Ss 0311 2017

SS 0311 2017.docx

APHIS Pest Reporting and Asian Longhorned Beetle Program

OMB: 0579-0311

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June 2017

SUPPORTING STATEMENT

APHIS Pest reporting

AND ASIAN LONGHORNED BEETLE PROGRAM

OMB NO. 0579-0311


NOTE: This is a reinstatement of a currently approved information collection with change.


In addition, the name of this information collection has been updated. Previously, this information collection was called “APHIS Pest Reporting Form” and now the name of the collection better reflects what is being reported on, “APHIS Pest Reporting and Asian Longhorned Beetle Program.”


A. Justification


1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.


The United States Department of Agriculture, Animal and Plant Health Inspection Service (APHIS), is responsible for preventing plant diseases or insect pests from entering the

United States, preventing the spread of pests and noxious weeds not widely distributed in the United States, and eradicating those imported pests when eradication is feasible. The Plant Protection Act (7 U.S.C. 7701, et seq.) authorizes the Department to carry out its mission.


Under the Plant Protection Act, the Secretary of Agriculture is authorized to prohibit or restrict the importation, entry, or movement of plants and plant pests to prevent the introduction of plant pests into the United States or their dissemination within the United States.


Plant health regulations promulgated by the United States Department of Agriculture (USDA) under this authority specifically address control programs for a number of pests and diseases of concern, including Asian Longhorned Beetle (ALB), emerald ash borer (EAB) beetle, and citrus greening, to name a few.


APHIS’ Plant Protection and Quarantine (PPQ) program relies on the public to report sightings of the pests of concern or suspicious signs of pest or disease damage they may see in their local area. This reporting can be done through an online form (PPQ Form 10, PPQ Pest Reporting Form). Reports can come from areas that are under regulatory oversight and those areas where no regulatory oversight currently exists. Surveys performed by members of the general public, nature organizations, school groups, garden clubs, and others help APHIS uncover unknown infestations. Surveys conducted by the public supplement the work done by the Agency’s surveyors. If a member of the public reports seeing signs of pests or diseases of concern, APHIS will take the appropriate steps to determine if a pest or disease is indeed present, and if so, to what extent.


APHIS is asking OMB to approve, for an additional 3 years, its use of these information collection activities in connection with APHIS’ efforts to ensure the detection and eradication of pests and diseases of concern in both regulated and non-regulated areas. In addition, APHIS plans to merge this information collection into OMB No. 0579-0088, Domestic Quarantine Regulations, the next time OMB No. 0579-0088 is renewed.



2. Indicate how, by whom, how frequently, 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 associated with the ALB program and pest reporting to pinpoint an outbreak or infestation of a pest or disease of concern:


7 CFR 301.51 - Online PPQ Pest Reporting, Form PPQ Form 10 (Individuals and Households) - APHIS uses the voluntary PPQ Form 10 to enable the public to submit reports about a variety of pests and diseases. This information is used to identify new or expanded outbreaks of pests and diseases of concern. As they are collected, the reports are transmitted to the appropriate officials in APHIS/PPQ for follow-up, including onsite inspections by APHIS officials or State Departments of Agriculture plant pest experts. Any follow-up questions or details on location will be obtained by contacting the respondent for more information and directions.


7 CFR 301.51 - Cooperative Agreement for Inspection (State, Local, or Tribal Govt.) - Cooperative Agreements are established for inspection and survey of host trees as well as removals and disposal of infested and high risk host trees. PPQ has one Cooperative Agreement with each of the three States with ALB quarantines. The States spend an average of 25 hours to develop each agreement. This includes Cooperative Agreements for States to conduct inspections, surveys, and removal of trees.


7 CFR 301.51-6 - State Compliance Training Workshop Records (State, Local, or Tribal Govt.) - Tree care/landscape businesses with Compliance Agreements (approved under OMB No. 0579-0088) are required to attend training. The business representatives sign in their names and business names on an attendance sheet. The State maintains the attendance sheet records up until 3 years after an area is no longer under quarantine.


7 CFR 301.51-3 - Inspections/Asian Longhorned Beetle Unified Survey, PPQ Form 375 (State, Local, or Tribal Govt.) (Business) - States under Cooperative Agreement survey approximately 35 percent of the trees from the States under contract, and businesses conduct an average of 30 percent of the surveys for infested trees. ALB host trees are inspected by ground surveys with binoculars and aerial surveys by tree climbers for potential infestations. Each tree takes approximately 30 minutes to survey and the information is documented on a PPQ Form 375 which captures the inspection method, treatment method, infestation status, tree designation, and tree location among other things. This data is used to delimit the infestation and determine where control efforts are needed.


7 CFR 301.51 - Contract for Inspection (Business) - Contracts are established with businesses for the removal and disposal of infested and high risk host trees. These contracts take the businesses approximately 10 hours to complete the paperwork, write, and agree to the contract.


7 CFR 301.51 - Permission to Inspect from Homeowner (documented verbal phone calls) (Individuals and Households) - An inspector requests permission to inspect trees from a property owner and gains verbal approval, if available. In Ohio and Massachusetts, inspections proceed if the property owner is not home. In New York, if the owner is not home, a letter is left for the property owner who calls the APHIS Program Office with verbal approval. If the property owner refuses to allow inspections, the warrant process is initiated. There are approximately 2,000 property owners, mostly in New York, who are contacted for permission to inspect their trees. Approximately 50 of those property owners, mostly in New York, refuse access to the property which initiates the process for a warrant.


7 CFR 301.51 - Refusal to Inspect from Homeowner (Individuals and Households) - An Inspector from PPQ, or the State Cooperator, requests permission to inspect trees from a property owner and gain verbal approval if available. In Ohio and Massachusetts, inspections proceed if the property owner is not home. In New York, if the owner is not home, a letter is left for the property owner who calls the Program Office with verbal approval. If the property owner refuses to allow an inspections the warrant process is initiated. There are approximately 2,000 property owners, mostly in New York, who are contacted for permission to inspect their trees. Approximately 50 of those property owners, mostly in New York, refuse access to the property which initiates the process for a warrant.


7 CFR 301.51 - Chemical Treatment Release from Homeowner (Individuals and households) - When insecticide treatments are applied, the property owners provide their signatures allowing the treatments to occur. On average, 75 properties are treated.


7 CFR 301.51 – Letter Prior to Litigations and Warrants (State, Local, or Tribal Govt.) - A warrant is issued by the State if a property owner does not give permission for infested tree inspections or removals.  About 300 letters are sent out requesting inspections that result in about 50 warrants per year requiring access to survey the trees with the majority of these occurring in New York.  Approximately one warrant per year is required to gain access to a property to remove an infested tree.  Actions taken to draft and implement the warrants require an average of 2 hours each to complete.


7 CFR 301.51 – Litigations and Warrants (State, Local, or Tribal Govt.) - A warrant is issued by the State if a property owner does not give permission for infested tree removal. There are about 300 letters that result in about 50 warrants per year with the majority of these occurring in New York. Actions taken to draft and implement the warrants require an average of 2 hours each to complete.


7 CFR 301.51 - Homeowner to Sign for Tree Removal (Individuals and Households) - Once a tree is found to be infested with ALB, the property owner signs a form agreeing for the infested tree to be removed. Approximately 40 properties require signatures annually.


7 CFR 301.51 - Removal/Monitoring (State, Local, or Tribal Govt.) - The States of Massachusetts and New York remove ALB infested and high risk host trees and are responsible for disposal (as discussed below) of the material and monitoring the work being done. There is one contract with Davey Tree to conduct tree removals and disposal in Ohio. Once a tree is infested with ALB, the only control measure to kill the beetle and ensure it isn’t spreading is to destroy the host tree. An average of 5 hours is spent to remove each tree.


7 CFR 301.51 - Contract for Treatment (business) - Treatment Contracts are established to allow for pesticide treatments within designated treatment areas.  There is typically one treatment contract with one business per year. Completing the paperwork for this one treatment contract takes approximately 10 hours.  


7 CFR 301.51 - Removal/Disposal (business) - Massachusetts and New York remove ALB infested and high risk host trees and are responsible for disposal of the material and monitoring the work being done. There is one contract with Davey Tree to conduct tree removals and disposal in Ohio. Once a tree is infested with ALB, the only control measure to kill the beetle and ensure it isn’t spreading is to destroy the host tree. An average of 5 hours is spent to remove each tree. The State also works on disposal of host plant material at Marshalling Yards in Massachusetts and New York under Cooperative Agreements with PPQ. Host material is chipped to a size where it is no longer considered regulated in the field and at Marshalling Yards where chips are disposed of.


7 CFR 301.51 - Disposal/Marshalling Yard (State, Local, or Tribal Govt.) - The States of Massachusetts and New York remove ALB infested and high risk host trees and are responsible for disposal of the material and monitoring the work being done. There is one contract with Davey Tree to conduct tree removals and disposal in Ohio. Once a tree is infested with ALB, the only control measure to kill the beetle and ensure it isn’t spreading is to destroy the host tree. The State works on disposal of host plant material at Marshalling Yards in Massachusetts and New York under Cooperative Agreements with PPQ. Host material is chipped to a size where it is no longer considered regulated in the field and at Marshalling Yards where chips need to be disposed of. Each State has two full time employees that work at the Marshalling Yards.


7 CFR 301.51 - Tree Warrant (State, Local, or Tribal Govt.) - A warrant is issued by the State if a property owner does not give permission for infested tree removals. There are about 50 warrants per year issued in Massachusetts, New York, and Ohio, with the majority of these occurring in New York. Actions taken to draft and implement the warrants require an average of 2 hours each to complete.


7 CFR 301.51 - Certificate/Permit Cancellation Appeal (Business) - If a business is found to be non-compliant with their Limited Permit or Certificate, it is cancelled. This occurs less than one time per year and takes approximately 30 minutes to complete the cancellation.



3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques 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.


The PPQ Pest Reporting Form (PPQ Form 10) will be available on the APHIS Web site at http://www.aphis.usda.gov/library/forms once this information collection is approved. This form may be linked to a number of Web pages or mini-sites that encourage the public to look for and report pests and diseases of concern, including ALB, EAB, and citrus greening, to name a few. The reporting form, which is completely voluntary, asks for only basic information and can be completed online. APHIS uses the voluntary PPQ Form 10 to enable the public to submit reports about a variety of pests and diseases. This information is used to identify new or expanded outbreaks of pests and diseases of concern. As the reports are collected, they are transmitted to the appropriate officials in APHIS/PPQ for follow-up, including on-site inspections by APHIS officials or State Departments of Agriculture plant pest experts. Any follow-up questions or details on location will be obtained by contacting the respondent for more information and directions.


The ALB Unified Survey (PPQ Form 375) will be available on the APHIS Web site at http://www.aphis.usda.gov/library/forms once this information collection is approved.


The Asian Longhorned Beetle Eradication System (ALBES) was a system housed at the National Information Technology Center (NITC) that went off-line the end of May 2015 due to NITC upgrades and the system’s incompatibility with eAuth 2.0. Since then, PPQ has been working to get all ALB data prepped and migrated to the Integrated Public Health Information System (IPHIS). During this time, the ALB program still has the need to gather survey, treatment, and removal data, and the ALB program has been utilizing their Personal Digital Assistants (PDAs) to continue to do so. At this time, the ALB program is still not entering ALB data into IPHIS.

IPHIS is the central repository for domestic plant health data. At present, IPHIS supports the collection of field survey information through the upload of locally collected data via spreadsheet functionality, or the use of its web service tools. Of the nearly 1,200 IPHIS users, no users are using IPHIS to actually do data collection. IPHIS merely supports local data collection by providing the two methods noted to facilitate that data upload.

 

IPHIS does have both an Apple Operating System (iOS) and Windows based simple field data collection tool in development. However, continued development of those tools to meet the very specific data collection needs of the ALB program would require hundreds of thousands of dollars and many months of development efforts. IPHIS is a general use system meant to be available to the majority of programs. The current survey tools about to be deployed will work for a good number of those programs, but not all, and they will not work for ALB. This is why the spreadsheet upload and web services tools will always be available to programs to get their data into IPHIS.

 

The ALB Program has Geographic Information System (GIS) based business needs and makes decisions on GIS based data. For example, information such as property boundaries is needed to take legal action against property owners or the removal of trees on a property. Another example is the need for data describing where power lines run through a property to determine what type of tree removal service is needed. The program also needs data stored regarding tree species density, wind direction, ALB infestation patterns, etc., to do predictions of spread and where to look next for the pest. IntraMaps Roam can utilize publicly available municipal GIS mapping data to gather intelligent survey data used to help make local program business decisions. IPHIS cannot currently, nor will the IPHIS simple data collection tools, be capable of meeting those local business needs. IntraMaps Roam can also be used to provide the information IPHIS does require (through spreadsheet upload and web services) so the National Program Staff can use IPHIS to make its decisions. As we continue to develop IntraMaps Roam, treatment and removal data will also be electronically captured.


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 not available from any other source. APHIS is the only Federal agency responsible for detecting and controlling the outbreak of certain plant pests and diseases.



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


The information APHIS is collecting is the minimum needed to determine if pests or diseases of concern are present in areas outside of currently regulated areas or other known areas of infestation. Burden is minimized by the fact that this is a completely volunteer form; the public doesn’t have to fill out the form if they do not wish to do so. Burden is further reduced by the fact that the form is an online form and asks for only the most basic information, including name, phone number, email address, date, street address, ZIP Code, and location of the potential sighting. APHIS has determined that none of the respondents are small entities.



6. Describe the consequence 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.


Collecting this information less frequently or failing to collect it could result in APHIS not receiving information about where infestations may exist, causing them to linger unreported and grow. Infestations of high-consequence pests and diseases, such as ALB, EAB, citrus greening, and others, could lead to significant economic damage to crops, forests, and landscapes.



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

  • 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;

  • 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 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 data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting form, 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.


APHIS consulted with the following individuals and organizations concerning this information collection:


Florida Department of Agriculture and Consumer Services

Director, Anderson H. Rackley

Division of Agricultural Environmental Services

3125 Conner Blvd., Ste. E
Tallahassee, FL 32399-1650

[email protected]

850-617-7900



Laura Petro

CA Department of Food and Agriculture

Plant Health and Pest Detection Services

1220 N. Street

Sacramento, CA 95814

916-654-0462


David Knauft, University of Georgia

Office of Environmental Sciences

109 Conner Hall

Athens, GA 30602

706-542-2471


On Thursday, March 31, 2016, page 18564-18565, APHIS published in the Federal Register a 60-day notice seeking public comments on its plans to request a 3-year extension 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 remuneration of contractors or grantees.


There are no plans to provide 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 or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.


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 burdens in Item 13 of OMB Form 83-I.


The hour burden is dependent on the number of respondents which, in this case, is voluntary. Based on the number of reports submitted by members of the public for the last 12-month period, APHIS estimates that the on-line form will potentially receive as many as 5,000 reports. For the purpose of estimating burden hours, APHIS estimates that it will take an individual submitting a report no more than 5 minutes to complete the on-line form.


For ALB - Burden estimates were developed based on real-time use and discussions with contractors, State Cooperators, landscape businesses, inspectors, and property owners.


For the related employees and salaries:

11-3011  Administrative Services Managers                                                            $44.35

19-1030  Conservation Scientists and Foresters                                                                  $30.30

19-1031  Conservation Scientists                                                                                  $30.97

19-1032  Foresters                                                                                                                  $28.88

45-1011  First Line Supervisors pf Farming, Fishing and Forestry Workers                $22.80

45-2011  Agriculture Inspectors                                                                                       $20.97

45-4011  Forest Conservation Workers                                                                                  $14.25


Average = $29.30


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


The estimate of the total annual cost of burden to the respondents (438,779 hours x $29.30) totals $12,856,224. See APHIS Form 71. Burden estimates were developed from discussions with program personnel and outside firms that conducted similar work.



13. Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates 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 is zero annual cost burden associated with capital and start-up costs, operation and maintenance expenditures, and purchase of services.



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 annualized cost to the Federal government is estimated at $2,584,177 (see APHIS Form 79).



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


This reinstatement is a program change resulting in 7,055 respondents, 688,746 responses, and 438,779 burden hours. Also within this reinstatement, APHIS is including additional collection activities that were omitted from the last renewal: (1) Cooperative Agreement for Inspection,

(2) State Compliance Training Workshop Records, (3) Inspections/Asian Longhorned Beetle Unified Survey; (4) Contract for Inspection, (5) Permission to Inspect from Homeowner,

(6) Refusal to Inspect from Homeowner, (7) Chemical Treatment Release from Homeowner,

(8) Letters Warning of Litigations and Warrants; (9) Litigations/Warrants; (10) Homeowner to Sign for Tree Removal, (11) Removals/Monitoring, (12) Contract for Treatment;

(13) Removals/Disposal, (14) Disposal/Marshalling Yard, (15) Tree Warrant, and

(16) Certificate/Permit Cancellation Appeal.



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


APHIS has no plans to publish information collected in connection with this program.



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


APHIS is not requesting the option to not display the expiration date for OMB approval of the information collection.


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


APHIS can certify compliance with all provisions of the Act.


B. Collections of Information Employing Statistical Methods


There are no statistical methods associated with the information collection activities used in this program.

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