Attachment D 

Renewal Consultations -- List of Representatives 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.com
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Sample Consultation Questions OPP ICR Renewals 

EPA Questions asked in Consultation 

(1) Publicly Available Data 

$ Is the data that the Agency seeks available 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 indicate that certain data elements are available, but 

that they don=t meet our data needs very well?) 

(2) Frequency of Collection 

$ Can the Agency collect the information less frequently and still produce the same 

outcome? 

(3) Clarity of Instructions 

$ The ICR is intended to require that respondents provide certain data so that the 

Agency can utilize them. 

$ Based on the instructions (regulations, PR Notices, etc.), is it clear what you are 

required to do and how to submit such data? If not, what suggestions do you have 

to clarify the instructions? 

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

$ Considering that there is no required submission format, is it difficult to submit 

information in ways that are clear, logical and easy to complete? 

$ Are there forms associated with this process? 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 alternatives to paper-based submissions 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 alternatives to paper-based records and data 

submissions? Current electronic reporting 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 electronically? If yes, in what format? 
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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 submission bring you in terms of burden reduction 

or greater efficiency in compiling 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 for 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 accounted for that may have been missed?