**SUPPORTING STATEMENT FOR AN**

**INFORMATION COLLECTION REQUEST (ICR)**

**1. [IDENTIFICATION OF THE INFORMATION COLLECTION]{.underline}**

**1(a) Title of the Information Collection:**

> Pesticide Registration Fee Waivers

OMB Control No.: 2070-0167 EPA ICR No.: 2147.03

**1(b) Short Characterization/Abstract**

This Information Collection Request (ICR) is a proposed renewal of an
existing ICR that is currently approved by OMB and is due to expire
December 31, 2007. This information collection will allow the
Environmental Protection Agency (EPA) to process requests for waivers of
fees under the Pesticide Registration Improvement Act of 2003 (PRIA).
The ICR covers the collection activities associated with requesting a
fee waiver and involves requesters submitting a waiver request,
information to demonstrate eligibility for the waiver, and certification
of eligibility. Waivers are available for small businesses, for minor
uses, and for actions solely associated with the Inter-Regional Research
Project Number 4 (IR-4). State and federal agencies are exempt from the
payment of fees. This ICR provides burden hour and labor cost estimates
for both applicants for fee waivers and EPA employees who process and
approve or deny waiver requests.

**2. [NEED FOR AND USE OF THE COLLECTION]{.underline}**

**2(a) Need/Authority for the Collection**

Under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA),
EPA must evaluate pesticides thoroughly, before they can be marketed and
used in the United States, to ensure that they will not pose
unreasonable adverse effects to human health and the environment.
Pesticides that meet this test are granted a license or \"registration\"
which permits their distribution, sale and use according to requirements
set by EPA to protect human health and the environment.

The PRIA amended FIFRA to provide for the collection of fees in order to
enhance the review of covered pesticide products (see Attachment A) .
Fees collected under this program will help to reduce time frames for
registration decisions; provide greater predictability and more
accountability for those decisions; ensure that Food Quality Protection
Act (FQPA) deadlines are met; and result in more predictable and
augmented funding for the pesticide program. The program provides
stability in funding for EPA's Office of Pesticide Programs (OPP) over
five years. The program's fee schedule under PRIA will be phased out
beginning on October 1, 2008, and ending on September 30, 2010. As
indicated above, the PRIA also established provisions that allow these
fees to be reduced or waived entirely.

A registration applicant may seek a waiver as a small business, defined
by the PRIA as a business with fewer than 500 employees and on average,
annual global gross revenue from pesticides of no more than \$60 million
over the most recent three-year maintenance fee billing cycle. For a
business entity with one or more affiliates, the gross revenue limit
includes total global revenues from pesticides for the entity and all of
its affiliates, including parent and subsidiary entities.

A registration applicant qualifying as a small businesses under the PRIA
will be entitled to a waiver of fifty percent (50%) of its fees. In
addition, all fees will be waived for small businesses with, on average,
annual gross global revenues from pesticides over the most recent
three-year maintenance fee billing cycle, including affiliates, of no
more than \$10 million. Small business applicants requesting waivers
must provide EPA with appropriate documentation demonstrating that they
meet these criteria.

A registration applicant may also request a minor use waiver or fee
reduction if the applicant can demonstrate that anticipated revenues
from the uses described in the registration application would be
insufficient to justify the imposition of the full application fee. The
Agency may grant a full waiver or a partial reduction in the fee based
upon its consideration of the supporting documentation provided.

In addition, the statute states that the Agency shall waive the
registration service fee for an application if the Administrator
determines that two criteria are met: that the application is solely
associated with IR-4 tolerance petition and that the waiver is in the
public interest. The Agency anticipates that most applications submitted
by the IR-4 program would qualify for a waiver. Finally, the statute
exempts agencies of the Federal Government or a State from fees.

The program is expected to generate in excess of \$10 million in new
registration service fees annually over five years and allows applicants
for pesticide registrations submitted prior to the effective date of the
Act to pay a portion of the fee voluntarily.

**2(b) Practical Utility/Users of the Data**

EPA is the sole intended user of the information collected. This
collection of information is critical for the proper performance of
Agency functions because the information collected will allow EPA to
properly review a request for a waiver of fees under the PRIA without
delay. The actual usefulness of the information to the Agency is that
the information collected will be used to determine if the applicant
qualifies for a fee waiver or fee reduction. Statutorily, in instances
where the applicant requests a fee waiver or fee reduction, the decision
review time period does not begin until either the Agency grants the
waiver or until the registrant has paid the appropriate registration
service fee (or, in the case of a partial waiver or fee reduction, the
balance of the appropriate registration service fee). Processing of the
application, therefore, will be delayed until the Agency can render a
decision on the fee waiver or fee reduction request. With the submission
of this data by the registrant, the Agency will be able to meet its
statutory obligation to grant or deny the waiver request within 60 days
and, potentially, earlier than the maximum 60 day period.

**3. [NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA]{.underline}**

**3(a) Non duplication**

No other federal agency or EPA program is collecting fees for the
processing of applications for pesticide registration or, therefore,
information for the waiver of such fees. As such, this information
collection activity does not duplicate any other collection of
information by the federal government.

**3(b) Public Notice Required Prior to ICR Submission to OMB**

Pursuant to 5 CFR 1320.8(d), EPA is publishing a Federal Register (FR)
notice soliciting comment on this information collection activity and
the Agency's intent to renew the OMB approval of this ICR. The FR notice
and the proposed renewal ICR as well as any public comment are located
in the docket for this action, which can be accessed at
[http://www.regulations.gov](http://www.regulations.gov/) using the
docket indentifier EPA-HQ-OPP-2006-0636.

**3(c) Consultations**

Prior to passage in 2004, the PRIA had been developed over a multi-year
period based upon input from the pesticide industry, industry trade
associations, public interest groups, and the Agency. The legislation
that was introduced into Congress was based upon a consensus reached by
stakeholders, informed with technical support provided by the Agency.
These stakeholders included CropLife America, the Consumer Specialty
Products Association, the Chemical Producers and Distributors
Association, the American Chemistry Council, the Natural Resources
Defense Council, and Consumers Union, among other parties.

During preparation of this ICR renewal, EPA staff will contact
representatives from a cross-section of pesticide registrant companies
by e-mail and telephone to seek feedback on the PRIA waiver process.
Their responses to EPA's consultation efforts will be summarized and
made publicly available.

In addition to these consultation activities, dialogue between industry
and the Agency on the PRIA waivers process, content, definitions,
format, and timing is frequent and on-going. In addition to phone
conversations, e-mails, and letters, Agency staff participate in
meetings with individual registrants as well as gatherings of large
groups of registrants from time to time. These communications permit an
exchange of issues, problems, and solutions on many issues.

**3(d) Effects of Less Frequent Collection**

The PRIA fee waiver program is still a new program (initiated March
2004) and the Agency and respondents are still in the learning stages of
what constitutes appropriate documentation demonstrating their
eligibility for waivers. Waivers applications are submitted and reviewed
on an application-by-application basis. As the Agency develops
experience with the review of these waiver requests, we will seek to
identify opportunities for reducing the frequency of collecting this
information, provided that such a reduction will still allow the Agency
to satisfy the statutory requirements of the PRIA. For example, when
registrants

that have been granted a small business waiver submit a subsequent small
business request

in the same maintenance fee billing cycle, they may incorporate by
reference the previously

submitted documentation to the extent that the information continues to
be accurate.

On March 1, 2006, the Agency published the second annual report
providing an update on "Implementing the Pesticide Registration
Improvement Act \-- Fiscal Year 2005" is available at
<http://www.epa.gov/pesticides/regulating/fees/pria_annual_report_2005.htm>
(see also Attachment B) which discusses in detail the processes that
have been streamlined and the stakeholder involvement during the first
two years of this new program.

**3(e) General Guidelines**

This collection activity complies with the guidelines for information
collections under the Paperwork Reduction Act (PRA). The recordkeeping
activities briefly described in this ICR exceed OMB's guideline that
agencies not require that records be retained for more than three years
(5 CFR 1320.5(d)(2)(iv)). As authorized under FIFRA section 8, EPA
regulations require that applicants retain records containing research
data relating to registered pesticides (including all data submitted to
EPA in support of a registration - see 40 CFR 169.2(k)) for as long as
the registration is valid and the producer is in business. However, the
burden related to the recordkeeping requirements is covered under
another ICR (see OMB Control No. 2070-0028, *Recordkeeping Requirements
for Producers of Pesticides under Section 8 of the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA)*).

The Government Paperwork Elimination Act (GPEA, see Public Law 105-277,
Title XVII) required agencies, by October 2003, to provide for both the
option of the electronic maintenance, submission, or disclosure of
information, when practicable as a substitute for paper; and for the use
and acceptance of electronic signatures, when practicable. The Agency
has published a policy paper stating its mission and goals for
Electronic Data Submission and Review Efforts,
<http://www.epa.gov/oppfead1/eds/edsgoals.htm>. (See Attachment C) OPP
has established standards for voluntary submission of study reports in
electronic form (Adobe PDF on CD-ROM). And in FY 2005, the Agency
encouraged registrants to submit electronic data evaluation records for
studies in support of new active ingredients. This innovation
facilitates data interpretation and conserves Agency resources,
permitting more rapid decisions, particularly for reduced risk
chemicals.

At this time, OPP may not be able to make electronic reporting available
for this information collection because the PRIA fee waiver information
collection may contain proprietary information (e.g., gross global
revenues, business structures and employment levels). EPA has not yet
promulgated appropriate regulations (i.e., Cross-Media Electronic
Reporting Rule) to address electronic reporting and electronic signature
issues. While this type of submission might be a candidate for
e-submissions in the future, after the promulgation of these
regulations, based on the Agency's needs, and on the Office of
Management and Budget's (OMB) GPEA guidance (as updated by OMB's policy
on E-Authentication), EPA would likely require that any electronically
submitted forms be signed with an e-signature technology such as public
key infrastructure (PKI). As this information collection request
indicates, both the basic product registrant and the distributor must
sign the required notification. EPA is currently unaware of how an
e-signature technology that offers both the Agency and the signatories
the level of signature security such as that offered by PKI can be
successfully applied to a document that requires multiple signatures.

**3(f) Confidentiality**

The information requested to document fee waiver requests may contain
confidential business information (CBI). However, data and/or
information submitted to the Agency in conjunction with service fee
waiver requests may be claimed as trade secret or commercial or
financial information and will be protected from disclosure under FIFRA
section 10 and the associated regulation as contained in 40 CFR Part 2,
Subpart B. Information claimed as CBI is protected from public
disclosure unless the Administrator determines that disclosure is in the
public interest. OPP routinely handles CBI data, and personnel are
familiar with security procedures in accordance with provisions of the
[FIFRA Confidential Business Security Manual]{.underline} to ensure
confidentiality. If any information is submitted that applicants claim
as confidential, the Agency will employ the established procedures for
handling such material.

**3(g) Sensitive Questions**

No information of a sensitive or private nature is requested in
conjunction with this collection activity. Further, this information
collection activity complies with the provisions of the Privacy Act of
1974 and OMB circular A-108.

**4. [THE RESPONDENTS AND THE INFORMATION REQUESTED]{.underline}**

> **4(a) Respondents/NAICS Codes**

The North American Industrial Classification System (NAICS) codes
assigned to the parties responding to this information collection are as
follows:

  ------------------- ------------------------ ----------------------------------
  [NAICS              [Category]{.underline}   [Description]{.underline}
  Code]{.underline}                            

  32532               Pesticide and other      individuals or entities engaged in
                      agricultural chemical    activities related to the
                      manufacturing            registration of a pesticide
                                               product

  32518               Other Basic Inorganic    manufacturers of inorganic
                      Chemical Manufacturing   chemicals used as inert
                                               ingredients in pesticide products

  32519               Other Basic Organic      manufacturers of organic chemicals
                      Chemical Manufacturing   used as inert ingredients in
                                               pesticide products.
  ------------------- ------------------------ ----------------------------------

**4(b) Information Requested**

\(i\) *Data items, including record keeping requirements*

A registration applicant who seeks a small business waiver must submit a
waiver request with appropriate documentation demonstrating that he
meets the criteria established in the PRIA, i.e., that he has fewer than
500 employees and has no more than \$60 million in annual global gross
revenue from pesticides, averaged over the most recent three maintenance
fee billing cycles, including any such revenue from affiliates. For this
purpose, the applicant may be required to submit documentation regarding
numbers of employees and, on behalf of itself and its affiliates, gross
revenue figures, and information on revenue from pesticides over a
three-year period.

A registration applicant who seeks a minor use waiver must provide
supporting documentation that anticipated revenues from the uses that
are the subject of the application would be insufficient to justify
imposition of the full registration fee.

A registration applicant seeking an IR-4 waiver must merely request the
waiver on Form 8570-1 (*Application for Pesticide Registration*,
approved under OMB Control #2070-0060) and submit the application at the
same time that the IR-4 tolerance petition is submitted. The Agency
will, in turn, determine whether the application is solely associated
with a tolerance petition submitted by IR-4 and that the waiver is in
the public interest.

Although there is no record keeping requirement, PRIA provides that an
application shall be subject to a registration service fee if, at any
time, EPA determines that (i) the documentation supporting the waiver
request is not accurate or (ii) based on the documentation or any other
information, the waiver or reduction should not have been granted.
Therefore, it is anticipated that applicants will retain copies of their
submissions as well as documents demonstrating that the applicant is
eligible for the waiver or reduction. There are currently no forms
associated with this information collection activity.

\(ii\) *Respondent Activities*

If a registration applicant wishes to request a fee waiver, at a
minimum, it must undertake the following activities:

· Generate and submit the necessary materials to support the request.

· Indicate that a waiver is requested and that the appropriate
documentation supporting the request is enclosed or has been otherwise
submitted to the Agency.

**5. [THE INFORMATION COLLECTED - AGENCY ACTIVITIES,
COLLECTION]{.underline} [METHODOLOGY, AND INFORMATION
MANAGEMENT]{.underline}**

**5(a) Agency Activities**

The Agency is expected to engage in the following activities:

· **Review and evaluate fee waiver requests.** Notify applicant of
decision.

· **Verify payments.** Cross check payment information from Financial
Management Division.

· **Store the data.** Image all forms, listings, telephone
conversations, etc., for archiving.

**5(b) Collection Methodology and Management**

Fee payments are sent to the Financial Management Division in
Pittsburgh, Pennsylvania and entered in to the Agency\'s Integrated
Financial Management System (IFMS). Payment information is extracted
from IFMS and loaded into OPP\'s tracking system (OPPIN). All invoices
are generated electronically and tracked in OPPIN. Incoming letters, fee
waiver applications, mail receipts, petitions, and other types of
correspondence from registrants will be retained in hard copy for a
period of time and then imaged for long term electronic storage.

Procedures for evaluating fee waiver requests will not change.
Information and materials submitted to justify a fee waiver are screened
for completeness by the receiving division. Economic data are sent to
OPP's Biological and Economic Analysis Division for analysis. The Agency
will keep applicants informed of the status of the waiver application
throughout the process by telephone and by mail.

**5(c) Small Entity Flexibility**

Small businesses may request a waiver of the registration service fee. A
waiver applicant must demonstrate that it meets the criteria as outlined
in the PRIA. The information that needs to be compiled in order to make
this determination is information that companies routinely collect and
maintain in the normal course of business.

**5(d) Collection Schedule**

Registration service fees are required for 90 different registration
categories identified by Congress, and published in the *Congressional
Record* of September 17, 2003 (pp. S11631-S11633). EPA reproduced the
table of categories from the *Congressional Record* and included it as
Attachment D. Fee categories have remained the same while the fees
listed in the Congressional Record were increased by 5% as of October 1,
2005, as specified by legislations. There is no set collection schedule,
per se. Rather, the registration service fee is collected each time a
registrant submits a registration application. The applicant must either
pay a fee or request and be granted a waiver for each registration
application submitted if the application is within the scope of one of
the 90 fee categories.

**6. [ESTIMATING THE BURDEN AND COST OF THE COLLECTION ]{.underline}**

**6(a) Estimating Respondent Burden**

For a period of some years, when estimating labor rates for most OPP
program ICR renewals, the Agency adjusted the ICR renewal labor rates by
using methods such as the NASA Gross Domestic Product (GDP) Deflator
Inflation Calculator to index the labor cost for a particular year.
However, in July 2006, Agency economists completely re-estimated wages,
benefits, and overhead for all labor categories for the pesticide
industry, state government and Agency employees. The Agency analysis
uses currently available information on labor rates and other benefits
from publicly available websites. A copy of the methodology used to
re-estimate the labor rates and formulas used to derive the fully loaded
rates and overhead costs are listed in Attachment E.

To derive the labor rates for this ICR, Agency economists estimated the
wages for the management, technical, and clerical labor categories using
the methodology cited above. The respondent costs for this renewal for
managerial, technical and clerical rates are estimated at \$100.86,
\$64.80, and \$33.05 per hour, respectively. These labor rates are fully
loaded and include benefits and overhead costs.

In calculating the potential respondent burden, the Agency estimated 389
responses per year for requesting fee waivers or reductions, based on
the numbers of fee waiver applications during the maintenance fee cycle
for the year of 2005.

IR-4 waiver requests are not accounted for in this burden estimation. To
be eligible for the IR-4 waiver under PRIA, the application must be
solely associated with a tolerance petition submitted by the IR-4
program and the waiver must be in the public interest. To facilitate
this request, the applicant may simply include the statement \"This
application is being submitted with a tolerance petition submitted in
connection with IR-4. I request EPA to waiver the registration service
fee for this application under the IR-4 waiver provisions of FIFRA
Section 33(b)(7)(E).\" on Form 8570-1 (Application for Pesticide
Registration). Burden hours associated with completing this form are
already covered by the ICR entitled "Application for New or Amended
Registration" (approved under OMB Control Number 2070-0060). EPA is not
requiring that registrants submit additional information. The Agency
will determine whether the application is solely associated with a
tolerance petition submitted by IR-4 and whether the waiver is in the
public interest.

There are three types of applications. The first type, Type A, is a
first-time applicant requesting fee waiver or reduction. The second
type, Type B, is an application requesting another fee waiver or
reduction within the same maintenance fee billing cycle. The third type,
Type C, is from an applicant who has applied for a fee waiver in a prior
maintenance fee billing cycle but not in the current cycle. EPA assumes
that the respondent burden and cost for the Type B application is the
lowest because Type B applicants will only need to certify that there
have been no changes to the information previously submitted or, in the
alternative, only provide documentation with respect to those elements
that have changed. Type C applications, on the other hand, will need to
submit all the documentation supporting the waiver request, providing
updated financial and employee information. EPA assumes, however, that
the cost and burden on most Type C applicants will be less than first
time applicants because applicants will already be familiar with the
waiver requirements and, in many cases, should have a portion of the
supporting financial and business affiliation documentation readily
available. The cost and burden on the Type A applicants will be the same
as those for the first-year applicants. EPA assumes that every new
applicant seeking a waiver of the registration service fee will want to
familiarize him/herself with the criteria from the outset, thus this
burden is considered a one-time burden that will occur the first time
the applicant submits a registration application under the PRIA.

Based on the number of waiver requests EPA received during the first
full year of PRIA, the maintenance billing cycle for 2005, EPA estimates
that 31% (121 out of 389) will be the first-time applicants (Type A)r,
57% (223 out of 389) to be the Type B applications, and 12% (45 out of
389) will be Type C applications each year.

**6(b) Estimating Respondent Costs**

EPA expects that applicants will incur minor expenses that are not
directly related to paperwork activities, such as the costs of producing
photocopies and postage costs. EPA estimates that these costs will
average about \$10 per applicant and has factored these costs into the
estimated total cost figures. Annual respondent burden and costs could
vary with such factors as business structure of waiver applicants and
types of information submitted. Therefore, the actual respondent burden
and costs to a respondent could be higher or lower than the estimated
respondent burden and costs below.

**Table 1: Annual Respondent Burden and Cost Estimates (Type A)\***

+--------------------------+--------+-------+------+--------+--------+
| COLLECTION ACTIVITY      | **     |       |      | **T    |        |
|                          | Burden |       |      | otal** |        |
|                          | Hours  |       |      |        |        |
|                          | (per   |       |      |        |        |
|                          | y      |       |      |        |        |
|                          | ear)** |       |      |        |        |
+--------------------------+--------+-------+------+--------+--------+
|                          | Mgmt.  | Tech. | C    | Hours  | Costs  |
|                          |        |       | ler. |        | (\$)   |
|                          | \$100  | \$64. |      |        |        |
|                          | .86/hr | 80/hr | \$   |        |        |
|                          |        |       | 33.0 |        |        |
|                          |        |       | 5/hr |        |        |
+--------------------------+--------+-------+------+--------+--------+
| Read regulation and plan | 7      | 0     | 0    | 7      | 706    |
| activities               |        |       |      |        |        |
+--------------------------+--------+-------+------+--------+--------+
| Generate materials for   | 0      | 24    | 0    | 24     | 1,555  |
| waiver request for       |        |       |      |        |        |
| submission to EPA        |        |       |      |        |        |
+--------------------------+--------+-------+------+--------+--------+
| Store/maintain/submit    | 0      | 0     | 6    | 6      | 198    |
| and produce information  |        |       |      |        |        |
+--------------------------+--------+-------+------+--------+--------+
| Totals                   | 7      | 24    | 6    | 37     | 2,460  |
+--------------------------+--------+-------+------+--------+--------+

\* All totals have been rounded to the nearest dollar or hour after all
computations were made; in 2006 dollars

PAPERWORK BURDEN:

37 hours/response x 121 responses = 4,477 total hours

\$2,460/response x 121 responses = \$297,602

NON-PAPERWORK COSTS:

\$10 (postage and paper copies) x 121 responses = \$1,210

TOTAL ANNUAL RESPONDENT BURDEN (TYPE A):

\$297,602 (paperwork) + \$1,210 (non-paperwork) = \$298,812

**Table 2: Annual Respondent Burden and Cost Estimates (Type B)\***

+--------------------------+--------+-------+--------+-------+--------+
| COLLECTION ACTIVITY      | **     |       |        | **To  |        |
|                          | Burden |       |        | tal** |        |
|                          | Hours  |       |        |       |        |
|                          | (per   |       |        |       |        |
|                          | y      |       |        |       |        |
|                          | ear)** |       |        |       |        |
+--------------------------+--------+-------+--------+-------+--------+
|                          | Mgmt.  | Tech. | Cler.  | Hours | Costs  |
|                          |        |       |        |       | (\$)   |
|                          | \$100  | \$64. | \$33   |       |        |
|                          | .86/hr | 80/hr | .05/hr |       |        |
+--------------------------+--------+-------+--------+-------+--------+
| Read regulation and plan | 2      | 0     | 0      | 2     | 202    |
| activities               |        |       |        |       |        |
+--------------------------+--------+-------+--------+-------+--------+
| Generate materials for   | 0      | 4     | 0      | 4     | 259    |
| waiver request for       |        |       |        |       |        |
| submission to EPA        |        |       |        |       |        |
+--------------------------+--------+-------+--------+-------+--------+
| Store/maintain/submit    | 0      | 0     | 6      | 6     | 198    |
| and produce information  |        |       |        |       |        |
+--------------------------+--------+-------+--------+-------+--------+
| Totals                   | 2      | 4     | 6      | 12    | 659    |
+--------------------------+--------+-------+--------+-------+--------+

\* All totals have been rounded to the nearest dollar or hour after all
computations were made; in 2006 dollars.

PAPERWORK BURDEN:

12 hours/response x 223 responses = 2,676 total hours

\$659/response x 223 responses = \$147,006

NON-PAPERWORK COSTS:

\$10 (postage and paper copies) x 223 responses = \$2,230

TOTAL ANNUAL RESPONDENT BURDEN (TYPE B):

\$147,006 (paperwork) + \$2,230 (non-paperwork) = \$149,239

**Table 3: Annual Respondent Burden and Cost Estimates (Type C)\***

+--------------------------+-------+-------+-------+--------+--------+
| COLLECTION ACTIVITY      | **B   |       |       | **T    |        |
|                          | urden |       |       | otal** |        |
|                          | Hours |       |       |        |        |
|                          | (per  |       |       |        |        |
|                          | ye    |       |       |        |        |
|                          | ar)** |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
|                          | Mgmt. | Tech. | Cler. | Hours  | Costs  |
|                          |       |       |       |        | (\$)   |
|                          | \     | \$64. | \$33. |        |        |
|                          | $100. | 80/hr | 05/hr |        |        |
|                          | 86/hr |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
| Read regulation and plan | 2     | 0     | 0     | 2      | 202    |
| activities               |       |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
| Generate materials for   | 0     | 19    | 0     | 19     | 1231   |
| waiver request for       |       |       |       |        |        |
| submission to EPA        |       |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
| Store/maintain/submit    | 0     | 0     | 6     | 6      | 198    |
| and produce information  |       |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
| Totals                   | 2     | 19    | 6     | 27     | 1631   |
+--------------------------+-------+-------+-------+--------+--------+

\* All totals have been rounded to the nearest dollar or hour after all
computations were made; in 2006 dollars.

PAPERWORK BURDEN:

27 hours/response x 45 responses = 1,215 total hours

\$1631/response x 45 responses = \$73,405

NON-PAPERWORK COSTS:

\$10 (postage and paper copies) x 45 responses = \$450

TOTAL ANNUAL RESPONDENT BURDEN (TYPE C):

\$73,405(paperwork) + \$450 (non-paperwork) = \$73,855

**6(c) Estimating Agency Burden and Cost**

The Agency's burden consists of reviewing, evaluating, and notifying
applicants of the Agency's decision to grant or deny fee waiver
requests; entering data into tracking systems; verifying fee payment;
and storing/maintaining this information. The table below estimates
EPA's burden for performing these activities.

**TABLE 4: Annual Agency Burden and Cost Estimates\***

+--------------------------+-------+-------+-------+--------+--------+
| COLLECTION ACTIVITY      | **B   |       |       | **T    |        |
|                          | urden |       |       | otal** |        |
|                          | Hours |       |       |        |        |
|                          | (per  |       |       |        |        |
|                          | ye    |       |       |        |        |
|                          | ar)** |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
|                          | Mgmt. | Tech. | Cler. | Hours  | Costs  |
|                          |       |       |       |        | (\$)   |
|                          | \$93. | \$66. | \$47. |        |        |
|                          | 07/hr | 34/hr | 17/hr |        |        |
+--------------------------+-------+-------+-------+--------+--------+
| Review submitted waiver  | 1     | 20    | 2     | 23     | 1,1514 |
| request and notify       |       |       |       |        |        |
| requestor of decision    |       |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
| Enter data into tracking | 0     | 0     | 0.5   | 0.5    | 24     |
| systems                  |       |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
| Verify payment           | 0     | 0     | 0.5   | 0.5    | 24     |
+--------------------------+-------+-------+-------+--------+--------+
| Store/maintain/submit    | 0     | 0     | 1     | 1      | 48     |
| information              |       |       |       |        |        |
+--------------------------+-------+-------+-------+--------+--------+
| Totals                   | 1     | 20    | 4     | 25     | 1,610  |
+--------------------------+-------+-------+-------+--------+--------+

\* All totals have been rounded to the nearest dollar or hour after all
computations were made; in 2006 dollars.

ANNUAL BURDEN: 25 hours/response x 389 responses = 9,725 Hours

ANNUAL COSTS: \$1610/response x 389 responses = \$626,290

**6(d) Bottom Line Burden Hour and Cost Tables**

**Table 5: Total Annual Burden and Cost Estimates**

+-------------------------+---------------------+---------------------+
|                         | TOTAL ESTIMATES     |                     |
+-------------------------+---------------------+---------------------+
|                         | Hours               | Costs               |
+-------------------------+---------------------+---------------------+
| Applicant -Annual       | 8,368               | \$521,903           |
|                         |                     |                     |
| (Type A + Type B + Type |                     |                     |
| C)                      |                     |                     |
+-------------------------+---------------------+---------------------+
| Type A                  | 4,477               | \$298,812           |
+-------------------------+---------------------+---------------------+
| Type B                  | 2,676               | \$149,236           |
+-------------------------+---------------------+---------------------+
| Type C                  | 1,215               | \$73,855            |
+-------------------------+---------------------+---------------------+
| Agency - Annual         | 9,725               | \$626,290           |
+-------------------------+---------------------+---------------------+

**6(e) Reasons For Changes In Burden**

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 37, 12, and 27 hours per
response, for the three different types of applications. The program is
just two years old and the Agency and respondents are learning to
streamline the process. Labor rates for both respondents and Agency
personnel in this ICR have decreased. The burden hour breakdown remains
unchanged from the last renewal period. In previous renewal cycles, the
Agency only adjusted the labor rates to account for inflation. However,
for this renewal, Agency economists have completely re-estimated labor
rates, benefits and overhead costs for both respondents Agency
personnel. This Agency analysis was completed in July 2006, see
Attachment E. The Agency believes this is a more realistic estimate of
the average respondent and Agency costs. As a result, there is a
decrease of \$209,469 in the estimated total annual respondent cost
(from \$728,372 to \$521,903). This change is an adjustment.

**6(f) Burden Statement**

According to the PRIA, "burden" means the total time, effort, or
financial resources expended by persons to generate, maintain, retain,
or disclose or provide information to or for a Federal agency. For this
collection it includes the time needed to read the new regulation,
review instructions, plan activities, assemble pertinent materials, and
transmit or otherwise disclose the information. An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information that is subject to the PRIA unless the Agency
displays a currently valid OMB control number. The OMB control numbers
for EPA\'s regulations in title 40 of the CFR, after initial display in
the final rule, are listed in 40 CFR part 9. Since the collection
activity in this ICR are contained in the PRIA and not a current
regulation, the OMB control number for this collection activity appears
in this ICR.

To comment on the Agency\'s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques.
All documents in the docket are listed in the docket index. Although
listed in the index, some information is not publicly available, e.g.,
CBI or other information whose disclosure is restricted by statute.
Certain other material, such as copyrighted material, is not placed on
the Internet and will be publicly available only in hard copy form. EPA
has established a public docket for this ICR under Docket ID No.
EPA-HQ-OPP-2006-0036, Publicly available docket materials are available
either in the electronic docket at
[*http://www.regulations.gov*](http://www.regulations.gov/), or, if only
available in hard copy, at the OPP Regulatory Public Docket in Rm.
S-4400, One Potomac Yard (South Building), 2777 S. Crystal Drive,
Arlington, VA. The hours of operation of this Docket Facility are from
8:30 a.m. to 4 p.m., Monday through Friday, excluding legal holidays.
The Docket telephone number is (703) 305-5805.

Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Officer for EPA. Please include
the EPA Docket ID No. EPA -HQ-OPP-2006-0636 and OMB Control No.
2070-0167 in any correspondence.

**ATTACHMENTS TO THE SUPPORTING STATEMENT:**

**Attachment A Pesticide Registration Improvement Act of 2003** --
Available electronically at
<http://www.epa.gov/pesticides/regulating/fees/index.htm> and in the
docket for this information collection activity.

**Attachment B Implementing the Pesticide Registration Improvement Act
-- Fiscal Year 2005**. Available electronically at
<http://www.epa.gov/pesticides/regulating/fees/pria_annual_report_2005.htm>.

**Attachment C Electronic Data Submission and Review Efforts** -
Available electronically at
<http://www.epa.gov/oppfead1/eds/edsgoals.htm>.

**Attachment D Categories of Registration Requiring Fees under the
PRIA** -- Available in the docket for this information collection
activity.

**Attachment E** **Methodology for Estimating OPP ICR Wage Rates for
Industry, State and EPA Labor Costs**; Memo From Richard Keigwin,
Director Biological and Economic Analysis Division, to Bill Diamond,
Arnold Layne, Lois Rossi and Elizabeth Leovey July 25, 2006. Available
in the docket for this information collection activity.