SUPPORTING STATEMENT FOR AN 

INFORMATION COLLECTION REQUEST (ICR)

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a).	Title of the Information Collection  

Pesticide Registration Fees Program

OMB Nos.:  2070-new

 		

EPA Nos.:  1214

1(b).	Short Characterization/Abstract 

In compliance with the Paperwork Reduction Act (PRA) (44 U.S.C. 3501 et
seq.), this document announces that Environmental Protection Agency’s
(EPA), Office of Pesticide Programs (OPP) is planning to submit a
request to consolidate several existing approved Information Collection
Requests (ICRs) to the Office of Management and Budget (OMB). Before
submitting the consolidated ICR to OMB for review and approval, EPA is
soliciting comments on specific aspects of this information collection. 
The new consolidated ICR, entitled: “Pesticide Registration Fees
Program” and identified by EPA ICR No. 1214 and OMB Control No.
2070-[new] will consolidate the following currently approved ICRs:
"Pesticide Registration Maintenance Fees," (EPA No. 1214.06, OMB No.
2070-0100) scheduled to expire on November 30, 2010 and “Pesticide
Registration Fee Waivers (PRIA)" (EPA No.214.02, OMB No. 2070-0167,)
scheduled to expire on January 31, 2010.

	

Collectively, these ICRs enable the EPA to process, grant and collect
pesticide registration fees and waivers. This information collection
will allow EPA to process requests for waivers under the Pesticide
Registration Improvement Act (PRIA). The collection also provides a
practical means of communication between the registrants and EPA’s
Office of Pesticide Program (OPP) to collect registration maintenance
fees from registrants as required by law.  EPA is specifically looking
for comments about the clarity and ease of public review this
consolidated document creates.

1(c).	The Consolidated Document

These ICRs are being consolidated in to one document because the
programs they represent share similar respondent populations,
registrants required to submit fees in order to enhance the review of
pesticide products under FIFRA. The Agency believes consolidating these
ICRs into one document will increase the clarity of review for the
public and will streamline Agency review for such programs.  

	The document is divided into two separate individual parts, Part A and
Part B.  No changes to the currently approved ICRs have been made. 

 

Part A 

Part A describes the Pesticide Registration Fee Waivers (PRIA) program
which authorizes EPA to process requests for waivers of fees. The
program allows for 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 business, for minor uses,
and for actions solely associated with the Inter-Regional Project Number
4 (IR-4). State and federal agencies are exempt from payment of fees.

This consolidated document does not change any substantive parts of the
original document. This document is being re-submitted to OMB for: 1)
re-assignment of OMB document tracking number and 2) public comment on
the consolidated document. 

Part B

Maintenance Fees are collected from pesticides registrants as required
by law.  Respondents complete and submit EPA Form 8570-30 indicating the
respondent’s liability for the registration maintenance fee. Annually
the Agency provides registrants a list of the registered products
currently with the Agency. Registrants are provided the opportunity to
review the list, determine its accuracy, and remit payment of
maintenance fee. The list of products has space identified for making
those products to be supported and those products that are cancelled.
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.  

This consolidated document does not change any substantive parts of the
original document. This document is being re-submitted to OMB for: 1)
re-assignment of OMB document tracking number and 2) public comment on
the consolidated document. 

Part A 

Applications and Summary Report for Emergency Exemption;

 OMB Number 2070-0100 and EPA Number 1214.07 

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.

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”



	

Part B 

Applications and Summary Report for Emergency Exemption;

 OMB Number 2070-0167 and EPA Number 1214.03 

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.

Page   PAGE  1  of   NUMPAGES  32 

