

                                    Attachment C
                                          
Summary of Consultations for the Renewal ICR, entitled " Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides (Renewal)"
OMB Control No. 2070-0198; EPA ICR No. 2511.02; Docket No. EPA-HQ-OPP-2018-0418


 Representatives contacted:
 VA Dept. of Agriculture & Consumer Services
 EPA Region 6 (Texas: Pesticide Section)
 EPA Region 5 (Illinois: Land & Chemicals Division)
 Questions and Responses:
Participation in the consultation process is voluntary and the Agency may or may not receive comments. EPA received responses from the following representatives:

 U.S. EPA Region 5 (Illinois: Land & Chemicals Division)
 VA Dept. of Agriculture & Consumer Services

The questions asked, and their feedback to those questions, are provided below: 

Organization:     Virginia Department of Agriculture & Consumer Services_____________ 
Date: December 17, 2018 	 	 


Publicly Available Data

 Is the data that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency?  
       
       No.  The data in Work Plan Template is the only annual description of tasks to be undertaken by the recipients in their respective assistance agreements using federal funds.  The entire electronic document is fully incorporated in their periodic grant applications, which are submitted electronically through http://www.grants.gov .

 If yes, where can you find the data?  (Does your answer indicate a true duplication, or does the input indicate that certain data elements are available?) 

(2)	 Frequency of Collection 
      
Can the Agency collect the information less frequently and still produce the same outcome?
       
       No.  The Work Plan Template is updated once per year for planning purposes, and can be used either 1) annually; 2) semi-annually; or 3) quarterly for reporting purposes.  Region 5 uses the Template for mid-year and year-end reporting; other Regions may use quarterly reporting for enhanced accountability, if necessary.  Prudent grants oversight requires at least annual reporting.  When activities under continuing environment program grants are relatively stable from year to year (and when multi-year grants are awarded), the Work Plan Template can be readily copied and updated from the current year to the next.

(3)	Clarity of Instructions 
  

 Based on the instructions in the 2018-2021 FRFRA Cooperative Agreement Guidance (February 14, 2017), is it clear what you are required to do and how to submit such data?  If not, what suggestions do you have to clarify the instructions?
    
       The Cooperative Agreement Guidance instructions are somewhat lengthy, but they are relatively clear to the first-time user for creating and/or updating the Work Plan Template.  The activities in the Template fully correspond to the expectations for FIFRA grant recipients, on a line-by-line basis.  The Work Plan Template itself is fully documented, with pick-lists, macros, color-coding, cross-references to guidance, and other features that support the user's objective.  The Template is relatively intuitive; some users can complete the rows and columns by referring to the instructions briefly from time to time as needed, or sometimes without the instructions (though this is not recommended).

Do you understand that you are required to maintain records?
       Yes.  Region 5 maintains electronic copies of the Work Plan Template as official agency records.

 (4) Burden and Costs

    Are the labor rates accurate?  
 The Agency assumes there is no capital cost associated with this activity.  Is that correct?
       
       Yes.  The Work Plan Template is reusable software, without capital expenditure.
       
 Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the paperwork involved with this ICR, are the estimated burden hours and labor rates accurate?  If you have burden and cost estimates that are substantially different from EPA's, please provide EPA with an estimate of your burden hours and an explanation of how you arrived at your estimates.
       
       Region 5 has used the Work Plan Template with each of its six FIFRA State Lead Agencies (SLAs) for the past several years, so that almost all program planning and reporting takes place based on the information in the Template.  Region 5 has not analyzed the burden associated with the Template among its SLAs, but believes that the burden has fallen as SLAs adapted to the Template during successive years, although using it for the first time remains time consuming.  Similarly, and because it describes almost all activities undertaken with FIFRA funds, Region 5 staff and managers use the Template more than the hours estimated. Region 5 has not analyzed the burden associated with using the Template; however, the Template remains our primary tool for negotiating annual commitments and reporting on accomplishments, for both staff and managers.
       
 Are there other costs that should be accounted for that may have been missed? 
       
       No, the burden analysis seems otherwise accurate and thorough.

EPA Questions Asked in Consultation for the FIFRA Cooperative Workplan Agreement ICR: 
 
Organization:     Virginia Department of Agriculture & Consumer Services_____________ 
Date: December 19, 2018 	 	 
 
 
(1) 	Publicly Available Data 
 
 Is the data that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency?   
      This data that the Agency seeks in not available from any public source, or already collected by another office at EPA. 
 If yes, where can you find the data?  (Does your answer indicate a true duplication, or does the input indicate that certain data elements are available?)  Not Applicable 
       
(2) 	 Frequency of Collection  
       
      a) Can the Agency collect the information less frequently and still produce the same outcome? 	 
      The Agency could not collect this information less frequently and still produce the same outcome. 
       
(3) 	Clarity of Instructions  
  
 Based on the instructions in the 2018-2021 FRFRA Cooperative Agreement Guidance (February 14, 2017), is it clear what you are required to do and how to submit such data?  
	If not, what suggestions do you have to clarify the instructions? 	 
    	Yes, the instructions in the 2018-2021 FRFRA Cooperative Agreement Guidance (February 14, 2017), are clear as to what we are required to do and how to submit such data. 
 Do you understand that you are required to maintain records?  Yes.  
 
(4)  	Burden and Costs 
 
	 	Are the labor rates accurate?   
	 	Yes 
 The Agency assumes there is no capital cost associated with this activity.  Is that correct?  
      Yes 
 Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the paperwork involved with this ICR, are the estimated burden hours and labor rates accurate?   
      Yes 
      If you have burden and cost estimates that are substantially different from EPA's, please provide EPA with an estimate of your burden hours and an explanation of how you arrived at your estimates.  
      Not Applicable  
 Are there other costs that should be accounted for that may have been missed?  
      No 
 	 

