Attachment D

Renewal Consultations -- List of Re presentatives and Questions Posed

List of Representatives Consulted

Dr. Russell P. Schneider Monsanto Company russell.p.schneider@monsanto.com

202-383-2866

Dr. Wendelyn Jones Greg Watson Syngenta Biotechnology, Inc wendelyn.jones@syngenta.com greg.watson@syngenta.com

James Barron Bayer Crop Science jim.barron@bayercropscience.com

Amy Roberts Technology Science Group, Inc. aroberts@tsgusa.com

Frederick Smith SciReg, Inc fsmith@scireg.com

Dr. Thomas Bade

Valent Biosciences

thomas.bade@valentbiosciences.com1 Sample Consultation Questions OPP ICR Renewals

EPA Questions asked in Consultation

(1) Publicly Available Data

$ Is the data that the Agency seeks ava ilable from any public source, or already collected by another office at EPA or by another agency?

$ If yes, where can you find the data? (Does your answer indicate a true duplication, or does the input i ndicate that certain data el ements are available, but that they don = t meet our data need s very well?)

(2) Frequency of Collection

$ Can the Agency collect the information le ss frequently and still produce the same

outcome?

(3) Clarity of Instructions

$ The ICR is intended to requi re that respondents provide certain data so that the Agency can utilize them.

$ Based on the instructions (regu lations, PR Notices, etc.), is it clear what you are required to do and how to submit such da ta? If not, what sugg estions do you have to clarify the instructions?

$ Do you understand that you are required to maintain records?

$ Considering that there is no required s ubmission format, is it difficult to submit information in ways that are clear, logical and easy to complete?

$ Are there forms associated with this pro cess? Do you use them? Are they clear, logical, and easy to complete?

(4) Electronic Reporting and Record keeping

The Government Paperwork Elimination Act requires agencies make available to the public electronic reporting alte rnatives to paper-based s ubmissions by 2003, unless there is a strong reason for not doing so. One such reason is that, at the present time, the Agency is unable to ensure the security of CBI that might be transmitted over the

Internet.

$ What do you think about electronic alternat ives to paper-based records and data submissions? Current electronic reporti ng alternatives include the use of web

forms @ /XML based submissions via the Agency’s Internet site and magnetic media-based submissions, e.g., diskette, CD-ROM, etc. Would you be interested in pursuing electronic reporting?

$ Are you keeping your records electronical ly? If yes, in what format?2 Although the Agency does not offer an electronic reporting option because of CBI-related security concerns at this time,

$ would you be more inclined to submit CBI on diskette (CD or DVD) than on paper?

$ what benefits would electronic submissi on bring you in terms of burden reduction or greater efficiency in co mpiling the information?

(5) Burden and Costs

$ Are the labor rates accurate?

$ The Agency assumes there is no capital cost associated with this activity. Is that

correct?

$ Bearing in mind that the burden and cost estimates include only burden hours and

costs associated with the paperwork involved with this ICR, e.g., the ICR does not

include estimated burden hours and costs fo r conducting studies, are the estimated

burden hours and labor rates accurate? If you provide burden and cost estimates that are substantially different from EPA’ s, please provide an explanation of how you arrived at your estimates.

$ Are there other costs that should be acc ounted for that may have been missed?