
APHIS estimates the total annualized cost to the above respondents to be $249,147. It arrived
at this figure by multiplying the hours of estimated response time (5,268) by the respondents’
estimated average hourly wage of $32.16, and then multiplying the result by 1.4706 to capture
benefit costs.

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According to the U.S. Department of Labor, Bureau of Labor Statistics May 2017 Report Occupational Employment and Wages in the United States, the average wage for wildlife
biologists is $31.85; for farmers and ranchers (agricultural managers), $38.62; property
managers, $34.79; conservation scientists/foresters, $31.18; and for private individuals (U.S.
average wage), $24.34. According to DOL BLS news release USDL-18-1499 dated
September 18, 2018 (see https://www.bls.gov/news.release/pdf/ecec.pdf), benefits account for
32% of employee costs, and wages account for the remaining 68%. Mathematically, total
costs can be calculated as a function of wages using a multiplier of 1.4706.
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 costs, maintenance costs,
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.
See APHIS Form 79. The estimated annualized cost to the Federal Government to include fringe
benefits and overhead is $263,288.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB Form 83-1.
Requested
Annual Number of
Responses
Annual Time
Burden (Hours)

Program
Change Due to Change Due to
Program
Change Due to Adjustment in
Potential
Change Due to
Agency
Agency
Violation of the
New Statute
Discretion
Estimate
PRA

Previously
Approved

111,040

0

111,040

0

0

0

5,268

0

5,268

0

0

0

This request for reinstatement of a previously approved information collection includes an
estimated 98,926 respondents; 111,040 responses; and 5,268 hours of burden.
Six new activities add 10,511 responses and 233 hours of burden. These activities are the
Permanent Assignment of Pyrotechnics and Repellants (WS Form 49), Livestock Protection
Collar (LPC) Accident Report (WS Form 92), Fixed Wing and Rotary Wing Proficiency Flight
Reviews (WS Forms 200 and 201), Protected Resources Queries, Selection Acknowledgement,
and Travel Reimbursement.

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Along with Selection Acknowledgement and Travel Reimbursement, Self nomination is
associated with the reestablished National Wildlife Service Advisory Committee (NWSAC).
Self nomination consists of two activities -- an AD Form 755 and a resume – which are approved
in information collection 0505-0001. Their responses and burden are not included in this
request.
The remaining 100,529 responses and 5,035 hours of burden will be reported as PRA violations
in the ICB.
The WS Form 68, Wildlife Services Abatement Program Assignment of U.S. Government
Property, and the program using it, were discontinued. Common forms SF 424, SF 424A, SF
424B, and SF LLL, are no longer used by the program.
16. For collections of information whose results are planned to be published, outline plans
for tabulation and publication.
APHIS has no plans to publish or tabulate information it collects in connection with this
program.
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.
The information collection expiration date will be shown on all forms used in this information
collection.
18. Explain each exception to the certification statement identified in "Certification for
Paperwork Reduction Act."
APHIS can certify compliance with all provisions in the Act.
B. Collections of Information Employing Statistical Methods
There are no statistical methods associated with the information collection activities used in this
program.

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