2021_0596-0003_Supporting Statement A_ico

The Supporting Statement for OMB 0596-0003

GRAZING PERMIT ADMINISTRATION FORMS

October 2021

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.

Annually, livestock grazing occurs on approximately 94 million acres of National Forest System (NFS) lands. Information must be collected on an individual basis from applicants and/or permit holders to allow proper administration of the livestock grazing program. Similar information is not available from any other source. The information collected is subject to authorization and administrative oversight by the U.S. Forest Service, and is required for the issuance and administration of livestock grazing permits, including fee collections, as authorized by the Federal Land Policy and Management Act (FLPMA) of 1976, as amended, 43 U.S.C. 1700 et seq. and USDA regulations at 36 CFR 222, subparts A and C.

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.)

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.

Table 1 below displays the types of information collection forms that are needed in connection with the rangeland management program. The information collected is needed to issue livestock grazing permits to qualified and/or preferred applicants. There is no change to that process for collecting data. Each form displays specific information that is required for the specific type of grazing permit. All seven forms included with this request are national-level rangeland management forms that allow for consistency among the established U.S. Forest Service Regions that authorize livestock grazing on NFS lands (Regions 1 through 9).

Each of these forms is designed to address a unique management circumstance associated with the livestock grazing program on NFS lands. The forms are completed by the new applicants requesting grazing use, by the existing permit holders (permittees) requesting a specific program administration action, or by prior permit holders requesting a new permit. This is done in cooperation with rangeland management personnel and the authorized officer at the appropriate administrative Forest Service office.

Table 1 – Information Collection

Form	Description	Information Provided to:	Prepared by
FS-2200-001	Refund, Credit, or Transfer Application*: Prepared to request a refund, credit, or transfer of any unused portion of previously paid grazing fees. The agency uses the information to determine the appropriate response to the permittee’s request as well as determine the amount of refund, credit, or transfer of the grazing fee. Authority for the request of this information is 5 U.S.C. 301, 36 CFR 222.50(i).	Forest Officer	Permit Holder
FS-2200-002 FS-2200-016 FS-2200-017	Application for Temporary Grazing or Livestock Use Permit (for Temporary Grazing or Livestock Use): Use of a specific form of livestock grazing that is based on the type of permit being requested. The Forest Service uses the information to determine qualifications and eligibility of an applicant for a permit and to issue the appropriate permit. This information is requested and specifically designed to provide information for a specific type of grazing permit as authorized in 5 U.S.C. 301, 36 CFR 222.3(c). Application for Term Grazing Permit (for Term Grazing) Application for Term Private Land Grazing Permit (for Term Private Land Grazing).	Forest Officer	Applicant and/or Permit Holder
FS-2200-012	Waiver of Term Grazing Permit*: Prepared when a permittee waives their permitted grazing privileges back to the United States. It may also identify a purchaser of the permitted livestock and/or base property associated with the permit. The Forest Service uses this information to cancel an existing grazing permit, to identify the preferred permit applicant based on the purchase of permitted livestock and/or base property, and to issue a subsequent grazing permit. This information is requested under the authority of 5 U.S.C. 301, 36 CFR 222.3(c)(1)(vi)(F).	Forest Officer	Permit Holder
FS-2200-013	Escrow Waiver of Term Grazing Permit Privileges*: Prepared when a permittee requests the use of permitted livestock or base property associated with a grazing permit as collateral security for a loan. The agency uses this information to identify a lien holder so that in the event of default on the loan, the grazing permit can be assigned to the lien holder. Escrow waiver provisions and procedures are acknowledged in the February 10, 1938 Memorandum of Understanding between the Department of Agriculture and the Farm Credit Administration and subsequent December 21, 1990 Memorandum of Understanding between the Forest Service and the Farm Credit Banks. Authority for requesting this information is 5 U.S.C. 301, 36 CFR 222.3(c)(1)(vi)(F).	Forest Officer	Applicant and/or Permit Holder
FS-2200-025	Ownership Statement by Corporation, Partnership, or Other Legal Entity*: Identifies the corporate or partnership structure of the applicant or permit holder. Allows the Forest Officer to issue grazing permits in consideration of the applicant’s or permittee’s legal organization of the entity. Authority for this information request is 5 U.S.C. 301, 36 CFR 222.3(c).	Forest Officer	Applicant and/or Permit Holder
* Forms or documents may be required in conjunction with FS-2200-002, FS-2200-016, FS-2200-017, and/or FS-2200-025.

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

The seven national-level standard rangeland management forms are used only to acquire data from applicants applying for new grazing permits or making changes to their current grazing permit(s). For new applicants, the information collected will be associated with acquiring a new livestock grazing permit. For existing permit holders, the information collected will be associated with actions pertaining to their current livestock grazing permit and/or renewal of their livestock grazing permit. For prior permit holders, the information collected will be the same as for new applicants (to acquire a new livestock grazing permit).

Additional uses for data collected via the rangeland management information collection forms include creating summaries and reports with electronic data to create year-end reports and the Annual Grazing Statistical Report, providing information to the National Agricultural Statistics Service every five years for their Census information.

4. 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?

These forms can be requested and obtained from the local NFS units electronically via fax, face-to-face, over the phone, over the internet, or via written request through U.S. mail. The forms would then be completed by the applicant and/or their representatives, or in situations of face-to-face settings with agency personnel. These forms are designed so they may be completed manually or electronically. The completed forms may be printed hardcopy or sent via email electronically.

Respondents would be allowed to choose the option best suited for their needs:

1. Complete form(s) on their own then submit for review electronically or hard copy;

2. Complete the grazing permit forms electronically with assistance from forest officer; and/or

3. Complete the grazing permit forms electronically or hard copy at face-to-face meetings with assistance from forest officer.

All completed forms must be reviewed and approved by the forest officer.

5. How frequently will the information be collected?

Frequency of use for each form would vary depending on the type of data collection form requested by respondents. In general:

1. FS-2200-001 is completed as needed to request a refund, credit, or transfer of paid grazing fees;

2. FS-2200-002 is completed annually to request temporary grazing or livestock use;

3. FS-2200-012 is completed on a one-time-basis when the grazing permit is waived;

4. FS-2200-013 is completed on a one-time-basis when a lien for the permitted livestock and/or base property exists and at the time of release from the lien;

5. FS-2200-016 is completed on a one-time-basis to apply for a term grazing permit;

6. FS-2200-017 is completed on a one-time-basis to apply for a private land permit; and

7. FS-2200-025 is completed on a one-time-basis when the applicant is recognized as a corporation, partnership, or other legal entity and anytime during the life of the term grazing permit to revise the existing ownership statement.

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

The information collected is shared with other organizations via the Annual Grazing Statistical Summary Report which displays grazing permit data for national, regional, and State totals for number and type of livestock data provided in data collection forms FS-2200-002, FS-2200-016, and FS-2200-017. The Annual Grazing Statistical Summary Report is also posted on the U.S. Forest Service website, for internet viewing by the public at www.fs.fed.us/rangeland-management/reports/index.shtml.

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

The information collection requirements for these seven rangeland management forms associated with the livestock grazing program have remained constant over time. The forms were updated to allow for electronic completion with fill-in data fields. This was done in an effort to provide an option for respondents to complete the data collection forms on printed copies or electronically.

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.

Information technology applications are available for this information collection. The forms are available electronically to agency personnel and may be forwarded to respondents electronically for completion or completed on-site at the respective NFS units. Completion of the national level rangeland management forms electronically reduces the amount of total time needed to complete, review, and process each form.

All seven forms have been updated to allow for electronic fill-in using common MS Word software. Information can be collected electronically from respondents. Upon final review and acceptance of the completed forms, original signatures must be acquired on hard copies from the applicant and/or permit holder requesting the action, from the Forest Officer that is recommending the action, and finally from the Forest Officer that is approving the action.

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 Bureau of Land Management (BLM) and U.S. Forest Service collect similar information associated with administration of their livestock grazing programs. A review was performed of each of these Agency’s programs and forms. Due to the geographically unique nature of these permits, and of the location of permit holders, no duplication was identified.

Each of the seven rangeland management forms collects specific information. This unique information required to issue and administer livestock grazing permits for geographically unique parcels of NFS lands 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.

The collection of information may impact small business or other small entities such as an individual, family partnership, corporation, or other legal entities associated with ranches or small farms, including commercial recreation operators who wish to graze livestock on NFS lands. The information is requested infrequently, such as when there is a new applicant, following the expiration of existing grazing permits, or when a particular administrative action is requested by the permittee. These forms have been specifically designed to collect the least amount of information possible and still achieve program compliance from all respondents in an effort to reduce burden to the public. Out of the average of 1,290 respondents annually, the Agency estimates that 70% are small businesses.

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 frequency of information collection has been minimized to the maximum extent possible and could not be reduced without elimination of the information collection. Elimination would make it impossible for the Forest Service to administer the livestock grazing program in accordance with statutes and regulations. It is essential that the agency acquire the requested information to determine the applicant’s qualifications for the livestock grazing permit, to ensure a permittee’s compliance with applicable laws and regulations, and for other administrative actions that may arise in the rangeland management program.

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 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.

There are no 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.

A notice of request for comments for this information system was published in the Federal Register on June 29, 2021, Vol. 86, No. 122, pages 34197-34199. Public comment period closed on August 30, 2021. Four public comments were received. Comments are not within scope of the information collection.

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.

Each group was provided a copy of the seven rangeland management forms to review and comment. Each group appreciated the opportunity to review the seven documents prior to renewal and had no comments.

Public Lands Council/National Cattlemen’s Beef Association

1275 Pennsylvania Ave. NW, Suite 801

Washington DC 20004

202.347.0228

American Sheep Industry Association

9785 Maroon Circle, Suite 360

Englewood, CO 80112

303.771.3500

National Cattlemen’s Beef Association

1275 Pennsylvania Avenue NW, Suite 801

Washington, D.C. 20004

(202) 347-0228

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

Payments or gifts will not be made to respondents of this information collection.

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

The information collected is not confidential. Information provided by applicants is publicly available and no assurance of confidentiality is given.

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.

Information of a sensitive nature is not requested.

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 2 below displays the total number of permits issued the last three years (2018 to 2020). Approximately 1,434 grazing permit related forms were completed in 2018, approximately 1,724 in 2019, and approximately 1,470 in 2020. The number of national level grazing permit forms completed varies by type and by year. Changes from year to year are a result of the random numbers of expiring permits, new applicants seeking to apply for grazing permits, and of special requests from existing permit holders each year.

Table 2: Total Number of Permits Issued, by Type, During Fiscal Years 2018-2020¹.

(a) Description of the Collection Activity	(b) Form Number	(c) Number of Respondents1
		FY2018	FY2019	FY2020
Refund, Credit, or Transfer Application	FS-2200-001	79	120	74
Application for Temporary Grazing or Livestock Use Permit	FS-2200-002	94	90	70
Waiver of Term Grazing Permit	FS-2200-012	125	151	130
Escrow Waiver of Term Grazing Permit	FS-2200-013	54	67	61
Application for Term Grazing Permit	FS-2200-016	627	757	654
Application for Term Private Land Grazing Permit	FS-2200-017	56	43	53
Ownership Statement by Corporation, Partnership, or Other Legal Entity	FS-2200-025	399	496	428
Total1	---	1,434	1,724	1,470

¹ Based on information reported in Rangeland Information Management System electronic database for each type of grazing permit issued during 2018 to 2020.

Table 3 below displays the Annual burden estimate. We will use the average value of the three-year cycle of 1,543 as the estimated number of respondents.

The annual burden hour is estimated by multiplying the estimated number of respondents by the amount of time needed to complete each form. The time needed per form is then converted to hours and rounded in order to calculate the number of annual burden hours.

Table 3: Annual Burden Estimate

(a) Description of the Collection Activity	(b) Number of Respondents	(c) Response time (Minutes)	(d) Annual Burden Hours
FS-2200-001, Refund, Credit, or Transfer Application	91	20	30.33
FS-2200-002, Application for Temporary Grazing or Livestock Use Permit	85	20	28.33
FS-2200-012, Waiver of Term Grazing Permit	135	30	67.50
FS-2200-013, Escrow Waiver of Term Grazing Permit	61	20	20.33
FS-2200-016, Application for Term Grazing Permit	679	30	339.50
FS-2200-017, Application for Term Private Land Grazing Permit	51	20	17
FS-2200-025, Ownership Statement by Corporation, Partnership, or Other Legal Entity	441	10	73.50
Total	1,543	---	576.50

Record keeping burden should be addressed separately and should include columns for: a) Description of record keeping activity:

b) Number of record keepers: (record keeper may vary for each unit)

c) Annual hours per record keeper:

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

There is no record keeping requirement placed upon the respondent in connection with this Information Collection.

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

Table 4: Estimated Annual Cost to Respondents

(a) Description of the Collection Activity	(b) Annual Burden Hours	(c) X Hourly Rate1	(d) = Annual Cost to Respondents
FS-2200-001, Refund, Credit, or Transfer Application	30	$36.93	$1,107.90
FS-2200-002, Application for Temp Grazing or Livestock Use Permit	28	$36.93	$1,034.04
FS-2200-012, Waiver of Term Grazing Permit	68	$36.93	$2,511.24
FS-2200-013, Escrow Waiver of Term Grazing Permit	20	$36.93	$738.60
FS-2200-016, Application for Term Gazing Permit	340	$36.93	$12,556.20
FS-2200-017, Application for Term Private Land Grazing Permit	17	$36.93	$627.81
FS-2200-025, Ownership Statement by Corporation, Partnership, or Other Legal Entity	74	$36.93	$2,732.82
Total	577	X $36.93	= $21,290.15

¹ Mean wage of $36.93 taken from Bureau of Labor Statistics - Occupational Employment Statistics May 2020 National Industry - Specific Occupational Employment and Wage Estimates - NAICS 115200 - Support Activities for Animal Production- Farmers, Ranchers, and Other Agricultural Managers https://www.bls.gov/oes/current/oes119013.htm

The cost to respondents is estimated by multiplying the annual burden hours by the average hourly rate for all farmers, ranchers, and other agricultural managers of $36.93 per hour. The estimated total cost to respondents, rounded to the next whole dollar, is $21,290.15.

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, or maintenance costs to the respondents for any of the seven rangeland forms.

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

Table 5: Estimated Annual Cost to the Federal Government

(a) Description of Activity	(b) Estimated Hours	(c) Estimated Hourly Cost to Government	(d) Estimated Total Annual Cost to Government
FS-2200-001, Refund, Credit, or Transfer Application	30	$35.62	$1,068.60
FS-2200-002, Application for Temporary Grazing or Livestock Use Permit	28	$35.62	$997.36
FS-2200-012, Waiver of Term Grazing Permit	68	$35.62	$2,422.16
FS-2200-013, Escrow Waiver of Term Grazing Permit	20	$35.62	$712.40
FS-2200-016, Application for Term Grazing Permit	340	$35.62	$12,110.80
FS-2200-017, Application for Term Private Land Grazing Permit	17	$35.62	$605.54
FS-2200-025, Ownership Statement by Corporation, Partnership, or Other Legal Entity	74	$35.62	$2,635.88
Materials for Developing, Printing, Storing of Forms (+ 10%)			$2,055.27
Total	577	X $35.62 incl overhead	=$20,552.74

¹ Estimated cost to the government is based on an average annual salary of a federal employee at a GS-9, step 3: $56,995. The hourly cost was calculated by dividing the annual salary of $56,995 by 2080 work hours per year for a total of $27.40 and then multiplying by 1.3 to account for estimated fringe benefits for a total hourly rate of $35.62. This estimate is derived from the U.S. Office of Personnel Management Salaries and Wages 2021 Salary Table for General Schedule federal employees, GS-9, Step 3 https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2021/RUS.pdf

The estimated total annual cost to the government is $20,552.74. Costs considered include making individual forms available to respondents at one-on-one meetings, electronically or by mail, completion of the forms, review, recommendation, and approval of each form, printing, processing, filing, overhead, and storage.

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

Upon this submission, the estimated number of responses is now based on the actual number of permits issued by U.S. Forest Service during the previous three years.

Using these more accurate figures, the estimated number of annual responses has increased by 253 responses, from 1,290 to 1,543. The total of estimated annual burden hours has subsequently increased 63 hours, from 504 to 577. The estimated annual cost to respondents has increased approximately $4,164 (from $17,126 to $21,290) due to the increased number of permits. The estimate includes the increase in mean wage from $33.98 to $36.93 per hour. The total estimated annual cost to the government increased $3,852 from approximately $18,700 to $22,552.

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

Information collected in these rangeland management forms are used in the publication in the Annual Grazing Statistical Summary Report. The report is published and posted on the U.S. Forest Service website for access by the public. Livestock numbers and type of livestock information from the data collection forms is displayed in the annual report and summarized for NFS lands, National Forests, and National Grasslands by national, regional, and state totals. It can be accessed at: www.fs.fed.us/rangeland-management/reports/index.shtml.

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 OMB control number and Expiration Date will be displayed on all associated forms.

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

There are no exceptions.

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