
                          SUPPORTING STATEMENT FOR AN
                     INFORMATION COLLECTION REQUEST (ICR)

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

      1(a) Title: Pesticide Spray Drift Reduction Technologies  

	EPA ICR No.:  2472.02

	OMB Control No.:  2070-0191

	1(b) Short Characterization

	
      The Environmental Protection Agency (EPA or the Agency) is seeking approval for an information collection request (ICR).  EPA has initiated a voluntary information collection for studies to verify the effectiveness of application technologies for agricultural pesticide sprays that have the potential to significantly reduce pesticide spray drift.  The focus of these studies is on technologies, such as spray nozzles, shrouds and shields, and nozzle/drift reducing adjuvant/pesticide formulation specific combinations, which are used for aerial or groundboom applications to row and field crops.  Collectively these technologies are referred to as drift reduction technologies (DRTs).  

       This voluntary program encourages the identification and use of DRTs that can substantially reduce drift of pesticide spray droplets from the target application site (e.g., a corn field) downwind to non-target areas.  Exposures and adverse effects to humans, wildlife, crops and other vegetation from pesticide spray drift are well recognized.  Published research suggests 1  -  10% or more of applied agricultural pesticide sprays drift from the target field. 
      
      EPA has seen data supporting application technologies that will have the potential to significantly reduce the amount of spray drift.  Studies conducted to measure spray drift reduction would verify the percent reduction achieved, and thus identify these technologies.  EPA, with input from a variety of stakeholders, has developed a testing protocol appropriate to the needs of this voluntary program. 
      
      As additional manufacturers become aware of this program and complete verification studies of their technologies (in accordance with the protocol), they will submit the test data to EPA's Office of Pesticide Programs (OPP) for evaluation.  EPA/OPP evaluates each data submission and, if appropriate, assigns a drift reduction rating to the specific tested technology (e.g., a nozzle) based on the technology's reduction in potential spray drift as compared to a standard application technology.  The rating categories are described in section 2(b).  EPA/OPP will then post on its website the identification of the manufacturer, its validated technology, and the EPA-assigned DRT rating.   
      
      A pesticide registrant would have the option of selecting one or more categories of DRT-rated technologies (e.g., one star, two star, etc.) for the pesticide product label that is sent to EPA for approval.  As part of the label approval process, EPA would consider the rating category, along with the appropriate drift reduction factor, in its risk assessment and risk management decisions. Upon EPA's approval of that label, the applicator would refer to the website to identify verified DRTs whose use could be compatible with their application and then follow the label directions for the DRT-rated technology selected for use. Alternatively, the pesticide registrant could specify the use of a specific DRT-rated technology (not a category of technologies) on their label that is sent to EPA for approval. EPA would consider this technology and the percent of drift reduction in its risk assessment and risk management decision for that product.  Upon EPA's approval of that label, the applicator would then follow the specific directions for use on that label.
      
      Use of DRT technologies offers the potential for (1) fewer/reduced application restrictions needed to mitigate spray drift from the intended application site(s), (2) application of more of the spray on the target site or crop which can improve efficacy, (3) a reduction in the associated potential risks, and (4) a reduction in costs to the applicator and grower (reduced potential for insurance claims and enforcement penalties). Thus, applicators and growers will have incentives to use these drift reduction technologies.  As applicators and growers use DRTs on a more routine basis, benefits will accrue. Less pesticide loss to non-target sites means more of the applied pesticides are deposited on the intended sites.  This results in improved efficacy, reduced costs to applicators and growers, and reductions in overall risks.
      
2.  NEED FOR AND USE OF THE COLLECTION 

	2(a) Need/Authority for the Collection 

      For the purpose of this document, pesticide spray drift is defined as the physical movement of pesticide droplets through the air at the time of application or soon thereafter from the target site to any non- or off-target site.  This does not include pesticide movements by erosion, migration, volatility, or windblown soil particles after application. Spray drift is dependent on the design of application equipment, size of spray droplets, weather conditions, and other factors.
      Today, there is increased sensitivity to spray drift due to increased suburban development in agricultural areas and the need to protect threatened or endangered species.  Spray drift management is of interest to pesticide and other chemical manufacturers, application equipment manufacturers, growers, pesticide applicators, government agencies, advocacy groups, and the public. 
      
      Under Section 3 of the Federal Insecticide, Fungicide and Rodenticide Act (Attachment A), EPA's Office of Pesticide Programs (OPP) licenses (or registers) pesticide products.  The EPA/OPP is charged with licensing the sale and use of pesticides and ensuring that when applicators use pesticides according to product label directions, the pesticides will not cause unreasonable adverse effects to humans or the environment. To perform these important functions, EPA must rely, in part, on quality scientific data and other information to estimate a pesticide's potential hazards, exposures, and risks from its intended use. An important component of this scientific assessment is the potential risks to humans and the environment from pesticide droplets or particles that drift from the application target site (e.g., a corn field) during or shortly after application. Generally, applications of most if not all sprays result in some amount of drift:  it is not possible to completely eliminate drift.
      
      EPA has spent considerable time and resources reviewing the best available science to better understand and estimate drift.  Given our current understanding, we know that application technologies and how they are used, meteorological conditions, and applicator behavior can profoundly affect the amount of pesticide spray drift.
      
      Over the years, industry, pesticide applicators, and university and government researchers have developed and employed a variety of pesticide application strategies and technologies to reduce spray drift. Examples of drift reduction technologies include spray nozzles, shrouds and shields, and nozzle/drift reducing adjuvant chemical combinations. Although these and other technologies have the potential to reduce pesticide spray drift, there is often uncertainty about their effectiveness or performance. Verification testing of technologies would provide quantitative, quality-assured data regarding the specific effectiveness of the tested technology to reduce spray drift.  EPA believes that equipment manufacturers, pesticide registrants, and others who have an interest in reducing spray drift can conduct these verification studies using EPA's test methods or another suitable peer-reviewed method provided they have access to appropriate test equipment and facilities.  In this document, EPA refers to these entities collectively as manufacturers.  These studies will demonstrate the potential for individual technologies to reduce spray drift by reducing the amount of the smallest droplets in spray that are most subject to drift, by trapping droplets within shields or shrouds around spray nozzles, or by other means.
      
      EPA envisions that use of DRTs will be included in the agency's pesticide risk assessments and risk management decisions for establishing application restrictions.  
      
      Use of these DRTs in the application of pesticides has the potential for significant benefits.  Benefits to growers and applicators would include:
 Substantiated, accepted performance claims of the verified technologies
 Greater deposition of applied pesticides on the target sites/crops which may result in improved efficacy of pest or weed control 
 With greater on-target deposition, potential reductions in application rates with a commensurate reduction in application costs
 Reduction of the currently estimated application restrictions for preventing adverse effects (e.g., smaller or no buffer zones) 
 Applications can be made with increased flexibility in application timing and options potentially saving applicators time and costs
 Applications under a wider range of environmental and application method conditions
 Reduced spray drift resulting in fewer incidents of adverse effects
 Fewer claims of violations of pesticide labeling requirements that need to be investigated by enforcement authorities
 Reduction in enforcement violation penalties
 Less litigation and associated costs, including insurance claim costs
         
         Benefits to manufacturers and pesticide registrants would include:
 Increased demand for DRT-rated equipment and pesticide products offering the option of DRT application methods on the label as applicators and growers use DRTs on a more routine basis. 
         
         
         
         
         Benefits to the public and the environment would include:
 Reduced spray drift means fewer incidents of adverse effects from spray drift to humans, and terrestrial and aquatic organisms and ecosystems, including threatened or endangered species.

      For its voluntary program, EPA intends to use the following `star' rating system  https://www.epa.gov/reducing-pesticide-drift/epa-verified-and-rated-drift-reduction-technologies similar to that used by the United Kingdom (U.K.).  (See http://www.pesticides.gov.uk/guidance/industries/pesticides/topics/using-pesticides/spray-drift/leraps/local-environment-risk-assessment-for-pesticides-leraps.htm).   
      Similar to the U.K. voluntary program, EPA's voluntary program would verify performance of the DRT and provide a website with the rating information for each verified DRT.  The website would also provide guidance to manufacturers on participating in this voluntary program and guidance to pesticide applicators for selecting DRTs with specific `star' ratings as specified on pesticide product labels.  The ability to incorporate information on the effectiveness of DRTs into Agency risk assessments and risk management decisions should allow pesticide applications that are protective of the environment and the health of those in the vicinity. Increasing the use of verified DRTs should allow more targeted, and therefore more effective, pesticide applications while significantly increasing public health and environmental protection by reducing the drift of pesticides to areas beyond the application sites.

	2(b) Practical Utility/Users of the Data

      Every registered pesticide product has a label that contains specific use directions and restrictions on how applicators are to properly and safely use the product.  EPA relies on scientific information and risk assessments to determine use restrictions appropriate for specific products and uses. EPA routinely uses models, such as AgDRIFT[(R)] and AGDISP(TM), to estimate the deposition of spray droplets downwind from the application site.  In its risk assessment, EPA/OPP correlates a pesticide's toxicity values with the estimated amounts of off-target spray drift to determine potential risks to sensitive sites, species, and humans. This analysis provides the basis for risk management measures, such as a buffer zone and its size, maximum wind velocity, pesticide release height, spray quality, and other application variables, to prevent unreasonable risks.
      
      DRT verification testing would be performed according to a protocol (Generic Verification Protocol for Testing Pesticide Application Spray Drift Reduction Technologies for Row and Field Crops (Attachment B)) developed with input from the Stakeholder Technical Panel (described in section 3(c)).  Testing conducted according to this protocol or a suitable peer- reviewed alternative will provide high quality data. The protocol addresses three testing approaches:  low speed wind tunnels (to simulate application by groundboom equipment), high speed wind tunnels (to simulate application by aircraft), and field testing (groundboom or aerial application).  One of the most important concepts in the protocol is the use of a reference nozzle.  EPA's protocol was specifically designed to include a reference nozzle. By requiring the use of a specific reference nozzle EPA can compare technologies and make sure that, for example, a 25 percent reduction for one technology is consistent with the same 25 percent reduction for another technology.
      
      
      
      Generally, testing of smaller technologies, such as spray nozzles or nozzle/adjuvant combinations, would be conducted in wind tunnels which measure the amount of the smallest driftable droplets, which are referred to as fines. The DRT rating of the test nozzle is determined by calculating the percent reduction of driftable fractions (fines) compared to the reference nozzle. The DRT rating will be based on the difference between the amounts of driftable fines from the test and reference nozzles.  
       EPA believes that field studies will most likely be used to determine drift reduction for shrouds or other large equipment that cannot fit into a wind tunnel. Vendors may also choose to test nozzles and nozzle/adjuvant/formulation specific combinations with field studies. Unlike wind tunnels, DRT field studies will collect data on downwind deposition of droplets resulting from an application using the larger technology and the reference nozzle.  Depositions are measured at varying distances.  EPA can use these data to estimate the percent drift reduction from the use of the tested technology.  Each of these field studies is likely to be unique, and involve case-by-case considerations.  
      
      EPA limited the protocol to technologies for application to row and field crops because a large majority of agricultural pesticides are applied to these crops by groundboom and aerial equipment.  Thus, a focus on encouraging the use of DRTs for row and field crop uses should have an overall greater benefit to drift reduction.  The Agency recognizes that verified DRTs for row and field crops may also be appropriate for use on other non-agriculture sites such as sod farms or golf courses as well as orchard/vineyard floors.
      
      Use of a standardized DRT test protocol will enable EPA to make valid comparisons of test results from nozzle to nozzle, to nozzle/adjuvant/formulation specific combinations to other tested technologies.  The drift reduction estimated by the study results would then be used to assign the technology its DRT rating. EPA's protocol and a format for data submission will be available via the EPA website at: https://www.epa.gov/reducing-pesticide-drift/about-drift-reduction-technology-program 
      
      EPA's process for review of submitted studies would:
 Verify the adequacy of the study
 Determine the potential for the DRT to reduce drift compared to a reference
 Based on that comparison, assign each verified technology to one of four drift reduction categories represented by stars:
 Less than 25% reduction = No DRT rating
 25 to 50 % reduction = DRT* rating
 51 to 75% reduction = DRT** rating
 76 to 90% reduction = DRT*** rating
 greater than 90% reduction = DRT**** rating
      
      As EPA/OPP rates technologies and makes the ratings available to the public via its website, EPA/OPP will encourage pesticide registrants to submit applications for new and amended registrations to include the use of verified DRTs on their product label use directions (e.g., "Apply this product with DRT** technologies."), as an alternative option to using application technologies that do not have a DRT rating. Applications with non-rated technologies will likely have greater application restrictions.  In review of these registration applications, EPA/OPP will "credit" the DRT-rated technology in the risk assessment-management decision (i.e., use a drift reduction factor in the risk assessment) instead of using a conservative default assumption that does not assume any spray drift reduction. Pesticide labels that include use directions that specify DRT-rated technologies would also specify spray drift risk management measures, such as buffer zones, maximum wind speed, or release height. Pesticide product labels will specify use of a technology with a particular DRT rating. Eventually, applicators will have a variety of technologies from which to choose once EPA/OPP has been able to review and rate multiple submissions on a variety of technologies. 
      
      Pesticide applications conducted in accordance with products labeled with the use of DRTs should result in significantly less off-target spray drift deposition and risk from applications, compared to applications conducted without the use of DRTs.  Reduction in off-target deposition and risk could result in a lessening of application restrictions necessary to prevent adverse risks from spray drift, such as reduction or elimination of a buffer zone, or allowing applications during greater wind velocity or release height.  Conversely, for identical or substantially similar pesticides without a DRT claim, EPA/OPP cannot apply the credit of a DRT claim and therefore would likely require greater application restrictions to address potentially greater off-target drift and risks. 
      
      Pesticide registrants could choose to label their products for use with both standard application equipment (non-DRT), as most are currently labeled, and DRT-rated equipment or technologies, thus giving the applicator a choice.  In this case such labels would have two sets of application restrictions:  one set of restrictions if the product is applied without DRT and another set of restrictions if the product is applied with a DRT.

      EPA anticipates labels would have a table, similar to the following, to express possible buffer zones, or other key application parameters such as maximum wind speed or release height.  
      
Label Directions--
Droplet Size
                               Buffer Zone (ft.)


                                     Human
                                    Health
                                    Aquatic
                                  Terrestrial
Non-DRT Rated Technology
Fine to Medium
                                      100
                                      100
                                      25
DRT* Rated Technology
                                      ---
                                      30
                                      25
                                      25
DRT** Rated Technology
                                      ---
                                      15
                                      15
                                      10
	
      The buffer zones for a particular label would be calculated specific to the active ingredients in the product and the use patterns on that label. The buffer zones on any particular label would represent the buffer needed for human health as well as the most sensitive of the non-target species. 

      In preparing to make a pesticide application labeled with a DRT claim, applicators would refer to the EPA website to identify the specific application technologies which have the DRT star rating identified on the pesticide product label.  For example, products labeled for use with DRT*** technologies, the applicator would refer to the EPA's DRT website to see the identities of the specific DRT*** rated technologies to make the application. Additionally, EPA expects manufacturers of the verified DRTs will identify those technologies in their catalogs and on their websites.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 

	3(a) Non-Duplication 

	OPP is not aware of any public or private assembly of verification data on the efficiency of DRT technologies.  Since each equipment or technology manufacturer would submit information unique to its products offered for sale, duplication is unlikely to occur.
	
	3(b) Public Notice Required Prior to ICR Submission to OMB 

	Pursuant to 5 CFR 1320.8(d), EPA is proposing to renew this ICR. EPA is publishing a notice in the Federal Register that provides 60-day public notice and comment period. The materials related to the renewal of this ICR, as well as any comments submitted during the public comment period may be accessed as described in section 6(e) of this supporting statement.
            
	3(c) Consultations

	In 2006, EPA established a technical panel to develop test methods to verify the potential effectiveness of drift reduction technologies. The technical panel includes representatives from EPA's Office of Pesticide Programs and Office of Research and Development, other government agencies (United States Department of Agriculture, California Department of Pesticide Regulation, and Canada's Pesticide Management Regulatory Agency), pesticide and application equipment industries, pesticide applicators, growers, environmental interests and university researchers. While the work of the panel to produce the verification protocol is considered to be completed, EPA continues to coordinate informational activities with panel members.  

	Since 2006, EPA has made presentations to various entities.  A few recent examples are:
 August 2011, at the Pesticide Application and Drift Modeling Workshop in Christchurch, New Zealand,  
 February 2012, at the Weed Science Society of America 2012 Annual Meeting,
 May 2012, at a meeting of the Pesticide Program Dialogue Committee (PPDC) there was an update on DRT Technology. (see http://www.epa.gov/pesticides/ppdc/), 
 May 2012, at the Council of Producers and Distributors of Agrotechnology, 2012 Adjuvants and Inerts Annual Conference,
 August 2012, a webinar for members of the Agricultural Retailers Association,
 April 2013, at the State-FIFRA Issues Research and Evaluation Group Meeting,
 May 2013, at the Council of Producers and Distributors of Agrotechnology, Adjuvants and Inerts Annual Conference,
 August 2013, at the Agrochemical Formulation USA Workshop,
 December 2013, at the Minnesota Crop Pest Management Course.
 May 2016, at the Council of Producers and Distributors of Agrotechnology, Adjuvants and Inerts Annual Conference
 September 2016, at the Husker Harvest Days Farm Show
During and after these presentations, many stakeholders provided information to EPA that was considered in the development of this program.

      As part of these contacts, EPA has received for review, protocols and data from manufacturers as well as notices from additional manufacturers who are conducting, or in the near future anticipate conducting, studies to measure spray drift reduction.  Such studies could be submitted to EPA as "stand-alone" submissions from an equipment manufacturer in which the applicant only seeks to have his technology receive a `star-rating' and posting on the DRT website.  Alternatively, the study could be submitted as part of an application for registration or amended registration of a pesticide product.  As part of that process, EPA would approve the use directions for the label for use of `star-rated' drift reduction technologies.
      
      Under 5 CFR 1320.8(d)(1), agencies are required to consult with potential ICR respondents and data users about specific aspects of ICR's before submitting an original or renewal ICR to OMB for review and approval.  During the development of this ICR, EPA staff will contact appropriate stakeholders and ask them for their assessment of the regulatory burden estimates expressed by the Agency in this ICR.  A summary of these consultations will be provided in the supporting statement during the second comment period.
      
      3(d) Effects of Less Frequent Collection
      >
	Not applicable.  Since this is a voluntary information collection, each tmanufacturer would determine if they wished to submit information to EPA, and their schedule for doing so.  

	3(e) Compliance with General OMB Guidelines

	This collection of information is consistent with all OMB guidelines under 5 CFR 1320.6.  

	3(f) Confidentiality 

	EPA will not collect proprietary trade secrets or other proprietary information.  The publically available information would be limited to the name of the technology manufacturer company, the name of and description of the technology including necessary application details and the `star' rating assigned by the agency.  Confidentiality of respondent information (the submitted studies) will be ensured to the maximum extent allowed by law.  The information collection will comply with the Privacy Act.

	
      
      
      
      
      3(g) Sensitive Questions 

	The information requested under this voluntary collection does not include questions of a sensitive nature.  Under this ICR, agricultural equipment manufacturers would submit to EPA research conducted according to protocols that were developed in cooperation with a Stakeholder Technical Panel.
	
4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

	4(a) Respondents/NAICS Codes

      Potential respondents affected by the voluntary collection activities under this ICR include pesticide application equipment manufacturers, chemical manufacturers, pesticide registrants, university researchers, and others who have an interest in reducing spray drift.  The North American Industrial Classification System (NAICS) codes for the principal respondents are:
      
Producers of pesticide products
32532
Crop Production
111
Research and Development in the Physical, Engineering, Life Sciences
541710
Colleges, universities, and professional schools
611310
      
This listing is not intended to be exhaustive, but rather provides a guide for readers regarding entities likely to be affected by this action.

	4(b) Respondent Activities

	EPA believes that most respondents will contract with a testing facility to conduct study(ies) that meet the criteria in the testing protocol.  (Attachment B) This may involve the following activities:
 Make arrangements for testing with a contract laboratory
 Submit contractor-prepared study reports to EPA for review and evaluation

5.  THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

	5(a) Agency Activities

	EPA will perform the following activities under this ICR:
 Review and evaluate the submitted study:  Assign a drift reduction `star' rating
 Post rating on EPA's website (https://www.epa.gov/reducing-pesticide-drift/epa-verified-and-rated-drift-reduction-technologies) 
      Although EPA has discussed the need to conduct risk assessments that credit the use of DRT, such risk assessments will be part of the label review process conducted as part of a registration action. (Registration actions are already covered under a different ICR.)
         
         
	
       5(b)	Collection Procedures
	
      Equipment manufacturers, chemical manufacturers, pesticide registrants, university researchers, and others who have an interest in reducing spray drift determine to "opt-in" to the voluntary program and submit information to EPA.  EPA is not requiring submission of this information, and does not intend to issue a Data Call-In for DRT studies.  This means that EPA will collect only the information submitted. 

	5(c)	Small Entity Flexibility

	Small businesses can choose whether or not to participate in the voluntary program by arranging for the needed testing, and then submitting the study to EPA.  Since this is a voluntary submission, there are no deadlines, and small businesses can create their own submission schedules.

	5(d)	Collection Schedule

	There is no collection schedule.  Potential respondents can choose whether or not to participate in the voluntary program, as well as the timing of any submissions. EPA anticipates that each year 4 to 7 companies will submit studies for review and evaluation.  EPA has identified a number of equipment manufacturing companies, pesticide registrants, and adjuvant chemical manufacturing companies that could be interested in submitting DRT studies to EPA.  EPA estimates that 12 companies could submit studies during the 3-year timeframe covered under this ICR. A study is a submission that could have the results of testing one or more nozzles, one or more nozzle/adjuvant/formulation specific combinations, one larger piece of equipment, or a combination of technologies.

 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

      This ICR includes all paperwork burden associated responses to the collection associated with wind tunnel and field studies for the SDRT program. Estimates of paperwork burden hours and costs for both types of studies are provided in this section. There are no other paperwork burdens addressed by this ICR. 

      Typically, EPA estimates the respondent paperwork burden hours for an ICR, then multiplies by the fully loaded wage rates of the appropriate labor categories to estimate costs. However, for this ICR costs are estimated first, then burden hours are back-calculated by dividing costs by fully loaded wage rates. This methodology has been used for other ICRs where respondents generally hire laboratories to conduct studies and prepare a report of the resulting data and conclusions. In these cases, the Agency uses 35% of the total cost of a study as a proxy for the total potential paperwork costs associated with the study. Although nearly all of these paperwork costs are typically borne by the respondent's contractor, the 35% estimate covers all associated paperwork activities by both the respondent and the contract laboratory, including reading instructions, planning the study, recording results, preparing, reviewing and submitting the report to EPA, and storing the data.

      EPA uses 35% of the estimated total cost of the study to calculate the total paperwork cost related to the study.  The 35% of the test cost is disaggregated by labor category, and then the estimate of the burden hours is calculated by using the loaded labor rates.  To disaggregate by labor category, the Agency considered the estimated distribution of paperwork activity across the labor categories represented and the existing methodology assumption that paperwork activities for data generation mostly involve the technical staff, with fewer activities related to management and clerical staff.  Figure 1 illustrates the method for calculating the paperwork burden of data generation.

                     Calculate 35% of the Total Study Cost
Divide the 35% of Total Cost into Labor Categories:
20% for Managerial 
65% for Technical
15% for Clerical
Divide cost for each category by Fully Loaded Wage Rate for that Labor Category
                        Burden Hours by Labor Category
                     Calculate 35% of the Total Study Cost
Divide the 35% of Total Cost into Labor Categories:
20% for Managerial 
65% for Technical
15% for Clerical
Divide cost for each category by Fully Loaded Wage Rate for that Labor Category
                        Burden Hours by Labor Category
Figure 1: Method for Calculating Paperwork Burden from Test Costs


Similar to the DCI ICR (OMB Control No. 2070-0107), this approach assumes and incorporates the following core considerations:

 Respondents have studies conducted consistent with the Agency's protocol (Attachment B), and none of the data is waived.
 All studies are conducted by an independent laboratory.
 Paperwork cost is disaggregated by labor category as follows:
 Managerial (20%)
 Technical (65%)
 Clerical (15%)
 Labor rates are fully loaded, meaning that they include the estimated costs of wages, overhead, and benefits paid to an employee. 

   Pesticide companies can help offset the costs of the studies by working with a SDRT company to test their products in each study setting.  Each study submitted is considered to be a single response, even if multiple studies are submitted by the one respondent.

Burden and cost estimates are provided and described in the following subsections. 

      6(a)	Estimating Respondent Cost 

      EPA contacted a research laboratory to estimate the total cost of performing a typical wind tunnel study, and the laboratory reported that EPA-related testing would cost a SDRT firm approximately $500 per treatment.  Studies gather spray diffusion data on the different permutations of treatments (nozzle/pressure/tank-solution combinations).  EPA assumes that an average wind tunnel study would consist of 50 treatments, and therefore cost a total of $25,000. Likewise, the total cost of a field study is estimated to be $100,000. 

As stated above, total paperwork costs are assumed to be 35% of the total cost of a study. EPA uses historical distribution of paperwork costs among labor categories of 20% managerial, 65% technical and 15% clerical. Estimated respondent paperwork costs per study are presented in Table 1, for both wind tunnel and field studies, by labor category and in total. The paperwork cost for a wind tunnel study is $8,750, and $35,000 for a field study.  

Table 1: Estimated Respondent Paperwork Costs per Response, by Type of Study, by Labor Category

Type of Study
Total Cost of Study[1]
Total Paperwork Cost[2]
Managerial[3]
Technical[4]
Clerical[5]



($126.56/Hr)
($71.69/Hr)
($42.97/Hr)



                          Paperwork Cost by Category
1 Wind Tunnel Study
$25,000 
$8,750 
$1,750
$5,688
$1,313
1 Field Trial Study
$100,000 
$35,000 
$7,000
$22,750
$5,250
 Estimate from independent testing laboratory
 35% of total cost of study
 20% of paperwork cost
 65% of paperwork cost
 15% of paperwork cost

      6(b)	Estimating Respondent Burden 

EPA uses the estimated paperwork costs associated with SDRT study responses, to calculate the respondent burden.  The paperwork cost for each labor category (Table 1) is divided by the fully loaded wage rate for that category to get the burden hours for that labor category.  Then, these labor category burden hours are summed to get the total respondent burden.

The estimated burden hours for one wind tunnel study for each labor category is 14 for managerial, 79 for technical and 31 for clerical, for a total of 124 burden hours.  The burden hours for one field study for each labor category is 55 for managerial, 317 for technical and 122 hours for clerical for total of 495 burden hours.  These burden hour estimates are shown in Table 2.

Table 2. Estimated Respondent Burden per Response by Type of Study, by Labor Category
Type of Study
                           Burden Hours per Response

                                  Management
                                   Technical
                                   Clerical
                                     Total

                                    $126.56
                                   per hour
                                    $71.69
                                   per hour
                                    $42.97
                                   per hour

Wind Tunnel Study
                                      14
                                      79
                                      31
                                      124
Field Study
                                      55
                                      317
                                      122
                                      495
Wage rates source: Bureau of Labor Statistics (3/30/2016), http://www.bls.gov/oes/current/naics4_325300.htm 
Numbers may not calculate exactly because they are displayed as rounded numbers.
Burden per Response, by labor category: 
 Cost per Response for labor category (Table 1) / Wage Rate for category = Burden Hours per Response for each labor category
 Sum of Burden Hours per Response for each category = Total Burden Hours per Response

To estimate the total annual respondent burden and cost of this collection of information, for each type of study, the Agency multiplies the estimated burden hours and costs per study (response) by the estimated number of responses submitted annually. EPA estimates that there will be approximately 20 wind tunnel studies submitted during the three-year period under this ICR, or about seven responses per year, on average, which is used to calculate total respondent burden.

Respondents also have the option of submitting a more extensive field study to test the effectiveness of the SDRT equipment outside of a controlled laboratory setting.  EPA estimates that two field studies will be submitted during the three-year period for this ICR.  The Agency conservatively assumes that there will be one field study submitted per year, on average, under this ICR.  The reason for this change is that EPA expects that for some respondents, data from a field study will be more appropriate due to the type of technology. While field studies are significantly more expensive than wind tunnel studies, some respondents may determine that the results more accurately reflect the effects associated with their specific technology.

Therefore, EPA assumes that respondents will submit an average of seven wind tunnel study responses and one field study response annually to the Agency during the three-year period that this ICR is in effect. This is a total of eight responses per year, including both types.

Agency economists updated the estimated wages, benefits and overhead for all labor categories for the affected industry and EPA employees based on publicly available data from the US Bureau of Labor Statistics.  The sources and formulas used to estimate the fully loaded wage rates for this ICR renewal are presented in Attachment C for respondents, and Attachment D for the Agency.

Assuming seven wind tunnel studies and one field trial study are submitted annually, the burden and costs associated with these activities are 1,361 hours and $96,250.

Table 3: Estimated Total Annual Respondent Burden and Costs 
Type of Response
Total Annual Burden[1] (Hours)
Total Annual Cost[2] ($)
Wind Tunnel Study
                                                                            868
                                                                         61,250
Field Study
                                                                            495
                                                                         35,000
Total
                                                                          1,361
                                                                         96,250
 Total Annual Respondent Burden: 
 Total Burden per Wind Tunnel Response (Table 2) x 7 wind tunnel studies per year = 868 Total Annual Burden Hours for wind tunnel studies
 Total Burden per Field Study Response (Table 2) x 1 field study per year = 495 Total Annual Burden Hours for field studies
 Total Annual Respondent Cost:
 Total Cost per Wind Tunnel Response (Table 1) x 7 wind tunnel studies per year = $61,250 Total Annual Cost for wind tunnel studies
 Total Cost per Field Study Response (Table 1) x 1 field study per year = $35,000 Total Annual Cost for field studies

	6(c)	Estimating Agency Burden and Cost

In the previous ICR, EPA anticipated that the number of studies submitted would be beyond the capacity of the agency to conduct a thorough and timely review of all the submitted studies and that the Agency would need the services of a contractor to assist in reviewing the results of the wind tunnel and field studies to verify the accuracy of the test results.  However, under the first ICR, the studies submitted did not actually warrant the services of a contractor for review.  Thus there are not any contractor burden hours or costs associated with reviewing the studies in this ICR.

EPA conducts a review to ensure the results from the SDRT studies are clear and comply with the program.  If supported by the results, EPA assigns a star rating based on the percent drift reduction indicated.  EPA's burden hours were apportioned using EPA's estimates from the previous SDRT ICR regarding the collection activities that Agency management, technical, and clerical staff performed.

EPA estimated the Agency's review burden to be two management hours and twenty technical hours, regardless of the type of study.  Using EPA's estimates regarding collection activity apportionment and applying the hourly rate for each labor category, the Agency's burden to perform a review of a study result is 22 hours and $1,877.

Table 4. Agency Burden and Cost Estimates per Response
                             Collection Activities
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

$124.89/hour
$81.37/hour
$46.41/hour


Plan activities
                                       1
                                      2.5
                                       0
                                      3.5
                                                                           $328
Gather/create information
                                       
                                      2.5
                                       0
                                      2.5
                                                                           $203
Compile and review
                                       1
                                      13
                                       0
                                      14
                                                                         $1,183
Complete paperwork
                                       
                                      1.5
                                       0
                                      1.5
                                                                           $122
Store/maintain data
                                       
                                      0.5
                                       0
                                      0.5
                                                                            $41
                                     TOTAL
                                       2
                                      20
                                       0
                                      22
                                                                         $1,877
Wage rates source: Bureau of Labor Statistics (3/30/2016), http://www.bls.gov/oes/current/naics4_999100.htm 
Numbers may not calculate exactly because they are displayed as rounded numbers.

Assuming that eight studies are submitted annually (seven wind tunnel studies and one field trial study), the Agency's annual burden and costs associated with these responses are 176 hours and $15,018.

Table 5: Estimated Total Annual Agency Burden and Costs
Total Annual Burden[1] (Hours)
Total Annual Cost[2] ($)
                                      176
                                    15,018
 Total Annual Agency Burden: 
 Total Burden per response (Table 4) x 8 total studies per year = 176 Total Annual Burden Hours
 Total Annual Agency Cost:
 Total cost per response (Table 4) x 8 total studies per year = $15,018 Total Annual Cost 
      
      6(d)	Bottom Line Paperwork Burden Hours and Costs

Table 6. Total Annual Paperwork Burden and Cost Estimates for Pesticide Spray Drift Reduction Technologies

                                TOTAL ESTIMATES

                                 Burden Hours
Costs
Respondent Burden/Cost Estimates
                                                                          1,361
                                                                        $96,250
Agency Burden/Cost Estimates
                                                                            176
                                                                        $15,018

	6(e)	Burden Statement

The previous SDRT ICR estimated the total annual respondent burden to be 539 hours and $73,000.  The total annual respondent burden and costs associated with this ICR are 1,361 hours and $96,250.  This represents an increase of 822 hours and $23,250 from the previous SDRT ICR.  The change in the burden and costs from the previous ICR are due to an additional field study expected to be submitted; updating cost information for wind tunnel studies; and changing the methodology to calculate the respondent's burden and costs, by using 35% of the total test cost as an estimate of total paperwork costs, then using the cost estimate to back-calculate the burden hour distribution for each labor category using fully loaded wage rates which were updated from the previous ICR.  These changes are an adjustment.  

      Burden is defined at 5 CFR 1320.03(b). 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 numbers for EPA's regulations, are listed in 40 CFR part 9, and appear on the information collection instrument as applicable, i.e., form or instructions.    
  	The Agency has established a public docket for this ICR under Docket ID No. EPA-HQ- OPP-2016-0506. It is available electronically through http://www.regulations.gov.  Follow the online instructions for submitting comments.  Do not submit electronically any information you consider to be Confidential Business Information (CBI) or other information whose disclosure is restricted by statute.

       A hard copy is available for viewing at the OPP Docket in the Environmental Protection Agency Docket Center (EPA/DC), located in EPA West, Room 3334, 1301 Constitution Ave, NW, Washington, DC 20460. The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Public Reading Room is (202) 566-1744, and the telephone number for the OPP Docket is (703) 305-5805). Please review the visitor instructions and additional information about the docket available at http://www.epa.gov/dockets.
      
      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.  
         
      Comments regarding burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden can be sent to: Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Avenue, 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-2016-0506 and OMB control number 2070-0191 in any correspondence.
ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for this Information Collection Request (ICR) under the docket identification number EPA-HQ-OPP-2016-0506. These attachments are available for online viewing at www.regulations.gov unless otherwise accessed as described in the sections below.  
Attachment A:  7 U.S.C. 136a - FIFRA Section 3: This attachment can be accessed via the internet at: http://www4.law.cornell.edu/uscode/7/usc_sec_07_00000136---a000-.html

Attachment B:  Generic Verification Protocol for Testing Pesticide Application Spray Drift Reduction Technologies for Row and Field Crops ( https://epa.gov/reducing-pesticide-drift/generic-verification-protocol-testing-pesticide-application-spray-drift )

Attachment C:  Wage Rates for Pesticide Registrants Using NAICS 325300

Attachment D: Wage Rates for the Federal Government Using NAICS 999100


	
