Supporting Statement A for 
Paperwork Reduction Act Submission

OMB Control Number 1018-0113
Neotropical Migratory Bird Conservation Act (NMBCA) Grants Program

Terms of Clearance.  None.

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

The Neotropical Migratory Bird Conservation Act (NMBCA), Pub. L. 106-247, establishes a competitive, matching grants program that supports public-private partnerships carrying out projects that promote the long-term conservation of neotropical migratory birds and their habitats in the United States, Latin America, and the Caribbean.  Principal conservation actions supported by the NMBCA are:

•	Protection and management of populations; 
•	Maintenance, management, protection and restoration of habitat; 
•	Research and monitoring; 
•	Law enforcement; and 
•	Community outreach and education.

In collecting the information, we adhere to 43 CFR part 12 and 49 CFR part 24 as well as to Secretarial and Bureau directives for administering Federal assistance grants.

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.  

Between 2002 and 2008, the NMBCA grants program supported 260 projects, coordinated by partners in 48 U.S. States/territories and 36 countries. More than $25.5 million from NMBCA grants have leveraged about $116.5 million in matching funds and $6.1 million in nonmatching funds. Projects involving land conservation have affected about 1.9 million acres of bird habitat. In 2008, 37 projects were approved for funding.  The NMBCA grants program works in concert with national and international bird conservation initiatives, including Partners in Flight, U.S. Shorebird Conservation Plan, North American Bird Conservation Initiative (NABCI), and the U.S. Bird Conservation Joint Ventures.

Competing for grant funds involves applications from partnerships that describe in substantial detail project locations, migratory bird benefits, partnership funding, and other characteristics to meet the requirements of the Act. The applications provide the basic information necessary to determine the appropriateness and eligibility of potential projects. We use a competitive process to score and rank all eligible applications.  We use information from the applications in the grant selection process only and do not share the information with other organizations.

Applicants receiving a grant must provide annual and final reports to document the progress and accomplishments of a NMBCA project (program reports). Applicants also must provide financial information that shows the actual award amount spent and the non-Federal match provided to the project.

Information collected under this program is used to respond to the Executive Branch of the Federal Government, Congress, and the general public for such needs as: 

•	GPRA reporting.
•	Grant agreements.
•	Grantee reporting requirements.
•	Budget reports and justification.
•	Requests for information.
•	Data provided to other programs for databases on similar programs.
•	Congressional inquiries and reports required by the NMBCA.    

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.].

Materials that describe the program, including grant instructions and application forms, are available online at http://www.fws.gov/birdhabitat/Grants/NMBCA/InstructionsENG.shtm and at Grants.gov.  Consistent with directives to move to E-Government, electronic applications are required and are submitted by e-mail or diskettes.  Very little hard copy is employed to communicate with applicants and grant recipients; virtually all of these communications are by phone, e-mail or facsimile.  We also list the grants programs in the Catalog of Federal Domestic Assistance.   

4.	Describe efforts to identify duplication.  

The information sought is unique for the NMBCA program as well as to each location, situation, and application. 

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

Small entities, e.g., land trusts and conservancies, would be affected in the same way and to the same degree as larger entities.  Many of the applicants and grantees qualify as small entities.  We only collect the minimum information necessary for evaluation of projects.

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.

Proposals and reports are submitted only once per year; therefore, reducing the frequency of collection is not possible.  If we did not collect the information, the grant program would be eliminated since it would be impossible to determine eligibility and the scale of resource values or relative worth of the proposed projects.  Elimination of the information collection would also place the Service in violation of the various legal strictures to which the program is subject.  

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.

No special circumstances exist that require us to collect the 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 June 24, 2008, we published in the Federal Register (73 FR 35703) a notice of our intent to request that OMB renew this information collection. In that notice, we solicited comments for 60 days, ending on August 25, 2008.  We received one comment.  The comment expressed opposition to the NMBCA grants program, but did not address the information collection requirements.  We did not make any changes to our information collection requirements as a result of this comment.  In addition, we contacted the following persons:
Ms. Melissa Krenke Norman
Neotropics Communication Manager
Rainforest Alliance
mkrenke@ra.org	Dr. Victoria Piaskowski
International Coordinator
Zoological Society of Milwaukee vickip@zoosociety.org	
Dr. David Mehlman
Director of Migratory Bird Program
The Nature Conservancy
dmehlman@tnc.org	Dr. George Finney
Director, Bird Studies Canada
gfinney@bsc-eoc.org

Everyone contacted agreed that the information collection is necessary and has practical utility.  Estimates of the burden for this collection varied according to the size and complexity of the project proposal, but as overall averages, the persons contacted believe our estimates are accurate.  

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 applicants or grant recipients.

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 applicants 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 estimate that we will receive 195 responses totaling 10,650 burden hours.  We estimate the annual dollar value of the burden hours to be $252,055.

ACTIVITY	TOTAL ANNUAL RESPONSES	COMPLETION TIME PER RESPONSE (HRS)	TOTAL ANNUAL BURDEN (HRS)	
Prepare Application 	40-U.S.
80-international	70	  2,800
  5,600 	
Reporting 	25-U.S.
50-international	30	     750
  1,500   	
Total	195		10,650	
 
See Tables 2 and 3 below 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 governments. To account for benefits, we multiplied the rate for individuals/households and the private sector by 1.4, and multiplied the rate for the State/local/tribal governments by 1.5.  We calculated the benefits in accordance with BLS news release USDL 07-1883, December 11, 2007.  

We were not able to locate wage information for scientists from countries in Latin America or the Caribbean.  The Bureau of Labor Statistics does provide information on manufacturing/production workers at http://www.bls.gov/fls/home.htm.  Using 2005 data from Table 2, Hourly Compensation Costs in U.S. dollars, we estimate the dollar value of an hour for applicants from Latin America or the Caribbean to be no more than $15 (U.S.) per hour, including benefits.

Table 2 – Dollar Value of Labor Costs - Applications
	NO. OF ANNUAL RESPONSES	COMPLETION TIME PER RESPONSE (HRS)	ANNUAL BURDEN HOURS	HOURLY LABOR COSTS	HOURLY LABOR COSTS INCL. BENEFITS	DOLLAR VALUE OF ANNUAL BURDEN HOURS	
Individuals	  1 U.S.	70	     70	$18.62	$26.07	$    1,824.90	
Private Sector	50 U.S.
60 international	70	3,500
4,200	$24.11	$33.75
$15.00	$118,125.00
$  63,000.00	
Govt	  8 U.S.
  1 international	70	   560
     70	$24.11	$36.17
$15.00	$  20,255.20
$    1,050.00	
TOTALS	120		8,400			$204,255.10	
 
Table 3 – Dollar Value of Labor Costs - Reports
	NO. OF ANNUAL RESPONSES	COMPLETION TIME PER RESPONSE (HRS)	ANNUAL BURDEN HOURS	HOURLY LABOR COSTS	HOURLY LABOR COSTS INCL. BENEFITS	DOLLAR VALUE OF ANNUAL BURDEN HOURS	
Individuals	  1 U.S.	30	     30	$18.62	$26.07	$       782.10	
Private Sector	21 U.S.
49 international	30	   630
1,470	$24.11	$33.75
$15.00	$  21,262.50
$  22,050.00	
Govt	  3 U.S.
  1 international	30	     90
     30	$24.11	$36.17
$15.00	$    3,255.30
$       450.00	
TOTALS	75		2,250			$  47,799.90	
 
13.	  Provide an estimate of the total annual [nonhour] cost burden to respondents or recordkeepers resulting from the collection of information.  

There is no nonhour cost burden to respondents.

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

The total estimated cost to the Federal Government for processing and reviewing proposals and reviewing reports as a result of this collection of information is $136,388.  This includes hourly wages only.  The table below shows Federal staff and grade levels performing various tasks associated with this information collection.  We used the Office of Personnel Management Salary Table 2008-DCB to determine the hourly wages and multiplied the hourly wage by 1.5 to account for benefits in accordance with BLS news release USDL 07-1883, December 11, 2007.  

Action	Position and Grade	Hourly Rate	Hourly Rate including Benefits	Total Annual Hours	Annual Cost	
Proposal Review	Wildlife Biologist/Grant Administrator 
GS 13/5	$45.05	$67.58	1,000	 $ 67,580	
	Wildlife Administrator (Grants Branch Chief)
GS 14/5	$53.24	$79.86	100	 $   7,986	

Report Review	Wildlife Biologist/Grant Administrator
GS 13/5	$45.05	$67.58	900	 $ 60,822	
Total	$136,388	

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

We are reporting 195 responses and 10,650 burden hours for this information collection.  This is a decrease of 25 responses and 2,350 burden hours from our last request.  We base this adjustment on a decrease in the number of proposal applications during the last 3 years. 

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

We will not publish data from this information collection.

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 appropriate materials.

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.