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PUBLIC SUBMISSION

Comment from ENTERED ON MARCH 10, 2026 INTO THE
RECORD BY SMALL BUSINESS DEFENSE CONTRACTOR
OBELISK TECH SYSTEMS INC. BY JAMES POOLE
Posted by the Animal and Plant Health Inspection Service on Mar 10, 2026

Docket (/docket/APHIS-2025-0704) / Document (APHIS-2025-0704-0001) (/document/APHIS-2025-0704-0001)
/ Comment

Comment

ENTERED ON MARCH 10, 2026 INTO THE RECORD BY JAMES H. POOLE THE CEO OF OBELISK
TECH SYSTEMS INC. A SMALL BUSINESS DEFENSE CONTRACTOR IN RURAL FEMA DISASTER
ZONE TRACT

APHIS_01_PRA_Core
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DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-01 OF 20

TITLE

Paperwork Reduction Act Core Objection: APHIS 30,930-Hour Burden Estimate
Understates True Small Farm Cost — Burden Increase Is Unjustified and OMB Must Reject
Revision to 0579-0090

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
This comment formally objects to the Animal and Plant Health Inspection Service's proposed revision to and
extension of approval of OMB Control Number 0579-0090, covering Specimen Submission forms for livestock
disease surveillance. APHIS discloses a total annual burden of 30,930 hours across 95,060 responses from 14,860
respondents. This estimate materially understates the true burden on small rural farms and rural veterinarians, and
the burden increase driving the revision — attributed to an increase in the number of respondents — has never
been adequately justified.
The PRA requires agencies to accurately estimate the full burden of information collections, including all time
necessary to gather, maintain, and submit the required information. 44 U.S.C. Section 3506(c)(2)(A). APHIS's
estimate of 0.325 hours per response — approximately 19.5 minutes — reflects the time to complete the form itself.
It does not count the time to: collect specimens from animals; prepare specimens for transport; coordinate with
laboratory submission requirements; document chain of custody; follow up on laboratory results; or manage the
administrative burden of multiple concurrent submissions during disease events. For small rural farms, the true perresponse burden is conservatively two to four times APHIS's disclosed estimate.
Obelisk Tech Systems Inc. operates in Thomasville, Thomas County, Georgia — a rural agricultural community
where livestock operations are a significant economic sector. Thomas County is directly affected by APHIS disease
surveillance requirements. The company and its principal, James Hunter Poole, have direct community standing to
challenge the accuracy of APHIS's burden estimate for rural livestock operations in Southwest Georgia.

SECTION II — QUANTIFIED ANALYSIS
A. The True Per-Response Burden
A realistic estimate of the per-response burden for a small rural livestock farm includes: specimen collection from
animals — estimated 20 to 45 minutes depending on animal type; specimen preparation for transport — estimated
15 to 30 minutes; completing the Specimen Submission form — estimated 15 to 20 minutes (APHIS's estimate
covers only this step); coordinating with a licensed veterinarian for certain specimens — estimated 30 to 60 minutes
if coordination is required; transporting specimens to submission point — estimated 30 to 120 minutes for rural
farms without local laboratory access; and follow-up documentation — estimated 15 to 30 minutes. Total perresponse true burden: estimated 1.5 to 5 hours per response versus APHIS's disclosed 0.325 hours.

B. The Burden Increase Is Unjustified
APHIS states that the revision reflects an increase in the number of respondents, responses, and total burden
hours. This increase has not been adequately justified. APHIS has not explained: why the number of respondents
has increased; whether this reflects an expansion of surveillance program scope; whether the additional
respondents are small farms that face higher per-response burdens; or whether the increased burden could be
achieved through less burdensome means. An unexplained burden increase is an independent PRA deficiency.

SECTION III — DEMANDED ACTIONS
Demanded Action 1
OMB shall reject the proposed revision to OMB Control Number 0579-0090 until APHIS submits a corrected burden
estimate reflecting the true per-response burden for small rural livestock farms — including specimen collection,
preparation, transport, and follow-up time — and provides an adequate explanation for the increase in respondents
and total burden hours. Deadline: Immediate rejection.

Demanded Action 2
APHIS shall conduct and publish a burden analysis based on time-use surveys of actual small rural farm
respondents, measuring the full time investment required to complete a Specimen Submission from specimen
collection through form submission. Deadline: 90 days from this comment.

Demanded Action 3
APHIS shall provide a written explanation of the reason for the increase in respondents, responses, and burden
hours, with specific identification of whether the increase reflects an expansion of surveillance scope and, if so, the
statutory authority and cost-benefit justification for that expansion. Deadline: 90 days from this comment.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Accurate burden disclosure required — 0.325 hour per
response estimate excludes majority of actual farm
burden

44 U.S.C. Section
3506(c)(2)(A)

PRA Burden Estimation

Full burden including specimen collection, preparation,
and transport must be counted — APHIS counts only
form completion

44 U.S.C. Section 3507(d)

OMB Review Requirement

Burden increase requires OMB approval with
adequate justification — justification not provided

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Unjustified burden increase is arbitrary — State Farm
requires reasoned explanation

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Agency must examine relevant data — true small farm
burden is relevant data not examined

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Small rural farms are most burdened respondents —
IRFA based on false estimate is deficient

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Statutory authority for surveillance does not authorize
unlimited burden expansion — scope must be justified

E.O. 12866

OIRA Cost-Benefit Review

True burden increase must be weighed against
disease surveillance benefit — analysis never done

APA Section 706 rights reserved.

APHIS_03_RFA_SmallFarm
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APHIS_04_RuralGeorgia_Standing
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Comment ID
APHIS-2025-0704-0004

Tracking Number
mmk-awie-curs

Comment Details

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DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-02 OF 20

TITLE

Practical Utility Challenge: APHIS Must Justify Each Form Element — Livestock Disease
Surveillance Does Not Require Every Data Point Currently Collected

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
The PRA requires that information collected by APHIS have practical utility — meaning it must be necessary for the
proper performance of APHIS's disease surveillance function. 44 U.S.C. Section 3506(c)(1). APHIS has never
demonstrated, element by element, that every data field on the Specimen Submission form and its continuation
sheet is necessary for effective disease surveillance. The Specimen Submission form collects extensive data about
the submitter, the animal source, the specimen type, and the suspected disease — not all of which is necessary for
every surveillance submission.
Effective disease surveillance requires: identification of the animal species and geographic source; the specimen
type and collection date; the suspected disease or purpose of testing; and the submitting veterinarian or institution
for results reporting. Additional data elements — detailed herd owner information, animal identification systems,
production classification data — serve program management rather than surveillance functions and could be
collected through less burdensome post-result processes. APHIS has never published an element-by-element
necessity analysis.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall conduct and publish an element-by-element necessity analysis of every data field on the Specimen
Submission form, demonstrating the specific disease surveillance function served by each element and why that
function cannot be served by less burdensome means. Deadline: 90 days from this comment.

Demanded Action 2
APHIS shall remove from the Specimen Submission form all data elements that serve program management rather
than immediate disease surveillance functions, and shall collect program management data through separate, less
burdensome post-result processes. Deadline: Prior to next renewal.

Demanded Action 3
OMB shall condition any renewal of OMB Control Number 0579-0090 on APHIS completing the element-by-element
necessity analysis demanded herein. Deadline: Immediate OMB condition.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3506(c)(1)

PRA Practical Utility
Requirement

Each data element must be necessary for agency
function — APHIS has never conducted element-byelement analysis

44 U.S.C. Section 3508

PRA Duplication Prohibition

Data available from state systems must not be
collected again federally — duplication documented in
APHIS-15

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Statutory authority is for disease surveillance — data
collection beyond surveillance necessity exceeds this
authority

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Collecting unnecessary data is arbitrary — no rational
basis for form elements beyond surveillance necessity

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Necessity of each form element is relevant data that
must be examined — APHIS has not examined it

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Unnecessary data collection disproportionately
burdens small rural farms without equivalent support
staff

E.O. 12866

OIRA Cost-Benefit Review

Cost of unnecessary data collection must be weighed
against surveillance benefit — never done

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Practical utility is threshold PRA requirement —
collection fails if any element lacks demonstrated
necessity

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-03 OF 20

TITLE

RFA Small Farm Impact: 14,860 Respondents Are Predominantly Small Rural Farmers and
Veterinarians — IRFA Is Inadequate and Must Be Revised

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
The Regulatory Flexibility Act requires APHIS to analyze the impact of the Specimen Submission information
collection on small entities — specifically the small rural farms, small veterinary practices, and small research
institutions that constitute the overwhelming majority of the 14,860 annual respondents. APHIS's IRFA for this
collection is inadequate because it applies a uniform 0.325-hour per-response burden estimate to all respondents
regardless of size, geographic location, or operational complexity — failing to recognize the systematic burden
asymmetry between large institutional respondents (universities, large laboratories, major veterinary practices) and
small rural farm operations.
A large veterinary diagnostic laboratory that submits hundreds of specimens per year to NVSL has established
submission procedures, trained staff, and electronic submission infrastructure. The per-response burden for such
an institution is approximately consistent with APHIS's 0.325-hour estimate. A small rural livestock farm in Thomas
County, Georgia that submits a handful of specimens per year in response to a suspected disease event has none
of this infrastructure. The per-response burden for this farm — including specimen collection, veterinarian
coordination, rural transport, and form completion — is estimated at 1.5 to 5 hours. The IRFA's failure to distinguish
these categories is a fundamental RFA deficiency.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall prepare and publish a revised IRFA that specifically analyzes the per-entity burden for small rural farms
versus large institutional respondents, using survey data from each category. Deadline: 90 days from this comment.

Demanded Action 2
APHIS shall adopt a simplified submission pathway for small rural farm respondents — a streamlined Specimen
Submission form with fewer fields that captures surveillance-essential data without the full burden of the standard
form. Deadline: Prior to next renewal.

Demanded Action 3

APHIS shall consult with the SBA Office of Advocacy, the National Farmers Union, and the American Farm Bureau
Federation before finalizing this revision, and shall include the record of that consultation in the docket. Deadline:
Prior to renewal approval.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Small rural farms are most burdened respondents —
IRFA must analyze their burden separately from
institutional respondents

5 U.S.C. Section 603

RFA IRFA Requirement

IRFA must analyze small entity impact — uniform
burden estimate across all respondents is insufficient

5 U.S.C. Section 604(a)(5)

RFA Least Burdensome
Alternative

Simplified form for small rural farms is least
burdensome alternative — RFA requires its adoption

Pub. L. 104-121 (SBREFA)

Small Business RFA
Enforcement

SBA Office of Advocacy must be consulted — small
rural farms qualify as small entities

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

True small farm burden never disclosed — PRA and
RFA deficiencies compound each other

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

IRFA deficiency is independent APA ground —
renewal without adequate small entity analysis is
arbitrary

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Statute does not authorize imposing disproportionate
burdens on small farms — RFA compliance required

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Small farm burden data is relevant data that must be
examined — APHIS has not examined it

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-04 OF 20

TITLE

Rural Georgia Standing: Thomas County Georgia Livestock Operations Are Directly
Affected — Rural High-Poverty Farm Community Impact Analysis Required

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
This comment establishes the standing of James Hunter Poole and Obelisk Tech Systems Inc. to comment on this
collection on behalf of rural livestock operators in Thomas County, Georgia, and demands that APHIS conduct a
specific impact analysis for rural high-poverty agricultural communities in the Deep South — communities that face
heightened burdens from federal specimen submission requirements due to geographic isolation, limited veterinary
infrastructure, and economic constraints.
Thomas County, Georgia is a rural high-poverty census tract with approximately 23 percent poverty and 14 percent
bachelor's degree attainment. The county's agricultural sector includes beef cattle, poultry, hogs, and other livestock
operations that are subject to APHIS disease surveillance requirements. Thomas County's rural geography — with
limited local veterinary laboratory infrastructure and significant driving distances to NVSL-connected facilities —
creates specimen submission burdens that are dramatically higher than the national average APHIS uses in its
burden estimate.
The practical consequence of APHIS's uniform burden estimate is that the compliance costs borne by a Thomas
County cattle farmer are systematically undercounted relative to those borne by a farmer near a major veterinary
diagnostic laboratory. This geographic burden asymmetry has real economic consequences for rural Southwest
Georgia livestock operations that are already operating on thin margins in a high-poverty community.

SECTION II — QUANTIFIED ANALYSIS
A. Southwest Georgia Veterinary Infrastructure Gap
The nearest NVSL-connected veterinary diagnostic laboratory to Thomasville, Georgia is the Georgia Diagnostic
and Investigative Laboratories facility in Tifton, Georgia — approximately 45 miles away. For a Thomas County
livestock farmer who must transport specimens to this facility, the transport burden alone adds approximately 1.5
to 2.5 hours per submission round trip. APHIS's 0.325-hour estimate does not include any transport time. For
Southwest Georgia farmers, transport alone increases the true per-response burden by 460 to 770 percent above
APHIS's estimate.

B. Economic Impact on High-Poverty Rural Communities

For a Thomas County livestock farmer with a median farm income at or below the county median household income
of approximately $35,000, the time cost of a single disease surveillance submission — including specimen
collection, veterinarian coordination, transport, and form completion — at a realistic 2 to 5 hours per response
represents a significant opportunity cost. At an agricultural labor opportunity cost of $15 to $25 per hour, a single
submission costs $30 to $125 in time — a burden that is proportionately far higher for a small rural farm than for a
large commercial operation or institutional respondent.

SECTION III — DEMANDED ACTIONS
Demanded Action 1
APHIS shall conduct and publish a rural geographic burden analysis that accounts for specimen transport time from
farms in rural counties without local NVSL-connected laboratory access — specifically including Thomas County,
Georgia and comparable Southwest Georgia counties. Deadline: 90 days from this comment.

Demanded Action 2
APHIS shall establish a mobile specimen collection and transport service for rural high-poverty counties without
local laboratory access, funded by APHIS rather than borne by individual farmers, as a burden reduction measure.
Deadline: Next USDA budget cycle.

Demanded Action 3
APHIS shall include Thomas County, Georgia as a case study community in all future burden analyses for the
Specimen Submission collection. Deadline: Incorporated in revised burden estimate.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Geographic transport burden not counted — material
understatement for rural counties without local lab
access

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Rural geographic burden asymmetry is a small entity
impact — RFA requires analysis

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Statute authorizes surveillance but not imposition of
disproportionate geographic burdens on rural farmers

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Geographic burden asymmetry is relevant data —
failure to examine it is arbitrary

E.O. 12866

OIRA Cost-Benefit Review

Rural geographic burden must be included in costbenefit analysis — significant cost never quantified

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Transport burden data is relevant data that must be
examined — APHIS has not examined it

42 U.S.C. Section 5170

Stafford Act

Disaster surveillance events impose emergency-level
burdens on rural farms — federal relief should cover
specimen transport

IRC Section 1400Z-2

Qualified Opportunity Zones

Thomas County is a rural high-poverty community —
federal agricultural programs must account for QOZ
community economic fragility

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-04 OF 20

TITLE

Rural Georgia Standing: Thomas County Georgia Livestock Operations Are Directly
Affected — Rural High-Poverty Farm Community Impact Analysis Required

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

B. Economic Impact on High-Poverty Rural Communities

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Geographic transport burden not counted — material
understatement for rural counties without local lab
access

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Rural geographic burden asymmetry is a small entity
impact — RFA requires analysis

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Statute authorizes surveillance but not imposition of
disproportionate geographic burdens on rural farmers

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Geographic burden asymmetry is relevant data —
failure to examine it is arbitrary

E.O. 12866

OIRA Cost-Benefit Review

Rural geographic burden must be included in costbenefit analysis — significant cost never quantified

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Transport burden data is relevant data that must be
examined — APHIS has not examined it

42 U.S.C. Section 5170

Stafford Act

Disaster surveillance events impose emergency-level
burdens on rural farms — federal relief should cover
specimen transport

IRC Section 1400Z-2

Qualified Opportunity Zones

Thomas County is a rural high-poverty community —
federal agricultural programs must account for QOZ
community economic fragility

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-05 OF 20

TITLE

State Veterinarian Authority: States Already Conduct Superior Disease Surveillance —
Federal Duplication of State Systems Is Waste — State-Led Model Must Be Evaluated

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
This comment challenges the expansion of the APHIS Specimen Submission information collection on the ground
that state veterinary diagnostic systems — specifically the network of state veterinary diagnostic laboratories, state
animal health programs, and cooperative state-federal surveillance programs — already collect substantially
equivalent data at the state level. Federal duplication of data already collected by state systems is waste under the
PRA's anti-duplication principle and the CFO Act's financial efficiency mandate.
Georgia operates the Georgia Diagnostic and Investigative Laboratories (GDIAL) network, which collects specimen
submission data from Georgia livestock operations as part of the state's animal health surveillance program. The
data collected by GDIAL is substantially equivalent to the data collected on APHIS's Specimen Submission form for
the same specimens. When a Georgia livestock farmer submits a specimen through the GDIAL network, the
specimen data is already collected at the state level. APHIS's additional federal collection of the same data — in
many cases for the same specimens — is duplicative under PRA Section 3508.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall conduct and publish a duplication analysis identifying all Specimen Submission data elements that are
also collected by state veterinary diagnostic laboratory systems in the states with APHIS cooperative agreements,
and shall eliminate all federally duplicative data collection where state data is adequate for surveillance purposes.
Deadline: 90 days from this comment.

Demanded Action 2
APHIS shall evaluate a state-led disease surveillance model under which state veterinary diagnostic laboratories
serve as the primary data collection mechanism for all routine surveillance submissions, with federal APHIS
collection limited to specimens requiring NVSL-level analysis not available at state laboratories. Deadline: 180 days
from this comment.

Demanded Action 3

APHIS shall negotiate data sharing agreements with state veterinary diagnostic laboratory networks to obtain statecollected submission data electronically, eliminating the need for separate federal form submissions for specimens
already reported to state systems. Deadline: 360 days from this comment.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3508

PRA Duplication Prohibition

Federal collection of data already in state systems is
duplicative — APHIS must eliminate duplicative
collection

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Federal-state cooperative surveillance framework
envisioned by statute — federal duplication of state
data contradicts this framework

E.O. 13132

Federalism

State authority over agricultural programs within state
borders — APHIS expansion should respect state
surveillance primacy

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Duplicating state data collection without justification is
arbitrary — state-led alternative never evaluated

Pub. L. 101-576

Chief Financial Officers Act

Federal duplication of state surveillance systems is
financial inefficiency — CFO Act requires evaluation

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Anti-duplication principle is core PRA mandate —
state-federal data sharing eliminates burden at zero
surveillance cost

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

State-led alternative is relevant alternative that must
be evaluated — APHIS has not evaluated it

E.O. 12866

OIRA Cost-Benefit Review

State-led surveillance model cost-benefit never
analyzed — would show dramatic burden reduction at
equivalent surveillance value

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-06 OF 20

TITLE

Automation Demand: Electronic Submission Alternatives Exist and Are Not Being Required
— PRA Section 3506(c)(3) Violated — APHIS Must Mandate Electronic Submission Before
Renewal

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
The PRA requires agencies to use automated collection techniques and other forms of information technology to
minimize the burden of information collections. 44 U.S.C. Section 3506(c)(3). Electronic specimen submission
systems exist and are in use by some NVSL submitters. Paper-based or PDF-based Specimen Submission forms
remain available and widely used by rural small farm submitters. APHIS has not required electronic submission,
has not provided universal access to electronic submission systems for small rural farms, and has not assessed
the burden reduction that electronic submission would produce. This is a PRA Section 3506(c)(3) violation.
Electronic submission of Specimen Submission data would: eliminate paper form completion time; enable
automated data validation reducing submission errors; allow pre-population of returning submitter data; integrate
directly with NVSL laboratory information management systems; and enable real-time submission tracking for
submitters. The burden reduction from universal electronic submission is estimated at 30 to 50 percent of the form
completion component of the total burden. APHIS has never analyzed this alternative.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall assess and publish the burden reduction potential of universal electronic submission for the Specimen
Submission collection, including the cost of deploying accessible electronic submission systems to rural small farm
submitters. Deadline: 90 days from this comment.

Demanded Action 2
APHIS shall deploy a mobile-accessible electronic Specimen Submission system — usable on a smartphone —
that enables rural small farm submitters to complete submissions electronically without internet connectivity
requirements. Deadline: Prior to next renewal.

Demanded Action 3

OMB shall condition any renewal of OMB Control Number 0579-0090 on APHIS implementing electronic submission
capabilities accessible to all categories of submitters, including rural small farms without broadband internet access.
Deadline: Immediate OMB condition.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3506(c)(3)

PRA Automation
Requirement

APHIS must use electronic submission — failure to
require it is PRA violation

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Automation is mandatory burden minimization tool —
APHIS failure to implement electronic submission
violates PRA core requirement

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Failure to evaluate electronic submission alternative is
arbitrary — State Farm requires examination of
available alternatives

E.O. 13960

AI in Government

Federal AI and automation policy requires agencies to
use technology to improve service delivery — APHIS
application process should comply

E.O. 12866

OIRA Cost-Benefit Review

30 to 50 percent burden reduction from electronic
submission — significant cost saving never analyzed

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Electronic submission alternative is relevant data that
must be examined — APHIS has not examined it

Infrastructure Investment and
Jobs Act

Rural Broadband

Rural broadband investment must be paired with
electronic submission systems accessible to rural
farms

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Electronic submission most benefits small rural farms
— RFA requires consideration of technology
alternatives

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-07 OF 20

TITLE

APA Section 706 Objection: Burden Increase Approved Without Adequate Explanation —
Why Are More Respondents Needed? State Farm Demands Reasoned Answer

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
APHIS states in the Federal Register notice that the revision to OMB Control Number 0579-0090 reflects an
increase in the number of respondents, responses, and total burden hours. This statement does not constitute the
reasoned explanation that Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance
Co., 463 U.S. 29 (1983), requires. Under State Farm, an agency must examine the relevant data and articulate a
satisfactory explanation for its action including a rational connection between the facts found and the choice made.
A bare statement that the number of respondents has increased is not a satisfactory explanation for why that
increase is appropriate, why a larger surveillance program is needed, or why the burden of the increase should fall
on private submitters rather than being absorbed by federal or state resources.
The questions APHIS must answer — and has not — include: What disease events or surveillance gaps drove the
decision to expand the respondent pool? What is the statutory authority for expanding the surveillance program
scope? Has APHIS conducted a cost-benefit analysis comparing the disease surveillance value of the expanded
program to the additional burden it imposes on rural farmers and veterinarians? Has APHIS evaluated whether the
surveillance expansion could be achieved through less burdensome means — electronic submission, state-level
data sharing, targeted surveillance rather than broad respondent expansion?

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall publish a written explanation of the reasons for the increase in respondents, responses, and total
burden hours — specifically identifying the disease surveillance gap or program expansion that drives the increase,
the statutory authority for the expanded scope, and the cost-benefit analysis supporting the decision to expand
rather than achieve equivalent surveillance through less burdensome means. Deadline: 90 days from this comment.

Demanded Action 2
APHIS shall evaluate whether the surveillance expansion that drives the burden increase can be achieved through
electronic data sharing with state veterinary diagnostic systems — as demanded in Documents APHIS-05 and
APHIS-06 — rather than through expansion of the federal Specimen Submission respondent pool. Deadline: 90
days from this comment.

Demanded Action 3
OMB shall reject the proposed revision until APHIS provides the written explanation demanded herein and
demonstrates that the burden increase is the least burdensome means of achieving the identified surveillance
objective. Deadline: Immediate OMB condition.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Burden increase without adequate explanation is
arbitrary — State Farm requires rational connection
between facts and choice

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Master Precedent

Bare statement of respondent increase is not
satisfactory explanation — reasoned analysis of why
increase is needed required

44 U.S.C. Section 3507(d)

OMB Review Requirement

Burden increase requires OMB approval with
adequate justification — justification not provided

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

PRA requires agencies to use minimum information
necessary — burden increase must be justified as
minimum necessary

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Statutory authority for surveillance does not authorize
unexplained expansion — statutory basis for increase
must be identified

E.O. 12866

OIRA Cost-Benefit Review

Disease surveillance value of expanded program must
be weighed against additional burden — analysis
never done

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Burden increase falls disproportionately on small rural
farms — RFA requires explanation of why less
burdensome alternative not adopted

Pub. L. 101-576

Chief Financial Officers Act

Unexplained program expansion consuming additional
private sector resources without demonstrated return
is CFO Act concern

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-08 OF 20

TITLE

OMB and OIRA Rejection Request: OMB Control Number 0579-0090 Revision Must Be
Rejected Until Burden Increase Is Justified and True Small Farm Burden Is Disclosed

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
This document constitutes a formal request to OMB and OIRA to reject the proposed revision to OMB Control
Number 0579-0090 on the grounds that: the burden estimate of 0.325 hours per response materially understates
the true small rural farm burden; the increase in respondents, responses, and total burden hours has not been
adequately explained or justified; the anti-duplication requirement of PRA Section 3508 has not been satisfied; and
the automation assessment required by PRA Section 3506(c)(3) has not been conducted. On each of these
independent grounds, OMB cannot lawfully approve this revision.
OMB's statutory obligation under 44 U.S.C. Section 3507(a)(2) is to determine whether the collection of information
is necessary for the proper performance of APHIS's functions. OMB cannot make this determination on the basis
of a revision notice that does not explain why the expanded respondent pool is necessary, does not disclose the
true burden on small rural farms, does not assess state system alternatives, and does not assess electronic
submission alternatives. The revision is deficient on its face.

SECTION II — DEMANDED ACTIONS
Demanded Action 1 — OMB
OMB shall reject the proposed revision to OMB Control Number 0579-0090 until APHIS: provides a corrected
burden estimate based on true small farm respondent time-use data; explains the reason for the respondent
increase; demonstrates no duplication with state veterinary systems; and assesses electronic submission
alternatives. Deadline: Immediate rejection.

Demanded Action 2 — OIRA
OIRA shall conduct an independent review of APHIS information collection burden estimates across all USDA
APHIS programs and determine whether APHIS's systematic use of minimal per-response time estimates — without
accounting for specimen collection, preparation, and transport burden — reflects agencywide PRA non-compliance.
Deadline: 90 days from this comment.

Demanded Action 3 — APHIS

APHIS shall prepare a revised revision notice addressing all deficiencies identified herein, publish it in the Federal
Register with a new 60-day comment period, and resubmit to OMB. Deadline: 120 days from this comment.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3507(a)(2)

OMB Review Authority

OMB must determine necessity of collection — cannot
do so on deficient submission

44 U.S.C. Section 3507(a)(1)

OMB Approval Requirements

OMB approval requires PRA compliance — current
submission is non-compliant on multiple grounds

44 U.S.C. Section 3508

PRA Duplication Prohibition

State system duplication not assessed — OMB cannot
approve without duplication analysis

44 U.S.C. Section 3506(c)(3)

PRA Automation
Requirement

Electronic submission alternative not assessed —
OMB cannot approve without automation analysis

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

OMB approval of non-compliant submission would
itself be arbitrary and capricious

E.O. 12866

OIRA Cost-Benefit Review

OIRA should review APHIS collection practices
agencywide — systemic PRA non-compliance
warrants review

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

OMB must examine relevant data before approving —
deficient submission prevents this examination

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

OMB approval of IRFA-deficient submission violates
RFA — small farm analysis must be adequate

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-09 OF 20

TITLE

Animal Health Protection Act Scope: 7 U.S.C. Section 8301 Does Not Authorize Unlimited
Expansion of Specimen Collection Forms — Statutory Limits Must Be Enforced

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
The Animal Health Protection Act, 7 U.S.C. Section 8301 et seq., provides APHIS with broad authority to conduct
disease surveillance necessary to prevent the introduction or spread of any pest or disease of livestock. This
authority is broad, but it is not unlimited. The APA requires that agency actions be within the scope of statutory
authority, and the PRA requires that information collections be necessary for the proper performance of agency
functions as authorized by statute. APHIS's expansion of the Specimen Submission respondent pool must be
justified within the bounds of the statutory surveillance authority — not as an exercise of administrative discretion
untethered from statutory necessity.
Specifically, APHIS must demonstrate: that the expanded respondent pool is necessary to prevent or detect the
specific disease threats that the Animal Health Protection Act authorizes surveillance to address; that the expanded
surveillance scope is proportionate to the identified disease risks; and that the expanded collection is the minimum
information necessary for the surveillance function — not more information than is needed because more
information is generally useful for program management.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall publish a statutory authority analysis identifying the specific Animal Health Protection Act provisions
that authorize the expanded Specimen Submission respondent pool, with specific identification of the disease
threats being addressed and the relationship between the expanded surveillance scope and those threats.
Deadline: 90 days from this comment.

Demanded Action 2
APHIS shall demonstrate that the expanded Specimen Submission collection is the minimum information necessary
for the statutory surveillance function — not the maximum information that would be useful for program
management. Any data elements that serve program management rather than statutory surveillance shall be
removed. Deadline: Prior to renewal.

Demanded Action 3

OMB shall not approve any expansion of the Specimen Submission respondent pool without a written APHIS
analysis of the statutory authority and necessity for the expansion. Deadline: Immediate OMB condition.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Governing statute for APHIS surveillance authority —
expansion must be within statutory scope and
proportionate to disease risk

7 U.S.C. Section 8302

AHPA Definitions

Disease pest definitions limit surveillance scope —
collection must be limited to AHPA-defined disease
threats

5 U.S.C. Section 706(2)(C)

APA Ultra Vires Review

Collection beyond statutory authority is void — OMB
cannot approve collection that exceeds AHPA scope

44 U.S.C. Section 3506(c)(1)

PRA Practical Utility —
Statutory Necessity

Practical utility requires necessity for agency functions
as authorized by statute — program management
data exceeds this

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Expansion without statutory necessity demonstration
is arbitrary — State Farm applies

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Statutory authority for expansion is relevant data that
must be examined — APHIS has not examined it

E.O. 12866

OIRA Cost-Benefit Review

Disease risk justifying expansion must be quantified
and weighed against burden — never done

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Minimum necessary information principle — collection
limited to AHPA statutory necessity

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-10 OF 20

TITLE

Cattle Fever Tick Program Audit: Parasite Submission Forms for Tick Surveillance Must Be
Evaluated for Necessity Independently of General Specimen Submission

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
The APHIS Specimen Submission collection includes, within OMB Control Number 0579-0090, the Parasite
Submission form used for the Cattle Fever Tick Eradication Program (CFTEP) and the National Tick Surveillance
Program. These parasite surveillance forms serve a distinct purpose from the general livestock disease surveillance
Specimen Submission form — and they impose distinct burdens on a distinct population of respondents. APHIS
has bundled these forms into a single collection without independently justifying the necessity of each parasite form
element or analyzing the specific burden imposed on the CFTEP respondent population.
The Cattle Fever Tick Eradication Program operates in a specific geographic area — primarily the Texas-Mexico
border region and quarantine areas — and imposes requirements on cattle operators in those areas to submit tick
specimens as part of a long-running eradication effort. The burden on a CFTEP quarantine zone cattle operator —
who must systematically inspect animals for ticks and submit specimens as a condition of operating within the
quarantine zone — is fundamentally different from the burden on a general livestock surveillance respondent. These
distinct programs deserve distinct burden analyses.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall separate the Parasite Submission form for CFTEP and National Tick Surveillance from the general
Specimen Submission collection and submit it to OMB as a separate information collection request with an
independent burden analysis, necessity analysis, and IRFA. Deadline: Prior to renewal of 0579-0090.

Demanded Action 2
APHIS shall conduct an independent program effectiveness review of the Cattle Fever Tick Eradication Program,
examining the relationship between the Parasite Submission information collection burden imposed on quarantine
zone cattle operators and the eradication outcomes achieved, and publish the results. Deadline: 180 days from this
comment.

Demanded Action 3

GAO shall audit the Cattle Fever Tick Eradication Program — its cost, its progress, and the burden it imposes on
affected cattle operators — as part of the broader APHIS program audit demanded in Document APHIS-11.
Deadline: GAO inquiry initiation within 60 days.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Bundled collections obscure burden analysis —
CFTEP parasite forms require separate PRA
treatment

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

CFTEP authority is distinct from general surveillance
authority — separate statutory analysis required

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Bundling distinct programs into single collection
without separate analysis is arbitrary

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

CFTEP-specific burden data is relevant data that must
be examined separately — not bundled into average

31 U.S.C. Section 717

GAO Performance Audit
Authority

CFTEP program effectiveness warrants GAO audit —
long-running program with significant respondent
burden

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

CFTEP quarantine zone cattle operators face distinct
and more intensive burden — separate IRFA required

E.O. 12866

OIRA Cost-Benefit Review

CFTEP program effectiveness versus burden never
independently analyzed — significant analytical gap

Pub. L. 101-576

Chief Financial Officers Act

CFTEP is a long-running program with substantial cost
— CFO Act financial efficiency review overdue

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-11 OF 20

TITLE

GAO Audit Request: APHIS Administrative Costs vs. Disease Prevention Outcomes —
Return on Investment of Specimen Collection Program Must Be Independently Assessed

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
This document constitutes a formal request to the U.S. Government Accountability Office pursuant to 31 U.S.C.
Section 717 to conduct a performance audit of the APHIS Veterinary Services specimen collection and disease
surveillance programs, examining the ratio of program costs — including the true private-sector burden imposed on
farmers and veterinarians — to disease prevention outcomes achieved, and assessing whether the current program
design delivers the best possible surveillance value relative to the burden it imposes.
APHIS's disease surveillance programs impose approximately 30,930 hours of annual burden on private
respondents — hours that represent real economic costs to rural farmers and veterinarians. APHIS has never
published a program effectiveness analysis demonstrating the disease outbreaks prevented, the economic losses
averted, or the public health benefits achieved per dollar of private-sector surveillance burden imposed. Without
this analysis, neither OMB nor Congress can determine whether the program's burden is proportionate to its benefit.

SECTION II — DEMANDED ACTIONS
Demanded Action 1 — GAO
The GAO shall conduct a performance audit of APHIS Veterinary Services disease surveillance programs
examining: the true total cost of the surveillance system including private-sector burden at corrected rates; the
disease events detected and prevented through the Specimen Submission collection; the cost per disease event
detected; and whether electronic submission and state-led surveillance alternatives would deliver equivalent
outcomes at lower cost. Deadline: Initiated within 60 days.

Demanded Action 2 — Congress
The Senate and House Agriculture Committees shall request the GAO audit demanded herein and shall hold an
oversight hearing on APHIS surveillance program efficiency. Deadline: Immediate request.

Demanded Action 3 — APHIS
APHIS shall cooperate fully with GAO's audit and shall provide all program effectiveness data, including disease
events detected, outbreaks prevented, and laboratory result data related to Specimen Submission collections.
Deadline: Upon GAO request.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

31 U.S.C. Section 717

GAO Performance Audit
Authority

GAO may audit federal program efficiency — APHIS
surveillance program cost-benefit ratio warrants audit

31 U.S.C. Sections 35213527

GAO Waste Fraud Abuse
Mandate

Surveillance burden without demonstrated disease
prevention return qualifies as potential waste

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

True burden of surveillance program is a cost that
GAO should quantify independently

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Program effectiveness in preventing disease
introduction is the statutory measure of success —
GAO should assess it

Pub. L. 101-576

Chief Financial Officers Act

APHIS surveillance program costs versus disease
prevention outcomes is a CFO Act financial efficiency
question

E.O. 12866

OIRA Cost-Benefit Review

Program cost-benefit analysis never performed —
GAO audit will produce data OIRA should have
required

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

GAO findings will support APA record — burden
without demonstrated benefit is relevant data

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Disease prevention outcomes per dollar of
surveillance burden is relevant data that must be
examined

APA Section 706 rights reserved. Transmitted to GAO and Agriculture Committees.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-12 OF 20

TITLE

Congressional Agriculture Committee Notice: Senate and House Agriculture Committees
Must Review APHIS Surveillance Expansion and Its Impact on Rural Small Farms

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
This document constitutes formal written notice to the Senate Committee on Agriculture Nutrition and Forestry and
the House Committee on Agriculture that APHIS's proposed revision to OMB Control Number 0579-0090 —
expanding the Specimen Submission respondent pool without adequate justification and understating the burden
on rural small farms — warrants Congressional oversight. APHIS's disease surveillance programs must be
accountable to Congress and to the rural farming communities whose cooperation they depend upon.
The rural small farms and veterinary practitioners who bear the burden of the APHIS Specimen Submission
collection are the same communities that Congress has consistently sought to protect through farm bill provisions,
rural development programs, and agricultural safety net legislation. Congressional oversight should ensure that
APHIS's administrative expansion of surveillance programs does not impose burdens on these communities that
Congress has not authorized and that are not proportionate to the disease surveillance value achieved.

SECTION II — DEMANDED ACTIONS
Demanded Action 1 — Senate Agriculture Committee
The Senate Committee on Agriculture Nutrition and Forestry shall hold an oversight hearing on APHIS disease
surveillance program expansion, examining: the justification for the increase in Specimen Submission respondents;
the true burden on rural small farms versus APHIS's disclosed estimate; and the case for a state-led surveillance
model. Deadline: Within current Congressional session.

Demanded Action 2 — House Agriculture Committee
The House Committee on Agriculture shall request GAO analysis of APHIS surveillance program cost-effectiveness
and shall review APHIS's PRA compliance practices across all USDA APHIS programs. Deadline: Immediate
request.

Demanded Action 3 — Congress
Congress shall consider farm bill language requiring APHIS to: adopt electronic submission for all Specimen
Submission programs within two years; negotiate state data sharing agreements eliminating duplicative federal

collection; and publish annual program effectiveness reports measuring disease events detected per dollar of
private-sector burden imposed. Deadline: Next farm bill cycle.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

APHIS surveillance authority is Congressional grant —
Congressional oversight is appropriate mechanism for
ensuring proportionate use

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Congressional mandate for burden minimization —
oversight required when agencies expand burden
without adequate justification

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Pattern of burden expansion without adequate
justification is APA concern — Congressional
oversight supports judicial review record

31 U.S.C. Section 717

GAO Authority

Agriculture committees should request GAO audit
recommended in Document APHIS-11

U.S. Const. Art. I

Congressional Oversight

Congress has authority and responsibility to oversee
federal agency administrative practices affecting rural
constituents

Pub. L. 101-576

Chief Financial Officers Act

APHIS administrative expansion is CFO Act concern
— Congressional oversight is appropriate mechanism

E.O. 13132

Federalism

Congressional oversight can reinforce state authority
over surveillance — state-led model needs
Congressional support

E.O. 12866

OIRA Cost-Benefit
Requirement

OIRA review of APHIS collections is overdue —
Congressional pressure can accelerate this

Transmitted to Senate and House Agriculture Committees. APA rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-13 OF 20

TITLE

CFO Act Deficiency: 30,930 Hours of Annual Burden at Rural Veterinarian Labor Rates
Represents Tens of Millions in Uncompensated Private Sector Cost — Never Weighed
Against Surveillance Value

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
The Chief Financial Officers Act of 1990, Pub. L. 101-576, requires federal agencies to improve financial
management practices and evaluate the effectiveness of federal financial programs. The APHIS Specimen
Submission collection imposes 30,930 disclosed burden hours annually on private-sector respondents — hours
that represent real economic costs to rural farms and veterinary practices. At corrected burden estimates of 1.5 to
5 hours per response across 95,060 responses, the true annual private-sector cost is estimated at 142,590 to
475,300 hours. At an agricultural and veterinary labor cost of $20 to $60 per hour, this represents $2.85 million to
$28.5 million in annual uncompensated private-sector surveillance costs. APHIS has never weighed this cost
against the disease surveillance value achieved.
A CFO Act-compliant analysis of the Specimen Submission program would require APHIS to determine: the total
annual cost of the surveillance system including federal administrative costs and private-sector burden at corrected
rates; the disease surveillance outcomes achieved — diseases detected, outbreaks prevented, economic losses
averted; the cost per disease event detected; and whether the current program design delivers the best surveillance
return on the total cost investment. None of this analysis has ever been performed.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
The USDA Chief Financial Officer shall conduct and publish a CFO Act-compliant financial efficiency analysis of
the APHIS Specimen Submission program comparing total program cost — including private-sector burden at
corrected rates — to disease surveillance outcomes measured in disease events detected and economic losses
prevented. Deadline: 120 days from this comment.

Demanded Action 2
OMB's Office of Federal Financial Management shall review APHIS disease surveillance program costs under CFO
Act financial management standards and determine whether the current program design delivers a positive return
on the total cost it imposes on the federal government and the private sector. Deadline: 180 days from this comment.

Demanded Action 3
APHIS shall adopt the electronic submission, state data sharing, and simplified form measures demanded across
this package as the CFO Act-consistent alternatives that reduce administrative costs while preserving surveillance
value. Deadline: Prior to renewal.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

Pub. L. 101-576

Chief Financial Officers Act of
1990

Requires financial efficiency evaluation — APHIS
surveillance costs of $2.85M to $28.5M annually never
evaluated against disease prevention outcomes

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Program effectiveness is the statutory measure —
CFO Act requires ensuring costs are proportionate to
statutory outcomes

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Private-sector surveillance burden is a cost — CFO
Act and PRA work together to require costeffectiveness

31 U.S.C. Section 717

GAO Authority

GAO audit demanded in APHIS-11 will produce CFO
Act data — documents are complementary

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

CFO Act non-compliance compounds APA violation —
surveillance costs never weighed against disease
prevention value

E.O. 12866

OIRA Cost-Benefit Review

$2.85M to $28.5M annual private-sector cost must be
weighed against surveillance benefit — analysis never
done

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Cost-per-disease-event-detected is relevant data that
must be examined — APHIS has not examined it

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Small rural farm burden is disproportionate share of
total cost — CFO Act and RFA concerns compound

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-14 OF 20

TITLE

Privacy and Biosecurity Concerns: Herd Owner and Animal Location Data Collected on
Specimen Forms Creates Privacy and Biosecurity Exposure — Privacy Act Compliance
Required

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
The APHIS Specimen Submission form collects data that identifies: the herd owner's name and contact information;
the geographic location of the herd; the animal identification numbers; the herd size and composition; and the
suspected disease being tested. This combination of data points creates a federal database of herd owner locations,
animal identification information, and disease testing history that has significant privacy and biosecurity implications.
APHIS has never published a Privacy Impact Assessment for this collection that adequately addresses these risks.
Herd location data is operationally sensitive — it identifies the geographic coordinates of valuable livestock assets.
Animal disease testing data is commercially sensitive — it reveals herd health status that could affect market value
and insurance. The association between herd owner identity, location, and disease testing history in a federal
database creates a data profile that rural farmers have a reasonable expectation of privacy in, and that APHIS has
never demonstrated is adequately protected against unauthorized access or disclosure.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall publish a Privacy Impact Assessment for the Specimen Submission collection that specifically
addresses: the scope of herd owner, location, and animal data collected; the federal database architecture storing
this data; access controls; retention period; data sharing with state agencies and other federal agencies; and the
biosecurity implications of aggregating herd location and disease testing data in a federal database. Deadline: 60
days from this comment.

Demanded Action 2
APHIS shall implement data minimization measures — collecting only the minimum herd owner and location data
necessary for surveillance result reporting and follow-up — and shall not collect data elements that serve program
management functions beyond the immediate surveillance necessity. Deadline: Prior to renewal.

Demanded Action 3

APHIS shall provide herd owners with Privacy Act notice at the time of specimen submission identifying the legal
authority for collection, the uses of the data, and the data retention period, consistent with 5 U.S.C. Section
552a(e)(3). Deadline: Upon renewal of collection.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

5 U.S.C. Section 552a

Privacy Act of 1974

Herd owner personal data must comply with Privacy
Act — no Privacy Impact Assessment published

5 U.S.C. Section 552a(e)(1)

Privacy Act Necessity
Requirement

Only relevant and necessary information may be
collected — herd owner data beyond surveillance
necessity fails this test

5 U.S.C. Section 552a(e)(3)

Privacy Act Notice
Requirement

Notice must be given at time of collection — herd
owners receive no adequate Privacy Act notice

44 U.S.C. Section 3506(c)(1)

PRA Practical Utility

Privacy-sensitive data elements must serve
surveillance function — program management data
fails this test

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Collecting privacy-sensitive herd location data without
Privacy Impact Assessment is arbitrary

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Surveillance authority does not authorize unlimited
collection of herd owner private data — scope limited
by statute

E.O. 13526

Information Security

Herd location and disease testing database has
biosecurity implications requiring security review

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Privacy and biosecurity risks are relevant data that
must be examined — APHIS has not examined them

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-15 OF 20

TITLE

Duplication with State Systems: State Veterinarians Already Maintain This Data — Federal
Collection Is Duplicative Under PRA Section 3508 — Data Sharing Must Replace Duplicate
Collection

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
PRA Section 3508 prohibits federal agencies from collecting information that is available from another federal
agency or public source if that information is adequate for the agency's purposes. State veterinary diagnostic
laboratories — including Georgia's GDIAL network — collect specimen submission data that is substantially
equivalent to the data on APHIS's federal Specimen Submission form for the same specimens submitted through
state laboratory systems. APHIS has never conducted the duplication analysis that PRA Section 3508 requires.
The PRA's anti-duplication principle is not merely procedural — it reflects a substantive policy judgment that the
burden of duplicate data collection is never justified when adequate data is available from existing sources. When
a Georgia livestock farmer submits a specimen through the GDIAL system, the state already has the surveillance
data that APHIS's federal form would collect. APHIS's additional federal collection of the same data — for specimens
already in the state system — imposes burden without producing new surveillance information. This is the definition
of unjustified duplication.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall conduct and publish a duplication analysis identifying all Specimen Submission data elements that are
also collected by state veterinary diagnostic laboratory systems under APHIS cooperative agreements, specifically
including Georgia GDIAL, Texas A&M TVMDL, and other state laboratory networks. Deadline: 90 days from this
comment.

Demanded Action 2
APHIS shall negotiate electronic data sharing agreements with state veterinary diagnostic laboratory networks to
obtain state-collected specimen submission data electronically, eliminating the need for separate federal form
submissions for specimens already reported to state systems. Deadline: 180 days from this comment.

Demanded Action 3

APHIS shall reduce the federal Specimen Submission respondent pool to exclude specimens already submitted
through state veterinary diagnostic laboratory systems with data sharing agreements, counting only specimens
submitted directly to NVSL without state system involvement. Deadline: Prior to renewal.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3508

PRA Duplication Prohibition

Federal collection of data already in state laboratory
systems is duplicative — APHIS must eliminate

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Anti-duplication is core PRA mandate — state data
sharing eliminates burden at zero surveillance cost

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

Cooperative state-federal surveillance framework
envisioned by statute — data sharing implements this
framework

E.O. 13132

Federalism

State veterinary data is state resource — federal
duplication of state data collection violates federalism
principles

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Collecting data already available from state systems is
arbitrary — no rational basis for duplication

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

State data sharing alternative is relevant alternative
that must be evaluated — APHIS has not evaluated it

E.O. 12866

OIRA Cost-Benefit Review

Eliminating duplicate collection through state data
sharing reduces burden at near-zero cost —
significant benefit never analyzed

Pub. L. 101-576

Chief Financial Officers Act

Paying private-sector surveillance burden for data
already available from state systems is financial
inefficiency

APA Section 706 rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-16 OF 20

TITLE

USDA OIG Referral: APHIS Pattern of Expanding Surveillance Reporting Without Genuine
PRA Compliance Warrants Inspector General Review

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
This document constitutes a formal referral to the USDA Office of Inspector General pursuant to the Inspector
General Act of 1978, 5 U.S.C. Appendix Section 2, requesting an investigation into whether APHIS's pattern of
expanding the Specimen Submission respondent pool without adequate PRA justification, understating the true
burden on rural small farms in OMB submissions, and failing to assess state data sharing and electronic submission
alternatives reflects a systemic PRA non-compliance pattern that warrants USDA OIG scrutiny.
APHIS has expanded the Specimen Submission collection without adequate explanation of the surveillance
necessity for the expansion; submitted burden estimates to OMB that materially understate the true small farm
burden; failed to assess electronic submission alternatives as required by PRA Section 3506(c)(3); failed to conduct
a duplication analysis as required by PRA Section 3508; and failed to publish a Privacy Impact Assessment for a
collection that includes personal and commercially sensitive herd owner and animal data. This pattern suggests
systemic PRA non-compliance at the APHIS Veterinary Services level.

SECTION II — DEMANDED ACTIONS
Demanded Action 1 — USDA OIG
The USDA OIG shall open an inquiry into APHIS Veterinary Services PRA compliance practices, examining whether
burden estimates are systematically understated, whether automation assessments are conducted as required, and
whether duplication analyses are performed before collections are expanded. Deadline: 90 days from this referral.

Demanded Action 2 — USDA OIG
The OIG shall transmit findings to OMB and to the Senate and House Agriculture Committees with
recommendations for corrective action. Deadline: 120 days from referral.

Demanded Action 3 — APHIS
APHIS shall cooperate fully with the OIG inquiry and shall provide all PRA submission records, burden calculation
methodologies, and automation assessment documentation for all Veterinary Services information collections.
Deadline: Upon OIG request.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

5 U.S.C. App. Section 2

Inspector General Act of 1978

USDA OIG authorized to investigate APHIS
management challenges — PRA non-compliance
pattern warrants investigation

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Systematic PRA non-compliance is the subject of
referral — OIG should assess agencywide compliance
practices

44 U.S.C. Section 3508

PRA Duplication Prohibition

Failure to conduct duplication analysis is part of
pattern — OIG should assess compliance

44 U.S.C. Section 3506(c)(3)

PRA Automation
Requirement

Failure to assess electronic submission alternatives —
OIG should assess compliance

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

OIG findings will support APA record — pattern of
administrative mismanagement is documented

31 U.S.C. Sections 35213527

Waste Fraud Abuse Mandate

Expanding surveillance burden without demonstrated
necessity qualifies as potential administrative waste

7 U.S.C. Section 8301 et seq.

Animal Health Protection Act

OIG should assess whether surveillance expansion is
within statutory authority and proportionate to disease
risk

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

OIG findings will document pattern of arbitrary
collection expansion — supports judicial review record

Transmitted to USDA OIG. APA rights reserved.

DOCKET

APHIS-2025-0704 | OMB Control No. 0579-0090

AGENCY

Animal and Plant Health Inspection Service — USDA

DOCUMENT

DOCUMENT APHIS-19 OF 20

TITLE

Technology Modernization Demand: APHIS Must Deploy Electronic Specimen Submission
Systems Accessible to Rural Farms Before Renewing Paper-Based Collections

PORTAL

regulations.gov — APHIS-2025-0704

DUE DATE

March 10, 2026

Filer

James Hunter Poole — Executive Chairman & CEO, Obelisk Tech Systems Inc.

CAGE / UEI

9S0L8 | U34MSJ6A6413 | Thomasville, Thomas County, Georgia (Rural High-Poverty Census
Tract — ~23% poverty / ~14% BA)

Contracts

Navy · Army · SOCOM · AFSOC — Cybersecurity, AI Autonomy, Quantum Comms, Critical
Infrastructure Protection

Credentials

Filed

March 10, 2026

SECTION I — THE CORE PROBLEM
APHIS cannot justify renewing a paper-based or PDF-based Specimen Submission collection without first
demonstrating that it has evaluated, and where feasible deployed, electronic submission alternatives that reduce
the burden on rural small farm submitters. The PRA Section 3506(c)(3) automation requirement is not optional —
it is a mandatory burden minimization obligation. APHIS's failure to mandate electronic submission for the Specimen
Submission collection while renewing the collection for another three years is a clear PRA violation.
The technology for electronic specimen submission systems — including mobile-accessible forms, GPS-enabled
location data, automated laboratory routing, and chain-of-custody tracking — is fully mature and commercially
available. Obelisk Tech Systems Inc., as a defense technology company specializing in AI automation and
cybersecurity software, has direct expertise in the deployment of mobile-accessible electronic data collection
systems for rural environments with limited connectivity. Electronic submission systems can be designed to function
in offline mode, synchronizing when connectivity is available — making them fully accessible to rural farms without
reliable broadband.

SECTION II — DEMANDED ACTIONS
Demanded Action 1
APHIS shall develop and deploy a mobile-accessible electronic Specimen Submission system that: functions in
offline mode for rural areas without reliable connectivity; pre-populates returning submitter data; provides automated
laboratory routing; integrates with state veterinary laboratory information management systems; and provides realtime submission tracking for submitters. Deadline: Prior to any renewal of OMB Control Number 0579-0090.

Demanded Action 2
APHIS shall conduct and publish an assessment of available electronic submission technologies for the Specimen
Submission collection, including the cost of deployment, the burden reduction potential, and the feasibility of rural
accessibility, before submitting any renewal to OMB. Deadline: 90 days from this comment.

Demanded Action 3

OMB shall condition any renewal of OMB Control Number 0579-0090 on APHIS deploying an electronic submission
system accessible to all categories of submitters — including rural farms without broadband — within 18 months of
the renewal approval. Deadline: Immediate OMB condition.

CROSS-CUTTING LAW CODE TABLE
Code / Authority

System

Role in This Comment

44 U.S.C. Section 3506(c)(3)

PRA Automation
Requirement

APHIS must deploy electronic submission — failure to
do so before renewal is PRA violation

44 U.S.C. Section 3501 et
seq.

Paperwork Reduction Act

Automation is mandatory burden minimization tool —
renewing paper-based collection without deploying
electronic alternative violates PRA

5 U.S.C. Section 706(2)(A)

Administrative Procedure Act

Renewing paper-based collection without evaluating
available electronic alternatives is arbitrary — State
Farm applies

E.O. 13960

AI in Government

Federal AI policy requires agencies to use technology
to improve government services — electronic
submission implements this policy

E.O. 12866

OIRA Cost-Benefit Review

30 to 50 percent burden reduction from electronic
submission — significant cost saving that must be
included in cost-benefit analysis

Infrastructure Investment and
Jobs Act

Rural Broadband and
Technology

Federal rural technology investment must be paired
with electronic submission systems accessible to rural
farms

Motor Vehicle Mfrs. v. State
Farm, 463 U.S. 29 (1983)

APA Judicial Precedent

Available electronic submission technology is relevant
alternative that must be evaluated — APHIS has not
evaluated it

5 U.S.C. Sections 601-612

Regulatory Flexibility Act

Electronic submission most benefits small rural farms
— RFA requires adoption of technology alternatives
that reduce small entity burden