                                 Attachment G
Respondent Response to the Consolidated Pesticide Registration Activities Questionnaire

1.	Publicly Available Data
●	Is the information that the Agency seeks available from any public source or already collected by another office at EPA or by another agency? 
Comment: All of the information the Agency seeks is usually not available from public sources.
●	If yes, where can you find the data?  

2.	Frequency of Collection
●	Can the Agency collect the information less frequently and still produce the same outcome?
Comment: I believe it's important for the Agency to have possession of the most current documentation pertaining to the products which they register.  This information is not normally found in its entirety from other agencies and is important to ensure with a high level of confidence these products when following the label are safe when it comes to human health and the environment.

3.	Clarity of Instructions
The ICR requires that respondents provide certain data so that the Agency can utilize them.
●	Based on the reporting activities described in the supporting statement, is it clear what you are required to do and how to submit the information? 
Comment:  The reporting activities described in the supporting statement was clear and it was understood that supportive data should be provided to justify responses.
●	If not, what suggestions do you have to clarify the instructions?
●	Do you understand the format of the consolidated ICR?
Comment:   I do understand the format of the consolidated ICR.
●	Can you locate the information relevant to your reporting and recordkeeping requirements?   
Comment: Yes, we can locate the information relevant to reporting and record-keeping.  
●	Do you understand that you are required to maintain records?  We do maintain both hard-copy and digital records for all the products registered for New Jersey. 
Comment:  The information requirements for reporting is easily obtained from the EPA websites.  This also includes the record keeping requirements.
●	Regarding the pesticide registration forms, do you use them? Are they clear, logical, and easy to complete?  
Comment:  Yes, we do use the pesticide registration forms.  Since I work with the registration of special pesticide products, Form 8570-25 is used on a regular basis.  The form is helpful, clear, and easy to work with.  Our pesticide program maintains the records of all the pesticide products registered for New Jersey.

4.	Electronic Reporting and Record keeping
The Government Paperwork Elimination Act requires agencies make available to the public electronic reporting alternatives to paper-based submissions by 2003, unless there is a strong reason for not doing so. One such reason was that, before September 2015, the Agency was unable to ensure the security of CBI that might be transmitted over the Internet.
::	Although the Agency does not offer an electronic reporting option at this time, what format other than paper would you be more inclined to submit section 18 and/or 24(c) submissions?
Comment: Traditionally we would submit paper copies of both section 18 and 24(c) registrations through a carrier service.  The submission of section 18 registrations through email has certainly helped our program since our resources are limited.  Recently, temporary approval of section 24(c) submissions through email because of the pandemic has helped our program even more.  The majority of special pesticide registrations in New Jersey consist mainly of special local need products, so having the option to submit 24(c) registrations through email reduces our burden in New Jersey.
::	What benefits would electronic submission bring you in terms of burden reduction or greater efficiency in compiling the information?  
Comment: Electronic submission for both section 18 and 24(c) registrations would significantly reduce the burden to our pesticide program and would allow us to compile more useful information for submittal.

5.	Burden and Costs
::	Are the labor rates accurate?  It is hard to determine if the labor rates are accurate since each state operates differently. 
Comment:  It is an expense to maintain the operation of section 3 registrations along with the special pesticide registrations.  The capital investment and maintenance involved with a data system to run a successful operation would be in the area of $174,892,655.
::	The Agency assumes there is no capital cost associated with this activity. Is that correct?
Comment:  Initially there is a capital cost associated with the pesticide operation in developing a data system to track registration status, maintain records, and payment of products registered with New Jersey.  Once established the capital expense is minimum.
::	Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the paperwork involved with this ICR, e.g., the ICR does not include estimated burden hours and costs for conducting studies, are the estimated burden hours and labor rates accurate?
Comment:   Once again it is hard to estimate from my point of view since I am only involved with the registration of special pesticide products, however the estimate appears to be fair.
::	Have you incurred additional paperwork burden as a result of third-party disclosure requirements involving disclosing product specific information to potential users and the general public through the pesticide label?  
Comment: There has been no burden on the part of New Jersey pertaining to the discloser of product specific information to potential users or the general public through the pesticide label.

  ::	Are there other costs that should be accounted for that may have been missed?
Comment:   I am not aware of any additional costs that may have been overlooked.

6.	Response to Emergency Exemption Process Revisions
●	How has the streamlined application process impacted your division as it pertains to the following:
●	Recertification of certain repeat emergency exemptions?  
Comment: The state of New Jersey does not have any current section 18 registrations so there hasn't been a recertification since 2018.

●	The criteria used to determine when a potential emergency condition is expected to cause a significant economic loss and the data requirements used to document the loss?  
Comment: In the past obtaining the data required to determine if a significant economic loss would occur was not a problem, since professionals such as the staff at Rutgers Agricultural Extension offices would be able to provide it for specific emergency exemptions.

7.	Has the application and review process for submitting repeat emergency exemptions improved since the regulation went into effect March 28, 2006? 
Comment:  I was not working on emergency exemption registrations back in 2006, however the process of repeat or amended section 18 submittals is not a burden.



