SUPPORTING STATEMENT 

FOR AN INFORMATION COLLECTION REQUEST

1.  	IDENTIFICATION OF THE INFORMATION COLLECTION

 	1(a)  Title of the Information Collection:

	Pesticide Product Registration Maintenance Fee

  	EPA No.: 1214.07   OMB No.: 2070-0100

1(b)  Short Characterization/Abstract:

This information collection provides a practical means of communication
between the registrants and Environmental Protection Agency’s Office
of Pesticide Programs (OPP) to collect registration maintenance fees
from pesticide registrants as required by law.  Respondents complete and
submit EPA Form 8570-30 (Attachment A) indicating the respondent's
liability for the registration maintenance fee.  

The first Registration Maintenance Fee filing form was sent to
approximately 5,000 pesticide registrant firms in 1989.   Since then,
the number of respondents has slowly declined from approximately 2800
firms in 1990 to 2500 in 1991, 2350 in 1992, 2250 in 1993, and 2200 in
1994.   Since 1994, the number of registrants to which these forms are
sent has declined steadily to a total of 1,720 in January, 2006   Each
affected firm is required to complete the filing form and submit their
fee payment by January 15 of each year.  

Annually, the Agency provides registrants a list of the registered
products currently registered with the Agency.   Registrants are
provided the opportunity to review the list, determine its accuracy, and
remit payment of the maintenance fee.   The list of products has space
identified for marking those products to be supported and those products
that are to be canceled.   The registrants are also instructed to
identify any products on the list which they believe to be transferred
to another company, and to add to the list any products which the
company believes to be registered that are not on the Agency-provided
list.   The failure to pay the required fee for a product will result in
cancellation of that product’s registration.  

2.	NEED FOR AND USE OF THE COLLECTION 

2(a)  Need/Authority for the Collection

On October 25, 1988, the Federal Insecticide, Fungicide, and Rodenticide
Act was amended in several significant ways.  Among the new provisions
of the Act was the institution of registration maintenance fees (FIFRA)
Section 4(i)(5), Attachment B.  These fees apply to all products
registered under Section 3 and Section 24(c) of FIFRA.  The fees are to
be paid annually for each product registered and payable on January 15
of each year beginning in 1989.  The authority to collect fees under the
1988 amendments would have terminated on September 30, 1997.  However
the Food Quality Protection Act extended the authority to collect these
fees until September 30, 2001.  The EPA Appropriation Bills of FY 2002
and FY 2003 also extended the authority to collect maintenance fees. 
The Pesticide Registration Improvement Act (PRIA), which became
effective on March 23, 2004, further extended the authority to collect
maintenance fees through fiscal year 2008.

      

 2(b)  Practical Utility/Users of the Data

In order to provide an efficient system to bill, collect, and account
for registration maintenance fees, the Agency has used a filing form
which is sent to all registrants of currently active products.  The
information is used by the Agency to ensure that the fees prescribed by
FIFRA have been paid by each registrant.  The information is also used
to adjust OPP's computer files to reflect changes in the status of
registrations resulting from registrant responses.

3.	NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

  

3(a)  Non duplication

The specific information required under this ICR (i.e., the number of
registrations that a given registrant wishes to maintain and, thus, the
fee amount that will be remitted to EPA) does not exist in data bases at
EPA or any other agency.  To determine the amount of maintenance fees
accurately, the Agency and the registrant must have a joint
understanding concerning the number of products currently registered. 
An alternative approach considered prior to seeking approval for the
original maintenance fee filing form (ICR) was to simply notify
registrants that fees were due for each of their products according to a
fee schedule.  The registrant would submit payment according to their
best information concerning the number of registrations that they wanted
to support.  However, if a registrant submitted payment that did not
correspond to the fee schedule, the Agency would be in a position of
either unilaterally determining which registrations to cancel, or
contacting each registrant to determine that registrant's intentions. 
This option was considered to be inefficient, and not in the best
interest of the Agency or the registrants.  

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 62432; October 25, 2006). EPA did not receive any
comments in response to that notice.

3(c)  Consultations

Consultation and/or dialogue between respondents and the Agency 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. 

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:

Kim Davis, 

RegWest Company, LLC

30856 Rocky Road

Greeley, CO 80631

(970) 353-0611

  HYPERLINK "mailto:Kim@regwest.com"  Kim@regwest.com 

(Consultant representing 36 companies holding 1 to 16 registrations)	Bob
Werdig

Pesticide Registration Association

715 8th Street S.E. 

Washington DC   20003

(202) 546-3260

(Consultant representing 4 companies holding 1 to 4 registrations)

Donna Leventhal

Delta Analytical

7910 Woodmont Avenue 

Bethesda, MD 20814

(301) 652-5495

(Consultant representing 22 companies holding 1 to 16 registrations)
William Mahrlburg 

Nufarm

2300 Frederick Avenue Suite 208 

St. Joseph,  MO 64504

(816) 676-9000

(Company holds 393 registrations)



All four of the above respondent representatives provided feedback to a
questionnaire about the collection process (see Attachment D).  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.  The
average time required to complete the maintenance fee filing form
depends upon the number of registrations held by the registrant.  Larger
companies with more registered pesticide products will take longer to
complete the form, on average, than companies with fewer registrations. 
The time required to complete the form estimated by the above
respondents ranged from 10 minutes to half an hour, all less than the
estimated 0.96 hours used in this ICR renewal.  In general, it appears
that the Agency’s burden estimates used are equal to or higher than
those actually incurred, and have not been revised.

The four respondent representatives were also asked their opinion of and
desire for electronic reporting.  Again, responses varied but they
indicated some concern over security and electronic signatures.  One
respondent indicated that electronic reporting would not change the
burden relative to paper responses, one said it would actually increase
the burden, and the other two said it could increase the burden for some
and decrease it for others.  Two of the respondents said that they would
still need to send a check to EPA, even if the form were submitted
electronically, thereby undermining the benefit of electronic reporting.

	Due to these responses, and similar feedback received informally from
other registrants, it is apparent that at least some may prefer
electronic reporting and payment and that some burden reduction may be
realized.  EPA will work with the Treasury Department to implement
electronic payment of maintenance fees via http://www.pay.gov.  The
Agency anticipates that this capability will be in place for the FY08
collection cycle and intends to offer the option of secure electronic
reporting and payment at that time. 

3(d)  Effects of Less Frequent Collection

The payment of maintenance fees for all pesticide products is mandated
in FIFRA amendments to occur annually.  Thus, there can be no option
other than to require a minimum submission of the filing form once a
year.  Less frequent information collection in this area would violate
the statute.

3(e)  General Guidelines

With respect to the PRA imposed guidelines contained in 5 CFR 1320.6,
this information collection activity has the following features:

The respondents are required to respond on an annual basis and hence the
quarterly response limitation is not applicable

The respondents are not required to keep records relating to this
information collection for a period of more than 3 years.

This information collection activity does not utilize a statistical
survey.  The requirement to collect maintenance fees for all products
means that all pesticide registrants submit replies.

The respondents are given at least 30 days to respond.

The information collection under this ICR can be held confidential under
long established procedures for properly handling Confidential Business
Information.  Confidentiality is discussed in more detail below. 

The respondents are not required to submit more than an original and two
copies of any document.

The ICR is for processing of fees mandated by Congress.  No provision in
the law allows for remuneration of respondents.

This information collection activity has used automation to the extent
practicable without electronic reporting and payment.  For example, the
name and address of each respondent is pre-printed by computer,
alleviating the registrant of the burden of writing it in.  A computer
generated listing of products is also provided, and the registrant must
only circle an appropriate keyword (CAN, PAY) etc.  Because the
regulated community runs the gamut from large multinational corporations
to small sole proprietor firms, some with limited technological
capabilities, the Agency believes that a simple filing form may continue
to be preferred by some but that others may now prefer electronic
reporting and payment (see section 3(c), above).   EPA will work with
the Treasury Department to implement electronic payment of maintenance
fees via http://www.pay.gov.  The Agency anticipates that this
capability will be in place for the FY08 collection cycle and intends to
offer the option of secure electronic reporting and payment at that
time.

As discussed in Section 4(c), this form requires the minimum amount of
information from all firms.

This collection activity does not apply to grantees.

3(f)  Confidentiality

Product registration maintenance fee information submitted by pesticide
registrants under this ICR is considered by OPP to contain no
confidential business information (CBI).  If, however, registrants
submit data that contains CBI or relates to trade secrets or commercial
or financial information, such information is protected from disclosure
under section 10 of FIFRA.  Such data submitted to the EPA are handled
strictly in accordance with provisions of the FIFRA Confidential
Business Security Manual. This manual contains instructions relative to
all contact with confidential documents including responsibilities of
EPA employees physical security measures; CBI copying and destruction
procedures; transfer of CBI materials within the EPA to contractors or
other government offices; computer security; CBI typing procedures; and
procedures internal to OPP. The manual dictates that all CBI must be
kept in secure (double-locked) areas, and all CBI intended to be
destroyed must be cleared by a Document Control Officer and shredded.

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

All pesticide registrants holding currently active registrations under
FIFRA section 3 and Section 24(c) are subject to this information
collection activity.  These include pesticide companies and state
governments.  The North American Industrial Classification System
(NAICS) codes are 325320 (Pesticide and other Agricultural Chemical
Manufacturing) and 9641 (Regulation of Agricultural Marketing and
Commodities).

  

4(b)  Information Requested

4(b)(i)  Data Items, Including Record Keeping Requirements



Part A -- Registrant Identification	Registrant Name and Address are
pre-printed. The registrant needs to complete this section only to
indicate a name and/or address change.

Part B -- EPA Company Numbers	If a firm has been assigned more than one
company number, the firm may combine its fee payments under a single
number by writing in all of the company numbers for which the firm is
paying.

Part C -- Maintenance Fee Calculation	The respondent must fill in the
number of registrations for which he is paying the fee, number of
registrations which he believes to   be transferred, number of
registrations to be canceled, number of registrations which he believes
to be in error, total fee amount due, and check number.

Part D -- Authorized Company Representative or Agent	The respondent must
print the name and title of the company representative or agent.  The
respondent must sign and date the form, and provide the telephone number
of the respondent.



	4(b)(ii)  Respondent Activities

 

Activities in which a registrant must engage in order to comply with
this collection include the following:

Read instructions	Read accompanying instructions to understand how to
fill out form, annotate list of registrations, and calculate fee due.

Plan Activities	Plan the activities necessary to respond to the billing.
 

Review Information	Review the attached listing of registrations and
compare to the firm's records.

Complete Paperwork	Annotate attached listing of registrations to
indicate which products the respondent is paying and which products are
to be canceled or transferred.

File Information	Maintain a copy of the form in company files.  Although
this is not required, the Agency assumes that most companies will retain
this information as a common business practice.



The existing paper version form is printed on 3 part NCR paper.  The
respondent sends one copy along with payment to the Headquarters
Accounting Operations Branch Lock Box in St. Louis and the second copy
together with the annotated list of products to OPP via a designated
Washington D.C. area mail box.  The third copy is retained by the
respondent for his own records.  Information contained on the forms
returned to OPP is used to check and ensure that the proper amount of
fees have been submitted by each registrant.  In the past there has been
a need for follow-up with some registrants when the information provided
indicates that there has been a misunderstanding of the requirements. 
For the most part these have been handled by telephone.  There is also a
toll free information line available which registrants may use to ask
questions and resolve problems regarding their maintenance fee payments.
 The information provided also serves as an update for pesticide product
information files.  Updates of the Agency’s files are an ongoing
process.

5.	THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION

	METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)  Agency Activities

The following activities are necessary to conduct the information
request:

Develop Letter	Prepare a cover/transmittal letter to be included in the
package.

Answer Questions	Staff a toll free information line to respond to any
questions that respondents have regarding payment requirements.

Review Submissions	Review submitted forms and annotated listings for
completeness.

Record Submissions	Record information provided by respondents into a
tracking system.  Make adjustments to Product Information Master Files
as required.

Verify Payments	Cross check payment information from Financial
Management Division to ensure that payment has been received.

Store Data	Image all forms, listings, and telephone conversation logs
for archiving.

  

5(b)  Collection Methodology and Management

For the past 17 years, the Agency has employed the same method of
collecting maintenance fees.  This method involves using OPP master
files of product information to identify the firms to which the billing
information is to be sent.  Computer generated listings of products are
mailed to each firm along with the Maintenance Fee Filing Form.  The
registrant is instructed to circle the word PAY, CAN, XFR, ERR, next to
each Registration Number to indicate if he wants to pay for the
registration, cancel the registration, indicate if he believes that the
registration was transferred, or if the registration is listed in error.

The list of registrations is pre-loaded into a tracking file, and only
the PAY, CAN, XFR, ERR indicator is keyed manually for each product. 
Company name and address information is also pre-loaded reducing the
data entry burden for the maintenance fee filing forms.  The total
number of products for each company is calculated by computer, and
totals entered from the filing form are verified by computer to ensure
that all items balance.  In addition, data entry for all forms is
quality checked visually.

Receipt of payment is entered by the Financial Management Division into
the Integrated Financial Management System (IFMS).  This information is
then extracted and posted to the maintenance fee tracking system to
close out each record.  Results are made available to OPP staff on
request as soon as the information is entered into the tracking system.

5(c)  Small Entity Flexibility

The Agency's filing form for the submission of maintenance fees requires
the minimum amount of information that is needed to provide adequate
communication between pesticide product registrants and the Agency.  The
needs of small businesses were of primary concern in designing the
filing form.  The respondents are asked to provide only readily
available information.  Experience indicates that there is no need for
more involved reporting by large business concerns to meet Agency needs.
  Hence, there is no separate requirement for small businesses versus
large business.  Only the basic requirement to identify products that
firms wish to continue to support is imposed on all registrants.   In
1990 the fee structure was changed to provide a 50% discount on the
first product supported.  Therefore, companies with only one registered
product received the greatest benefit from the discount.

5(d)  Collection Schedule

The payment of maintenance fees for all pesticide products is mandated
in FIFRA to occur annually.  Thus, there can be no option other than to
require a minimum submission of the filing form once a year.  Less
frequent information collection in this area would violate the statute.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)  Estimating Respondent Burden

Experience has shown that the average burden per respondent has remained
at approximately 1 hour.  The agency believes that the decline in actual
burden hours is due to the fact that registrants now have 17 years of
experience with the form, and the attrition of former pesticide firms
that no longer hold pesticide registrations not required to complete
this form.  In 2006, 1,720 firms responded to the collection request.  A
summary of firms and their number of registrations is provided below.

Table 1. Number of Registrations Held by Registrants (Summary)

Number of Products	Number of Registrants	Registrants Cumulative total
Cumulative %

   1 – 10	1,477	1,477	86%

  11 – 20	95	1,572	91%

  21 – 50	78	1,650	96%

  50 - 100	32	1,682	98%

    > 100	38	1,720	100%



Based on consultations with several respondents, both in the past and
for this ICR renewal, we believe that the average time required to
complete the maintenance fee filing form depends upon the number of
registrations held by the registrant.  A list of the registrants
contacted for this renewal is contained in Attachment C.  Below is the
breakdown of the burden associated with the 2006 maintenance fee filing
based on registrant-supplied information.

Table 2. Respondent Burden, by Number of Registrations Held      

Number of Products	Avg Time (hrs.)	Number of Registrants	Tot.  Hr.

   1 – 10	0.75	1,477	1108

  11 – 20	1.0	95	95

  21 – 50	2.0	78	156

  51 – 100	3.0	32	96

    > 100	5.0	38	190

Totals	   

1,720	1,645

PAPERWORK BURDEN: 

1645 (total hours) / 1720 (number of respondents) = 0.96 hrs./response.

These calculations were made using the average case scenario.   The
average case burden was developed from the above table.

Table 2a. Average Respondent Burden 

Collection Activities	Management	Technical	Clerical	Hours

1.  Read Instructions

0.25

0.25

2.  Plan Activities	0.20

	0.20

3.  Review Information	0.20

	0.20

4.  Complete Paperwork

0.20

0.20

5.  File Information

	0.11	0.11

Total	0.40	0.45	0.11	0.96

Total Annual Burden: Avg. Hr. per form (0.96) X No. Of Respondents
(1720) = 1645 hrs.

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.  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 C. 

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. 

The table below describes the average costs for completing one
maintenance fee filing form.  The average hourly burden was derived from
conversations with a selected group of respondents, and is described
above.

Table 3. Average Respondent Paperwork Costs

Collection Activities	

Mgmt.

($100.86/hr)	

Tech.

($64.80/hr)	

Cler.

($33.05/hr)	

Costs ($)



1.  Read Instructions	

	

0.25	

	

16.20



2.  Plan Activities	

0.20	

	

	

20.17



3.  Review Information	

0.20	

	

	

20.17



4.  Complete Paperwork	

	

0.20	

	

12.96



5.  File Information	

	

	

0.11	

3.64



TOTALS	

0.4

($40.34)	

0.45

($29.16)	

0.11

($3.64)	

73.14

ANNUAL PAPERWORK BURDEN: 0.96 hours X 1720 respondents = 1645 hrs.

ANNUAL PAPERWORK COSTS:

(a) Management: 	0.40 hrs.  X  $100.86/hr.  X  1720 respondents =
$69,392

(b) Technical:		0.45 hrs.  X    $64.80/hr.  X  1720 respondents =  
50,155 

(c) Clerical:		0.11 hrs.  X    $33.05/hr.  X  1720 respondents =    
6,253 

           TOTAL = $125,800

6(c)  Estimating Agency Burden and Cost

The cost to the Federal Government for this ICR is estimated to be
$86,319.  This is based on actual experience, and the following table
and calculations reflect averages.

Table 4. Agency Burden Hours per filing form and Total Cost

Collection Activities	Mgmt.

($93.07/hr)	Tech.

($66.34/hr)	Cler.

($47.17/hr)	 Total Cost ($)

1.  Generate Listings/Mass Mailing*

8	16	 1285.44

2.  Pre-load Tracking Data*

 4

265.36

3.  Receive/Review Submissions

	 0.2	16,226.48

4.  Enter Data into Tracking Sys.

	 0.2	16,226.48

5.  Reconcile Discrepancies

 0.5

3,317

6.  Respond to Questions

 0.5

9,951

7.  Verify Payment

 0.2

22,820.96

8.  File Documents

	 0.2	16.226.48

Total

N/A	N/A	86,319.20

* Estimated burden hours for items 1 and 2 reflect the entire set of
forms and the entire set of data pre-loaded.  The unit burden (per
filing form) for this operation is so small that it would not be
appropriate to express these figures in terms of units.  All other
figures reflect the burden for processing an average filing form. 
Therefore, the burden figures are not additive.

Item 3: 1720 responses X 0.2 hr.  X $47.17 per hour = 16,226.48

Item 4: 1720 responses X 0.2 hr.  X $47.17 per hour = 16,226.48

Item 5: 100 discrepancies X 0.5 hr.  X $66.34 per hour = 3,317

Item 6: 300 questions X 0.5 hr X $66.34 per hour = 9,951    

Item 7: 1720 payments X 0.2 hr X $66.34 per hour = 22,820.96

Item 8: 1720 responses X 0.2 hr.  X $47.17 per hour = 16,226.48

6(d)  Bottom Line Burden Hours and Cost Tables

Table 5. Total Annual Respondent and Agency Burden and Costs

	

	Total



	

Hours	

Costs



Annual Respondent Burden/Cost Estimates	

1,645	

$125,800



Annual Agency Burden/Cost  Estimates	

1,588	

 $86,319



6(e)  Reasons for Change in Burden

The total annual burden for respondents associated with this renewal is
1,645 hours.  This reflects a decrease of 118 hours from the last
renewal period.  The decrease represents the steady decline of the
number of pesticide registrants and, therefore, participation under this
program.  In 2006, the estimate is 1,720 registrants.  This represents a
decrease of 157 respondents from the 1,877 reported in the last ICR
renewal.  The average time required to complete the maintenance fee
filing form depends upon the number of registrations held by the
registrant. In addition to fewer respondents in 2006, a smaller
percentage of registrants held a small number of registered products.
This shift to a slightly larger average number of registrations per
registrant resulted in a slight increase in the average burden hours
required to complete the form, from 0.94 hours in the last ICR renewal,
to 0.96 hours.  This change is an adjustment.

6(f)  Burden Statement

The annual "respondent" (applicant) burden for the Pesticide Product
Registration Maintenance Fee program is estimated to average 0.96 hours
per form, or per respondent, as there is one form per respondent. 
According to the Paperwork Reduction Act, “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 is the time reading the regulations,
planning the necessary activities, reviewing the information, and
completing the maintenance fee filing form.  The agency may not conduct
or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. 
The OMB control number for this information collection appears at the
beginning and the end of this document, as well as on the maintenance
fee filing form itself.

The Agency has established a public docket for this ICR under Docket ID
No. EPA-HQ-OPP-2006-0660, 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-2006-0631 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.

Comments may be submitted to EPA electronically through
http://www.regulations.gov or by mail addressed to Director, Collection
Strategies Division, U.S. Environmental Protection Agency (2822T), 1200
Pennsylvania Ave., NW, Washington, D.C. 20460.  You can also send
comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503,
Attention: Desk Office for EPA.  Include docket ID No.
EPA-HQ-OPP-2006-0660 and OMB control number 2070-0100 in any
correspondence but do not submit fee waiver requests to these addresses.
 The information described in this ICR is to be submitted to the address
identified in section 4(b) of this supporting statement.

ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public
docket established for this ICR under docket identification number
EPA-HQ-OPP-2006-0660.  These attachments are available for online
viewing at   HYPERLINK "http://www.regulations.gov_" 
www.regulations.gov  or otherwise accessed as described in section 6(f)
of the supporting statement.

Attachment A:	EPA Form 8570-30 - Pesticide Registration Maintenance Fee
Filing Form.

Also available electronically at   HYPERLINK
"http://www.epa.gov/opprd001/forms/8570-30.pdf" 
www.epa.gov/opprd001/forms/8570-30.pdf 



Attachment B	The Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA) Section 4(i)(5).  Also available electronically at   HYPERLINK
"http://www.epa.gov/opp00001/regulating/fifra.pdf" 
http://www.epa.gov/opp00001/regulating/fifra.pdf  



Attachment C:	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.



Attachment D:	Record of Consultations Between the U.S. Environmental
Protection Agency and Respondents to the Information Collection Request:
 “Pesticide Product Registration Maintenance Fee”



	

: 	

	

	

 

February 12, 2007

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