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 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 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 business 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 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

	In preparing to renew this ICR, EPA published a notice in the Federal
Register which provided a 60-day public notice and comment period on the
draft ICR (see 71 FR 62431; October 25, 2006).  EPA did not receive
comment in response to this notice.

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.

Consultation and/or dialogue between respondents 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 personnel 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. 

	On March 1, 2006, the Agency published the second annual report
providing an update on “Implementing the Pesticide Registration
Improvement Act -- Fiscal Year 2005.”  The report, available at  
HYPERLINK
"http://www.epa.gov/pesticides/regulating/fees/pria_annual_report_2005.h
tm" 
http://www.epa.gov/pesticides/regulating/fees/pria_annual_report_2005.ht
m   (see also Attachment B), discusses in detail the processes that have
been streamlined and the stakeholder involvement during the first two
years of this new program.  

During the preparation of this ICR renewal, EPA staff contacted the
following representatives of pesticide registrants by phone or e-mail
and asked them for their assessment of the burden estimates in the ICR:

Jim Kunstman;  PBI/Gordon;  jkunstman@pbigordon.com

Jim Messina;  Exponent, Agent for SePro and Ajay North America; 
jmessina@exponent.com

Terry Pizzarello;  Falcon Labs;  tjpizza@optonline.net

Judith Thompson;  Hacco Inc.;  920-326-5141, ext. 2461

All four of the above respondent representatives provided feedback to a
questionnaire about the collection process and the burden and labor rate
estimates used by EPA (see Attachment C).  As is the case with pesticide
registrant companies, the above respondents vary widely in company size
and structure. This variability among companies included in this
consultation resulted in variable responses, particularly with respect
to estimated labor rates.  Two representatives felt that one or more of
the labor rate categories should be higher, one did not comment, and the
other suggested that the labor rates should be lower for the technical
and clerical categories.  Although Mr. Messina stated that labor rates
should be higher, he suggested that this was due to use of a consulting
company by the respondent.  The Agency expects that where respondents
elect to employ consulting firms, labor rates will typically be higher. 
However, EPA does not have data on how many respondents use the services
of consulting firms, or on typical labor rates for such firms.  EPA’s
default assumption is that companies respond to the information
collection using in-house employees.  Overall, it appears that the labor
rate estimates used by EPA are reasonable, and these consultations did
not provide sufficient basis to amend them.

With respect to respondent burden, the four respondent representatives
indicated that EPA’s burden estimates are either similar to, or in
some cases higher than, the burden they actually incur.  Again, these
consultations indicated that actual burden varies widely among
respondents, as does the distribution of burden among labor categories,
as well as the difference between burden for the first waiver request in
a billing cycle and that for subsequent requests.  In general, it
appears that the Agency’s burden estimates used for each of the three
types of waiver requests are equal to or higher than those actually
incurred, and have not been revised.

3(d) 	Effects of Less Frequent Collection

  

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. 
Therefore, the frequency of collection depends entirely on the frequency
with which an applicant submits registration applications for which they
are eligible for a fee waiver.  EPA cannot grant a waiver when one has
not been requested and documented.  Therefore, less frequent collection
is not an option.

3(e) 	General Guidelines

This collection activity complies with the guidelines for information
collections under the Paperwork Reduction Act (PRA).  There is no record
keeping requirement for information submitted under this information
collection.

A registration applicant eligible for a fee waiver must submit their
signed request for the waiver, certification of eligibility, and
required documentation demonstrating eligibility.  The industry has
developed a form for the fee waiver request.  Many requesters use this
form, although the Agency does not require it.  Most waivers are granted
based on the small business status of the applicant, and Confidential
Business Information is included in their submission (e.g., gross global
revenues, business structures and employment levels).  Although EPA
would accept waiver requests sent in Adobe PDF format on CD-ROM, the
Agency’s expectation based on experience is that the majority of
registrants want to send their requests in writing with ink signatures. 
In the future, if it appears that electronic submission of waiver
requests by e-mail is beneficial and feasible for respondents and EPA,
we will seek to facilitate such submissions.

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

	4(b)(i)	    Data items, including record keeping requirements

A registration applicant who seeks a small business waiver must submit a
waiver request 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 EPA forms associated with this information
collection activity.  However, an industry workgroup comprised of
representatives of registrant companies and trade associations designed
a form for assisting pesticide registrants when they submit small
business waiver requests under PRIA.  The form is available
electronically through the Consumer Specialty Products Association’s
web site (  HYPERLINK
"http://www.cspa.org/public/news/fees_document.pdf" 
http://www.cspa.org/public/news/fees_document.pdf ).  EPA does not
sponsor this form and its use is strictly voluntary.  The Agency will
accept information that is submitted via the industry form as well as
any other format that meets the requirements of the statute.

	4(b)(ii)	    Respondent Activities

	Guidance on the content and submission of fee waiver requests is
available on EPA’s website at   HYPERLINK
"http://www.epa.gov/pesticides/fees/questions/waivers.htm" 
http://www.epa.gov/pesticides/fees/questions/waivers.htm  (also, see
Attachment D).  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:

     ·	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

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

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 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 actually received during the
first full year of PRIA, the maintenance billing cycle for 2005, EPA
estimates that 1,577 requests for registration actions will be received
per year, of which 389 will request fee waivers or reductions. Of the
389 responses EPA estimates that 31% (121 out of 389) will be the
first-time applicants (Type A), 57% (223 out of 389) will be the Type B
applications, and 12% (45 out of 389) will be Type C applications each
year, (also observed values from 2005).  EPA estimates of respondent
burden hours per response, for each of the three response types, were
corroborated by representative respondents in consultations (see section
3(c) of this supporting statement) and have not been revised for this
ICR renewal.  The burden per response, number of responses, and total
burden for each of the three response types are presented in Tables 1,
2, 3, and 5, below.

6(b) 	Estimating Respondent Costs

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 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.  The methodology used to re-estimate
the labor rates, including formulas used to derive the fully loaded
rates and overhead costs, is 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.

 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 reflected in tables 1, 2, and 3. 

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

COLLECTION ACTIVITY	

Burden Hours (per year)	

Total

	

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

PAPERWORK BURDEN AND COST: 

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 COST (TYPE A): 

$297,602 (paperwork) + $1,210 (non-paperwork) = $298,812Table 2: Annual
Respondent Burden and Cost Estimates (Type B)

COLLECTION ACTIVITY	

Burden Hours (per year)	

Total

	

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

PAPERWORK BURDEN AND COST: 

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 COST (TYPE B): 

$147,006 (paperwork) + $2,230 (non-paperwork) = $149,239

Table 3: Annual Respondent Burden and Cost Estimates (Type C)

COLLECTION ACTIVITY	

Burden Hours (per year)	

Total

	

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

PAPERWORK BURDEN AND COST: 

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 COST (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.  Table 4 estimates EPA’s
burden for performing these activities.

Table 4: Annual Agency Burden and Cost Estimates 

COLLECTION ACTIVITY	

Burden Hours (per year)	

Total

	

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

ANNUAL BURDEN: 25 hours/response x 389 responses = 9,725 Hours

ANNUAL COSTS: $1610/response x 389 responses = $626,290

	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 total estimated annual respondent burden for this ICR has decreased
by 2,302 hours, from 10,670 hours in the existing ICR, to 8,368 hours
for this renewal.  The average estimated burden per response for each of
the three types of applications has not changed:  37 hours for Type A,
12 hours for Type B, and 27 hours for Type C.  These estimates of burden
per response were corroborated by consultations with respondents (see
section 3(c) of this supporting statement).  However, the total number
of responses per year increased slightly from 360 to 389, and the
percentage of the total received for each type changed significantly.  
Both the total number of waiver requests received, and the number (or
percentage) of each of the three types of responses, were based on EPA
estimates in the current ICR, as the program was still very new and a
year’s worth of observations were not available.  However in this
renewal request, the annual number and distribution of responses among
the three types are based on actual responses received.  The major shift
in the distribution of responses to the least-burdensome type (Type B),
resulted in the lower total estimated burden, more than offsetting the
effects of the slight increase in the total number of responses per
year.  

	6(f) 	Burden Statement

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.    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
activities 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. 

The Agency has established a public docket for this ICR under Docket ID
No. EPA-HQ-OPP-2006-0636, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the OPP Regulatory Public Docket in Rm. S-4400, One
Potomac Yard (South Building), 2777 S. Crystal Drive, Arlington, VA. 
This docket facility is open from 8:30 a.m. to 4 p.m., Monday through
Friday, excluding legal holidays.  The docket telephone number is (703)
305-5805.  You may submit comments regarding 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.  

Submit your comments, referencing Docket ID No. EPA-HQ-OPP-2006-0636 to
(1) EPA online using www.regulations.gov (our preferred method), or by
mail to: Public Information and Records Integrity Branch (PIRIB), Mail
Code: 7502P, Office of Pesticide Programs (OPP), Environmental
Protection Agency, 1200 Pennsylvania Ave., NW, Washington, DC 20460, and
(2) OMB by mail to: Office of Information and Regulatory Affairs, Office
of Management and Budget (OMB), Attention: Desk Officer for EPA, 725
17th Street, NW, Washington, DC 20503. Include docket ID No.
EPA-HQ-OPP-2006-0636 and OMB control number 2070-0167 in any
correspondence but do not submit fee waiver requests to these
addresses.ATTACHMENTS TO THE SUPPORTING STATEMENT:

Attachment A	Pesticide Registration Improvement Act of 2003 –
Available electronically at   HYPERLINK
"http://www.epa.gov/pesticides/regulating/fees/index.htm" 
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   HYPERLINK
"http://www.epa.gov/pesticides/regulating/fees/pria_annual_report_2005.h
tm" 
http://www.epa.gov/pesticides/regulating/fees/pria_annual_report_2005.ht
m and in the docket for this information collection activity.

Attachment C	Record of Consultations Between the U.S. Environmental
Protection Agency and Respondents to the Information Collection Request:
 “Pesticide Registration Fee Waivers”  Available in the docket for
this information collection activity.

Attachment D	Guidance on How to Request Fee Waivers and Fee Reductions. 
Available electronically at   HYPERLINK
"http://www.epa.gov/pesticides/fees/questions/waivers.htm" 
http://www.epa.gov/pesticides/fees/questions/waivers.htm  and 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.



	.

	            

	

	

	

 All table totals have been rounded to the nearest dollar or hour after
all computations were made; in 2006 dollars.

 All table totals have been rounded to the nearest dollar or hour after
all computations were made; in 2006 dollars.

January 31, 2007

Page   PAGE  14  of   NUMPAGES  15 

