0579-0387 2018 Ss

January 2017
SUPPORTING STATEMENT
IMPORTATION OF LITCHI AND LONGAN FRUIT FROM VIETNAM INTO THE
CONTINENTAL UNITED STATES
OMB NO. 0579-0387

A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary. Identify
any legal or administrative requirements that necessitate the collection.
The Plant Protection Act (PPA, 7 U.S.C. 7701 et seq.) authorizes the Secretary of Agriculture to
restrict the importation, entry, or interstate movement of plants, plant products, and other articles
within the United States to prevent the introduction of plant pests or their dissemination. The
Animal and Plant Health Inspection Service (APHIS) Plant Protection and Quarantine (PPQ)
Program enforces the Act by regulating the importation of fruits and vegetables into the United
States. These regulations are found in Section 319 of the Code of Federal Regulations (CFR)
under ‘‘Subpart—Fruits and Vegetables’’ (7 CFR 319.56–1 through 319.56–81).
Under §319.56–70, litchi and longan fruit from Vietnam may be imported into the continental
United States except Florida only under certain conditions to ensure it is free of insect plant pests
and disease. Information collection activities are used to ensure these conditions are met.
APHIS is requesting the Office of Management and Budget (OMB) to approve, for an additional
3 years, the use of these information collection activities to prevent the introduction of dangerous
plant pests into the United States.

2. 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.
Application for Permit to Import Plants or Plant Products (PPQ Form 587);
(7 CFR 319.56-3); (Business)
Importers may be required to obtain permits from APHIS before shipping to the United States
litchi or longan fruit from Vietnam that may not be in full compliance with 7 CFR 319.56-70.
Permits allow APHIS to inform applicants of importation requirements imposed on the fruit at its
country of origin and any special conditions the consignments must meet when arriving at United
States ports.
Appeal of Denial or Revocation of Permit; (7 CFR 319.7-5); (Business)
Denial or revocation of an import permit may be appealed in writing by the importer within 10
days of notification by APHIS.

Orchard Registration; (7 CFR 319.56-70(a)); (Business) (Foreign Government)
Litchi fruit must be grown in orchards registered with and monitored by the Vietnam NPPO to ensure it
is free of disease caused by Phytophthora litchii. Registration allows for inspection of fruit crops and
provides traceability of fruit origin.
Labeling “Not for Importation Into or Distribution in FL”; (7 CFR 319.56-70(c));
(Business)
Cartons containing litchi or longan fruit must be stamped “Not for importation into or
distribution in Florida.” This is consistent with other APHIS import programs where shipments
fruit are prohibited in Florida for the same pest.
Phytosanitary Certificate with Additional Declaration; (7 CFR 319.56-70(e)); (Business)
(Foreign Government)
Each consignment of litchi and longan fruit must be accompanied by a phytosanitary certificate
issued by the Vietnam NPPO which includes a declaration stating the conditions of 7 CFR
319.56-70 have been met. Certificates for litchi must also include an additional statement that the
consignment has been inspected and found free of Phytophthora litchii.
Notice of Arrival (PPQ Form 368); (7 CFR 319.56-3d(1)); (Business)
Importers of regulated articles must complete PPQ Form 368 (or equivalent Federal form
depending upon port procedures) at or before the shipment’s arrival into the United States. The
form provides information needed by Federal inspectors or officers to identify and track
shipments en route to the United States, and to schedule inspections and treatments at the
appropriate ports of entry. Timely submission mitigates delays in the port clearance process.
Emergency Action Notification (PPQ Form 523); (7 CFR 319.56-3d(2)); (Business)
PPQ Form 523 is prepared by a Federal official and issued to a broker, shipper, market owner, or
other stakeholder responsible for a certain consignment failing specific import requirements and
requiring remedial action. The form describes the reasons for refusal of entry into the United
States and basic explanations of required remedial actions. Receipt and consignment disposition
are annotated by the stakeholder before further port clearance procedures may resume.
Recordkeeping; (7 CFR 319.56-70); (Business) (Foreign Government)
Other records related to the burdens in this information collection and created and maintained by
businesses and foreign governments may be requested by APHIS to assist with the identification,
tracking, and mitigation of plant pests before they enter the United States.

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 considerations of using information technology
to reduce burden.
The Vietnam NPPO documents orchard registrations and issues phytosanitary certificates.
APHIS has no influence over other nations with regard to automating phytosanitary certificates
but they may follow APHIS or international guidelines for format and content. APHIS enters
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phytosanitary certificate information into the electronic APHIS Agricultural Quarantine Activity
System (AQAS) upon receipt at the United States port of entry.
Methodology for labeling cartons is at the discretion of packaging facilities.
The Notice of Arrival (PPQ Form 368) and Application for Permit to Import Plants or Plant
Products (PPQ Form 587) may be completed online by e-Permits account holders at website
https://www.aphis.usda.gov/aphis/resources/permits/sa_plants/ct_ppq_epermits. Fillable versions
of the forms also may be obtained from the APHIS forms website at https://www.aphis.usda.gov/
aphis/resources/forms/ct_ppq_forms and then faxed or emailed to APHIS. Users also may obtain
more information about the forms by visiting the PPQ permit information webpage at
https://www.aphis.usda.gov/aphis/ourfocus/planthealth/import-information/permits/plants-andplant-products-permits/ct_plantproducts.
There is no prescribed format for preparing and submitting an appeal of denial or revocation of
import permit.
The Emergency Action Notification (PPQ Form 523) is initiated by Federal officials.
APHIS works closely with CBP and is involved with the Government-wide utilization of the
International Trade Data System (ITDS) via the Automated Commercial Environment (ACE) to
improve business operations and further Agency missions. ITDS will allow respondents to
submit data required by U.S. CBP and its Partner Government Agencies (PGAs) to import and
export cargo through a Single Window concept. APHIS is also developing a system known as
e-File for CARPOL (Certification, Accreditation, Registration, Permitting, and Other Licensing)
activities. It is still under development and will strive to efficiently automate some of these
information collection activities.

4. Describe efforts to identify duplication. Show specifically why any similar information
already available cannot be used or modified for use of the purpose described in item 2
above.
The mission to prevent the spread of plant pests in the United States is exclusive to USDA
APHIS and the information it collects is not available from any other source.

5. If the collection of information impacts small businesses or other small entities, describe
any methods used to minimize burden.
The information APHIS collects is the minimum needed to protect the United States from
destructive plant pests while ensuring increased variety of fruits and vegetables imported from
other countries. APHIS estimates 98 percent of the business respondents are small entities.

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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 severely limit APHIS’ ability to ensure litchi and
longan fruit shipments from Vietnam are not carrying plant pests such as Bactrocera cucurbitae
and Conogethes punctiferali. Consequently, the introduction of insect pests and disease into the
United States could result in catastrophic losses to American fruit crops and the loss of hundreds
of millions of dollars for the United States fruit industry.

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;
Revocation of an import permit may be appealed in writing within 10 days of notification
by APHIS.
An Emergency Action Notice (PPQ Form 523) may be issued by a Federal official and
issued to a broker, shipper, market owner, or other stakeholder responsible for a certain
consignment failing specific import requirements and requiring remedial action. The form
describes the reasons for refusal of entry into the United States and basic explanations of
required remedial actions. The notice is signed by the stakeholder on the day it is issued.
• 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

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• 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 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 recently consulted with the following individuals regarding this program:
Phat Ming Tran
An Phu Irradiation Joint Stock Company
119A.2 Group 4, Hamlet 1B
An Phu, Thuan An Dist,
Binh Duong Province, Vietnam
Tel. 011-84-650-371-4036
Vo Sok Diong
An Son Joint Stock Company
247 Kim Ma, Ba Dinh.
Hanoi, Vietnam
Tel. 011-84-8-754-0164
Huong Cho Kim
Thuy Son Joint Stock Company
No 01
TS1 Street, Tien Son Industrial
Tien Du District, Bac Ninh, Vietnam
Tel. 011-84-241-626-3679
On Friday, November 3, 2017, APHIS published in the Federal Register on pages 51211 and
51212 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.

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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,
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 personal or sensitive nature.

12. Provide estimates of 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.
See APHIS Form 71.
• Provide estimates of annualized cost to respondents for the hour burdens for
collections of information, identifying and using appropriate wage rate categories.
The annualized cost to respondents is determined by multiplying the total burden hours
(529) by the estimated hourly wage ($19 per hour). APHIS estimates the annualized cost
to respondents to be $10,051.
Respondents are growers, importers, and Vietnamese government officials. The average
hourly wage was calculated using wage information for agricultural growers and
government agricultural officials ($7.25) and importers (buyers and purchasing agents,
$30.73) obtained from the APHIS International Services Office in Manila, Philippines;
and the U.S. Department of Labor’s May 2016 Occupational Employment and Wages
Report (https://www.bls.gov/news.release/pdf/ocwage.pdf).

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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 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 no annual cost burden associated with the capital and start-up cost, maintenance costs,
and purchase of services in connection with this program.

14. Provide estimates of annualized cost 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.
See APHIS 79. The estimated cost for the Federal Government is $10,103.

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

Requested
Annual Number of
Responses
Annual Time
Burden (Hours)

Program
Change Due to Change Due to
Program
Change Due to Adjustment in
Potential
Change Due to
Agency
Agency
Violation of the
New Statute
Discretion
Estimate
PRA

Previously
Approved

31,019

515

29,502

1,002

529

271

2

256

In this renewal, the number of respondents increased from 3 to 7, adding importers and the
Vietnamese NPPO. The number of annual responses changed from 1,002 to 31,019 for a net
increase of +30,017 responses, and the total total burden hours changed from 256 to 529 for a net
increase of + 273 hours.
The most significant change is attributed to an estimate adjustment. Labeling (Business) has
increases to its estimates for both responses and burden, adding 29,502 additional responses and
2 additional hours of burden. The increases are attributed to more cartons and an adjustment to
response time.
Two activities have discretionary program adjustments attributed to additional respondent types
being added to the activities. They are Orchard Registration (Foreign Government) which added
6 responses and 6 hours of burden, and Phytosanitary Certificates (Business) which added 498
responses and 249 hours of burden.
Six activities are new, being inadvertently omitted in the previous submission and now added as
potential violations of the Paperwork Reduction Act. They include Recordkeeping (Business)
with 6 responses and 6 hours of burden, and Recordkeeping (Foreign Government) with 1
response and 6 hours of burden. Also added were Application for Permit (PPQ Form 587,
Appeal of Denial or Revocation of Permit (Business), Notice of Arrival (PPQ Form 368)
(Business), and Emergency Action Notification (PPQ Form 523) (Business). These four
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activities added 1 response and 1 hour of burden each. They are not substantial and were added
as placeholders for future burden analysis.
All of these changes are summarized in the two tables below. Under the respondent type column,
B = business, I = individual, FG = foreign government, NFP = not for profit, and Farm = farm.
Under the Type of Change column, “Adjust” indicates an adjustment to the Agency estimate,
“Program” indicates a program change due to agency discretion, and “New” indicates a new
burden.

CHANGES IN RESPONSES

REGS
319.56-3
319.7-5
319.56-70(a)
319.56-70(a)
319.56-70(c)
319.56-70(e)
319.56-70(e)
319.56-3d(1)
319.56-3d(2)
319.56-70
319.56-70

REASON
RESP
Import Permit
B
Appeal of Denial of Permit B
Orchard Registration
B
Orchard Registration
FG
Labeling
B
Phytosanitary Certificate
B
Phytosanitary Certificate
FG
Notice of Arrivals
B
Emergency Action Notif
B
Recordkeeping
B
Recordkeeping
FG

PREVIOUS
NEW
RESPONSES RESPONSES DIFFERENCE
0
1
1
0
1
1
6
6
0
0
6
6
498
30,000
29,502
0
498
498
498
498
0
0
1
1
0
1
1
0
6
6
0
1
1
+ 1,002
+31,019
+30,017

TYPE OF CHANGE
New
New
No Change
Program - respondent
Adjust
Program - respondent
No Change
New
New
New
New

CHANGES IN BURDEN HOURS

REGS
319.56-3
319.7-5
319.56-70(a)
319.56-70(a)
319.56-70(c)
319.56-70(e)
319.56-70(e)
319.56-3d(1)
319.56-3d(2)
319.56-70
319.56-70

REASON
RESP
Import Permit
B
Appeal of Denial of Permit B
Orchard Registration
B
Orchard Registration
FG
Labeling
B
Phytosanitary Certificate
B
Phytosanitary Certificate
FG
Notice of Arrivals
B
Emergency Action Notif
B
Recordkeeping
B
Recordkeeping
FG

PREVIOUS
BURDEN
0
0
6
0
1
0
249
0
0
0
0
+ 256

NEW
BURDEN
1
1
6
6
3
249
249
1
1
6
6
+ 529

DIFFERENCE
1
1
0
6
2
249
0
1
1
6
6
+ 273

TYPE OF CHANGE
New
New
No Change
Program - respondent
Adjust
Program - respondent
No Change
New
New
New
New

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 it collects.

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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.
PPQ Form 368, PPQ Form 523, and PPQ Form 587 are used for multiple information collections
which have different expiration dates. APHIS requests that an expiration date not be annotated
on these forms.

18. Explain each exception to the certification statement identified in the “Certification for
Paperwork Reduction Act.”
APHIS is able to certify compliance with all the provisions under the act.

B. Collections of Information Employing Statistical Methods.
Statistical methods are not used in this information collection.

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