1 **Consultation Questions Regarding an Information Collection Activity: Notice of Supplemental Distribution of a Registered Pesticide Product** 

**U.S. Environmental Protection Agency Distributor Company**  **Representative (s)**  **Consulted** Name : Jeffery Jones Company Represented : USDA APHI S WS Contact Information (email and mailing) : jeffery .w.jones@aphis.usda.gov 4700 River Road, Unit 87 Riverdale, MD 20737 **Questionnaire** (1) Publicly

Available Data
• Are the data that the Agency seeks available from any public source, or already collected by another office at EPA or by 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 very

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? I f not, what suggestions do y ou have to clarify the instructions? Yes . • Do y ou understand that you are required to maintain records? Yes .2

• Are there forms associated with this process? D o you use them? Are they clear, logical, and eas y to 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 s uch reason is that, at the present time, the Agency is unable to ensure the securit y of CBI that might be transmitted over the Internet.
• What do y ou think about electronic alternatives to paper - based records and data submissions? Current electronic repor ting 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, however, USDA APHIS has not y et provided guidance on electronic signature authority . • Are you keeping your records electronically? No. If yes, in what format?
• Although the Agency does not offer an electronic reporting option because of CBI - related securit y concerns at this time, would you be more inclined to submit CBIon diskette (CD or DVD) than on paper? NA . • What benefits would electronic submission bring you in terms of burden reduction or greater efficiency

in compiling the information? Compliance with records manage ment sy stem. (5) Burden and Costs
• Are the labor rates accurate? Yes . • 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 p aperwork involved with this ICR ( e.g., the IC R does not include estimated burden hours and costs for conducting studies), are the estimated burden hours and labor rates accurate? Yes . I f you provide burden and cost estimates th at are substantially

different from EPA ’ s, please provide an explanation of how y ou arrived at yo ur estimates.
• Are there other costs that should be accounted for that may have been missed? No.3

**Distributor Company Representative**  **(s) Consulted**  Name : Kent Drake Company Represented : Wyoming Department of Agriculture Contact Information (email and mailing) : kent.drake@wyo.gov 6607 Campstool Road Chey enne, WY 82002 **Questionnaire** (1) Publicly

Available Data
• Are the data that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency ? alread y collected
• 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?) My

office files (2) Frequency

of Collection
• Can the Agency

collect the information less frequently and still produce the same outcome? ye s (3) C larity

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 suggestions do you have to clarify the instructions? ye s
• Do y ou understand that you are required to maintain records? yes
• Are there forms associated with this process? Do you use them? Are they clear, logical, and eas y to comp lete? ye s, y es, ye s (4) Electronic Reporting and Record keeping4

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 securit y of CBI that might be transmitted over the Internet.
• What do y ou think about electronic alternatives to paper - based records and data submiss ions? 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? no
• Although the Agency does not offer an electronic reporting option because of CBI - related securit y concerns at this time, would you be more inclined to submit CBI on diskette (CD or DVD) than on paper? no
• What benefits would electronic submission bring you in terms of burden reduction or greater efficiency

in compiling the information? less postage costs, less paper, greater storage efficiency (5) Burden and Costs
• Are the labor rates accurate? ye s
• The Agency

assumes there is no capital cost associated with this activity . Is that correct? ye s
• Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the p aperwork involved with this ICR ( e.g., the IC R 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. yes
• Are there other costs that should be accounted for that may have been missed? no