Attachment G

Attachment G - Consultation Response

Below are a series of questions related to the renewal of the Pesticide Registration Fee Waivers
ICR; OMB Control No.: 2070-0179, EPA ICR No.: 2330.03. Your response is voluntary. However,
should you choose to respond, your response will be published at regulations.gov in the public
docket EPA-HQ-2016-0463. As part of the consultation process for this ICR renewal we ask the
following:
Company name: RegWest Company LLC
Name of person consulted: Kim Davis
Date: February 23, 2017
When preparing your waiver request did you conduct any research on the EPA websites
https://www.epa.gov/pria-fees and https://www.epa.gov/pesticide-registration/pesticideregistration-fees-and-fee-waivers? Were these resources helpful to you?
A: I have consulted the websites many times. I find them very helpful, especially when I was
preparing the voluntary form for my clients to use as a check list of the required documentation.
Are there improvements or clarifications that you like to suggest for the waiver resource
websites?
A: Based on my clients’ experiences with waiver requests, most problems are encountered in
providing sufficient affiliation information and pesticide revenue breakdown when total revenues
are from both pesticidal and non-pesticidal sources. However, Christopher Green has been most
helpful in resolving these issues.
A majority of registrants use Pay.gov to pay for PRIA and product registration maintenance
fees. Do you use the Pay.gov site?
A: Yes.
If you use the Pay.gov website, do you find it helpful? Was the site easy to use?
A: Pay.gov is the only way to pay PRIA and product registration/maintenance fees since the EPA
does not accept checks anymore. I have found it very helpful (and more cost/time efficient) to pay
fees on-line and the site very easy to navigate and use. I especially like being able to send multiple
payment confirmation emails.
The projected hourly industry wage rates used to calculate the burden estimates in the
Pesticide Registration Fee renewal ICR are $126.56 for Management; $71.69 for Technical;
and $42.97 for Clerical. These rates are fully loaded rates. (see Attachment F for wage
calculation details). Are these industry averages too high, too low or just about right for
your company? Or alternatively, what do you think the appropriate hourly wages are?
A: As RegWest is a small regulatory consulting firm, I have no direct knowledge of hourly industry
wage rates.
Would you like to submit any additional comments?
A: Thank you for the opportunity to participate in the survey.

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