Attachment D - Renewal Consultations

Attachment D
Renewal Consultations -- List of Representatives and Questions Posed

List of Representatives Consulted
Dr. Russell P. Schneider
Monsanto Company
russell.p.schneider@monsanto.com
202-383-2866
Dr. Wendelyn Jones
Greg Watson
Syngenta Biotechnology, Inc
wendelyn.jones@syngenta.com
greg.watson@syngenta.com
James Barron
Bayer Crop Science
jim.barron@bayercropscience.com
Amy Roberts
Technology Science Group, Inc.
aroberts@tsgusa.com
Frederick Smith
SciReg, Inc
fsmith@scireg.com
Dr. Thomas Bade
Valent Biosciences
thomas.bade@valentbiosciences.com 

Sample Consultation Questions OPP ICR Renewals
EPA Questions asked in Consultation
(1)

(2)

Publicly Available Data
$

Is the data that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?

$

If yes, where can you find the data? (Does your answer indicate a true
duplication, or does the input indicate that certain data elements are available, but
that they don=t meet our data needs very well?)

Frequency of Collection
$

(3)

(4)

Can the Agency collect the information less frequently and still produce the same
outcome?

Clarity of Instructions
$

The ICR is intended to require that respondents provide certain data so that the
Agency can utilize them.

$

Based on the instructions (regulations, PR Notices, etc.), is it clear what you are
required to do and how to submit such data? If not, what suggestions do you have
to clarify the instructions?

$

Do you understand that you are required to maintain records?

$

Considering that there is no required submission format, is it difficult to submit
information in ways that are clear, logical and easy to complete?

$

Are there forms associated with this process? Do you use them? Are they clear,
logical, and easy to complete?

Electronic Reporting and Record keeping
The Government Paperwork Elimination Act requires agencies make available to the
public electronic reporting alternatives to paper-based submissions by 2003, unless there
is a strong reason for not doing so. One such reason is that, at the present time, the
Agency is unable to ensure the security of CBI that might be transmitted over the
Internet.
$

$

What do you think about electronic alternatives to paper-based records and data
submissions? Current electronic reporting alternatives include the use of web
forms@/XML based submissions via the Agency’s Internet site and magnetic
media-based submissions, e.g., diskette, CD-ROM, etc. Would you be interested
in pursuing electronic reporting?
Are you keeping your records electronically? If yes, in what format?
1

Although the Agency does not offer an electronic reporting option because of CBI-related
security concerns at this time,
$
$

(5)

would you be more inclined to submit CBI on diskette (CD or DVD) than on
paper?
what benefits would electronic submission bring you in terms of burden reduction
or greater efficiency in compiling the information?

Burden and Costs
$
$
$

$

Are the labor rates accurate?
The Agency assumes there is no capital cost associated with this activity. Is that
correct?
Bearing in mind that the burden and cost estimates include only burden hours and
costs associated with the paperwork involved with this ICR, e.g., the ICR does not
include estimated burden hours and costs for conducting studies, are the estimated
burden hours and labor rates accurate? If you provide burden and cost estimates
that are substantially different from EPA’s, please provide an explanation of how
you arrived at your estimates.
Are there other costs that should be accounted for that may have been missed?

2