Overview
Title
Agency Information Collection Activities; Renewal Request Submitted to OMB for Review and Approval; Comment Request; Pesticide Program Public Sector Collections (FIFRA Sections 18 & 24(c)) (Renewal)
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ELI5 AI
The EPA wants to keep collecting information about how some pesticides are used in emergencies or special cases. They are asking people to comment on this plan for another month before the February deadline.
Summary AI
The Environmental Protection Agency (EPA) is seeking public comments on a proposed extension for collecting information related to pesticide use, as required by specific sections of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). This process involves collecting information from various entities like states and federal agencies about emergency exemptions for unregistered pesticide use and special local needs for additional pesticide uses. The current approval for this information collection expires on February 28, 2021, and the EPA is offering an additional 30-day period for public feedback. The estimated annual burden for respondents, which include state and federal government agencies and agricultural chemical manufacturers, is 25,753 hours, costing a total of $1,829,103.
Abstract
The Environmental Protection Agency (EPA) has submitted the following information collection request (ICR), Pesticide Program Public Sector Collections (FIFRA Sections 18 & 24(c)) (EPA ICR Number 2311.04 and OMB Control Number 2070-0182), to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. This is a proposed extension of ICR, which is currently approved through February 28, 2021. Public comments were previously requested via the Federal Register on August 17, 2020 during a 60-day comment period. This notice allows for an additional 30 days for public comments. A fuller description of the ICR is given below, including its estimated burden and cost to the public. An agency may not conduct or sponsor and a person is not required to respond to a collection of information unless it displays a currently valid OMB control number.
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AnalysisAI
General Summary
The document from the Environmental Protection Agency (EPA) proposes the continuation of data collection concerning the use of pesticides as mandated by specific sections of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The request is aimed at gathering information from states and federal agencies about emergency exemptions for unregistered pesticide use and special local needs for additional uses of pesticides. This information collection, which is necessary for protecting public health and the environment, is currently approved until the end of February 2021. The EPA has opened an additional 30-day comment period for public feedback on this extension.
Significant Issues or Concerns
Several significant issues arise from the document:
Cost Transparency: The document notes an annual cost of over $1.8 million for respondents, but it fails to provide a detailed breakdown of how these costs are derived. This lack of transparency might concern stakeholders who want to understand how funds are allocated.
Technical Jargon: The frequent use of technical terms and references to specific FIFRA sections without clear explanations could alienate those not familiar with regulatory or agricultural terminology.
Ambiguous Language: Phrases like "an agency may not conduct or sponsor and a person is not required to respond" are not as clear as they could be. More explicit language about the conditions and consequences of non-compliance might improve understanding.
Unexplained Form Numbers: The document cites specific form numbers without explaining their purpose or the kind of information they collect. This oversight might create confusion, particularly for individuals new to these regulatory processes.
Lack of Explanation on Burden: While the document states there is no change in the estimated burden from previous approvals, it does not explain how this conclusion was reached or its implications, leaving a knowledge gap about the basis for these estimations.
Public Impact
The public broadly may see the continued collection of this data as beneficial because it aims to address public health and environmental concerns associated with pesticide use. However, complexities in understanding the document could hinder public engagement, underscoring the need for clearer communication from the EPA.
Impact on Specific Stakeholders
For states, federal agencies, and agricultural chemical manufacturers, this process remains mandatory under FIFRA, potentially requiring significant resources and time—an estimated 25,753 hours annually—for compliance. Stakeholders might view this as a continuation of established practices, yet might also express worry about costs and administrative burdens, especially without a detailed cost allocation. Conversely, by providing emergency exemptions and accommodating special local needs, the information collection could allow these entities to respond more effectively to local and urgent pest management challenges.
In conclusion, the document outlines a necessary procedure for environmental and public health protection but raises concerns about transparency and accessibility of information that the EPA would need to address for effective stakeholder and public engagement.
Financial Assessment
The document outlines an update to the information collection request (ICR) by the Environmental Protection Agency (EPA), specifically under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The financial reference in the document highlights the estimated total cost associated with the ICR.
Financial Summary
The document states that the estimated total costs for the activities related to the ICR are $1,829,103 per year. This amount, however, does not include any annualized capital investment or maintenance and operational costs. This suggests that the financial estimate is limited to specific activities or operations, potentially relating to the processing of applications, training, or administration functions necessary for handling pesticide registration requests and emergency exemptions under FIFRA.
Relation to Identified Issues
Several issues are apparent in connection with the financial allocation in the document. Firstly, there is no breakdown provided detailing how the $1,829,103 is allocated across various activities. This lack of transparency can lead to questions regarding the efficiency and effectiveness of the spending, as stakeholders may be interested in understanding which specific areas are consuming the most resources.
Moreover, without a detailed explanation or breakdown, it becomes difficult to assess whether the financial estimate effectively supports the intended objectives of the ICR, such as ensuring the safe and efficient regulation of pesticide use in emergency scenarios. Additionally, the document does not address whether there have been any significant changes in cost calculations or why the estimated burden in terms of respondent hours remains unchanged from the previous ICR, despite the financial estimate remaining the same.
Lastly, the document references technical terms and specific form numbers like 8570-25 & 8570-4 without detailing what they entail or their relationship to the financial estimate. A clearer explanation of these elements could help contextualize the estimated costs, demonstrating how these forms and processes contribute to the overall spending.
Overall, the document's financial estimate highlights a critical component of the EPA's plan to manage pesticide regulation through the public sector, but further clarification and transparency would better inform the public and allow for more informed commentary and engagement.
Issues
• The document mentions the estimated total costs as $1,829,103 per year but does not provide a breakdown of how these costs are calculated, which could lead to concerns regarding transparency in spending.
• The document uses technical terms and references specific sections of FIFRA without providing a layman's explanation, which could make it difficult for the general public to understand the context and implications.
• The phrase 'an agency may not conduct or sponsor and a person is not required to respond' could be clearer by including the conditions or consequences more explicitly for non-compliance.
• The document references specific form numbers (8570-25 & 8570-4) but does not explain their purpose or what information they collect, which might lead to ambiguity for someone unfamiliar with these forms.
• The document states there is no change in the number of hours in the total estimated respondent burden compared to the previous ICR but does not explain how this conclusion was reached or its implications.
• While it lists states, federal government agencies, and manufacturers as affected entities, the document does not provide an explanation or criteria for how these entities are involved or impacted by the ICR.