Supporting Statement A for 
Paperwork Reduction Act Submission

OMB Control Number 1018-0101

Monitoring Recovered Species After Delisting – American Peregrine Falcon

FWS Forms 3-2307, 3-2308, and 3-2309

Terms of Clearance.  None.

1.	Explain the circumstances that make the collection of information necessary.  

This information collection implements the requirements of the Endangered Species Act (16 U.S.C. 1539) (ESA).  The American peregrine falcon was removed from the List of Endangered and Threatened Wildlife on August 25, 1999.  Section 4(g) of the ESA requires that all species that are recovered and removed from the List of Endangered and Threatened Wildlife (delisted) be monitored in cooperation with the States for a period of not less than 5 years. The purpose of this requirement is to detect any failure of a recovered species to sustain itself without the protections of the ESA.  There are no corresponding Fish and Wildlife Service (we/Service) regulations for the ESA’s post-delisting monitoring requirement.  

This information collection also implements the Migratory Bird Treaty Act (16 U.S.C. 704) contained in Fish and Wildlife Service (we/Service) regulations in Chapter I, Subchapter B of Title 50 of the Code of Federal Regulations (CFR).

The American peregrine falcon has a large geographic distribution that includes a substantial amount of non-Federal land.  Although the ESA requires that monitoring of recovered species be conducted for not less than 5 years, the life history of American peregrine falcons is such that it is appropriate to monitor this species for a longer period of time in order to meaningfully evaluate whether or not the recovered species continues to maintain its recovered status.  The Monitoring Plan for the American Peregrine Falcon is available on our website at http://www.fws.gov/endangered/pdfs/peregrin/Peregrineplan2003.pdf .  Formal collection of monitoring data commenced in 2003.  Rangewide population monitoring of American peregrine falcons under the Monitoring Plan will take place every 3 years through 2015.  

2.	Indicate how, by whom, how frequently, and for what purpose the information is to be used.  If the information collected will be disseminated to the public or used to support information that will be disseminated to the public, explain how the collection complies with all applicable Information Quality Guidelines.  

We will use the information supplied on the FWS Forms 3-2307, 3-2308, and 3-2309 to review the status of the American peregrine falcon in the United States and to determine if it remains recovered:

(1)  FWS Form 3-2307 (Peregrine Falcon Monitoring Form) addresses the reporting requirements to record observations on the nesting pair, and the numbers of eggs and young during each nest visit.  Each nest will be visited two (or more) times.  

(2)  FWS Form 3-2308 (Peregrine Falcon Egg Contaminants Data Sheet) addresses the reporting requirements to record data on eggs collected opportunistically during a nest visit.  

(3)  FWS Form 3-2309 (Peregrine Falcon Feather Contaminants Data Sheet) addresses the reporting requirements to record data on feathers collected opportunistically during a nest visit.  Once collected, the eggs and feathers will be archived in a deep freeze for analysis at a later time.

Professional biologists employed by Federal and State agencies and other organizations, and volunteers who have been involved in past peregrine falcon conservation efforts complete FWS Forms 3-2307, 3-2308, and 3-2309.  The egg and feather contaminants data sheets (FWS Forms 3-2308 and 3-2309) are filled out by biologists with permits to collect eggs and feathers at nest sites, as described in the monitoring plan.  The obligation to provide the information is voluntary.  Nest data are collected every 3 years, and were last collected in 2006.  A report of the indicators chosen to monitor the health of peregrine populations, territory occupancy, nest success, and productivity was last published in 2006.  The report is available at http://library.fws.gov/btp/peregrine_breeding.pdf .

All the data requested on the nest monitoring and contaminants forms are required for later analyses.  On the nest monitoring forms, the location and observer information are critical for proper attribution of the data, and contact with observers if there is some question as to what was observed.  The information requested about observation post, the peregrines observed, and nest contents helps interpret the observations made about the likely nest stage and outcome of the nesting attempt.  The questions asked on the contaminants data sheets all help with ultimate interpretation of the quality, origin, and quantity of the samples submitted for analyses.

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].

About half of the forms are submitted electronically.  We leave it up to the States or  biologists/volunteers as to how they submit the data.  The forms will be available online in a fillable format and the completed forms can be e-mailed to the Service.  However, many of the biologists and volunteers take hard copies of the form to the monitoring sites and complete the forms in the field.  Many choose to submit hard copies of the forms to the Service rather than retyping and submitting electronically.

4.	Describe efforts to identify duplication.  

There is efficiency rather than duplication of effort in the case of the Service’s monitoring plan.  In most States these data are already being collected; the FWS monitoring plan merely unifies the data being collected for a subset of nests and maintains and analyzes those data in a uniform way.  

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

We collect the minimum information necessary to determine if the peregrine falcon remains recovered.  There is little impact on small entities because most of the work is done by public employees and volunteers.  

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.

Failure to collect these data as established in the monitoring plan, or at all, would be a failure of the Service to uphold its responsibilities under the ESA.  

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 special circumstances that require us to collect this information in a manner inconsistent with OMB guidelines.

8.	Provide 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 (or in response to a PRA statement) and describe actions taken by the agency in response to these comments.  

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.  [Please list the names, titles, addresses, and phone numbers of persons contacted.]

On February 25, 2008, we published in the Federal Register (73 FR 10048) a notice of our intent to request that OMB renew this collection of information.  We solicited comments for 60 days, ending on April 25, 2008.  We did not receive any comments in response to this notice.

In addition to publishing the notice in the Federal Register, we contacted several people who participated in the peregrine monitoring effort in the past.  Contact information for those who responded is listed below.  The frequency of data collection is once every 3 years, which the respondents thought was adequate.  The instructions were clear according to the respondents, as were the reporting format, burden estimate, and the data elements. 

Name	Title	Email	Address	Phone	
Christy Klinger	Wildlife Biologist	cklinger@ndow.org	NDOW, 4747 Vegas Drive, Las Vegas, NV 89108	702-486-5127 ext 3717	
Bob Oakleaf	Nongame Coordinator	Bob.Oakleaf@wgf.state.wy.us	Wyoming Game and Fish Department, 260 Buena Vista,  Lander WY 82520	307-332-2688	
Jim Ozier	Program Manager	jim.ozier@dnr.state.ga.us	Georgia DNR, 116 Rum Creek Dr, Forsyth, GA  31029	478-994-1438	
Janet Linthicum	Staff Research Associate	janetl@cats.ucsc.edu	Predatory Bird Research Group, UCSC Santa Cruz, CA 95060	831-459-2466	
Dr. Sartor O. Williams III	Research Associate	sunbittern@earthlink.net	Museum of Southwestern Biology, Univ. Of New Mexico	505-247-3731	

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

We do not provide gifts or payments 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 respondents any assurance of confidentiality. 

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.  

We do not ask questions of a sensitive nature.

12.  Provide estimates of the hour burden of the collection of information.  

We are requesting 1,635 burden hours for this collection.  Table 1 displays new estimates for the number of respondents and burden hours calculated based on the number of respondents collecting data in 2003 and 2006.  The expected number of respondents is lower than previously estimated.  The number of total responses is higher than previously estimated, based on a conservative recalculation of the number of nest sites visited and the number of visits per site (every 3 years).  The annualized time per response was also recalculated as 2.5 hours, based on the experiences of those collecting data in 2003 and 2006, including a variety of travel times to get to and from sites, and then averaged across the nation.  Monitoring peregrine falcons takes place in 42 States.  Tables 2 through 4 explain how we calculated the dollar value of the burden hours.

Table 1 – Annual Burden Estimates

Activity	Annual Number of Responses	Average Burden Hours per Action	Total Annual Burden Hours	$ Value of Annual Burden Hours*	
FWS Form 3-2307  - Collection at Nest Sites	638	2.5 hours	1,595	$48,941.10	
FWS Form 3-2308 – Egg Data	   8	2.5 hours	    20	       611.70	
FWS Form 3-2309 – Feather Collection	   8	2.5 hours	    20	       611.70	
Total	654		1,635	$50,164.50	

*See Tables 2-4 for calculation of the dollar value of the annual burden hours.  To obtain the rate for individuals/households, we used the wage calculator at www.bls.gov for all of the United States, all occupations.  To obtain the rate for State/local/tribal government, we used data from  http://www.bls.gov/oes/current/naics4_999200.htm , Table 19-1023 -- wildlife biologist mean income.  For this collection, we have assumed that the rate for the private sector is identical to the rate for State/local/tribal. To account for benefits, we multiplied the rate for individuals/households by 1.4, and multiplied the rate for the private sector and State/local/tribal governments by 1.5.

Table 2 – Dollar Value of Labor Costs for Nest Monitoring	
Form 3-2307	

Annual
Responses	Completion
Time per
Response
(hours)	Annual
Burden
Hours	Hourly Labor Costs	Hourly Labor Costs including
Benefits	Dollar Value of
Annual
Burden 
Hours	
Individual/Households	312	2.5	780	$18.62	$26.07	$20,334.60	
Private Sector 	  14	2.5	35	$23.40	35.10	     1,228.50	
State/Local/Tribal	312	2.5	   780	$23.40	35.10	   27,378.00	
Total	638		 1,595			$48,941.10	

Table 3 – Dollar Value of Labor Costs for Egg Collection	
Form 3-2308	

Annual
Responses	Completion
Time per
Response
(hours)	Annual
Burden
Hours	Hourly Labor Costs	Hourly Labor Costs including
Benefits	Dollar Value of
Annual
Burden 
Hours	
Individual/Households	4	2.5	  10	$18.62	$26.07	$260.70	
State/Local/Tribal	4	2.5	  10	$23.40	35.10	      351.00	
Total	8		  20			$611.70	

Table 4 – Dollar Value of Labor Costs for Feather Collection	
Form 3-2309	

Annual
Responses	Completion
Time per
Response
(hours)	Annual
Burden
Hours	Hourly Labor Costs	Hourly Labor Costs including
Benefits	Dollar Value of
Annual
Burden 
Hours	
Individual/Households	4	2.5	  10	$18.62	$26.07	$260.70	
State/Local/Tribal	4	2.5	  10	$23.40	35.10	      351.00	
Total	8		  20			$611.70	

13.	Provide an estimate of the total annual [nonhour] cost burden to respondents or recordkeepers resulting from the collection of information.  

The nonhour burden cost for this collection is insignificant, and we estimate the total nonhour burden cost to be $156.00.  Nonhour costs are incurred when contaminants samples must be shipped to designated labs for analysis and storage.  Shipping contaminants samples is estimated to be $10 per sample for eggs, including the cost of ‘blue ice’ or other suitable cold-pack, and overnight mailing.  Twelve samples are shipped per year, for a total annualized shipping cost of $120.  The cost of sending feather samples is estimated to be $3 per sample.  Twelve samples are shipped per year, for a total annualized shipping cost of $36.

14.	Provide estimates of annualized costs to the Federal Government.  

We estimate the annual cost to the Federal Government to administer this information collection to be $38,341.  In estimating salary costs, we used the Office of Personnel Management Salary Table 2008-GS and multiplied the hourly rate by 1.5 to account for benefits.  

	Grade/Step	Total 
Annual 
Hours	Hourly
Rate	Hourly
Rate
Including
Benefits	Total costs	
Nest Monitoring						
Regional Coordinators (GS-11)	GS-11/5	100	$26.15	$39.23	$  3,923.00	
National Coordinators (GS-12)	GS-12/5	700	$31.34	$47.01	  32,907.00	
						
Contaminants Monitoring						
Regional Preparation (GS-11)	GS-11/5	10	$26.15	$39.23	        392.30	
NOAA facility 	GS-13/5	20	$37.27	$55.91	   1,118.20	
Total					$38,340.50	

15.	Explain the reasons for any program changes or adjustments.

We are reporting an adjustment in the number of responses and annual burden hours for this collection.  We are reporting 654 responses, which is an increase of 160 from our last request.  We estimate these responses will require 1,635 burden hours, which is a decrease of 3,447 from our last request.  We have made these adjustments in our estimates based on our experience during the 2003 and 2006 collections of data.  Also, our previous estimates or burden erroneously included burden for the Federal Government, which we have deleted from these estimates.

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

We will publish data after each 3-year monitoring effort.  Publication of results will follow standard publication guidelines of peer-reviewed journals, and will appear first in Federal Government publications, e.g., the Biological Technical Publications series of the Service, but will likely be published in standard peer-reviewed journals after three or more monitoring seasons (i.e. starting after 2009).

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.

18.	Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

There are no exceptions to the certification statement.