0579-0311 2020 Ss

August 2020

SUPPORTING STATEMENT

APHIS Pest reporting

AND ASIAN LONGHORNED BEETLE PROGRAM

OMB NO. 0579-0311

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 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.

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:

PPQ Pest Reporting Form (PPQ Form 10); (7 CFR 301); (Individuals and Households)

APHIS uses the voluntary PPQ Form 10 (form or online entry) 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. In the case of emerald ash borer, APHIS will also use the pest reports to identify locations for releasing biological control agents to control and suppress pest populations. As reports are collected, they 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 are obtained by contacting the respondent for more information and directions.

Cooperative Agreement for Inspection; (7 CFR 301.51); (State, Local, or Tribal Government)

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.

State Compliance Training Workshop Records; (7 CFR 301.51-6); (State, Local, or Tribal Government) - 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.

Inspections/Asian Longhorned Beetle Unified Survey (PPQ Form 375); (7 CFR 301.51-3); (State, Local, or Tribal Government)(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.

Contract for Inspection; (7 CFR 301.51); (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.

Permission to Inspect from Homeowner (documented verbal phone calls); (7 CFR 301.51); (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.

Refusal to Inspect from Homeowner; (7 CFR 301.51); (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.

Chemical Treatment Release from Homeowner; (7 CFR 301); (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.

Letter Prior to Litigations and Warrants; (7 CFR 301); (State, Local, or Tribal Government)

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.

Litigations and Warrants; (7 CFR 301); (State, Local, or Tribal Government)

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.

Homeowner to Sign for Tree Removal; (7 CFR 301); (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.

Removal/Monitoring; (7 CFR 301.51); (State, Local, or Tribal Government)

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.

Contract for Treatment; (7 CFR 301); (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.  

Removal/Disposal; (7 CFR 301); (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.

Disposal/Marshalling Yard; (7 CFR 301.51); (State, Local, or Tribal Government)

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.

Tree Warrant; (7 CFR 301); (State, Local, or Tribal Government)

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.

Certificate/Permit Cancellation Appeal; (7 CFR 301.51); (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) is available on the APHIS forms website. It is also being incorporated into a number of APHIS Web pages or mini sites that encourage the public to look for and report pests and diseases of concern, including Asian longhorned beetle, emerald ash borer, and citrus greening.

The ALB Unified Survey (PPQ Form 375) is available on the APHIS forms website.

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 continues working towards getting all ALB data prepped and migrated to the Integrated Public Health Information System (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.

APHIS has determined that none of the respondents are small entities. 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, and to conduct Asian Longhorned Beetle program operations. Burden is minimized by making completion of these forms voluntary and completion online.

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.

Not collecting pest reports from the public could result in APHIS not receiving information about where infestations may exist, causing them to linger unreported and grow. Collecting this information less frequently or failing to collect it could hamper the operations of APHIS’ pest management programs. Further, infestations of high-consequence pests and diseases, such as Asian longhorned beetle, emerald ash borer, 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 concerning the activities and burden in this information collection. There were no recommended changes.

Ann Gibbs

Director, Division of Animal & Plant Health

Maine Department of Agriculture, Conservation & Forestry

22 State House Station

Augusta, ME 04333

Tel. (207) 287-7602

Joan Mahoney

Field Operations Manager

New York State Department of Agriculture and Markets

320 Merrick Road

Amityville, NY 11701

Tel. (631) 831-8136

Dan Kenny

Manager, Plant Pest Control Section

Division of Plant Industry

Ohio Department of Agriculture

8995 East Main Street

Reynoldsburg, OH 43068

Tel. (614) 728-6400

On Monday, June 1, 2020, APHIS published in the Federal Register on pages 33080 and 33081 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.

See APHIS Form 71 for hour burden estimates.

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

The total annualized cost to respondents is $19,209,000. This was computed by multiplying the estimated average hourly wage ($30.64) by the total number of burden hours (438,719) needed to complete the work, and then multiplying the result by 1.429 to capture benefit costs.

The average hourly rates used to calculate the estimate are for sales representative (SOCC 41-4012, $34.19); conservation scientist (SOCC 19-1031, $32.23); forester (SOCC 19-1032, $30.42); and all occupations (SOCC 00-0000, $25.72), using information found at the U.S. DOL Bureau of Labor Statistics occupational employment statistics website at http://www.bls.gov/current/oes_stru.htm.

According to DOL BLS news release USDL-20-0451 released March 19, 2020, employee benefits account for 30 percent of employee costs, and wages account for the remaining 70 percent. Mathematically, total costs can be calculated as a function of wages using a multiplier of 1.429.

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.

See APHIS Form 79. The estimated cost for the Federal government is $4,428,140.

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

	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	688,757	0	0	11	0	688,746
Annual Time Burden (Hr)	438,719	0	0	(60)	0	438,779

This request for renewal of an information collection request contains 688,757 responses and 438,719 hours of burden, an increase of 11 responses and decrease of 60 hours of burden from the previous submission. The number of estimated respondents remains unchanged at 7,055.

All of the changes are attributed to adjustments of agency estimates. The total number of responses for five activities were each rounded to the nearest 10, adding 11 responses. These activities were Inspections/ALB Unified Survey (+9), Litigations and Warrants (+2), Removal/ Monitoring (-2), Removal/ Disposal (+4), and Disposal/Marshalling Yard (-2). These changes also resulted in a decrease of 66 hours of burden. Finally, four activities had their estimated response time changed from .16 hours to .167 hours per response, adding 2 hours of burden to the information collection request.

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.

In an effort to efficiently manage instruments across multiple media, APHIS requests approval to not display the expiration date for OMB approval on the forms. The agency continues working towards automating the PPQ Forms 10 and 375 for website entry and phasing out the print versions of the forms.

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.