Supporting Statement A
NPS
Preservation Values for Individual Animals
OMB Control Number:
1024-NEW
Terms of Clearance: Not Applicable – New Collection.
1.
Explain the
circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate
the collection.
From its founding more than a century ago, the National Park Service (NPS) has been authorized to collect information that will “improve the ability of the Service to provide state-of-the-art management, protection, and interpretation of, and research on, the resources of the System” (54 U.S.C. 100701). Furthermore, social science research in support of park planning and management is mandated in the NPS Management Policies 2006 (Section 8.11.1, “Social Science Studies”). The NPS pursues a policy that facilitates social science studies in support of the NPS mission to protect resources and enhance the enjoyment for present and future generations (National Park Service Act of 1916, 38 Stat 535, 16 USC 1, et seq.). NPS policy mandates that social science research be used to provide an understanding of park visitors, the non-visiting public, gateway communities and regions, and human interactions with park resources. Such studies are needed to provide a scientific basis for park planning and development.
The mission of the National Park Service (NPS) is, in part, to conserve the wildlife and natural processes within its units and provide for the enjoyment of these resources in a manner that will leave them unimpaired for the enjoyment of future generations. When park wildlife is affected by incidents such as poaching and motor vehicle collisions, it is the responsibility of the NPS to characterize the loss in economic value to the public. Under the System Unit Resource Protection Act (SURPA), parks have the authority to seek compensation for the value of lost resources if those resources cannot be restored or replaced. Unfortunately, the economics literature has little to say about such values.
The NPS Environmental Quality Division needs economic value estimates focused on the preservation (avoided loss) of individual animals, such as elk, moose, and fox, for use in damage assessments and other policy contexts. Because much of the public’s value for wildlife is driven by passive use motivations, such as existence and bequest values, a stated preference study is needed. For instance, animals in parks may be illegally poached or accidentally killed in vehicle collisions. Further, oil spills or other contaminants can cause the loss of wildlife. The NPS does not have any valuation estimates when an individual animal is killed or injured due to such intentional or accidental actions. For the current collection, five parks are included with two to three species of interest within each park. Three parks include terrestrial animals: Yellowstone National Park (bison, wolf, and mountain lion), Ozark National Scenic Riverways (beaver and otter), and Olympic National Park (elk and fox). Two parks include aquatic animals: Padre Island National Seashore (plovers and sea turtles) and Anacostia Park (geese and ducks). The data generated through the proposed information collection NPS Preservation Values for Individual Animals will provide theoretically sound and statistically defensible estimates of individual animal values for use in gauging required compensation for lost or damaged wildlife resources.
Legal and administrative justifications for this collection include:
The National Park Service Organic Act of 1916 (54 USC 100701.) Requires that the National Park Service (NPS) preserve the national parks for the use and enjoyment of present and future generations. At the field level, this means resource preservation, public education, facility maintenance and operation, and physical developments that are necessary for public use, health, and safety.
SURPA (System Unit Resource Protection Act 54) (54 USC 100721-100725) Gives parks the authority to seek compensation for the value of lost resources if those resources cannot be restored or replaced.
National Park Service Omnibus Management Act of 1998 (Pub. L. 105-391; Section 5911) Assures that the management of units of the National Park System is enhanced by the availability and utilization of a broad program of the highest quality science and information
NPS Management Policies 2006 (Section 8.11.1, “Social Science Studies”) Outlines that the NPS will facilitate social science studies that support the NPS mission, including providing a scientific basis for park planning, operations, and management.
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 proposed collection and subsequent analysis will be used by the NPS to provide parks with defensible estimates of economic losses to park visitors associated with the accidental or intentional loss of individual animals. The Aquatic and Terrestrial surveys are designed to collect information at selected park units addressing different species. For each species, a value per animal will be estimated and used by the NPS to collect damages in relevant cases under SURPA. Once compensation is obtained, the information will then be used by park managers for restoration activities such as habitat restoration, installation of collision reduction structures (e.g., fences, bridges, culverts, etc.), or invasive species removal.
Further, while the goal of the collection is limited to estimating values for a small range of commonly killed or injured species, the data and analysis of this study will provide a basis for species-specific studies that the NPS may need in the future.
This study includes a short on-site, intercept survey and a follow-up mail-back/electronic survey. The intercept survey will also provide the metrics used to describe any potential non-response bias analysis in the follow-up survey. Section/Question justifications for the surveys are included in Table 2.1 and on the survey instruments.
Table 2.1: Justification of Survey Questions/Sections
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.
The on-site intercept survey will be administered 100% electronically. A tablet computer (iPad or similar) will be used to conduct the on-site survey. The survey software platform, Qualtrics, will be used to save responses automatically. Responses will be uploaded at the end of each study day.
The follow-up survey will be available for completion in paper or electronic format. Based on results of the NPS Socioeconomic Monitoring Program (SEM) phase II pilot (Socioeconomic Pilot Survey, Phase II; OMB Control #1024-0224; ex. 5/31/2023), employing the same methodology (on-site intercept and mail-back/online follow-up), we anticipate 80% of respondents will opt to fill out the paper survey, while 20% will complete the electronic version.
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 known duplication of efforts. There are no existing or ongoing studies focused on the value of individual animals in NPS units.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This collection will not involve small businesses or other small entities. The survey will only target members of the general public visiting national parks.
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.
Currently the NPS relies on either state restitution values for poaching, which have no basis in economic theory and do not represent the public’s preferences, or wildlife value estimates pulled from economic studies that were not designed to address the loss of one or a small numbers of individual animals in a protected park setting. As a result, the values currently used by NPS in their SURPA cases are often set at an extremely conservative level due to a lack of consistent value estimates based on NPS visitor values. Therefore, the amount of habitat restoration conducted with the recovered monies is insufficient. Without this collection, the NPS will not have an improved, and more appropriate, empirical basis for setting the value of lost wildlife when seeking compensation from those responsible for the loss. The NPS acts as a trustee on behalf of the public of the natural and cultural resources within its boundaries. In the absence of the information collected in this study, the public (to whom these resources belong) will not be fully compensated for their loss. This is a one-time collection.
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.
This request contains no special circumstances.
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.
A Federal Register Notice published on July 19, 2022 (87 FR 43054) solicited public comments. No public comments were received. In addition to the Federal Register Notice, we solicited feedback from three professionals (Table 8.1) with expertise in economic valuation, message testing, survey design, and methodology. We incorporated their collective feedback on the sampling design, clarity of the survey and instructions, and burden estimates.
Table 8.1. Peer Reviewers
|
Reviewer Title |
Affiliation |
1 |
Professor - statistical analysis |
University of Montana |
2 |
Professor - wildlife collision avoidance programs |
Montana State University - Western Transportation Institute - |
3 |
Economist |
DOI Office of Policy Analysis |
“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: Overall, reviewers provided positive feedback on the utility of the study. They felt the Minnesota (MN) resident survey1 [upon which this NPS survey effort is based] provided a solid foundation for this study.
NPS Response: The NPS agreed and worked closely with the MN research team in the creation of this study.
“The accuracy of our estimate of the burden for this collection of information”
Comments: We based our burden estimate on the MN resident survey and arrived at an estimate of 15 minutes. Reviewers agreed with this estimate.
“Ways to enhance the quality, utility, and clarity of the information to be collected”
Reviewer #1: Suggested including only two or three distinct species. Noted that the use of two related species in the MN survey (common turtles and T&E turtles) led to some ambiguous results in the final estimated model from that study.
NPS Response: This advice was heeded, and the proposed collection includes two-three distinct species, e.g., piping plover and sea turtles, for the terrestrial and aquatic surveys.
Reviewer #2: For the terrestrial mail-back survey, the reviewer stressed the importance of being explicit that crossing structures must be used in conjunction with some amount of exclusionary fencing for the crossing to be effective relative to the contingent valuation questions.
NPS Response: The terrestrial mail-back survey was closely reviewed to ensure this information was present and clear. Within the “overpasses” paragraph on page 4 between questions 5 and 6, “with fencing to direct wildlife to the overpass” was added to emphasize the use of fencing in conjunction with crossing structures. The “hybrid underpasses” and fencing and culverts" sections already included language about the use of fencing.
Reviewer #3: Provided feedback that the percentage decreases in animal mortality used in the discrete choice and payment card questions should also be presented as the estimated number of fewer animals killed to improve overall understanding and utility.
NPS Response: This information was added to the terrestrial and aquatic mail-back surveys. For the terrestrial survey, questions 9 and 10 were edited to add the number of species that corresponded to the percentage decrease (e.g., Q9: 50% decrease in number of Elk collisions (100 fewer elk killed)). For the aquatic survey, questions 7 and 8 were edited to add the number of species that corresponded to the percentage decrease (e.g., Q7: 50% decrease in number of sea turtle deaths from oil (100 in total over 5 years)).
“Ways to minimize the burden of the collection of information on respondents”
Comments: We did not receive comments on this.
9. Explain any decisions to provide any payments or gifts to respondents, other than remuneration of contractors or grantees.
There are no payments or gifts associated with this collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The
anonymous nature of responses will be described to respondents in the
initial on-site intercept contact and reiterated in the written
literature accompanying the paper or electronic follow-up survey.
The only personally identifiable
information collected from visitors will be home mailing addresses
and/or email addresses for the sole purpose of administering the
follow-up survey. This information
will only be accessible and used by the study team for the purposes
described in this study, except as required by law.
Each follow-up survey will be
assigned a unique identifier to tie it to the respondent’s
intercept survey. This identifier will safeguard the respondent’s
anonymity and allow researchers to both join data upon follow-up
survey completion, as well as monitor mail-back, and non-response
bias. The unique identifier will be
used in all databases; only one password-protected list will link the
unique identifier to respondents’ mailing and/or email
addresses. At the end of the data analysis period, all personally
identifiable information will be destroyed. The
evaluation and statistical analysis will be conducted independently
of personal contact information, and respondents’ names will
never be connected to their responses.
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.
No questions of a sensitive nature will be asked as part of this collection.
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. Instead, this cost should be included under item 13.
This study will be conducted at a total of 5 NPS units (2 aquatic: Padre Island National Seashore and Anacostia Park and 3 terrestrial: Yellowstone National Park, Ozark National Scenic Riverways, and Olympic National Park). We will employ the same intercept methodology across each unit and expect the same number of intercepts and responses per unit (outlined in Supporting Statement Part B). We plan to contact a total of 7,000 visitors (1,400/park). We expect to receive about 8,876 completed responses (this includes the intercept survey (n=5,600), non-response survey (n=1,260) and mail-back surveys (n=2,016)). The total burden for this one-time collection is estimated to be 1,014 hours. The total annual burden and cost is described below and shown in Table 12.1.
1. On-site Intercept Survey: For the intercept survey, we will randomly approach 1,400 visitors per park (n=7,000) while on-site at 5 different park units. We estimate that 80% (n=5,600 total; 1,120/park) of initial contacts will participate in the on-site visitor survey, resulting in 2,240 aquatic intercept respondents and 3,360 terrestrial intercept respondents. The on-site survey will take 5 minutes to complete, including the 1-minute initial contact, resulting in a total burden of 467 hours (aquatic: 187 hours; terrestrial: 280 hours). Further, it is assumed that 90% (n=5,040 total; 1,008/park) of those agreeing to the Intercept Survey will also agree to receive the Follow-up Mail/Online Survey.
2. Non-Response Check & Observations: Of the 1,400 visitors who refuse to participate in the on-site survey, we anticipate 90% (n=1,260 total; 252/park (aquatic=504; terrestrial=756) will agree to answer the nonresponse bias questions and 10% will refuse to participate outright (hard refusals). For visitors who decline to take the on-site survey but agree to the non-response bias questions, the surveyor will ask three questions to collect information for possible non-response bias weighting:
1. “Are you a permanent resident of the United States?”
2. “Which of the following best describes your age (under 30, 30 to 60, over 60)?”
3. ”
Have you personally ever been driving or
riding in a vehicle that has been in a collision with wildlife?[For
Terrestrial version]” and “Have you personally ever been
to a coastal area where contamination from an oil spill was evident?
[For Aquatic version].”
Responses and observations will be recorded and compared to final respondent data. Researchers will use this information to check for non-response bias by testing to determine any significantly different responses compared to the rest of the sample. If a nonresponse bias is found, any limitations will be described in the findings. We expect each nonresponse bias contact to take 2 minutes, including the initial contact time of 1 minute, resulting in a total burden of 42 hours (aquatic: 17 hours; terrestrial: 25 hours).
3. Mail/Online Follow-up Visitor Survey: As noted, the current collection benefits from and builds in minor ways on the successful MN 2021 survey instrument. This MN random household mail survey was anticipated to have a 14% to 16% response rate—typical for this type of unsolicited random household survey. The final response rate for the MN survey was 21%, which was considered a very good response for the methodology and protocol used. This response rate also reflects the interest the general public has in the subject matter. For the NPS surveys, the target population is a much more engaged one, who will have agreed to participate in the mail-back/online survey when contacted on-site. For this reason and based on the SEM mail-back response rate, it is anticipated that response rates for the mail-back/online survey will be 40%. Assuming a 40% response rate (n=2,016; 403/park (aquatic=806; terrestrial=1,209)) with a completion time of 15 minutes, the mail-back/online survey will result in a total burden of 505 hours (aquatic: 202 hours; terrestrial: 303 hours).
We estimate the respondent burden and annualized costs to be $43,867 (Table 12.1). The estimated dollar value of the burden hours for this collection takes into account the nature of our respondents which include individuals or households. This estimated dollar value is based on the National Compensation Survey: Occupational Wages in the United States published by the Bureau of Labor Statistics Occupation and Wages, (BLS news release USDL-23-19712 June 2023 for Employer Costs for Employee Compensation—released September 12, 2023). The particular value utilized was $43.26 for individuals or households.
Table 12.1 Estimated annual respondent burden and annualized costs
Activity |
Estimated Number of Respondents |
Completion Time per Respondent (minutes) |
Total Annual Burden* (hours) |
Hourly Rate Including Benefits |
$ Value of Annual Burden Hours |
Intercept Survey |
|
|
|
|
|
Aquatic |
2,240 |
5 |
187 |
$43.26 |
$8,090 |
Terrestrial |
3,360 |
5 |
280 |
$43.26 |
$12,113 |
Subtotal |
5,600 |
|
467 |
|
$20,203 |
Non-response Survey |
|
|
|
|
|
Aquatic |
504 |
2 |
17 |
$43.26 |
$735 |
Terrestrial |
756 |
2 |
25 |
$43.26 |
$1,082 |
Subtotal |
1,260 |
/ |
42 |
|
$1,817 |
Mail-back/On-line Survey |
|
|
|
|
|
Aquatic |
806 |
15 |
202 |
$43.26 |
$8,739 |
Terrestrial |
1,210 |
15 |
303 |
$43.26 |
$13,108 |
Subtotal |
2,016 |
|
505 |
|
$21,847 |
TOTAL |
8,876 |
|
1,014 |
|
*Figures rounded to match ROCIS
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.)
There is no non-hour cost burden nor are there any fees associated with collection of this information.
14. Provide estimates of annualized costs 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.
We estimate that the total cost of this one-time information collection to the Federal Government will be $341,021. This cost includes the estimated salary costs of federal personnel and operational expenses (see 14.1 and 14.2 below). We used the Office of Personnel Management Salary Table 2023-DEN3 to determine the hourly wages for the Federal employees associated with this collection. We multiplied the hourly wage by 1.6 to account for benefits in accordance with the Bureau of Labor Statistics News Release USDL-22-18924, June 2023 for Employer Costs for Employee Compensation—released September 12, 2023.
Table 14.1 Annualized cost to the Federal Government
Position |
GS Level |
Hourly rate
|
Hourly Rate incl. benefits (1.6X hourly pay rate) |
Estimated time per task (hrs.) |
Annual Cost |
NPS Economist |
13/5 |
$59.25 |
$95 |
120 |
$11,400 |
* The calculations in this table are rounded up to the nearest whole number.
The operational expenses for this collection listed below are approximately $329,621, which includes contracted services through Bio economics ($267,451) and other operational expenses ($62,170).
Table 14.2 Annual Operational Expenses*
Support Staff |
Estimated Costs |
Senior Project Director |
$11,062 |
Economist 1 |
$45,258 |
Economist 2 |
$120,595 |
Senior Economist |
$41,496 |
Surveyor |
$30,660 |
Database Administrator |
$13,869 |
Project Administrative Assistant |
$4,511 |
Subtotal |
$267,451 |
Other Expenses |
Estimated Costs |
Survey mailings and postage |
$21,950 |
Travel (e.g., airfare, lodging, per diem) |
$32,720 |
Supplies (e.g., field equipment) |
$7,500 |
Subtotal |
$62,170 |
TOTAL |
$329,621 |
* The calculations in this table are rounded up to the nearest whole number.
15. Explain the reasons for any program changes or adjustments in hour or cost burden.
This is a new collection.
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.
Data analysis will include descriptive statistics, frequencies and percentages, and averages of appropriate questions in the final report of findings. For estimation of individual animal values, data from contingent choice and/or payment card format questions will be analyzed using a cumulative logistic regression model and/or survival analysis, depending on the question format analyzed.
This project is slated to occur once in 2024. The principal investigators will prepare a final report for the NPS that summarizes park-specific results, and individual reports to each participating park unit. It is expected that the final reports will be completed by early 2025.
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 control number and expiration date on all of the information collection instruments.
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.
1 The Minnesota survey and associated report were prepared for: Western Transportation Institute, College of Engineering, Montana State University and Nevada Department of Transportation NAS-NRC, for the following larger project: Wildlife Vehicle Collision (WVC) Reduction and Habitat Connectivity Task 1 – Cost Effective Solutions Transportation Pooled-Fund Project TPF-5(358) (Administered by: Nevada Department of Transportation).
2 https://www.bls.gov/news.release/pdf/ecec.pdf
3 https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2023/DEN_h.pdf
4 https://www.bls.gov/news.release/pdf/ecec.pdf
File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
Author | Ponds, Phadrea D. |
File Modified | 0000-00-00 |
File Created | 2023-12-13 |