1018-0092 SSA Renewal w-o Change 12102025

Supporting Statement A for

Paperwork Reduction Act Submission

Federal Fish and Wildlife Permit Applications and Reports—

Law Enforcement; 50 CFR 13 and 14

OMB Control Number 1018-0092

Terms of Clearance: None. This is a simple renewal, without change, to extend the expiration date of the collection while the Service prepares a proposed deregulatory rule, RIN 1018-BF16, “Importation, Exportation, and Transportation of Wildlife; Updates to the Regulations.” OMB designated that proposed rule as significant and as such, the Service would not have time to publish the final rule to extend the expiration date of this collection prior to its current expiration ate of February 28, 2026.

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

Section 9(d) of the Endangered Species Act (ESA) (16 U.S.C. 1531 et seq.), as amended, makes it unlawful to import or export wildlife or wildlife products for commercial purposes without first obtaining an import/export license (50 CFR Part 14.91). Persons required to obtain an import/export license must keep records that fully and correctly disclose each importation or exportation of fish, wildlife, or plants and the subsequent disposition made by them with respect to such fish, wildlife, or plants for a period of 5 years (50 CFR Part 13.46 and 14.93). Any live wildlife possessed under permit issued by the U.S. Fish and Wildlife Service (we, Service) must be maintained under humane and healthful conditions (50 CFR Part 13.41).

If an applicant resides or is located outside the United States and conducting commercial activities, the applicant must have an agent located in the United States (50 CFR Part 13.12).

Section 9(f) of the ESA requires that fish or wildlife be imported into or exported from the United States only at a designated port or at a nondesignated port under certain limited circumstances. The Secretary of the Interior, with approval of the Secretary of Homeland Security, designates these ports after notice and opportunity for public comment. To date, 18 U.S. Customs and Border Protection (CBP) ports of entry are designated for the import and export of wildlife and wildlife products (50 CFR 14.12). The Service has strategically located staff so that wildlife shipments are funneled through the most active CBP ports. Exceptions to the designated port requirement are permitted (1) scientific purposes (50 CFR 14.31); (2) to minimize deterioration or loss (50 CFR 14.32); and (3) to alleviate undue economic hardship (50 CFR 14.33).

The Marine Mammal Protection Act (MMPA), 16 U.S.C., Section 1371, paragraph (b)(2), allows for Native Alaskans to take marine mammals, including the polar bear, walrus, and sea otter, for subsistence purposes or, for the purpose of creating handicrafts. THE MMPA, 16 U.S.C., Section 1373, paragraph (a), allows for the Secretary to prescribe regulations with respect to the take of these marine mammal species by Native Alaskans.

Tanneries and registered agents with the Service can apply for an exemption under the MMPA to receive marine mammal parts and products from Native Alaskans for the purposes of tanning or transferring and ensure that these marine mammal parts and products are returned to Native Alaskans.

All of the laws, treaties, and regulations administered by the Service that authorize activities for which a permit is required provide the basis for our regulations in 50 CFR Part 13 (General Permit Requirements) and 50 CFR Part 14 (Importation, Exportation, and Transportation of Wildlife). The requirements in 50 CFR Parts 13 and 14 are in addition to any other permit requirements that may apply to a specific circumstance, as outlined in other sections of the Code of Federal Regulations, Title 50, Chapter 1, subchapter B.

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.

Designated Port Exception Permit (Form 3-200-2)

The information collected on the 3-200-2 will be used by Service employees to determine if the applicant qualifies to use a nondesignated port. The information we collect corresponds to the requirements in 50 CFR 14.31, 14.32, and 14.33. We also collect the Social Security Number or Employer Identification Number via the form. This critical information is used by wildlife inspectors and special agents during law enforcement investigations to ensure the identities of individuals are accurate and not mistaken while investigating wildlife crimes and to verify the applicant is the same person that had knowledge of wildlife laws and regulations.

The permits can be valid for up to 2 years from the date of issuance and can cover a single import/export shipment, multiple import/export shipments or shipments during a specified period of time. The permit can be renewed upon request.

We include Q&As in front of the application to clarify information for the applicant and to reduce the number of nondesignated port applications received because many applicants do not need to apply in the first place.

Director’s Order 212 (signed December 9, 2015) establishes policy and procedure for us to assert our full legal and regulatory authority to deny wildlife violators the ability to obtain wildlife permits and licenses.

Import/Export License (FWS Form 3-200-3a and 3-200-3b) (Paper and Electronic)

The Import/Export License is broken down into 2 separate forms: 1) for U.S. Entities (3-200-3a) and 2) Foreign Entities (3-200-3b) to reduce confusion. We include Q&As specific to the different entities in front of each form to clarify information for the applicant and to reduce the number of import/export licenses we issue. We found recently some foreign entities applied for an Import/Export License, when the U.S. importer/exporter should have obtained the license and not a foreign entity.

Director’s Order 212 (signed December 9, 2015) establishes policy and procedure for us to assert our full legal and regulatory authority to deny wildlife violators the ability to obtain wildlife permits and licenses. The information we collect corresponds to the requirements in 50 CFR 14.91, 14.92, and 14.93. We use this information as an enforcement tool and management aid to: (a) monitor the international wildlife market and (b) detect trends and changes in the commercial trade of wildlife and wildlife products. Import/export licenses are valid for up to 1 year and can be renewed upon request.

Permit Application Form: Registration of an Agent/Tannery under the Marine Mammal Protection Act (MMPA) (FWS Form 3-200-44)

The information collected on Form 3-200-44 will be used by Service employees to confirm that an applicant has provided a written description of the procedures that they will use to receive, store, process and, ship marine mammal parts and products and, a written description system of the bookkeeping and inventory that they will use used to receive, store, process and ship marine mammal parts and products, from Native Alaskans to Native Alaskans.

Registered Agent/Tannery Bi-Annual Inventory Report (FWS Form 3-200-44a)

The information collected on Form 3-200-44a will be used by Service employees to review the activities of the registered agent or registered tannery regarding the receipt and transfer of marine mammal parts and products from Native Alaskans to Native Alaskans.    

Unless a form number is specified in the table below, we collect the following information on FWS Forms 3-200-2, 3-200-3a, 3-200-3b, 3-200-44, and 3-200-44a:

We collect information on…	So that we can…
Name of the individual and personal identifying information such as date of birth, social security number, occupation, and address and contact information	Identify the individual and the activity conducted by the applicant for which a license/permit is required.
Name of business, tax identification number or social security number, description of business, website, and name and contact information for the principal officer	Identify the business and the activity conducted by the applicant for which a license/permit is required.
Name, street address, and contact information for each additional partner/principal officer (3-200-3a &3b)	Identify all individuals or businesses associated with the entity requesting a license/permit.
Whether or not applicant has or has ever had any Federal fish and wildlife permits. If yes, number of current permit or permit to be renewed/reissued	Identify prior or current activity under Federal wildlife permits. This helps in determining their knowledge of Service laws and regulations.
U.S. address for foreign applicant	Inspect records, as necessary.
Name, physical address, and telephone number of agent or location where business records will be maintained	Inspect records, as necessary.
Street address and contact information for location where wildlife inventories will be kept (3-200-3a & 3b)	Licensees are required to provide Service Officers access to their facility to examine inventories of wildlife or wildlife products imported or to be exported.
Port(s) of entry where importation/exportation is requested (3-200-2)	Determine if it is an appropriate port to be requested. Determine if additional workload can be accommodated by staff presently available at the requested port.
Valid import/export license number (for commercial shipments) (3-200-2)	Establish compliance with commercial import/export requirements.
Reason for requesting port exception (3-200-2)	Determine if there is a bona fide scientific purpose, potential deterioration or loss, or potential economic hardship that would benefit from the issuance of the permit.
General description of wildlife or wildlife products	Determine workload burden.
Whether the applicant is applying for a registration under the MMPA as agent, tannery or both (3-200-44)	Determine whether the business qualifies for a registration under the MMPA.
The species that the agent or tannery wishes to use in the transfer of marine mammal parts and products from Native Alaskans to Native Alaskans (3-200-44).	Determine that the species requested are eligible under the MMPA.
The procedure that the agent or tannery will use to receive, store, process and, ship marine mammal parts and products from Native Alaskans to Native Alaskans (3-200-44).	Determine that these procedures are sufficient to ensure the legitimate transfer of mammal parts and products from Native Alaskans to Native Alaskans.
The system of bookkeeping and inventory used to receive, store, process and, ship marine mammal parts and products from Native Alaskans to Native Alaskans (3-200-44).	Determine that the system of bookkeeping and inventory are sufficient to ensure the legitimate transfer of mammal parts and products from Native Alaskans to Native Alaskans.
A certification by the applicant that they will responsibly receive, store, process and, ship marine mammal parts and products from Native Alaskans to Native Alaskans to receive an exemption under the MMPA (3-200-44).	Confirm that the applicant is aware of the requirements in order to receive an exemption under the MMPA.
A description of the activities of the registered agent or registered tannery regarding the receipt and transfer of marine mammal parts and products from Native Alaskans to Native Alaskans (3-200-44a).	Confirm that the applicant is receiving, storing, processing and, shipping marine mammal parts and products from Native Alaskans to Native Alaskans.

Permittees and licensees must maintain records that accurately describe each importation or exportation of wildlife or wildlife products under the permit/license, and any subsequent sale or transfer of the wildlife or wildlife products. In addition, licensees must make these records and the corresponding inventory of wildlife or wildlife products available for our inspection at reasonable times, subject to applicable limitations of law. Any live wildlife possessed under a Service permit/license must be maintained under humane and healthful conditions. We believe the burden associated with these recordkeeping requirements is minimal because the records already exist. Importers and exporters must complete Form 3-177 (Declaration for Importation or Exportation of Fish or Wildlife) for all imports or exports of wildlife or wildlife products. This form provides an accurate description of the imports and exports. OMB has approved the information collection for FWS Form 3-177 and assigned OMB Control Number 1018-0012. Normal business practices should produce records (e.g., invoices or bills of sale) needed to document additional sales or transfers of the wildlife or wildlife products.

Generally, we do not require individuals and government entities to submit a report on activities conducted under the authority of a designated port exception permit. On an occasional basis, we may require entities to provide a report on activities conducted under a designated port exception permit or an import/export license.

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.

Currently forms 3-200-2 and 3-200-3a/3b are available on the Internet in a fillable format and can be submitted either by a hard copy, originally signed, or by electronic submission. Online application and submission of Form 3-200-2 can be found here: eDecs and online application and submission of Forms 3-200-3a/3b can be found here: USFWS eLicense.

eLicense – The automated FWS Forms 3-200-3a/3b are available in our new eLicense system. We will continue to offer hard copy versions to applicants without access to eLicense. This electronic option will simplify the application process and give the applicant the ability to pay online thru Pay.gov via credit card or direct bank payment. This reduces the number of applicants requesting multiple licenses for the same business, and reduces the number of bad addresses and bounced checks we contend with. An applicant will not be able to submit both an electronic and paper application.

Permittees/Licensees receive their digitally signed permit/license electronically via the email address provided on the application. Renewal notifications will also be sent via e-mail at 90, 60, and 30 days prior to expiration.

eDPEP – The automated FWS Form 3-200-2 is available in the eDecs system. We will continue to offer hard copy versions to applicants without access to eDecs. This electronic option will simplify the application process and give the applicant the ability to pay online thru Pay.gov via credit card or direct bank payment. This reduces the number of applicants requesting multiple licenses for the same business, and reduces the number of bad addresses and bounced checks we contend with. An applicant will not be able to submit both an electronic and paper application.

ePermits – We are continuing to expand the use of our automated permit application system referred to as “ePermits.” The ePermits System allowed the agency to move towards a streamlined permitting process to more significantly reduce the information collection burden on the public, particularly small businesses. 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 ePermits System fully automates the permitting process to improve the customer experience and reduces time burden on respondents. This system enhances the user experience by allowing users to enter data from any device that has Internet access, including personal computers, tablets, and smartphones. It also links the permit applicant to the Pay.gov system for payment of the associated permit application fee.

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) via ePermits. Through the ePermits account registration, we will track and be able to more accurately report the numbers 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.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The information that we collect is unique to the applicant and is not available from any other source. By tailoring application forms to particular activities, we eliminate duplication, provide better customer service, and improve our ability to process applications.

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

Almost all of our permittees/licensees are small businesses. We have carefully analyzed and constructed these requirements to ensure that the information requested of all applicants is the minimum necessary, while still ensuring our ability to determine if an applicant qualifies for the permit/license. In addition, we have consolidated our 8 issuing offices into 2 (East Coast and West Coast) to reduce inconsistencies in the issuance process. We have designed the eLicense application process requiring the individual, sole owner or principal officer apply directly, which will save the small entity money because they no longer hire a Customshouse broker to complete their application.

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.

If we do not collect this information, applicants would not be issued permits/licenses. The information is either required on the permit itself or needed to make the necessary legal findings under the ESA or Director’s Order 212. If we do not issue designated port exception permits, applicants who meet one or more of the three exemptions for importing or exporting wildlife or wildlife products at staffed, nondesignated ports, would be unable to do so. If import/export licenses are not issued, businesses could not commercially import or export wildlife or wildlife products.

If we collect this information less frequently, (1) the information establishing the eligibility may no longer be applicable, and (2) the frequency for collecting this information would not be consistent with the duration of validity for designated port exception permits and import/export licenses established in 50 CFR Parts 14.31, 14.32, 14.33 and 14.93.

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.

The only special circumstance that is inconsistent with OMB guidelines is the timeframe for the retention of documents. Permit regulations (50 CFR Parts 13.46 and 14.93) require that records of any taking, possession, transportation, sale, purchase, barter, export or import of wildlife pursuant to a permit be maintained for 5 years from the expiration date of the permit. The statute of limitations for enforcement is 5 years. Since commercial importers and exporters may have applied for and been issued permits under the general permit procedures, including designated port exception permits, we believe it would be in the public interest that the records maintenance requirements be consistent with those regulations.

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 September 11, 2025, we published in the Federal Register (90 FR 44091) a notice of our intent to request that OMB approve this information collection. The Service published the Federal Register notice on Regulations.gov (Docket No. FWS-HQ-LE-2025-0592) to provide the public with an additional method to submit comments (in addition to the typical email and U.S. mail submission methods). In that notice, we solicited comments for 60 days, ending on November 10, 2025. We received the following comments in response to that notice:

Comment 1: Anonymous electronic comment received 11/10/2025 via Regulations.gov (FWS-HQ-LE-2025-0572-0007). The commenter did not address the information collection requirements.

Agency Response to Comment 1: No response required.

Comment 2: Electronic comment received 11/10/2025 via Regulations.gov (FWS-HQ-LE-2025-0572-0008) from the Zoological Society of San Diego, doing business as the San Diego Zoo Wildlife Alliance (SDZWA). The submission included the following comments:

SDZWA emphasized the importance of this permit in supporting conservation programs such as the Species Survival Programs (SSP) and other recovery efforts. These programs require frequent movement of animals between institutions to maintain genetic diversity and population sustainability.

The organization provided several recommendations to improve the permit process:

1. Necessity and Utility: The permit is essential for managing wildlife transport and preventing illegal trade. It also helps reduce stress on animals by allowing the shortest and most direct travel routes.

2. Burden Estimate Accuracy: The current estimate of 1.25 hours to complete the form is often inaccurate, especially when specific scenarios require input from multiple experts, sometimes taking days.

3. Quality and Clarity: SDZWA suggests revising the application format to better align questions with the information USFWS needs. Clearer guidance would help applicants provide accurate and complete responses.

4. Minimizing Burden: The organization recommends transitioning to ePermits and accepting online payments, which would streamline the process and reduce reliance on paper checks.

5. Conservation Impact: Clarifying when the permit is required—particularly in relation to CITES and ESA protections—would enhance the effectiveness of the process. For instance, animals born in the U.S. and not listed under CITES or ESA may not require the permit, and such guidance should be made explicit.

The commenter concluded by reaffirming their commitment to wildlife conservation and expressed appreciation for the opportunity to contribute to the improvement of the permitting process.

Agency Response to Comment 2: The Service appreciates the comments from the SDZWA and acknowledges the variances of completion times when completing permit applications. The currently approved burden represents an estimate based on the variety of applicants and their comfort level completing the permit applications.

The Service is working to automate permits but is currently waiting on the new direction regarding electronic permitting processes expected to be developed by the Department of the Interior in the coming year.

We will also take their remaining for revisions and the development of improved guidance under consideration as we work to develop the proposed deregulatory action under RIN 1018-BF16, “Importation, Exportation, and Transportation of Wildlife; Updates to the Regulations” which is expected in late calendar year 2026.

Comment 3: Electronic comment received 11/10/2025 via Regulations.gov (FWS-HQ-LE-2025-0572-0009) from Dan Ashe, President and CEO, on behalf of the Association of Zoos and Aquariums (AZA). The submission included the following key recommendations and observations:

1. Necessity and Utility: The permit is vital for enabling direct and efficient transport of wildlife, reducing stress on animals and supporting conservation goals. It also aids USFWS in managing wildlife trade and preventing illegal activities.

2. Burden Estimate Accuracy: The current estimate of 1.25 hours to complete the form is often inaccurate. The complexity of the application, especially when specific scenarios are required, can extend the process to several days.

3. Clarity and Quality of Application: AZA recommends revising the application format to better align questions with the information USFWS needs. A guided form or clearer questions would help applicants provide accurate and complete responses.

4. Minimizing Burden: AZA urges USFWS to digitize the permit process through ePermits and allow online payments, replacing the current paper-based system and mailed checks. This would reduce administrative burden for both applicants and agency staff.

AZA concluded by expressing appreciation for USFWS’s commitment to wildlife protection and law enforcement, and emphasized the importance of continued collaboration to streamline processes that support the conservation and recovery of threatened and endangered species.

Agency Response to Comment 3: The Service appreciates the comments from the AZA and acknowledges the variances of completion times when completing permit applications. The currently approved burden represents an estimate based on the variety of applicants and their comfort level completing the permit applications.

The Service is working to automate permits but is currently waiting on the new direction regarding electronic permitting processes expected to be developed by the Department of the Interior in the coming year.

We will also take their remaining for revisions and the development of improved guidance contained in this collection of information under consideration as we work to develop the proposed deregulatory action under RIN 1018-BF16, “Importation, Exportation, and Transportation of Wildlife; Updates to the Regulations” which is expected in late calendar year 2026.

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
Canurture Nutraceuticals Inc.	Primary contact on license
N/A	Private citizen
Goldbelt Heritage Foundation	Primary contact on license
Guerrero Imports	Primary contact on license
Adverum Biotechnologies	Primary contact on license
Harry’s Marine Life	Owner
Golden Lion Xu Trading	President
Barmah Hats USA	Owner
Knight’s Taxidermy	Primary contact on Registration

“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: The commenters responded that they believe that the collection of information is necessary, for example for tracking potential import and export of wildlife at ports that are not usually well versed on certain wildlife. Additionally, the forms have utility, for example they allow authorized ports to be identified in advance and helps prevent shipment delays.

Agency Response/Action Taken: The Service appreciates the recognition of the utility of these forms and the support for continued efforts to strengthen our processes through informed data collection.

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

Comments: The commenters estimated that the paper application to complete Import/Export License Form 3-200-3b took 1.5 hours and had a recordkeeping estimate of 15 minutes. And the Designated Port Exception Permit Form 3-200-2 took an estimated 15-20 minutes to complete.

Agency Response/Action Taken: The Service appreciates the comments and notes the burden estimates. We acknowledge the variances of completion times when completing permit applications. The currently approved burden represents an estimate based on the variety of applicants and their comfort level completing the permit applications.

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

Comments: The commenters suggested to include brief examples based on import type on the Designated Port Exception Permit Form 3-200-2. No additional suggestions to enhance the quality, utility, and clarity of the information to be collected were received.

Agency Response/Action Taken: The Service appreciates the comments and suggestion. We will take the development of improved guidance under consideration as we work to develop the proposed deregulatory action under RIN 1018-BF16, “Importation, Exportation, and Transportation of Wildlife; Updates to the Regulations” which is expected in late calendar year 2026.

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

Comments: A commenter advised that they had to use the paper process as a foreign entity. And another commenters suggested allowing the system to auto-populate applicant information from existing eDecs accounts and integrate permit requests with other import/export permits to reduce duplicate data entry.

Agency Response/Action Taken: The Service appreciates the comments and suggestions.

The Service is working to better automate permits but is currently waiting on the new direction regarding electronic permitting processes expected to be developed by the Department of the Interior in the coming year. We will also take their remaining for revisions and the development of improved guidance under consideration as we work to develop the proposed deregulatory action under RIN 1018-BF16, “Importation, Exportation, and Transportation of Wildlife; Updates to the Regulations” which is expected in late calendar year 2026.

Comments: The commenters suggested continual modernization, utilizing technology and allowing most forms to be completed online.

Agency Response/Action Taken: The Service appreciates the comments and suggestions. We agree that expanding digital access and streamlining processes through online platforms are essential to enhancing efficiency, transparency, and user experience. We are actively working to modernize our systems and increase the availability of electronic forms and digital services. This includes transitioning many paper-based processes to secure online platforms, improving website functionality, and exploring new technologies that support remote access and real-time communication.

We did not receive responses from 7 entities, despite a minimum of 2 emails and 1 phone call follow up. These individuals include each entity in the list above, following the private citizen.

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 payment 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 may be disclosed in accordance with the Freedom of Information Act (FOIA) or the Privacy Act of 1974 and the routine uses listed in Systems of Records Notices INTERIOR/DOI-10, DOI Law Enforcement Records Management System (LE RMS) (January 10, 2024, 89 FR 1594) and/or INTERIOR/FWS–21, Permits System (January 12, 2024, 89 FR 2230). These records may be subject to disclosure under provisions of the Freedom of Information Act.

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 that we will receive 11,953 responses totaling 13,431 annual burden hours for this information collection. The total dollar value of the annual burden hours is approximately $611,448 (rounded). We provided the detailed burden calculations in Attachment A uploaded to ROCIS.

We used the Table 1 of the Bureau of Labor Statistics (BLS) News Release, USDL-25-0958, June 13, 2025, Employer Costs for Employee Compensation—March 2025, to calculate the total annual burden:

• Individuals - lists the hourly rate for all workers $47.92, including benefits.

• Private Sector - lists the hourly rate for all workers as $45.38, including benefits.

• Government - lists the hourly rate for all workers as $64.00, including benefits.

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.

The total annual nonhour dollar cost burden to the respondents is approximately $1,188,700 for application fees (see Attachment A uploaded to ROCIS). The fee Forms 3-200-2 and 3-200-3a/b received from individuals and private sector is $100/each. The fee for Forms 3-200-44 is $150/each. We do not charge application fees from government agencies or for processing reports.

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.

We estimate that the total annual cost to the Federal Government for this information collection is $581,972 (rounded – $581,872 in salaries and $100 in operational expenses).

Salaries/Benefits - $581,872 (rounded – See Attachment A in ROCIS). Import/export license and Designated Port Exception Permits are issued at 2 issuing centers – East Coast (located in Atlanta, Georgia) and West Coast (located in Sacramento, California). Registration of agent/tannery permit applications under the MMPA are issued in the Anchorage office. These issuers are solely dedicated to reviewing and processing applications and reports for designated port exception permits, import/export licenses and, agent/tannery permit applications under the MMPA.

We used the Office of Personnel Management Salary Table 2025-RUS to determine the hourly wage rate for a GS-8, step 5, the median grade/step for these employees. To calculate benefits, we multiplied the hourly rate ($30.05) by 1.62 to account for benefits in accordance with BLS News Release USDL-25-0958, resulting in an hourly cost factor of $48.68 (rounded).

We estimate that we will receive 11,953 applications and reports annually. It takes approximately 1 hour to process these for a total of 11,953 hours, at a cost of $581,872.04 ($48.68 X 11,953).

Operational Expenses - $100. These applications are almost exclusively obtained electronically from the Service website (https://www.fws.gov/forms/) and issued electronically and delivered via email.

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

We are not reporting any program changes or adjustments.

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 perform any analyses, develop statistical reports, or publish the results of 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.

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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