Attachment E - Record of ICR Consultations

Consultation Process: Responses to Standard Questions
Henry Uhden
Wyoming Department of Agriculture
Questions:
1. The ICR is intended to require that respondents provide certain data so that the
Agency can utilize them. Based on the instructions, is it clear to respondents what they
are required to do and how to submit such data? If not, what suggestions do you have to
clarify the instructions?
Yes
2. Do respondents understand what they are required to submit or maintain in their
records? Is the reporting form clear, logical, and easy to complete?
Yes
3. 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. If the Agency were able to ensure the security of CBI
that might be transmitted over the Internet and the reporting form could be completed
electronically, would you be interested in submitting it electronically?
Yes
Current electronic reporting alternatives include the use of “web forms”/XML based
submissions via the Agency’s internet site and magnetic media-based submissions (i.e.,
on diskette, CD-ROM, etc.) Are you interested in using, or are they currently utilizing,
electronic reporting/record-keeping options?
Yes
4. Where a reporting requirement includes a signature requirement, consider whether a
secure electronic signature method (such as Private Key Infrastructure) should be
required if submitting electronically; whether a less secure method (such as the use of
PINs and passwords) would be more appropriate; or, whether a signed cover sheet may
be sufficient for the Agency’s purposes when data is submitted on disk.
A signed cover sheet is sufficient.
5. If you prefer one method to another, does your choice balance burdens and costs
against electronic data and signature security integrity?
No

6. If an electronic reporting option is not offered because of CBI-related concerns, would
you be more inclined to submit CBI on diskette than on paper? What benefits would you
realize? (Burden reduction? Greater efficiency in compiling the information?).
N/A
7. The labor rates included in the Agency’s estimated burden hours and costs are a U.S.
average that includes costs for overhead and benefits. These estimates include only
burden hours and costs associated with the paperwork involved with this ICR (i.e., the
Agency does not include estimated burden hours and costs for usual and customary
business practices such as R&D, marketing, etc.). Are the estimated burden hours and
labor rates accurate?
N/A
8. Are there other costs that should be accounted for that may have been missed, such as
capital/start-up/M&O expenditures? If so, please provide an explanation of how you
arrived at your estimate of burden and cost if substantially different than EPA’s estimate.
N/A

Consultation on the Livestock Protection Collar (LPC) 1080 Information Collection
Request (ICR)
APHIS' Wildlife Services and Environmental Services have considered their current
reporting requirements and how their reporting process would be applicable to
implementing the ICR.
We are providing the following responses to the list of questions:
1. The ICR is intended to require that respondents provide certain data so that the
Agency can utilize them. Based on the instructions, is it clear to respondents what they
are required to do and how to submit such data? If not, what suggestions do you have to
clarify the instructions?
Response: Yes, data reporting and submission requirements are clear.
2. Do respondents understand what they are required to submit or maintain in their
records? Is the reporting form clear, logical, and easy to complete?
Response: Yes, we use a standard government Wildlife Services form to record
collected data.
3. 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. If the Agency were able to ensure the security of CBI
that might be transmitted over the Internet and the reporting form could be completed
electronically, would you be interested in submitting it electronically? Current electronic
reporting alternatives include the use of “web forms”/XML based submissions via the
Agency’s internet site and magnetic media-based submissions (i.e., on diskette, CDROM, etc.) Are you interested in using, or are they currently utilizing, electronic
reporting/record-keeping options?
Response: Yes, paper or electronic reporting is fine depending upon who would be
responsible for the initial development and implementation of an electronic reporting
process for APHIS.
4. Where a reporting requirement includes a signature requirement, consider whether a
secure electronic signature method (such as Private Key Infrastructure) should be
required if submitting electronically; whether a less secure method (such as the use of
PINs and passwords) would be more appropriate; or, whether a signed cover sheet may
be sufficient for the Agency’s purposes when data is submitted on disk.
Response: N/A Our annual report is submitted with a signed cover sheet.
5. If you prefer one method to another, does your choice balance burdens and costs
against electronic data and signature security integrity?

Response: N/A
6. If an electronic reporting option is not offered because of CBI-related concerns, would
you be more inclined to submit CBI on diskette than on paper? What benefits would you
realize? (Burden reduction? Greater efficiency in compiling the information?).
Response: Paper
7. The labor rates included in the Agency’s estimated burden hours and costs are a U.S.
average that includes costs for overhead and benefits. These estimates include only
burden hours and costs associated with the paperwork involved with this ICR (i.e., the
Agency does not include estimated burden hours and costs for usual and customary
business practices such as R&D, marketing, etc.). Are the estimated burden hours and
labor rates accurate?
Response: Reasonably so, probably an overestimate.
8. Are there other costs that should be accounted for that may have been missed, such as
capital/start-up/M&O expenditures? If so, please provide an explanation of how you
arrived at your estimate of burden and cost if substantially different than EPA's estimate.
Response: N/A.