July
28.
2006
SUPPORTING
STATEMENT
FOR
AN
INFORMATION
COLLECTION
REQUEST
(
ICR)

1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection:
Pesticide
Registration
Fee
Waivers
OMB
Control
No.:
2070­
0167
EPA
ICR
No.:
2147.03
1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
is
a
proposed
renewal
of
an
existing
ICR
that
is
currently
approved
by
OMB
and
is
due
to
expire
December
31,
2007.
This
information
collection
will
allow
the
Environmental
Protection
Agency
(
EPA)
to
process
requests
for
waivers
of
fees
under
the
Pesticide
Registration
Improvement
Act
of
2003
(
PRIA).
The
ICR
covers
the
collection
activities
associated
with
requesting
a
fee
waiver
and
involves
requesters
submitting
a
waiver
request,
information
to
demonstrate
eligibility
for
the
waiver,
and
certification
of
eligibility.
Waivers
are
available
for
small
businesses,
for
minor
uses,
and
for
actions
solely
associated
with
the
Inter­
Regional
Research
Project
Number
4
(
IR­
4).
State
and
federal
agencies
are
exempt
from
the
payment
of
fees.
This
ICR
provides
burden
hour
and
labor
cost
estimates
for
both
applicants
for
fee
waivers
and
EPA
employees
who
process
and
approve
or
deny
waiver
requests.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Under
the
Federal
Insecticide,
Fungicide
and
Rodenticide
Act
(
FIFRA),
EPA
must
evaluate
pesticides
thoroughly,
before
they
can
be
marketed
and
used
in
the
United
States,
to
ensure
that
they
will
not
pose
unreasonable
adverse
effects
to
human
health
and
the
environment.
Pesticides
that
meet
this
test
are
granted
a
license
or
"
registration"
which
permits
their
distribution,
sale
and
use
according
to
requirements
set
by
EPA
to
protect
human
health
and
the
environment.

The
PRIA
amended
FIFRA
to
provide
for
the
collection
of
fees
in
order
to
enhance
the
review
of
covered
pesticide
products
(
see
Attachment
A)
.
Fees
collected
under
this
program
will
help
to
reduce
time
frames
for
registration
decisions;
provide
greater
predictability
and
more
accountability
for
those
decisions;
ensure
that
Food
Quality
Protection
Act
(
FQPA)
deadlines
are
met;
and
result
in
more
predictable
and
augmented
funding
for
the
pesticide
program.
The
program
provides
stability
in
funding
for
EPA's
Office
of
Pesticide
Programs
(
OPP)
over
five
years.
The
program's
fee
schedule
under
PRIA
will
be
phased
out
beginning
on
October
1,
2008,
and
ending
on
September
30,
2010.
As
indicated
above,
the
PRIA
also
established
provisions
that
allow
these
fees
to
be
reduced
or
waived
entirely.

A
registration
applicant
may
seek
a
waiver
as
a
small
business,
defined
by
the
PRIA
as
a
business
with
fewer
than
500
employees
and
on
average,
annual
global
gross
revenue
from
2
pesticides
of
no
more
than
$
60
million
over
the
most
recent
three­
year
maintenance
fee
billing
cycle.
For
a
business
entity
with
one
or
more
affiliates,
the
gross
revenue
limit
includes
total
global
revenues
from
pesticides
for
the
entity
and
all
of
its
affiliates,
including
parent
and
subsidiary
entities.

A
registration
applicant
qualifying
as
a
small
businesses
under
the
PRIA
will
be
entitled
to
a
waiver
of
fifty
percent
(
50%)
of
its
fees.
In
addition,
all
fees
will
be
waived
for
small
businesses
with,
on
average,
annual
gross
global
revenues
from
pesticides
over
the
most
recent
three­
year
maintenance
fee
billing
cycle,
including
affiliates,
of
no
more
than
$
10
million.
Small
business
applicants
requesting
waivers
must
provide
EPA
with
appropriate
documentation
demonstrating
that
they
meet
these
criteria.

A
registration
applicant
may
also
request
a
minor
use
waiver
or
fee
reduction
if
the
applicant
can
demonstrate
that
anticipated
revenues
from
the
uses
described
in
the
registration
application
would
be
insufficient
to
justify
the
imposition
of
the
full
application
fee.
The
Agency
may
grant
a
full
waiver
or
a
partial
reduction
in
the
fee
based
upon
its
consideration
of
the
supporting
documentation
provided.

In
addition,
the
statute
states
that
the
Agency
shall
waive
the
registration
service
fee
for
an
application
if
the
Administrator
determines
that
two
criteria
are
met:
that
the
application
is
solely
associated
with
IR­
4
tolerance
petition
and
that
the
waiver
is
in
the
public
interest.
The
Agency
anticipates
that
most
applications
submitted
by
the
IR­
4
program
would
qualify
for
a
waiver.
Finally,
the
statute
exempts
agencies
of
the
Federal
Government
or
a
State
from
fees.

The
program
is
expected
to
generate
in
excess
of
$
10
million
in
new
registration
service
fees
annually
over
five
years
and
allows
applicants
for
pesticide
registrations
submitted
prior
to
the
effective
date
of
the
Act
to
pay
a
portion
of
the
fee
voluntarily.

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
is
the
sole
intended
user
of
the
information
collected.
This
collection
of
information
is
critical
for
the
proper
performance
of
Agency
functions
because
the
information
collected
will
allow
EPA
to
properly
review
a
request
for
a
waiver
of
fees
under
the
PRIA
without
delay.
The
actual
usefulness
of
the
information
to
the
Agency
is
that
the
information
collected
will
be
used
to
determine
if
the
applicant
qualifies
for
a
fee
waiver
or
fee
reduction.
Statutorily,
in
instances
where
the
applicant
requests
a
fee
waiver
or
fee
reduction,
the
decision
review
time
period
does
not
begin
until
either
the
Agency
grants
the
waiver
or
until
the
registrant
has
paid
the
appropriate
registration
service
fee
(
or,
in
the
case
of
a
partial
waiver
or
fee
reduction,
the
balance
of
the
appropriate
registration
service
fee).
Processing
of
the
application,
therefore,
will
be
delayed
until
the
Agency
can
render
a
decision
on
the
fee
waiver
or
fee
reduction
request.
With
the
submission
of
this
data
by
the
registrant,
the
Agency
will
be
able
to
meet
its
statutory
obligation
to
grant
or
deny
the
waiver
request
within
60
days
and,
potentially,
earlier
than
the
maximum
60
day
period.

3.
NON
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
3
CRITERIA
3(
a)
Non
duplication
No
other
federal
agency
or
EPA
program
is
collecting
fees
for
the
processing
of
applications
for
pesticide
registration
or,
therefore,
information
for
the
waiver
of
such
fees.
As
such,
this
information
collection
activity
does
not
duplicate
any
other
collection
of
information
by
the
federal
government.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Pursuant
to
5
CFR
1320.8(
d),
EPA
is
publishing
a
Federal
Register
(
FR)
notice
soliciting
comment
on
this
information
collection
activity
and
the
Agency's
intent
to
renew
the
OMB
approval
of
this
ICR.
The
FR
notice
and
the
proposed
renewal
ICR
as
well
as
any
public
comment
are
located
in
the
docket
for
this
action,
which
can
be
accessed
at
http://
www.
regulations.
gov
using
the
docket
indentifier
EPA­
HQ­
OPP­
2006­
0636.

3(
c)
Consultations
Prior
to
passage
in
2004,
the
PRIA
had
been
developed
over
a
multi­
year
period
based
upon
input
from
the
pesticide
industry,
industry
trade
associations,
public
interest
groups,
and
the
Agency.
The
legislation
that
was
introduced
into
Congress
was
based
upon
a
consensus
reached
by
stakeholders,
informed
with
technical
support
provided
by
the
Agency.
These
stakeholders
included
CropLife
America,
the
Consumer
Specialty
Products
Association,
the
Chemical
Producers
and
Distributors
Association,
the
American
Chemistry
Council,
the
Natural
Resources
Defense
Council,
and
Consumers
Union,
among
other
parties.

During
preparation
of
this
ICR
renewal,
EPA
staff
will
contact
representatives
from
a
cross­
section
of
pesticide
registrant
companies
by
e­
mail
and
telephone
to
seek
feedback
on
the
PRIA
waiver
process.
Their
responses
to
EPA's
consultation
efforts
will
be
summarized
and
made
publicly
available.

In
addition
to
these
consultation
activities,
dialogue
between
industry
and
the
Agency
on
the
PRIA
waivers
process,
content,
definitions,
format,
and
timing
is
frequent
and
on­
going.
In
addition
to
phone
conversations,
e­
mails,
and
letters,
Agency
staff
participate
in
meetings
with
individual
registrants
as
well
as
gatherings
of
large
groups
of
registrants
from
time
to
time.
These
communications
permit
an
exchange
of
issues,
problems,
and
solutions
on
many
issues.

3(
d)
Effects
of
Less
Frequent
Collection
The
PRIA
fee
waiver
program
is
still
a
new
program
(
initiated
March
2004)
and
the
Agency
and
respondents
are
still
in
the
learning
stages
of
what
constitutes
appropriate
documentation
demonstrating
their
eligibility
for
waivers.
Waivers
applications
are
submitted
and
reviewed
on
an
application­
by­
application
basis.
As
the
Agency
develops
experience
with
the
review
of
these
waiver
requests,
we
will
seek
to
identify
opportunities
for
reducing
the
frequency
of
collecting
this
information,
provided
that
such
a
reduction
will
still
allow
the
Agency
to
satisfy
4
the
statutory
requirements
of
the
PRIA.
For
example,
when
registrants
that
have
been
granted
a
small
business
waiver
submit
a
subsequent
small
business
request
in
the
same
maintenance
fee
billing
cycle,
they
may
incorporate
by
reference
the
previously
submitted
documentation
to
the
extent
that
the
information
continues
to
be
accurate.
On
March
1,
2006,
the
Agency
published
the
second
annual
report
providing
an
update
on
"
Implementing
the
Pesticide
Registration
Improvement
Act
­­
Fiscal
Year
2005"
is
available
at
http://
www.
epa.
gov/
pesticides/
regulating/
fees/
pria_
annual_
report_
2005.
htm
(
see
also
Attachment
B)
which
discusses
in
detail
the
processes
that
have
been
streamlined
and
the
stakeholder
involvement
during
the
first
two
years
of
this
new
program.

3(
e)
General
Guidelines
This
collection
activity
complies
with
the
guidelines
for
information
collections
under
the
Paperwork
Reduction
Act
(
PRA).
The
recordkeeping
activities
briefly
described
in
this
ICR
exceed
OMB's
guideline
that
agencies
not
require
that
records
be
retained
for
more
than
three
years
(
5
CFR
1320.5(
d)(
2)(
iv)).
As
authorized
under
FIFRA
section
8,
EPA
regulations
require
that
applicants
retain
records
containing
research
data
relating
to
registered
pesticides
(
including
all
data
submitted
to
EPA
in
support
of
a
registration
­
see
40
CFR
169.2(
k))
for
as
long
as
the
registration
is
valid
and
the
producer
is
in
business.
However,
the
burden
related
to
the
recordkeeping
requirements
is
covered
under
another
ICR
(
see
OMB
Control
No.
2070­
0028,
Recordkeeping
Requirements
for
Producers
of
Pesticides
under
Section
8
of
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)).

The
Government
Paperwork
Elimination
Act
(
GPEA,
see
Public
Law
105­
277,
Title
XVII)
required
agencies,
by
October
2003,
to
provide
for
both
the
option
of
the
electronic
maintenance,
submission,
or
disclosure
of
information,
when
practicable
as
a
substitute
for
paper;
and
for
the
use
and
acceptance
of
electronic
signatures,
when
practicable.
The
Agency
has
published
a
policy
paper
stating
its
mission
and
goals
for
Electronic
Data
Submission
and
Review
Efforts,
http://
www.
epa.
gov/
oppfead1/
eds/
edsgoals.
htm.
(
See
Attachment
C)
OPP
has
established
standards
for
voluntary
submission
of
study
reports
in
electronic
form
(
Adobe
PDF
on
CD­
ROM).
And
in
FY
2005,
the
Agency
encouraged
registrants
to
submit
electronic
data
evaluation
records
for
studies
in
support
of
new
active
ingredients.
This
innovation
facilitates
data
interpretation
and
conserves
Agency
resources,
permitting
more
rapid
decisions,
particularly
for
reduced
risk
chemicals.

At
this
time,
OPP
may
not
be
able
to
make
electronic
reporting
available
for
this
information
collection
because
the
PRIA
fee
waiver
information
collection
may
contain
proprietary
information
(
e.
g.,
gross
global
revenues,
business
structures
and
employment
levels).
EPA
has
not
yet
promulgated
appropriate
regulations
(
i.
e.,
Cross­
Media
Electronic
Reporting
Rule)
to
address
electronic
reporting
and
electronic
signature
issues.
While
this
type
of
submission
might
be
a
candidate
for
e­
submissions
in
the
future,
after
the
promulgation
of
these
regulations,
based
on
the
Agency's
needs,
and
on
the
Office
of
Management
and
Budget's
(
OMB)
GPEA
guidance
(
as
updated
by
OMB's
policy
on
E­
Authentication),
EPA
would
likely
require
that
any
electronically
submitted
forms
be
signed
with
an
e­
signature
technology
such
as
public
key
infrastructure
(
PKI).
As
this
information
collection
request
indicates,
both
the
basic
product
registrant
and
the
distributor
must
sign
the
required
notification.
EPA
is
currently
unaware
of
5
how
an
e­
signature
technology
that
offers
both
the
Agency
and
the
signatories
the
level
of
signature
security
such
as
that
offered
by
PKI
can
be
successfully
applied
to
a
document
that
requires
multiple
signatures.

3(
f)
Confidentiality
The
information
requested
to
document
fee
waiver
requests
may
contain
confidential
business
information
(
CBI).
However,
data
and/
or
information
submitted
to
the
Agency
in
conjunction
with
service
fee
waiver
requests
may
be
claimed
as
trade
secret
or
commercial
or
financial
information
and
will
be
protected
from
disclosure
under
FIFRA
section
10
and
the
associated
regulation
as
contained
in
40
CFR
Part
2,
Subpart
B.
Information
claimed
as
CBI
is
protected
from
public
disclosure
unless
the
Administrator
determines
that
disclosure
is
in
the
public
interest.
OPP
routinely
handles
CBI
data,
and
personnel
are
familiar
with
security
procedures
in
accordance
with
provisions
of
the
FIFRA
Confidential
Business
Security
Manual
to
ensure
confidentiality.
If
any
information
is
submitted
that
applicants
claim
as
confidential,
the
Agency
will
employ
the
established
procedures
for
handling
such
material.

3(
g)
Sensitive
Questions
No
information
of
a
sensitive
or
private
nature
is
requested
in
conjunction
with
this
collection
activity.
Further,
this
information
collection
activity
complies
with
the
provisions
of
the
Privacy
Act
of
1974
and
OMB
circular
A­
108.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
The
North
American
Industrial
Classification
System
(
NAICS)
codes
assigned
to
the
parties
responding
to
this
information
collection
are
as
follows:

NAICS
Code
Category
Description
32532
Pesticide
and
other
agricultural
chemical
manufacturing
individuals
or
entities
engaged
in
activities
related
to
the
registration
of
a
pesticide
product
32518
Other
Basic
Inorganic
Chemical
Manufacturing
manufacturers
of
inorganic
chemicals
used
as
inert
ingredients
in
pesticide
products
32519
Other
Basic
Organic
Chemical
Manufacturing
manufacturers
of
organic
chemicals
used
as
inert
ingredients
in
pesticide
products.

4(
b)
Information
Requested
(
i)
Data
items,
including
record
keeping
requirements
A
registration
applicant
who
seeks
a
small
business
waiver
must
submit
a
waiver
request
6
with
appropriate
documentation
demonstrating
that
he
meets
the
criteria
established
in
the
PRIA,
i.
e.,
that
he
has
fewer
than
500
employees
and
has
no
more
than
$
60
million
in
annual
global
gross
revenue
from
pesticides,
averaged
over
the
most
recent
three
maintenance
fee
billing
cycles,
including
any
such
revenue
from
affiliates.
For
this
purpose,
the
applicant
may
be
required
to
submit
documentation
regarding
numbers
of
employees
and,
on
behalf
of
itself
and
its
affiliates,
gross
revenue
figures,
and
information
on
revenue
from
pesticides
over
a
three­
year
period.

A
registration
applicant
who
seeks
a
minor
use
waiver
must
provide
supporting
documentation
that
anticipated
revenues
from
the
uses
that
are
the
subject
of
the
application
would
be
insufficient
to
justify
imposition
of
the
full
registration
fee.

A
registration
applicant
seeking
an
IR­
4
waiver
must
merely
request
the
waiver
on
Form
8570­
1
(
Application
for
Pesticide
Registration,
approved
under
OMB
Control
#
2070­
0060)
and
submit
the
application
at
the
same
time
that
the
IR­
4
tolerance
petition
is
submitted.
The
Agency
will,
in
turn,
determine
whether
the
application
is
solely
associated
with
a
tolerance
petition
submitted
by
IR­
4
and
that
the
waiver
is
in
the
public
interest.

Although
there
is
no
record
keeping
requirement,
PRIA
provides
that
an
application
shall
be
subject
to
a
registration
service
fee
if,
at
any
time,
EPA
determines
that
(
i)
the
documentation
supporting
the
waiver
request
is
not
accurate
or
(
ii)
based
on
the
documentation
or
any
other
information,
the
waiver
or
reduction
should
not
have
been
granted.
Therefore,
it
is
anticipated
that
applicants
will
retain
copies
of
their
submissions
as
well
as
documents
demonstrating
that
the
applicant
is
eligible
for
the
waiver
or
reduction.
There
are
currently
no
forms
associated
with
this
information
collection
activity.

(
ii)
Respondent
Activities
If
a
registration
applicant
wishes
to
request
a
fee
waiver,
at
a
minimum,
it
must
undertake
the
following
activities:

·
Generate
and
submit
the
necessary
materials
to
support
the
request.

·
Indicate
that
a
waiver
is
requested
and
that
the
appropriate
documentation
supporting
the
request
is
enclosed
or
has
been
otherwise
submitted
to
the
Agency.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
Agency
is
expected
to
engage
in
the
following
activities:
7
·
Review
and
evaluate
fee
waiver
requests.
Notify
applicant
of
decision.
·
Verify
payments.
Cross
check
payment
information
from
Financial
Management
Division.
·
Store
the
data.
Image
all
forms,
listings,
telephone
conversations,
etc.,
for
archiving.

5(
b)
Collection
Methodology
and
Management
Fee
payments
are
sent
to
the
Financial
Management
Division
in
Pittsburgh,
Pennsylvania
and
entered
in
to
the
Agency's
Integrated
Financial
Management
System
(
IFMS).
Payment
information
is
extracted
from
IFMS
and
loaded
into
OPP's
tracking
system
(
OPPIN).
All
invoices
are
generated
electronically
and
tracked
in
OPPIN.
Incoming
letters,
fee
waiver
applications,
mail
receipts,
petitions,
and
other
types
of
correspondence
from
registrants
will
be
retained
in
hard
copy
for
a
period
of
time
and
then
imaged
for
long
term
electronic
storage.

Procedures
for
evaluating
fee
waiver
requests
will
not
change.
Information
and
materials
submitted
to
justify
a
fee
waiver
are
screened
for
completeness
by
the
receiving
division.
Economic
data
are
sent
to
OPP's
Biological
and
Economic
Analysis
Division
for
analysis.
The
Agency
will
keep
applicants
informed
of
the
status
of
the
waiver
application
throughout
the
process
by
telephone
and
by
mail.

5(
c)
Small
Entity
Flexibility
Small
businesses
may
request
a
waiver
of
the
registration
service
fee.
A
waiver
applicant
must
demonstrate
that
it
meets
the
criteria
as
outlined
in
the
PRIA.
The
information
that
needs
to
be
compiled
in
order
to
make
this
determination
is
information
that
companies
routinely
collect
and
maintain
in
the
normal
course
of
business.

5(
d)
Collection
Schedule
Registration
service
fees
are
required
for
90
different
registration
categories
identified
by
Congress,
and
published
in
the
Congressional
Record
of
September
17,
2003
(
pp.
S11631­
S11633).
EPA
reproduced
the
table
of
categories
from
the
Congressional
Record
and
included
it
as
Attachment
D.
Fee
categories
have
remained
the
same
while
the
fees
listed
in
the
Congressional
Record
were
increased
by
5%
as
of
October
1,
2005,
as
specified
by
legislations.
There
is
no
set
collection
schedule,
per
se.
Rather,
the
registration
service
fee
is
collected
each
time
a
registrant
submits
a
registration
application.
The
applicant
must
either
pay
a
fee
or
request
and
be
granted
a
waiver
for
each
registration
application
submitted
if
the
application
is
within
the
scope
of
one
of
the
90
fee
categories.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
For
a
period
of
some
years,
when
estimating
labor
rates
for
most
OPP
program
ICR
renewals,
the
Agency
adjusted
the
ICR
renewal
labor
rates
by
using
methods
such
as
the
NASA
8
Gross
Domestic
Product
(
GDP)
Deflator
Inflation
Calculator
to
index
the
labor
cost
for
a
particular
year.
However,
in
July
2006,
Agency
economists
completely
re­
estimated
wages,
benefits,
and
overhead
for
all
labor
categories
for
the
pesticide
industry,
state
government
and
Agency
employees.
The
Agency
analysis
uses
currently
available
information
on
labor
rates
and
other
benefits
from
publicly
available
websites.
A
copy
of
the
methodology
used
to
re­
estimate
the
labor
rates
and
formulas
used
to
derive
the
fully
loaded
rates
and
overhead
costs
are
listed
in
Attachment
E.

To
derive
the
labor
rates
for
this
ICR,
Agency
economists
estimated
the
wages
for
the
management,
technical,
and
clerical
labor
categories
using
the
methodology
cited
above.
The
respondent
costs
for
this
renewal
for
managerial,
technical
and
clerical
rates
are
estimated
at
$
100.86,
$
64.80,
and
$
33.05
per
hour,
respectively.
These
labor
rates
are
fully
loaded
and
include
benefits
and
overhead
costs.

In
calculating
the
potential
respondent
burden,
the
Agency
estimated
389
responses
per
year
for
requesting
fee
waivers
or
reductions,
based
on
the
numbers
of
fee
waiver
applications
during
the
maintenance
fee
cycle
for
the
year
of
2005.

IR­
4
waiver
requests
are
not
accounted
for
in
this
burden
estimation.
To
be
eligible
for
the
IR­
4
waiver
under
PRIA,
the
application
must
be
solely
associated
with
a
tolerance
petition
submitted
by
the
IR­
4
program
and
the
waiver
must
be
in
the
public
interest.
To
facilitate
this
request,
the
applicant
may
simply
include
the
statement
"
This
application
is
being
submitted
with
a
tolerance
petition
submitted
in
connection
with
IR­
4.
I
request
EPA
to
waiver
the
registration
service
fee
for
this
application
under
the
IR­
4
waiver
provisions
of
FIFRA
Section
33(
b)(
7)(
E)."
on
Form
8570­
1
(
Application
for
Pesticide
Registration).
Burden
hours
associated
with
completing
this
form
are
already
covered
by
the
ICR
entitled
"
Application
for
New
or
Amended
Registration"
(
approved
under
OMB
Control
Number
2070­
0060).
EPA
is
not
requiring
that
registrants
submit
additional
information.
The
Agency
will
determine
whether
the
application
is
solely
associated
with
a
tolerance
petition
submitted
by
IR­
4
and
whether
the
waiver
is
in
the
public
interest.

There
are
three
types
of
applications.
The
first
type,
Type
A,
is
a
first­
time
applicant
requesting
fee
waiver
or
reduction.
The
second
type,
Type
B,
is
an
application
requesting
another
fee
waiver
or
reduction
within
the
same
maintenance
fee
billing
cycle.
The
third
type,
Type
C,
is
from
an
applicant
who
has
applied
for
a
fee
waiver
in
a
prior
maintenance
fee
billing
cycle
but
not
in
the
current
cycle.
EPA
assumes
that
the
respondent
burden
and
cost
for
the
Type
B
application
is
the
lowest
because
Type
B
applicants
will
only
need
to
certify
that
there
have
been
no
changes
to
the
information
previously
submitted
or,
in
the
alternative,
only
provide
documentation
with
respect
to
those
elements
that
have
changed.
Type
C
applications,
on
the
other
hand,
will
need
to
submit
all
the
documentation
supporting
the
waiver
request,
providing
updated
financial
and
employee
information.
EPA
assumes,
however,
that
the
cost
and
burden
on
most
Type
C
applicants
will
be
less
than
first
time
applicants
because
applicants
will
already
be
familiar
with
the
waiver
requirements
and,
in
many
cases,
should
have
a
portion
of
the
supporting
financial
and
business
affiliation
documentation
readily
available.
The
cost
and
burden
on
the
Type
A
applicants
will
be
the
same
as
those
for
the
first­
year
applicants.
EPA
assumes
that
every
new
applicant
seeking
a
waiver
of
the
registration
service
fee
will
want
to
familiarize
him/
herself
with
the
criteria
9
from
the
outset,
thus
this
burden
is
considered
a
one­
time
burden
that
will
occur
the
first
time
the
applicant
submits
a
registration
application
under
the
PRIA.
Based
on
the
number
of
waiver
requests
EPA
received
during
the
first
full
year
of
PRIA,
the
maintenance
billing
cycle
for
2005,
EPA
estimates
that
31%
(
121
out
of
389)
will
be
the
firsttime
applicants
(
Type
A)
r,
57%
(
223
out
of
389)
to
be
the
Type
B
applications,
and
12%
(
45
out
of
389)
will
be
Type
C
applications
each
year.

6(
b)
Estimating
Respondent
Costs
EPA
expects
that
applicants
will
incur
minor
expenses
that
are
not
directly
related
to
paperwork
activities,
such
as
the
costs
of
producing
photocopies
and
postage
costs.
EPA
estimates
that
these
costs
will
average
about
$
10
per
applicant
and
has
factored
these
costs
into
the
estimated
total
cost
figures.
Annual
respondent
burden
and
costs
could
vary
with
such
factors
as
business
structure
of
waiver
applicants
and
types
of
information
submitted.
Therefore,
the
actual
respondent
burden
and
costs
to
a
respondent
could
be
higher
or
lower
than
the
estimated
respondent
burden
and
costs
below.

Table
1:
Annual
Respondent
Burden
and
Cost
Estimates
(
Type
A)*

Burden
Hours
(
per
year)
Total
COLLECTION
ACTIVITY
Mgmt.
$
100.86/
hr
Tech.
$
64.80/
hr
Cler.
$
33.05/
hr
Hours
Costs
($)

Read
regulation
and
plan
activities
7
0
0
7
706
Generate
materials
for
waiver
request
for
submission
to
EPA
0
24
0
24
1,555
Store/
maintain/
submit
and
produce
information
0
0
6
6
198
Totals
7
24
6
37
2,460
*
All
totals
have
been
rounded
to
the
nearest
dollar
or
hour
after
all
computations
were
made;
in
2006
dollars
PAPERWORK
BURDEN:
37
hours/
response
x
121
responses
=
4,477
total
hours
$
2,460/
response
x
121
responses
=
$
297,602
NON­
PAPERWORK
COSTS:
$
10
(
postage
and
paper
copies)
x
121
responses
=
$
1,210
TOTAL
ANNUAL
RESPONDENT
BURDEN
(
TYPE
A):
$
297,602
(
paperwork)
+
$
1,210
(
non­
paperwork)
=
$
298,812
10
Table
2:
Annual
Respondent
Burden
and
Cost
Estimates
(
Type
B)*

Burden
Hours
(
per
year)
Total
COLLECTION
ACTIVITY
Mgmt.
$
100.86/
hr
Tech.
$
64.80/
hr
Cler.
$
33.05/
hr
Hours
Costs
($)

Read
regulation
and
plan
activities
2
0
0
2
202
Generate
materials
for
waiver
request
for
submission
to
EPA
0
4
0
4
259
Store/
maintain/
submit
and
produce
information
0
0
6
6
198
Totals
2
4
6
12
659
*
All
totals
have
been
rounded
to
the
nearest
dollar
or
hour
after
all
computations
were
made;
in
2006
dollars.

PAPERWORK
BURDEN:
12
hours/
response
x
223
responses
=
2,676
total
hours
$
659/
response
x
223
responses
=
$
147,006
NON­
PAPERWORK
COSTS:
$
10
(
postage
and
paper
copies)
x
223
responses
=
$
2,230
TOTAL
ANNUAL
RESPONDENT
BURDEN
(
TYPE
B):
$
147,006
(
paperwork)
+
$
2,230
(
non­
paperwork)
=
$
149,239
Table
3:
Annual
Respondent
Burden
and
Cost
Estimates
(
Type
C)*

Burden
Hours
(
per
year)
Total
COLLECTION
ACTIVITY
Mgmt.
$
100.86
/
hr
Tech.
$
64.80/
hr
Cler.
$
33.05/
hr
Hours
Costs
($)

Read
regulation
and
plan
activities
2
0
0
2
202
Generate
materials
for
waiver
request
for
submission
to
EPA
0
19
0
19
1231
Store/
maintain/
submit
and
produce
information
0
0
6
6
198
Totals
2
19
6
27
1631
*
All
totals
have
been
rounded
to
the
nearest
dollar
or
hour
after
all
computations
were
made;
in
2006
dollars.
11
PAPERWORK
BURDEN:
27
hours/
response
x
45
responses
=
1,215
total
hours
$
1631/
response
x
45
responses
=
$
73,405
NON­
PAPERWORK
COSTS:
$
10
(
postage
and
paper
copies)
x
45
responses
=
$
450
TOTAL
ANNUAL
RESPONDENT
BURDEN
(
TYPE
C):
$
73,405(
paperwork)
+
$
450
(
non­
paperwork)
=
$
73,855
6(
c)
Estimating
Agency
Burden
and
Cost
The
Agency's
burden
consists
of
reviewing,
evaluating,
and
notifying
applicants
of
the
Agency's
decision
to
grant
or
deny
fee
waiver
requests;
entering
data
into
tracking
systems;
verifying
fee
payment;
and
storing/
maintaining
this
information.
The
table
below
estimates
EPA's
burden
for
performing
these
activities.

TABLE
4:
Annual
Agency
Burden
and
Cost
Estimates*

Burden
Hours
(
per
year)
Total
COLLECTION
ACTIVITY
Mgmt.
$
93.07/
hr
Tech.
$
66.34/
hr
Cler.
$
47.17/
hr
Hours
Costs
($)

Review
submitted
waiver
request
and
notify
requestor
of
decision
1
20
2
23
1,1514
Enter
data
into
tracking
systems
0
0
0.5
0.5
24
Verify
payment
0
0
0.5
0.5
24
Store/
maintain/
submit
information
0
0
1
1
48
Totals
1
20
4
25
1,610
*
All
totals
have
been
rounded
to
the
nearest
dollar
or
hour
after
all
computations
were
made;
in
2006
dollars.

ANNUAL
BURDEN:
25
hours/
response
x
389
responses
=
9,725
Hours
ANNUAL
COSTS:
$
1610/
response
x
389
responses
=
$
626,290
12
6(
d)
Bottom
Line
Burden
Hour
and
Cost
Tables
Table
5:
Total
Annual
Burden
and
Cost
Estimates
TOTAL
ESTIMATES
Hours
Costs
Applicant
­
Annual
(
Type
A
+
Type
B
+
Type
C)
8,368
$
521,903
Type
A
4,477
$
298,812
Type
B
2,676
$
149,236
Type
C
1,215
$
73,855
Agency
­
Annual
9,725
$
626,290
6(
e)
Reasons
For
Changes
In
Burden
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
37,
12,
and
27
hours
per
response,
for
the
three
different
types
of
applications.
The
program
is
just
two
years
old
and
the
Agency
and
respondents
are
learning
to
streamline
the
process.
Labor
rates
for
both
respondents
and
Agency
personnel
in
this
ICR
have
decreased.
The
burden
hour
breakdown
remains
unchanged
from
the
last
renewal
period.
In
previous
renewal
cycles,
the
Agency
only
adjusted
the
labor
rates
to
account
for
inflation.
However,
for
this
renewal,
Agency
economists
have
completely
re­
estimated
labor
rates,
benefits
and
overhead
costs
for
both
respondents
Agency
personnel.
This
Agency
analysis
was
completed
in
July
2006,
see
Attachment
E.
The
Agency
believes
this
is
a
more
realistic
estimate
of
the
average
respondent
and
Agency
costs.
As
a
result,
there
is
a
decrease
of
$
209,469
in
the
estimated
total
annual
respondent
cost
(
from
$
728,372
to
$
521,903).
This
change
is
an
adjustment.

6(
f)
Burden
Statement
According
to
the
PRIA,
"
burden"
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
For
this
collection
it
includes
the
time
needed
to
read
the
new
regulation,
review
instructions,
plan
activities,
assemble
pertinent
materials,
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
that
is
subject
to
the
PRIA
unless
the
Agency
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
in
title
40
of
the
CFR,
after
initial
display
in
the
final
rule,
are
listed
in
40
CFR
part
9.
Since
the
collection
activity
in
this
ICR
are
contained
in
the
PRIA
and
not
a
current
regulation,
the
OMB
control
number
for
this
collection
activity
appears
in
this
ICR.
13
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques.
All
documents
in
the
docket
are
listed
in
the
docket
index.
Although
listed
in
the
index,
some
information
is
not
publicly
available,
e.
g.,
CBI
or
other
information
whose
disclosure
is
restricted
by
statute.
Certain
other
material,
such
as
copyrighted
material,
is
not
placed
on
the
Internet
and
will
be
publicly
available
only
in
hard
copy
form.
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
EPA­
HQ­
OPP­
2006­
0036,
Publicly
available
docket
materials
are
available
either
in
the
electronic
docket
at
http://
www.
regulations.
gov,
or,
if
only
available
in
hard
copy,
at
the
OPP
Regulatory
Public
Docket
in
Rm.
S­
4400,
One
Potomac
Yard
(
South
Building),
2777
S.
Crystal
Drive,
Arlington,
VA.
The
hours
of
operation
of
this
Docket
Facility
are
from
8:
30
a.
m.
to
4
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
Docket
telephone
number
is
(
703)
305­
5805.

Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
No.
EPA
­
HQ­
OPP­
2006­
0636
and
OMB
Control
No.
2070­
0167
in
any
correspondence.
14
ATTACHMENTS
TO
THE
SUPPORTING
STATEMENT:

Attachment
A
Pesticide
Registration
Improvement
Act
of
2003
 
Available
electronically
at
http://
www.
epa.
gov/
pesticides/
regulating/
fees/
index.
htm
and
in
the
docket
for
this
information
collection
activity.

Attachment
B
Implementing
the
Pesticide
Registration
Improvement
Act
 
Fiscal
Year
2005.
Available
electronically
at
http://
www.
epa.
gov/
pesticides/
regulating/
fees/
pria_
annual_
report_
2005.
ht
m.

Attachment
C
Electronic
Data
Submission
and
Review
Efforts
­
Available
electronically
at
http://
www.
epa.
gov/
oppfead1/
eds/
edsgoals.
htm.

Attachment
D
Categories
of
Registration
Requiring
Fees
under
the
PRIA
 
Available
in
the
docket
for
this
information
collection
activity.

Attachment
E
Methodology
for
Estimating
OPP
ICR
Wage
Rates
for
Industry,
State
and
EPA
Labor
Costs;
Memo
From
Richard
Keigwin,
Director
Biological
and
Economic
Analysis
Division,
to
Bill
Diamond,
Arnold
Layne,
Lois
Rossi
and
Elizabeth
Leovey
July
25,
2006.
Available
in
the
docket
for
this
information
collection
activity.
