Consultation Process: Responses to Standard Questions 

Ann Nasr/Jeff Jones 

U.S. Department of Agriculture 

Animal and Plant Health Inspection Service 

Questions: 

1. The ICR (Information Collection Request) is intended to require that respondents 

provide certain data so that the Agency can utilize them. Based on the instructions, is it 

clear to respondents what they are required to do and how to submit such data? If not, 

what suggestions do you have to clarify the instructions? 

Yes, the ICR instructions are clear. 

2. Do respondents understand what they are required to submit or maintain in their 

records? Is the reporting form clear, logical, and easy to complete? 

 Yes. APHIS WS reports submitted to EPA regarding 1080 LPC use summarize the 

following pertinent data: application sites, application dates, number of collars applied, 

number of collar nights, number of lost and damaged collars, number of confirmed or 

suspected coyotes killed, adverse incidents pertaining to human health or safety, or 

confirmed poisoning of nontarget species. 

3. 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. If the Agency were able to ensure the security of CBI 

that might be transmitted over the Internet and the reporting form could be completed 

electronically, would you be interested in submitting it electronically? 

Yes; however, USDA APHIS has not yet provided guidance on electronic signature 

authority. 

Current electronic reporting alternatives include the use of “web forms”/XML based 

submissions via the Agency’s internet site and magnetic media-based submissions (i.e., 

on diskette, CD-ROM, etc.) Are you interested in using, or are they currently utilizing, 

electronic reporting/record-keeping options? 

No.

4. Where a reporting requirement includes a signature requirement, consider whether a 

secure electronic signature method (such as Private Key Infrastructure) should be 

required if submitting electronically; whether a less secure method (such as the use of 

APHIS_Consultations Response_1249.09_01072010 (2 pages)
PINs and passwords) would be more appropriate; or, whether a signed cover sheet may 

be sufficient for the Agency’s purposes when data is submitted on disk. 

No. APHIS WS will not be submitting electronically for the present time (until or unless 

electronic signature authority is granted). 

5. If you prefer one method to another, does your choice balance burdens and costs 

against electronic data and signature security integrity? 

Preference for the “paper” choice is based on not having electronic signature authority. If 

and when granted, APHIS WS is willing to submit the information requested 

electronically. 

6. If an electronic reporting option is not offered because of CBI-related concerns, would 

you be more inclined to submit CBI on diskette than on paper? What benefits would you 

realize? (Burden reduction? Greater efficiency in compiling the information?). 

NA 

7. The labor rates included in the Agency’s estimated burden hours and costs are a U.S. 

average that includes costs for overhead and benefits. These estimates include only 

burden hours and costs associated with the paperwork involved with this ICR (i.e., the 

Agency does not include estimated burden hours and costs for usual and customary 

business practices such as R&D, marketing, etc.). Are the estimated burden hours and 

labor rates accurate? 

There is a need to add Cost of Living costs (2-3percent /year) to each year, since the last 

report on this information. 

8. Are there other costs that should be accounted for that may have been missed, such as 

capital/start-up/M&O expenditures? If so, please provide an explanation of how you 

arrived at your estimate of burden and cost if substantially different than EPA’s estimate. 

No. 

APHIS_Consultations Response_1249.09_01072010 (2 pages)
1

Consultation Process: Responses to Standard Questions 

Kent Drake 

Wyoming Department of Agriculture 

[from telephone interview by W. Jacobs, 1/19/2010] 

Questions: 

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

Agency can utilize them. Based on the instructions, is it clear to respondents what they 

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

clarify the instructions? 

“Yes” 

2. Do respondents understand what they are required to submit or maintain in their 

records? Is the reporting form clear, logical, and easy to complete? 

“Yes” 

3. 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. If the Agency were able to ensure the security of CBI 

that might be transmitted over the Internet and the reporting form could be completed 

electronically, would you be interested in submitting it electronically? 

“Yes” 

Current electronic reporting alternatives include the use of “web forms”/XML based 

submissions via the Agency’s internet site and magnetic media-based submissions (i.e., 

on diskette, CD-ROM, etc.) Are you interested in using, or are they currently utilizing, 

electronic reporting/record-keeping options? 

“Yes” 

4. Where a reporting requirement includes a signature requirement, consider whether a 

secure electronic signature method (such as Private Key Infrastructure) should be 

required if submitting electronically; whether a less secure method (such as the use of 

PINs and passwords) would be more appropriate; or, whether a signed cover sheet may 

be sufficient for the Agency’s purposes when data is submitted on disk. 

Mr. Kent indicated that a signed cover sheet was sufficient. 

WDA_Consultations Response_1249.09_0119020 (2 pages)
2

Kent Interview (cont.) 

5. If you prefer one method to another, does your choice balance burdens and costs 

against electronic data and signature security integrity? 

“Yes” 

6. If an electronic reporting option is not offered because of CBI-related concerns, would 

you be more inclined to submit CBI on diskette than on paper? What benefits would you 

realize? (Burden reduction? Greater efficiency in compiling the information?). 

Mr. Kent would prefer to make a CD submission, other things being equal (irradiation of 

mail can damage diskettes). 

7. The labor rates included in the Agency’s estimated burden hours and costs are a U.S. 

average that includes costs for overhead and benefits. These estimates include only 

burden hours and costs associated with the paperwork involved with this ICR (i.e., the 

Agency does not include estimated burden hours and costs for usual and customary 

business practices such as R&D, marketing, etc.). Are the estimated burden hours and 

labor rates accurate? 

Mr. Kent said he thought that the labor rates were “about right” and “adequate”. 

8. Are there other costs that should be accounted for that may have been missed, such as 

capital/start-up/M&O expenditures? If so, please provide an explanation of how you 

arrived at your estimate of burden and cost if substantially different than EPA’s estimate. 

Mr. Kent said that did not think so. 

WDA_Consultations Response_1249.09_0119020 (2 pages)