1018-0102 SSA Revision 11052021

Supporting Statement A for

Paperwork Reduction Act Submission

National Wildlife Refuge

Special Use Permit Applications and Reports

50 CFR 25, 26, 27, 29, 30, 31, 32, and 36

OMB Control Number 1018-0102

Terms of Clearance: None.

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The below listed authorities govern the administration and uses of national wildlife refuges and wetland management districts:

• National Wildlife Refuge System Administration Act of 1966 (Administration Act, 16 U.S.C. 668dd–668ee), as amended by the National Wildlife Refuge System Improvement Act of 1997.

• Refuge Recreation Act of 1962 (Recreation Act, 16 U.S.C. 460k–460k-4).

• Alaska National Interest Lands Conservation Act (ANILCA, 16 U.S.C. 3101 et seq.).

The Administration Act consolidated all of the different refuge areas into a single National Wildlife Refuge System (System). It also authorizes us to allow public accommodations, including commercial visitor services, on lands of the System when we find that the activity is compatible and appropriate with the purpose for which the refuge was established. The Recreation Act allows the use of refuges for public recreation when it is not inconsistent with, or does not interfere with, the primary purpose(s) of the refuge.

ANILCA provides specific authorization and guidance for the administration and management of national wildlife refuges within the State of Alaska. Its provisions provide for the issuance of permits by the System under certain circumstances. We implement these provisions through 50 CFR sections identified below.

In our general refuge regulations, we provide for public entry for specialized purposes, including economic activities such as the operation of guiding and other visitor services on refuges by concessionaire or cooperators under appropriate contracts or legal agreements or special use permits (50 CFR 25.41, 25.61, 26.36, 27.71, 27.91, 27.97, 29.1, 29.2, 30.11, 31.2, 31.13, 31.14, 31.16, 32.2, 36.31, 36.32, 36.33, 36.37, 36.39, 36.41 and 43 CFR 5). These regulations provide the authorities and procedures for allowing permits on national wildlife refuges and wetland management districts, including those in the State of Alaska.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

The likely respondents to this information collection are individuals, businesses, nonprofits, and educational institutions, as well as State/local/tribal and Federal governments.

We issue special use permits for a specific period as determined by the type and location of the use or visitor service provided. These permits authorize activities such as:

• Agricultural activities (haying and grazing, 50 CFR 29.1 and 29.2);

• Beneficial management tools that we use to provide the best habitat possible on some refuges (50 CFR 30.11, 31.14, 31.16, and 36.41);

• Special events, group visits and other one-time events (50 CFR 25.41, 25.61, 26.36, and 36.41);

• Recreational visitor service operations (50 CFR 25.41, 25.61 and 36.41);

• Guiding for fishing, hunting, wildlife education, and interpretation (50 CFR 25.41 and 36.41);

• Commercial filming (43 CFR 5, 50 CFR 27.71) and other commercial activities (50 CFR 29.1 and 36.41);

• Building and using cabins to support subsistence or commercial activities (in Alaska) (50 CFR 26.35,and 36.41);

• Research, inventory and monitoring, and other noncommercial activities (50 CFR 26.36 and 36.41).

We use the following three application forms:

• FWS Form 3-1383-G (General Activities Special Use Application).

• FWS Form 3-1383-C (Commercial Activities Special Use Application).

• FWS Form 3-1383-R (Research and Monitoring Special Use Application).

These forms will continue to ensure:

• Applicants are aware of the types of information needed for permit issuance and that the Office of Management and Budget (OMB) approves the collection of this information in accordance with the Paperwork Reduction Act of 1995.

• The requested activities are compatible and appropriate with the purpose(s) for which the refuge was established.

• The eligibility of the applicant (or the most qualified applicant) to receive the special use permit.

We collect the necessary information in form and nonform format (through discussions in person or over the phone, over the Internet, by email, or by letter). In some instances, respondents will be able to provide information verbally. Often, a simple email or letter describing the activity will suffice. For activities (e.g., commercial visitor services, research, etc.) that might have a large impact on refuge resources, we may require applicants to provide more detail on operations, techniques, and locations. Because of the span of activities covered by special use permits and the different management needs and resources at each refuge, we may not require respondents to answer all questions. Depending on the requested activity, refuge managers will have the discretion to ask for less information than appears on the proposed forms. However, refuge managers cannot ask for more or different information. The burden listed in item 12 includes any non-form collection.

Many permittees provide services and facilities to the public. We issue permits for a specific period as determined by the type and location of the use or service provided. We use these permits to ensure that the applicant is aware of: (1) the requirements of the permit and (2) his/her legal rights. Refuge-specific special conditions may be required for the permit. We identify conditions as an addendum to the permit. Most of the special conditions pertain to how a permitted activity may be conducted and do not require the collection of information. However, some special conditions, such as activity reports, before and after site photographs, or data sharing, would qualify as an information collection, and we have included the associated burden in this information collection request.

We also use form, FWS Form 3-1384, “Bid Sheet – National Wildlife Refuge System” to streamline collection of the necessary pre-award information from applicants during bidding processes to conduct economic uses on Service lands, such as livestock, harvesting hay and stock feed, or removing timber (50 CFR 29.21). This form simplifies the pre-award selection/bidding process for bidders and for refuge staff. The Bid Sheet helps bidders to better understand what information the refuge needs in order to select bids for economic use, and, therefore, reducing the time and burden for the public and Service staff in the pre-award selection bidding process. This form is also easily customizable to the individual economic use being awarded. We use the Commercial Special Use Permit as the actual award document that will outline the terms and conditions of the economic use on Service lands.

For all forms we ask …	So that we can…
Whether the application is for a new permit or for renewal or modification of an existing permit	Determine the level of information required to process the application.
Signature of applicant and date of application	Determine who provided the information and the date the application was signed.
Full name of applicant (and/or business), organization (and/or business), address, phone number, fax number, and email address	Contact the applicant during the application process or after issuing a permit.
Description of the activity	Determine whether or not an activity is compatible with the purpose of the refuge, the impact on refuge resources, and if special conditions apply.
Names and addresses of assistants/subcontractors/subpermittees	Identify the people involved in the proposed activity.
Activity/site occupancy timeline	Reduce or eliminate scheduling conflicts, anticipate time frame of activity, and manage the long- and short-term impact of site usage.
Frequency of activity	Reduce or eliminate scheduling conflicts, manage the long- and short-term impact of site usage, and determine whether an activity is compatible with the purpose of the refuge.
Specific location	Reduce or eliminate scheduling conflicts and manage the long- and short-term impact of site usage.
Map of location	Identify specific location of activity (primarily used for rural activity locations).
If other certifications are required	Determine if an applicant meets all requirements to conduct the activity.
If other Federal, State or tribal permits are required.	Determine if an applicant meets all requirements to conduct the activity.
Logistics and transportation details	Determine whether an activity is compatible with the purpose of the refuge and assess the impact on refuge resources.
Vehicle descriptions and license plate numbers, including those from boats and planes	Confirm that specific vehicles are authorized to be in restricted areas.
Equipment used	Determine whether an activity is compatible with the purpose of the refuge and assess the impact on refuge resources.
If overnight stays are required	Determine whether an activity is compatible with the purpose of the refuge, assess the impact on refuge resources, reduce or eliminate scheduling conflicts, and manage the long- and short-term impact of site usage.
Description of onsite or living or working accommodations	Determine whether an activity is compatible with the purpose of the refuge and assess the impact on refuge resources.
Insurance coverage	Determine that an applicant can protect himself/herself and the System from future legal and financial predicaments.
Detailed information on ship-to-shore, intersite, and onsite transportation logistics	Determine whether an activity is compatible with the purpose of the refuge and assess the impact on refuge resources.

For FWS Form 3-1383-G and Form 3-1383-C we ask…	So that we can…
Activity type	Determine if an activity is appropriate to be considered for a special use permit.
Expected number of participants/clients	Assess the impact on refuge resources.
Operational plan	Understand the details of the activity so we can determine whether an activity is compatible with the purpose of the refuge and assess the impact on refuge resources.

For FWS Form 3-1383-C and Form 3-1383-R we ask …	So that we can…
Safety plan	Determine if appropriate safety measures are in place.

For FWS Form 3-1383-C we ask…	So that we can…
Business tax number	Process payment of fees and charges in accordance with the Debt Collection Improvement Act.
Trip activity timeline	Reduce or eliminate scheduling conflicts, manage the long- and short-term impact of site usage, and determine whether an activity is compatible with the purpose of the refuge.
Current or past history of violations of State, Federal, or local laws or regulations related to fish and wildlife.	Assess past compliance with fish and wildlife laws and regulations, and determine that the applicant is qualified to undertake the activity.

For FWS Form 3-1383-R we ask…	So that we can…
Affiliation/Sponsoring organization	Verify that the applicant is a bona fide researcher and determine if the applicant is qualified to undertake the activity.
Applicant's relationship to affiliation/sponsoring organization (professor, staff, student, etc.)	Verify that the applicant is a bona fide researcher and determine if applicant is qualified to undertake the activity.
Other cooperators/institutions	Determine whether the project is supported by other entities, verify that the applicant is a bona fide researcher, and determine if applicant is qualified to undertake the activity.
Applicant Curriculum Vitae or Resume	Determine if the applicant is qualified to undertake the activity.
Title and copy of research/monitoring proposal	Assess the scientific rigor of the proposal.
Hypothesis	Determine focus of the project and assess the scientific rigor of the proposal.
Species involved, samples to be taken, and data to be collected, including schedule	Assess the scientific rigor of the proposal, the impact on refuge resources, and determine whether an activity is compatible with the purpose of the refuge.
Details of offsite transportation of samples	Reduce or eliminate scheduling conflicts, manage the long- and short-term impact of site usage, and determine whether an activity is compatible with the purpose of the refuge.
Expected benefits of research/monitoring project	Assess the scientific rigor of the proposal, and determine the long and short- term impacts on refuge resources.
Project history and relationships to other research/ monitoring projects	Determine the temporal scale of the project and whether the project is supported by other entities,
General timeline for analysis, write-up and publication	Determine how and when the results of the project will be shared with the scientific/conservation community.
Submission of an Animal Care form, or Institutional Animal Care and Use Committee approval (or equivalent)	Assess the scientific rigor of the proposal and ensure that any animals involved in the project are appropriately cared for.
Details on installation, maintenance and removal of instrumentation	Reduce or eliminate scheduling conflicts, manage the long- and short-term impact of site usage, and determine whether an activity is compatible with the purpose of the refuge.

For FWS Form 3-1384 we ask…	So that we can …
Full name of applicant (and/or business), organization (and/or business), address, phone number, fax number, and email address	Contact the applicant during the application process or after issuing a permit.
Business tax number	Process payment of fees and charges in accordance with the Debt Collection Improvement Act.
Current Pesticide Applicator’s License and Certified Logger	Determine if an applicant meets all requirements to conduct the activity.
Bid Information	Determine the location and type of activity and compare applications
How the activity meets the objectives of the refuge, including what in-kind services bidder would be willing to provide	Understand the details of the activity so we can assess how the activity would meet the Service’s laws and policies for allowing the activity.
Bidder knowledge and experience	Determine if the applicant is qualified to undertake the activity.
List of equipment and personnel	Assess the ability of the bidder to successfully complete the activity.
Contact information from three landowners	Determine if the applicant is qualified to undertake the activity.

PROPOSED REVISIONS TO THIS INFORMATION COLLECTION

With this submission, we are proposing the following revisions to the existing information collection:

Activity Reports/Associated Document Requirements

In addition to the previously approved activity report criteria, the Service will also collect data associated with client use days and their fees. The Service also updated the reporting rate for permits issued for both Commercial Use and Research to reflect current requirements. We use this information to calculate fees, monitor compliance, and evaluate visitor and habitat impacts.

NOTE: The burden estimate for this IC in question 12 is significant change from our last submission. Approximately 90% of research and commercial permits require some type of a report. We feel the last submission underestimated the amount of reporting required. With the proposed automation of the ICs associated with this submission, we will have more reliable data to report in the next renewal in 3 years.

Amendments and Renewals

Through our review of the special use permitting process in preparation for automation in the ePermits system, we discovered that we need to account for amendments to and renewals of special use permits separately from the initial applications, because amendments/renewals have time burdens that are different from those of the initial submissions. The revised burden table below includes our initial estimates for amendments and renewals.

ePermits Initiative

The Service's new “ePermits” initiative is an automated permit application system that will allow the agency to move towards a streamlined permitting process to reduce public burden. Public burden reduction is a priority for the Service; the Assistant Secretary for Fish, Wildlife, and Parks; and senior leadership at the Department of the Interior. The intent of the ePermits initiative is to fully automate the permitting process to improve the customer experience and to reduce time burden on respondents. This new system will enhance the user experience by allowing users to enter data from any device that has Internet access, including PCs, tablets, and smartphones. It will also link the permit applicant to the Pay.gov system for payment of the associated permit application fee. We anticipate including the following Service forms in the ePermits system: 3–1383–G, 3–1383–C, 3–1383–R, and 3–1384.

Once these forms are automated in the new ePermits system, we anticipate a reduction in the amount of time necessary for an applicant to apply for a permit and perform regular actions related to that permit (e.g., amend, renew, report). Through the ePermits account registration, we will track and be able to more accurately report the number of small business applicants, along with the type of business (for-profit, farm, not-for profit). This information will allow the Service to be more responsive in identifying the possibility of additional burden reduction on small businesses.

We also plan to eliminate the necessity for physical mail-in applications (though this will remain an option for those who either don’t have access to the internet or prefer to use mail-in applications), thus further reducing public burden. With ePermits, an applicant will be able to establish an account and apply for multiple permits through a single interface. The system allows the applicant to track all their applications, permits and permit-related actions, as well as all communications between Service staff and the permittee/applicant within the same interface, significantly reducing the burden on the government to process these applications and manage permit-related actions. The decrease in submissions of paper-based forms is expected to reduce the government cost of administering and processing permit applications.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden and specifically how this collection meets GPEA requirements.

FWS Forms 3-1383-G, 3-1383-C, 3-1383-R, and 3-1384 will be available on our agency websites in a fillable format. Applicants must print the form and submit it to the appropriate refuge for review and approval by a refuge official. In some instances, applicants may be able to submit the information for Forms 3-1383-G, 3-1383-C, or 3-1383-R in a non-form format.

We estimate 20 percent of FWS Form 3-1383-G users will submit their applications in a non-form format or electronically (via email). Few users of FWS Forms 3-1383-C and 3-1383-R will use a non-form format or be able to submit the information electronically. We estimate 100% of users will submit information electronically on Form 3-1384.

When required, we accept electronic submission of activity reports via 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.

There is no duplication. The information is specific to the applicant, the use or activity proposed, and the refuge where the proposed activity will take place

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

This collection of information does not have a significant impact on a substantial number of small entities. Applicants submit the information for specific needs, and this information is not available from any other source. Small businesses from which we collect information are typically recreational visitor service operations (outfitters/guides), farming operations, commercial filming, and other commercial activities. We collect only the minimum information necessary to establish eligibility, protect resources, and demonstrate that applicants are aware of information they need to know to protect themselves from legal and financial predicaments. As a further means to reduce burden, we will use applicable portions from original applications to process renewals.

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 the information requested, we would be unable to review the proposed uses and evaluate the impacts or effects of proposed uses on System lands. This would preclude our ability to fulfill statutory requirements and our responsibilities under the Administration Act, the Recreation Act, ANILCA, and other relevant laws and regulations to determine if the proposed activity or use meets refuge compatibility standards.

We collect the information on either an as-needed basis (one-time or one-season event) or an annual basis. Some special uses, such as haying and grazing, are beneficial management tools that we use to provide the best habitat possible on some refuges and wetland management districts. We could not accomplish these management objectives without the cooperation and involvement of private individuals.

Special use permits provide us with a legal and binding document authorizing the particular use.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

* requiring respondents to report information to the agency more often than quarterly;

* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

* requiring respondents to submit more than an original and two copies of any document;

* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

* in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study;

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

* requiring respondents to submit proprietary trade secrets, or other confidential information, unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no circumstances requiring the collection of information in a manner inconsistent with OMB guidelines.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and in response to the PRA statement associated with the collection over the past three years, and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every three years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

On July 13, 2021, we published a notice in the Federal Register (86 FR 36762) announcing our intent to request renewal of this information collection. We solicited public comment for sixty days, ending on September 13, 2021. We received the following comment in response to that notice:

Comment 1: Email Comment from Jean Public dated 07132021. The commenter objected to all haying and grazing activities on wildlife refuges.

Agency Response to Comment 1: The commenter did not address the information collection requirements. No response is required; however, the Service would like to add haying and grazing are used as a habitat management tool only in situations where we cannot meet our resource management objectives through maintenance, management, or mimicking of natural ecosystem processes or functions.

In addition to the Federal Register Notice, we consulted with the nine (9) individuals identified in Table 8.1 who familiar with this collection of information in order to validate our time burden estimate and asked for comments on the questions below:

Table 8.1

Organization	Title
Ventures Birding	Administrator
Louisiana State University	Associate Professor
Capable Partners	President
Livewire Bait Supply	Owner
KS Nature Photography	Owner
Yellowhorn Outfitters	Guide
Teton Science School	Administrator
USDA APHIS	Supervisory Wildlife Biologist
C&J Outdoors	Owner

“Whether or not the collection of information is necessary, including whether or not the information will have practical utility; whether there are any questions they felt were unnecessary”

Comments: Respondents indicated that yes, the information collected is necessary for FWS to evaluate the use. One respondent indicated that if a field was not relevevant to their needs, they responded n/a.

Agency Response/Action Taken: No response required.

“The accuracy of our estimate of the burden for this collection of information”

Comments: Respondents indicated the burdens ranged from 15 minutes to 2 hours, including gathering supporting documents. They commented that processes for other agencies take longer and that forms are easier after they have completed them once.

Agency Response/Action Taken: Based on these estimates, the Service plans to increasea our burden estimate for activity reports/supporting documentation from 30 minutes to 1 hour, as an average. We will continue to remain alert to opportunities to streamline the ICs via ePermits.

“Ways to enhance the quality, utility, and clarity of the information to be collected”

Comments: One commented suggested making it easier to apply to more than one refuge at a time.

Agency Response/Action Taken: We will explore this option for the next revision of this collection as we work towards automation of the forms via ePermits.

And

“Ways to minimize the burden of the collection of information on respondents”

Comments: Commenters suggested having the application available for download and providing contact info on every website. They also suggested online forms and submissions, but to retain contact with refuge staff.

Agency Response/Action Taken: We will explore this option for the next revision of this collection as we work towards automation of the forms via ePermits.

Additional comments received during the outreach:

Comments: Several commenters appreciated the helpfulness of Refuge staff in the application and permit process.

Agency Response/Action Taken: We appreciate the positive comments about our employees.

We contacted nine organizations and individuals for feedback. One responded they did not have time during hunting season to respond. Three provided feedback. The others did not respond, despite multiple efforts.

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

We do not provide 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.

We do not provide any assurance of confidentiality. Information is collected and protected in accordance with the Privacy Act (5 U.S.C. § 552a) and the Freedom of Information Act (5 U.S.C. 552). We will maintain the information in a secure System of Records (National Wildlife Refuge Special Use Permits, FWS-5, May 28, 1999, 64 FR 29055; modification published June 4, 2008, 73 FR 31877).

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

We do not ask questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here.

We estimate 13,903 responses totaling 21,446 annual burden hours for information collection associated with special use permits on national wildlife refuges. We estimate the total dollar value of the annual burden hours for this collection to be $840,631 (rounded).

We used Table 1 of the of Bureau of Labor Statistics (BLS) News Release USDL-21-1647, September 16, 2021, Employer Costs for Employee Compensation—June 2021, to calculate the total annual burden.

• Individuals – the hourly rate for all workers is listed as $38.91, including benefits.

• Private Sector – the hourly rate for all workers is listed as $36.64, including benefits.

• Government – the hourly rate for all workers is listed as $53.59, including benefits.

Requirement	Annual Number of Respondents	Total Annual Responses	Completion Time per Response (Hours)	Total Annual Burden Hours*	Hourly Rate	$ Value of Annual Burden Hours
General Special Use Application (Form 3–1383–G)
Individuals	1,142	1,142	0.5	571	$ 38.91	$ 22,217.61
Private Sector	609	609	0.5	305	36.64	11,175.20
Government	152	152	0.5	76	53.59	4,072.84
ePermits – General Special Use Application (Form 3–1383–G)
Individuals	1,143	1,143	0.33	377	$ 38.91	14,669.07
Private Sector	610	610	0.33	201	36.64	7,364.64
Government	153	153	0.33	50	53.59	2,679.50
Amendments – General Special Use Application (Form 3–1383–G)
Individuals	114	114	0.25	29	$ 38.91	1,128.39
Private Sector	61	61	0.25	15	36.64	549.60
Government	15	15	0.25	4	53.59	214.36
ePermits Amendments – General Special Use Application (Form 3–1383–G)
Individuals	114	114	.2	23	$ 38.91	894.93
Private Sector	61	61	.2	12	36.64	439.68
Government	15	15	.2	3	53.59	160.77
Renewals – General Special Use Application (Form 3–1383–G)
Individuals	228	228	.33	75	$ 38.91	2,918.25
Private Sector	122	122	.33	40	36.64	1,465.60
Government	30	30	.33	10	53.59	535.90
ePermits Renewals – General Special Use Application (Form 3–1383–G)
Individuals	228	228	.25	57	$ 38.91	2,217.87
Private Sector	122	122	.25	31	36.64	1,135.84
Government	30	30	.25	8	53.59	428.72
Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	797	797	4	3,188	$ 38.91	124,045.08
Private Sector	500	500	4	2,000	36.64	73,280.00
Government	54	54	4	216	53.59	11,575.44
ePermits – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	798	798	3.75	2,993	$ 38.91	116,457.63
Private Sector	500	500	3.75	1,875	36.64	68,700.00
Government	54	54	3.75	203	53.59	10,878.77
Amendments – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	80	80	1	80	$ 38.91	3,112.80
Private Sector	50	50	1	50	36.64	1,832.00
Government	5	5	1	5	53.59	267.95
ePermits Amendments – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	80	80	0.75	60	$ 38.91	2,334.60
Private Sector	50	50	0.75	38	36.64	1,392.32
Government	5	5	0.75	4	53.59	214.36
Renewals – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	160	160	2	320	$ 38.91	12,451.20
Private Sector	100	100	2	200	36.64	7,328.00
Government	27	27	2	54	53.59	2,893.86
ePermits Renewals – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	160	160	1.5	240	$ 38.91	9,338.40
Private Sector	100	100	1.5	150	36.64	5,496.00
Government	27	27	1.5	41	53.59	2,170.40
Research and Monitoring Special Use Application (Form 3–1383–R)
Individuals	104	104	5	520	$ 38.91	20,233.20
Private Sector	201	201	5	1,005	36.64	36,823.20
Government	67	67	5	335	53.59	17,952.65
ePermits – Research and Monitoring Special Use Application (Form 3–1383–R)
Individuals	105	105	4.75	499	$ 38.91	19,416.09
Private Sector	202	202	4.75	960	36.64	35,174.40
Government	68	68	4.75	323	53.59	17,309.57
Amendments – Research and Monitoring Special Use Application (Form 3–1383–R)
Individuals	10	10	1.5	15	$ 38.91	583.65
Private Sector	20	20	1.5	30	36.64	1,099.20
Government	7	7	1.5	11	53.59	589.49
ePermits Amendments – Research and Monitoring Special Use Application (Form 3–1383–R)
Individuals	10	10	1.25	13	$ 38.91	505.83
Private Sector	20	20	1.25	25	36.64	916.00
Government	7	7	1.25	9	53.59	482.31
Renewals – Research and Monitoring Special Use Application (Form 3–1383–R)
Individuals	21	21	2	42	$ 38.91	1,634.22
Private Sector	40	40	2	80	36.64	2,931.20
Government	14	14	2	28	53.59	1,500.52
ePermits Renewals – Research and Monitoring Special Use Application (Form 3–1383–R)
Individuals	21	21	1.5	32	$ 38.91	1,245.12
Private Sector	40	40	1.5	60	36.64	2,198.40
Government	14	14	1.5	21	53.59	1,125.39
Activity Reports/Associated Document Requirements
Individuals	1,122	1,122	1	1,122	$ 38.91	43,657.02
Private Sector	730	730	1	730	36.64	26,747.20
Government	198	198	1	198	53.59	10,610.82
ePermits – Activity Reports/Associated Document Requirements
Individuals	1,122	1,122	.75	842	$ 38.91	32,762.22
Private Sector	730	730	.75	548	36.64	20,078.72
Government	198	198	.75	149	53.59	7,984.91
Amendments – Activity Reports/Associated Document Requirements
Individuals	2	2	0.33	1	$ 38.91	38.91
Private Sector	23	23	0.33	8	36.64	293.12
Government	5	5	0.33	2	53.59	107.18
ePermits Amendments – Activity Reports/Associated Document Requirements
Individuals	2	2	0.25	1	$ 38.91	38.91
Private Sector	23	23	0.25	6	36.64	219.84
Government	5	5	0.25	1	53.59	53.59
Bid Sheet – National Wildlife Refuge System (Form 3–1384)
Private Sector	125	125	1	125	$ 36.64	4,580.00
ePermits – Bid Sheet – National Wildlife Refuge System (Form 3–1384)
Private Sector	125	125	.75	94	$ 36.64	3,444.16
Amendments – Bid Sheet – National Wildlife Refuge System (Form 3–1384)
Private Sector	13	13	0.33	4	$ 36.64	146.56
ePermits Amendments – Bid Sheet – National Wildlife Refuge System (Form 3–1384)
Private Sector	13	13	0.25	3	$ 36.64	109.92
TOTALS:	13,903	13,903		21,446		$ 840,631.10

*Rounded

13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)

* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information (including filing fees paid for form processing). Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

While most commercial use applications require submission of an application fee of between $50 and $200 (Forms 3-1383-C), we estimate the average fee per application is $100. Therefore, we estimate that the annual nonhour cost burden associated with this information collection is $337,500 ($100.00 x 3,375 applications as shown below).

We charge fees for a diverse set of commercial activities. However, not all sites charge an application fee for commercial activities, and not all regions or activities have fee schedules. Individual sites that require an application fee will advertise it on their site specific permit application instructions which are found on site-specific websites. Most are based on a local market analysis, and in some cases, a bidding process if we need to limit the amount of permits we issue for resource protection purposes.

Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	797	$ 100	$ 79,700
Private Sector	500	100	50,000
ePermits – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	798	$ 100	$ 79,800
Private Sector	500	100	50,000
Amendment - Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	80	$ 100	$ 8,000
Private Sector	50	100	5,000
ePermits Amendment – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	80	$ 100	$ 8,000
Private Sector	50	100	5,000
Renewals – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	160	$ 100	$ 16,000
Private Sector	100	100	10,000
ePermits Renewals – Commercial Activities Special Use Application (Form 3–1383–C)
Individuals	160	$ 100	$ 16,000
Private Sector	100	100	10,000
TOTALS:	3,375		$ 337,500

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

The estimated annual cost to the Federal Government to administer this information collection is $429,986 ($414,986 – salaries and $15,000 – other costs).

Salary/Benefits: $414,986 (rounded). We estimate that it will take an average of 1 hour to review and process each application and report, or a total of 7,865 hours. Applications and reports are reviewed at national wildlife refuges in all 50 States, some of which are in locality pay areas.

To determine hourly wage rates, we used the Office of Personnel Management Salary Table 2021-RUS as an average nationwide rate. To account for benefits, we multiplied the hourly rate by 1.59 in accordance with from BLS News Release USDL-21-1647, September 16, 2021, Employer Costs for Employee Compensation—June 2021 News Release USDL-21-1647, September 16, 2021, Employer Costs for Employee Compensation—June 2021.

Position	Grade/ Step	Hourly Pay Rate	Fully Burdened Hourly Rate (Incl. Benefits)	Total Hours	Total Cost (Fully burdened rate x total hours)*
Clerical, unskilled	GS-07/05	$ 23.72	$ 37.71	2,359	$ 88,957.89
Professional/technical staff	GS-11/05	35.11	55.82	4,719	263,414.58
Management (Refuge Mgr)	GS-13/05	50.04	79.56	787	62,613.72
Totals:				7,865	$ 414,986.19

* Rounded

Other Costs: $15,000 (printing, copying, postage, and overhead (not including employee benefits).

15. Explain the reasons for any program changes or adjustments in hour or cost burden.

We are reporting a burden change of 5,788 annual responses (4,344 discretionary and 1,444 change in agency estimate), 4,440 annual burden hours (2,693 discretionary and 1,747 change in agency estimate), and $78,000 annual cost burden in conjunction with the proposed revisions (outlined in question 2) associated with the new ICs for activity reports and associated document requirements, automation in ePermits, and amendments/renewals not previously reported.

The changes in agency estimate above are associated with the change in burden estimates (explained in question 2) are associated with the increase in burden estimates for the original IC for activity reports which was previously approved by OMB. Since our last submission, our outreach to refuges when communicating our plan to seek OMB approval to automate ICs in this collection, we discovered approximately 90% of research and commercial permits require some type of a report. We feel the last submission underestimated the amount of reporting required. With the proposed automation of the ICs associated with this submission, we will have more reliable data to report in the next renewal in 3 years.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

We will not publish this information. Information collected is strictly for use by refuge staff to determine eligibility for permits.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

We will display the OMB approval number and expiration date.

18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."

There are no exceptions to the certification statement.

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