EPA I CR No. 2415.01 OMB Control No. 2070

- XXXX **ATTACHMENT F**  **New ICR Consultations**  **- List of Representatives, Questions Posed, and Responses** 
**List of Representatives Consulted** Lonnie E. Anderson Terminix International landerson@terminix.com Joellen M. Lampman Audubon International jlampman@auduboninternational.org Bob Rosenberg National Pest Management Association Rosenberg@pestworld.org

**I. Sample Consultations Questions for OPP ICR Renewals**  **EPA Questions Asked in Consultation Regarding ICR the Document** (1) Publicly

Available Data $ Is the data that the Agency seeks available from any public source, or already collected b y another office at EPA or b y 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 I CR 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 yo u are required to do and how to submit such data? I f not, what sugges tions do you have to clarify the instructions? $ Do y ou understand that you are required to maintain records? $ Considering that there is no required submission format, is it difficult to submit information in way s that are clear, logical and easy to comp lete? $ Are there forms associated with this process? Do you use them? Are they clear, logical, and eas y 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 Int ernet. $ What do you think about electronic alternatives to paper

- based records and data submissions? Current electronic reporting alternatives include the use of web forms @ /XMLbased 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? $ w ould you be more inclined to submit CBIon 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 wi th this I CR, 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 estimatesthat are substantiall y different from EPA’s, please provi de an explanation of how yo u arrived at your estimates. $ Are there other costs that should be accounted for that may have been missed?

**II. Consultations Responses**  **Response 1 EPA/OPP ICR** 

**– P**  **e st**  **i c**  **ide E**  **nvironme n**  **tal S**  **te wa**  **rdship P**  **rog ra**  **m A**  **n nu**  **a l Me**  **a sur**  **e s**  **R e**  **porting**
OMB No: 2070

- XXXX ; EPA No: 2415.01 **Contact Information** Lonnie E. Anderson Terminix International landerson@terminix.com **Questions and responses regarding ICR document** (1) Publicly Available Data $ Is the data that the Agency seeks available from any public source, or already collected b y another office at EPA or b y another agency ? **NO** $ 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 ve ry well?) (2) Frequency of Collection $ Can the Agency

collect the information less frequently and still produce the same outcome? **NO** (3) Clarity of Instructions $ The I CR 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 yo u are required to do and how to submit such data? **YES** If not, what su ggestions do y ou have to clarify

the instructions?$ Do y ou understand that you are required to maintain records? **YES**

$ Considering that there is no required submission format, is it difficult to submit information in way s that are clear, logical and easy t o complete? **NOT IF WE COLLECT THE DATA IN THE FIRST PLACE**  $ Are there forms associated with this process? Do you use them? Are they clear, logical, and eas y 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 en sure 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 @ /XMLbased submission s 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? **YES** $ Are you keeping your records electronically? If yes, in what format? **YES** Although the Agency does not offer an electronic reporting option because of CBI

- related security concerns at this time, $ would y ou be more inclined to submit CBIon diskette (CD or DVD) than on paper? **YES** $ what benefits would electronic submission bring you in terms of burden reduction or greater efficiency

in compiling the information? **FEWER LABOR HOURS** (5) Burden and Costs $ Are the labor rates accurate? **LABOR RATES ARE LOW** $ The Agency

assumes there is no capital cost associated with this activity . Is that correct? **NO**

**– SOFTWARE DEVELOPMENT AND IMPLEMENTATION**  **MAY BE REQUIRED. There are data being requested that we cannot produce at this time. To add those data fields to our**  **system would probably cost somewhere around $10,000 to $15,000. Excluding the cost of adding**  **additional data fields, we are probably talking about $1,000.00 to $1,500.00 in cost to completely answer all of the questions on Attachment F PESP**  **Strategy -**  **Prog ress Reporting Form.**  **Specially, the below questions are not**  **currently collected: 1.**  **The first question in the Pesticide Risk Reduction and Usage section that request information on pesticide use.**  **(Total Amount of Pesticide Applied (or purchased only if app**  **lication data is not available)) 2.**  **The fifth question in the Organizational Profile Measures section**  **that request the total num**  **ber of nonchemical treatments. This data is not captured in any easy way to produce. However, as we move forward, we**  **may be able to capture this data in the future.**  **There are other measures that we don’t currently capture however, those measure were not noted as a required reporting measure.**  $ Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the paperwork involved with this I CR, 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 est imates that are substantiall y different from EPA ’ s, please provide an explanation of how yo u arrived at your estimates. $ Are there other costs that should be accounted for that may have been missed?
**Response 2 EPA/OPP ICR** 

**– P**  **e st**  **i c**  **ide E**  **nvironme n**  **tal S**  **te wa**  **rdship P**  **rog ra**  **m A**  **n nu**  **a l Me**  **a sur**  **e s**  **R e**  **porting**
OMB No: 2070

- XXXX ; EPA No: 2415.01 **Contact information** Joellen M. Lampman Audubon International jlampman@auduboninternational.org **Questions and responses**  **regarding the ICR document** (1) Publicly

Available Data

• Is the data that the Agency seeks available from any public source, or already collected b y another office at EPA or b y another agency ? No• If yes, where can you find the data? (Does yo ur 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 sti ll produce the same outcome? No, since pest burdens are dependent upon so many volatile factors including, but not limited to, weather, new pest species, and the price of fuel/fertilizer/water. (3) Clarity

of Instructions

• The I CR 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 yo u are required to do and how to submit such data? I f not, what sugges tions do you have to clarify the instructions? Yes

• Do y ou understand that you are required to maintain records? Yes

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

information in way s that are clear, logical and easy to complete? No

• Are there forms associated with this process? Do you use them? Are they clear, logical, and eas y to complete? Yes/Yes/Yes (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 submissi ons? Current electronic reporting alternatives include the use of web forms @ /XMLbased 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?Yes

• Are you keeping your records electronically? If yes, in what format?

Yes. We have a database that can converted to Excel spreadsheets. Although the Agency

does not offer an electronic reporting option because of CBI

- related securit y concerns at this time,

• would y ou be more inclined to submit CBIon diskette (CD or DVD) than on paper? Yes

• what benefits would electronic submission bring you in terms of burden reduction

or greater efficiency

in compiling the information? There is the possibility

that Icould set up our database to dump information directly into an electronic form. (5) Burden and Costs

• Are the labor rates accurate? I cannot determine this at this time.

• The Agency

assumes there is no capital cost associated with this activity . Is that correct? Yes

• Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the paperwork involved with this I CR, 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 substantiall y different from EPA’s, please provide an explanation of how yo u arrived at your estimates. I cannot determine this at this time.

• Are there other costs that should be accounted for that may have been missed? I do not believe so.**Response 3**

**EPA/OPP ICR**

**– P**  **e st**  **i c**  **ide E**  **nvironme n**  **tal S**  **te wa**  **rdship P**  **rog ra**  **m A**  **n nu**  **a l Me**  **a sur**  **e s**  **R e**  **porting**
OMB No: 2070

- XXXX ; EPA No: 2415.01 **Contact Information** Bob Rosenberg National Pest Management Association Rosenberg@pestworld.org **Questions and responses regarding the ICR document** (1) Publicly Available Data $ Is the data that the Agency seeks available from any public source, or already collected b y another office at EPA or b y another agency ? No $ 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 me et our data needs very well?) N/A (2) Frequency of Collection $ Can the Agency

collect the information less frequently and still produce the same outcome? No (3) Clarity of Instructions $ The I CR is intended to require that respondents provide certain data so that the Agency can utilize them. Yes $ Based on the instructions (regulations, PR Notices, etc.), is it clear what yo u are required to do and how to submit such data? I f not, what suggestions do you have to clarify the instructions? Yes $ Do y ou understand that you are required to maintain records? Yes $ Considering that there is no required submission format, is it difficult to submit information in way s that are clear, logical and easy to complete? N/A $ Are there forms associated with this process? Do you use them? Are they clear, logical, and eas y t o complete? Yes(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? Curr ent electronic reporting alternatives include the use of web forms @ /XMLbased 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? Yes $ Are you keeping your records electronically? If yes, in what format? No Although the Agency does not offer an electronic reporting option because of CBI

- related security concerns at this time, $ would y ou be more inclined to submit CBIon diskette (CD or DVD) than on paper? Yes $ what benefits would electronic submission bring you in terms of burden reduction or greater efficiency

in compiling the information? Easier to compile and less costly. (5) Burden and Costs $ Are the labor rates accurate? Not sure $ The Agency

assumes there is no capital cost associated with this activity . Is that correct? That is correct. $ Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the paperwork involved with this I CR, 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 substantiall y different from EPA ’ s, please provide an explanation of how yo u arrived at your estimates. We think the numbers may be high. $ Are there other costs that should be accounted for that may have been missed? No