Supporting Statement - 0117

SUPPORTING STATEMENT

Environmental Monitoring Form

OMB-0579-0117

A. JUSTIFICATION March 2014

1. Explain the circumstances that make the collection of information necessary.

Identify any legal or administrative requirements that necessitate the collection.

The mission of the Animal and Plant Health Inspection Service (APHIS) is to provide leadership in ensuring the health and care of animals and plants, to improve agricultural productivity and competitiveness, and to contribute to the national economy and the public health.

APHIS is committed to accomplishing its mission in a manner that promotes and protects the integrity of the environment. This includes APHIS’ compliance with all applicable environmental statutes.

Primary among these statutes is the National Environmental Policy Act (NEPA),

42 U.S.C. 4321 et seq. and the regulations of the Council on Environmental Quality that implement the procedural aspects of NEPA (40 CFR 1500-1508). APHIS’ regulations require APHIS to implement environmental monitoring for certain activities conducted for pests and disease control and eradication programs.

Activities for which APHIS conducts monitoring are those that have the greatest potential for harm to the human environment such as the use of pesticides, and for mitigations that have been developed to avoid that harm. APHIS conducts monitoring to ensure that the mitigations are enforced, and that mitigations are effective. In many cases, monitoring is required where pesticides are used close to habitats of endangered and threatened species. APHIS’ monitoring is developed in coordination with the United States Department of Interior, Fish and Wildlife Service and the United States Department of Commerce, National Marine Fisheries Service, in compliance with the Endangered Species Act

(50 CFR 17.11 and 17.12).

2. APHIS uses the following information activities to monitor activities that pose great harm to the human environment and for enforcement of mitigations. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

APHIS uses the following information activities to implement environmental monitoring for certain activities conducted for pests and disease control and eradication programs.

APHIS Form 2060 – Environmental Monitoring Form (State) and (Business)

APHIS field personnel, sometimes with the assistance of personnel from State departments of agriculture as well as private foundations, obtain information onsite at the time samples are collected. This information is recorded on APHIS Form 2060, and includes such items as the number of collected samples, description of the samples, and the environmental conditions at the collection site, including wind speed and direction, temperature, and topography. This form is used to collect information concerning the effects of pesticide use in sensitive habitats.

The information contained on the APHIS Form 2060 is vital for interpreting the laboratory tests APHIS conducts on its collected samples. If a sample was not accompanied by this form, APHIS would have no way of knowing from which site the sample was taken.

Using information on the form as well as the laboratory results from tests conducted on the samples, APHIS can assess the effects of pesticide use at a site and determine what, and if any, corrective action should be taken to mitigate the effects of the pesticide.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

An example of APHIS Form 2060 is posted as a PDF file in the PPQ Manual under Imported Fire Ant. The website is: http://www.aphis.usda.gov/ppq/manuals/online_manuals.html. The document is not fillable and is used as an example only. Form 2060 needs to be completed in triplicate.

APHIS has investigated an electronic edition of the form, but it is not practical at this time. Information collected on the form needs to go to multiple recipients for different purposes who do not have the same software for receiving electronic data. Additionally, one of the most important fields on the form is the ‘Remarks’ section, where staff is able to draw maps or other pictographic information that is not easily collected in an electronic format.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose described in item 2 above.

The information that APHIS collects is exclusive to its mission of monitoring the effects of pesticide use in sensitive habitats. It is narrowly defined for APHIS’ purpose. It describes environmental conditions in the immediate vicinity and is very time specific to each particular sample. The information recorded on APHIS Form 2060 describes the environmental context for the unique sample taken at a specific site and does not overlap with other State or Federal data gathering efforts.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

APHIS has endeavored to reduce the burden on all entities, including small businesses and other small entities. APHIS has determined 50 percent of the respondents are small entities.

The information APHIS collects is the minimum needed to monitor the well-being of sensitive habitats and the threatened or endangered species that may dwell within them. The destruction of these habitats could have serious, long-term consequences for American agriculture.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Failing to collect this information would prevent APHIS from actively monitoring the effects of pesticides in areas where the inappropriate use of these chemicals could eventually produce disastrous results for vulnerable habitats and species.

If information is not collected frequently enough, APHIS’ ability to effectively monitor chemical residues in the environment is compromised. A compromised monitoring program could hamper APHIS’ ability to initiate corrective action, should it be needed. In addition, a compromised monitoring program would result in APHIS failing to comply with National Environmental Policy Act and Environmental Science Associates regulations, as well as APHIS Directives.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

requiring respondents to report informa­tion to the agency more often than quarterly;requiring respondents to report informa­tion to the agency more often than quarterly;

Daily Log
For purposes of security, facility operators must maintain a daily log to record the entry and exit of all persons entering and leaving the facility while quarantine is in progress.  

requiring respondents to prepare a written response to a collection of infor­ma­tion in fewer than 30 days after receipt of it;

Licensees and permittees must immediately, but no later than 2 days, send stop distribution and sale notices to any jobbers, wholesalers, dealers, foreign consignees, or other persons known to have any such veterinary biological product in their possession, which instruct them to stop the preparations, distribution, sale, barter, exchange, shipment, or importation of any such veterinary biological product.  All notification shall be documented in writing by the licensee or permittee.

Shipments of live VHS-regulated fish must be presented for inspection at a port of entry.  For live fish entering through certain limited ports listed in APHIS’ regulations, the importer must notify the APHIS port veterinarian at least 72-hours in advance of the arrival in the United States of the shipment.  This notification is necessary to ensure APHIS is prepared for the arrival of the shipment at the port of entry, to ensure that inspectors and facilities are available for inspection in the United States, and to contact appropriate persons if any questions arise concerning the importation.  This prior notification to the port veterinarian may be made via phone, fax, or e-mail.

requiring respondents to submit more than an original and two copies of any docu­ment;
requiring respondents to retain re­cords, other than health, medical, governm­ent contract, grant-in-aid, or tax records for more than three years;

Testing records to support an aquaculture facility's claim of disease freedom from VHS virus must be maintained for a maximum of 4 years.  This recordkeeping will provide APHIS with historical documentation to determine the risk of spreading VHS from a given facility.  

APHIS is requiring herd owners to maintain their herd records for as long as the herd remains in the CWD program.  This time varies from herd to herd.

in connection with a statisti­cal sur­vey, that is not de­signed to produce valid and reli­able results that can be general­ized to the uni­verse of study;
requiring the use of a statis­tical data classi­fication that has not been re­vie­wed and approved by OMB;
that includes a pledge of confiden­tiali­ty that is not supported by au­thority estab­lished in statute or regu­la­tion, that is not sup­ported by dis­closure and data security policies that are consistent with the pledge, or which unneces­sarily impedes shar­ing of data with other agencies for com­patible confiden­tial use; or
requiring respondents to submit propri­etary trade secret, or other confidential information unless the agency can demon­strate that it has instituted procedures to protect the information's confidentiality to the extent permit­ted by law.

requiring respondents to report information to the agency more often than quarterly;

Documentation of environmental samples is reported on Form 2060 on an as-needed basis, usually within a few days of collection of the samples. Samples must be promptly prepared and shipped to the analytical chemistry lab so that the samples do not degrade over time, and a copy of Form 2060 is shipped along with the sample. The sample collection schedule, therefore, dictates the schedule on which the information is reported to APHIS.

requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

Most samples and the associated Form 2060 are prepared within a week of the collection of the sample.

requiring respondents to submit more than an original and two copies of any document;

Form 2060 is a carbonless quadruplicate form. Three copies are automatically made as the original is completed. The original is submitted to APHIS, two copies are submitted with the samples to the analytical laboratory, and the third copy is retained by the creator of the document.

requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

requiring the use of a statistical data classi­fication that has not been reviewed and approved by OMB;

that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

No other special circumstances exist that would require this collection to be

conducted in a manner inconsistent with the general information collection guidelines

in 5 CFR 1320.5.

8. Describe efforts to consult with persons outside the Agency to obtain their views on the availability of, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting from, and on the data elements to be recorded, disclosed, or reported. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, soliciting comments on the information collection prior to submission to OMB.

The following individuals were contacted during 2014.

Randy Whorton

Texas Boll Weevil Eradication Foundation

P.O. Box 5089

Abilene, TX 79608

(325) 672-2800

Jennifer Forman Orth

ALB Cooperative Eradication Program

151 W. Boylston Drive

Worcester, MA 01606

(508) 414-4878

Leah Roberts

Plant Industry Division

NC Department of Agriculture and Consumer Services

1060 Mail Service Center

Raleigh, NC 27699

(919) 707-3754

On Thursday, January 30, 2014, page 4865, APHIS published in the Federal Register, a 60-day notice seeking public comments on its plans to request a 3-year renewal of this collection of information. No comments from the public were received.

9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.

This information collection activity involves no payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

No additional assurance of confidentiality is provided with this information collection. Any and all information obtained in this collection shall not be disclosed except in accordance with 5 U.S.C. 552a.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and others that are considered private. This justification should include the reasons why the agency considers the questions necessary.

This information collection activity asks no questions of a personal or sensitive nature.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burden in Item 13 of OMB Form 83-I.

• Provide estimates of annualized cost to respondents for the hour burden hours for collections of information, identifying and using appropriate wage rate categories.

$30.60 is the hourly rate derived from the U.S. Department of Labor, Bureau of Labor Statistics May 2012 Report - Occupational Employment and Wages in the United States. See http://www.bls.gov/news.release/pdf/ocwage.pdf

See APHIS Form 71 for hour burden estimates. $30.60 x 1,100 = $33,660

13. Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information, (do no include the cost of any hour burden shown in items 12 and 14). The cost estimated should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

There are no additional cost burdens to the respondents.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The estimated cost for the Federal Government is $20,623.00 (See APHIS Form 79)

15. Explain the reasons for any program changes or adjustments reported in Items 13 of 14 of the OMB Form 83-1.

	Requested	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate	Change Due to Potential Violation of the PRA	Previously Approved
Annual Number of Responses	2,200	0	-800	0	0	3,000
Annual Time Burden (Hr)	1,100	0	-400	0	0	1,500
Annual Cost Burden ($)	0	0	0	0	0	0

There is a program decrease in burden hours and respondents due to the removal of individuals/households in this collection. During the review process of this renewal, the program realized that individual households should have never been solicited because residents were not qualified to place the traps in the first place. Due to this change, the number of respondents has decreased from 150 to 110, the number of responses has decreased from 3,000 to 2,200, and the burden hours have decreased from 1,500 hours to 1,100 hours.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

APHIS has no plans to tabulate or publish the information APHIS collects.

17. If seeking approval to not display the expiration date of OMB approval of the information collection, explain the reasons that display would be inappropriate.

APHIS has no plans to seek approval for not displaying the OMB expiration date on its form.

18. Explain each exception to the certification statement identified in the “Certification for Paperwork Reduction Act.”

APHIS certifies compliance with all provisions of the Act.

B. Collections of Information Employing Statistical Methods.

Statistical methods are not used in this information collection.