0104 Ss 20180912

Supporting Statement

Gypsy Moth Identification Worksheet

0579-0104

September 2018

1. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), is responsible for preventing the entry of plant diseases or insect pests from entering into the United States, preventing the spread of plant pests and noxious weeds not widely distributed in the United States, and eradicating those imported pests when eradication is feasible.

Under the Plant Protection Act (7 U.S.C. 7701 – et seq.), the Secretary of Agriculture, either independently or in cooperation with the States, is authorized to carry out operations or measures to detect, eradicate, suppress, control, prevent, or retard the spread of plant pests new to the United States or not widely distributed throughout the United States. Plant Protection and Quarantine (PPQ), a program within APHIS is responsible for implementing the intent of this Act, and does so through the enforcement of its Domestic Quarantine Regulations contained in Title 7 of the Code of Federal Regulations (CFR) Part 301.

The gypsy moth (GM) regulations (7 CFR §§ 301.45 through 301.45-12, referred to as the regulations) restrict the interstate movement of regulated articles from quarantined areas to prevent the artificial spread of the GM to noninfested areas of the United States.

PPQ engages in detection surveys to monitor the presence of the European GM and the Asian GM.

The European GM is one of the most destructive pests of fruit and ornamental trees as well as hardwood forests. First introduced into the United States in Medford, Massachusetts in 1869, the European GM has gradually spread to infest the entire northeastern portion of the country.

Heavily infested areas are inundated with actively crawling larvae, which cover trees, fences, vehicles, and houses during their search for food. Entire areas may be stripped of all foliage, often resulting in heavy damage to trees. This damage can have long lasting effects, depriving wildlife of food and shelter, and severely limiting the recreational value of forested areas.

The Asian GM is an exotic strain of GM that is closely related to the European variety already established in the United States. While the Asian GM has been introduced into the United States on several different occasions, it is currently not established in this country.

Due to significant behavioral differences, this strain is considered to pose an even greater threat to trees and forested areas. Unlike the flightless European female adult GM, Asian GM female adults are capable of strong directed flight between mating and egg deposition, significantly increasing their ability to spread and become widely established within a short period of time.

In addition to this risk, Asian GM larvae feed on a much wider variety of hosts, allowing them to exploit more areas and cause more damage than the European GM.

In order to determine the presence and extent of an European GM or an Asian GM infestation, APHIS sets traps in high risk areas to collect specimens. Once an infestation is identified, control and eradication work (usually involving State cooperation) is initiated to eliminate the moths.

Since the European GM and the Asian GM are strains of the same species, they cannot be visually distinguished from each other. APHIS’ GM Identification Worksheet, and the information collected on it, is needed to clearly identify and track specific specimens that are sent to the Otis Laboratory for identification tests based on DNA analysis. Based on the DNA tests conducted at Otis, APHIS can evaluate the true pest risk and take appropriate action.

Checking the GM traps and recording information on the GM Identification Worksheet are information collection activities that are vital to APHIS’ ability to monitor, detect, and eradicate GM infestations.

APHIS is asking OMB to approve, for 3 additional years, its use of these activities in connection with APHIS’ efforts ability to monitor, detect, and eradicate GM infestations.

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.

APHIS uses the following information activities to restrict the interstate movement of regulated articles from quarantined areas to prevent the artificial spread of the GM to non-infested areas of the United States.

PPQ 391 – Specimens for Determination (State) - 7 CFR 301-45.2

APHIS personnel, with the assistance from the State Department of Agriculture personnel, check traps for the presence of GM. If moths or other suspicious insects are found in the trap, they are sent to the APHIS laboratory at the Otis Methods Development Center so that they can be correctly identified.

The individual submitting the moth for analysis (whether a PPQ employee or State employee) completes the Insect Collection Worksheet that accompanies the insect to the laboratory. The worksheet enables both Federal and State regulatory officials to identify and track specific specimens through the DNA identification tests that APHIS conducts.

If a specimen was submitted without the accompanying worksheet, laboratory personnel would have no way of knowing who submitted the specimen or where it was collected. The specimen would be meaningless.

Information on the worksheet includes the name of the submitter, the submitter’s agency, the date collected, the trap number, the trap’s location (including the nearest port of entry), the number of specimens in the trap, and the date the specimen was sent to the laboratory.

Surveys for the European GM are conducted throughout all areas not known to be infested with the European GM. Surveys for the Asian GM are conducted at sites that APHIS considers to be high risk for an Asian GM incursion, including international seaports as well as the two known areas of previous incursions (the Pacific Northwest ports and waterways in Oregon and Washington), and the Carolina coastal area between Wilmington, North Carolina and Myrtle Beach, South Carolina.

PPQ Form 377 - Gypsy Moth Checklist and Record of Your Self-Inspection (Individual)

7 CFR 301.45-4(a)

Any individual moving from a GM quarantine area to a non-quarantine area between the months of April and August must inspect his/her outdoor household items for the GM using the PPQ Form 377 and remove all life stages before moving.

Self-home Inspection (Individual) - 7 CFR 301.45-4(a)

Individuals may use the self-inspection checklist or hire a qualified certified applicator by contacting the state office to inspect outdoor household articles. If a qualified certified applicator performs the inspection, the individual must obtain a copy of the completed, signed checklist.

Recordkeeping of Self-Inspection (Individual) - 7 CFR 301.45-4(a)

A signed copy of the completed, checklist must accompany the vehicle driver(s) moving the individual’s household goods in case USDA or State officials request it during the move.

Moving Industry Notifying Homeowner (Business) - 7 CFR 301.45-4(a)

Moving company may choose to notify the person moving of the regulation requiring the OHA form to be done when they are moving from an infected area of GM to a non-infested area. The moving company may provide the inspection and associated recordkeeping as a service to the homeowner.

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.

The PPQ 391 – Specimens for Determination is posted and downloadable at:

https://www.aphis.usda.gov/library/forms/pdf/PPQ_Form_391.pdf. The form can be submitted to APHIS via mail or fax.

Gypsy Moth Checklist Record of Your Self-Inspection – PPQ Form 377 is a fillable PDF which provides the option of using an electronic signature. PPQ Form 377 in digital format is acceptable for presentation to State and Federal officials under all circumstances. PPQ Form 377 is available online and is posted at https://www.aphis.usda.gov/publications/plant_health/fsc-moving-check-gypsy-moth.pdf or an electronic checklist can be filled out online at https://www.aphis.usda.gov/proxy/http/feb.aphis.usda.gov/forms/before/moving/check/for/gypsy/moth. Providing and accepting the form in digital format increases public access to the form and eases burden on individuals and the industry.

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 APHIS collects is exclusive to its mission of protecting the United States from incursion by exotic agricultural pests and 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 restrict the interstate movement of regulated articles from quarantined areas to prevent the artificial spread of the GM to non-infested areas of the United States. APHIS estimates that 98 percent of the total respondents are small entities in connection with its GM activities.

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.

The European GM has been damaging Northeastern forests for more than 100 years. The Asian GM, which APHIS considers an even greater threat, has the potential to devastate forests, woodlands, and residential landscapes over a much larger range.

APHIS must conduct its GM survey activities on a continuous basis to prevent an incursion of Asian GM, and to prevent the further spread of the European GM. APHIS estimates that if the Asian GM were able to successfully establish itself in the United States, economic losses could exceed $1 billion during the next 40 years.

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;

Some GM traps must be checked daily, others biweekly. Due to the nature of the insect pests APHIS is monitoring, survey activities must be conducted at this intensity level if APHIS’ monitoring program is to be successful.

It should be noted that the Insect Collection Worksheet is completed only when traps are found to contain specimens.

According to Title 7, Code of Federal Regulations, Part 301.45-4(a), any individual moving from a GM quarantine area to a non-quarantine area between the months of April and August must inspect his/her outdoor household items for the GM and remove all life stages before moving.

• 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 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.

Consultations concerning APHIS’ information collection activities were held with the following groups:

Michael Bienviendes

Oregon Department of Agriculture

635 Capital Street, NE

Salem, Oregon 97310-0110

Phone: (503) 986-4773

Erica Palinski

Division of Plant Industry, Gypsy Moth

New Jersey Dept. of Agriculture

PO Box 330

Trenton, NJ 08625-033

Phone: 609-406-6948

Nicholas Adamis

Biological Control Administrator Plant Protection

N.C. Department of Agriculture and Consumer Services

1060 Mail Service Center

Raleigh, NC 27699-1060

Phone: 919-233-8214

On Friday, October 13, 2017, pages 47693-47694, 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 were received from the public.

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 (other than appropriate, program-related 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, 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 83-1.

See APHIS Form 71 for hour burden estimates. These estimates were developed using historical data, calculated average number of traps checked and moths detected, and discussions with field personnel.

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

The costs to State regulatory agencies cooperating in APHIS’ Asian gypsy moth survey activities were estimated by determining how much time it takes Federal personnel to complete the same survey activities (checking traps and completing the worksheet).

APHIS estimates the annualized cost to respondents to be $117,274,234.

The hourly rate of $43.25 was derived from the U.S. Department of Labor; Bureau of Labor Statistics May 2017 Report – Occupational Employment and Wages in the United States. See

http://www.bls.gov/oes/current/999101.htm. The total cost to respondents is computed by multiplying APHIS arrived at this figure by multiplying the average wage by the total number of hours needed to complete the work: 2,711,543 x $43.25 = $117,274,234.

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, maintenance costs, and purchase of services in connection with this program.

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 $318,910.00. (See APHIS Form 79.)

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

ICR Summary of Burden:
	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	7,500,250	0	0	7,100,010	0	400,240
Annual Time Burden (Hr)	2,711,543	0	0	2,494,902	0	216,641
Annual Cost Burden ($)	0	0	0	0	0	0

There is an adjustment increase of +50 respondents and +7,100,010 respondents and + 7,100,010 responses resulting in an increase of +2,494,902 total burden hours.  The Your Move Gypsy Moth Free Brochure, Program Aid No. 2147 was converted to an official APHIS form - PPQ Form 377.  The increase is due to a collaboration with the United States Postal Service, which has provided accurate numbers of how many respondents have put in for change of address forms within the quarantine areas and for the Moving Industry notifying Homeowners of GM requirements. Also the PPQ Form 305 has been replaced with the PPQ Form 391.

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. However, results of DNA identification analysis are widely distributed using electronic mail via the PPQ and Asian GM bulletin boards.

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.

This is not applicable. APHIS will display the expiration date.

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.