0104 2021 Ss (20210921)

September 2021

Supporting Statement

Gypsy Moth Identification Worksheet

0579-0104

TERMS OF CLEARANCE: “Before this ICR is renewed, the agency should review the respondent and burden estimates to ensure they reflect the most reasonable and robust data available.” There is not a direct reporting requirement for the PPQ 377. However, there is correlation between those who should complete the checklist and those who move out of the quarantine areas.  APHIS collaborated with the United Stated Postal Service to estimate the number of “change of address” forms submitted annually by individuals within the quarantine areas and used this estimate for the number of individual respondents preparing PPQ 377.

1. JUSTIFICATION

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

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

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

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

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

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

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

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

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

In addition to this risk, Asian GM larvae feed on a much wider variety of hosts, allowing them to exploit more areas and cause more damage than the European GM. In order to determine the presence and extent of a European GM or an Asian GM infestation, APHIS sets traps in high-risk areas to collect specimens. Once an infestation is identified, control and eradication work (usually involving State cooperation) is initiated to eliminate the moths.

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

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

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

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

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

Specimens for Determination (PPQ Form 391); (7 CFR 301.45-2); (State)

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

The specimens are accompanied by the PPQ 391, Specimens for Determination, worksheet. The worksheet enables both Federal and State regulatory officials to identify and track specific specimens through the DNA identification tests conducted by APHIS laboratories.

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

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

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

Gypsy Moth Checklist and Record of Your Self-Inspection (PPQ Form 377 or PPQ Form 377A); (7 CFR 301.45‑4(a)); (Individual)

(This activity and the Self-home Inspection activity were merged.)

Any individual moving from a GM quarantine area to a non-quarantine area between the months of April and August must inspect his/her outdoor household items for the GM using the PPQ Form 377 checklist (or its replacement in development, PPQ Form 377A) and remove all life stages before moving.

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

Recordkeeping for Gypsy Moth Checklist and Record of Your Self-Inspection (previously Recordkeeping of Self-Inspection); (7 CFR 301.45-4(a)); (Individual)

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

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

A moving company may choose to notify the person moving of the regulation requiring the PPQ 377 when they are moving from an infected area of GM to a non-infested area. The moving company may provide the inspection and associated recordkeeping as a service to the homeowner.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting

this means of collection. Also, describe any consideration of using information technology to reduce burden.

PPQ Form 391, Specimens for Determination, must physically accompany the plant pest or pathogen being sent for identification. This form may be completed and downloaded from the APHIS website http://www.aphis.usda.gov/library/forms/pdf/PPQ_Form 391.pdf.

PPQ Form 377, Gypsy Moth Checklist Record of Your Self-Inspection, may be downloaded from APHIS Forms Library web site https://www.aphis.usda.gov/library/forms/pdf/ppq377.pdf or completed online at https://www.aphis.usda.gov/aphis/ourfocus/planthealth/plant-pest-and-disease-programs/pests-and-diseases/gypsy-moth/gm-checklist. The form may be electronically signed, and in digital format, is acceptable for presentation to State and Federal officials under all circumstances. APHIS is developing a less cumbersome version of the form (PPQ 377A) to streamline the user experience for certification and anticipates fielding it in the next twelve months.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose described in item 2 above.

The information APHIS collects is exclusive to its mission of protecting the United States from incursion by exotic agricultural pests and is not available from any other source.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

APHIS estimates that 98 percent of the total respondents are small entities. The information APHIS collects is the minimum needed to restrict the interstate movement of regulated articles from quarantined areas to prevent the artificial spread of the GM to non-infested areas of the United States.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

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

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

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

• requiring respondents to report informa­tion to the agency more often than quarterly;

• requiring respondents to prepare a writ­ten response to a collection of infor­ma­tion in fewer than 30 days after receipt of it;

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

The Insect Collection Worksheet is completed only when traps are found to contain specimens.

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

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain re­cords, other than health, medical, governm­ent contract, grant-in-aid, or tax records for more than three years;

• in connection with a statisti­cal sur­vey, that is not de­signed to produce valid and reli­able results that can be general­ized to the uni­verse of study;

• requiring the use of a statis­tical data classi­fication that has not been revie­wed and approved by OMB;

• that includes a pledge of confiden­tiali­ty that is not supported by au­thority estab­lished in statute or regu­la­tion, that is not sup­ported by dis­closure and data security policies that are consistent with the pledge, or which unneces­sarily impedes shar­ing of data with other agencies for com­patible confiden­tial use; or

• requiring respondents to submit propri­etary trade secret, or other confidential information unless the agency can demon­strate that it has instituted procedures to protect the information's confidentiality to the extent permit­ted by law.

No other special circumstances exist that would require this collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

8. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting form, and on the data elements to be recorded, disclosed, or reported. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, soliciting comments on the information collection prior to submission to OMB.

Productive consultations concerning our information collection activities were made with the following individuals by telephone to discuss the information collection activities associated with the Gypsy Moth Identification Worksheet and Checklist. We discussed the nature of the insect pests APHIS is monitoring and the survey activities which must be conducted at this intensity level if APHIS’ monitoring program is to be successful. They had no recommendations for improving this information collection.

Joseph Zoltowkski

Division of Plant Industry
New Jersey Dept. of Agriculture
PO Box 330
Trenton, NJ 08625-033

Phone: 609-406-6939
joseph.zoltowski@ag.nj.gov

Tim Brown

Plant Industries Division
West Virginia Dept. of Agriculture
1900 Kanawha Blvd. East
Charleston, WV 25305-0191

Phone: 304-558-2212

tlbrown@wvda.us

Dan Kenny, Division Chief

Division of Plant Health
Ohio Dept. of Agriculture
8995 East Main St.
Reynoldsburg, OH 43068

Phone: 614-728-6400

Daniel.Kenney@agri.ohio.gov

On Friday, February 12, 2021, APHIS published in the Federal Register (86 FR 9319), a 60‑day notice seeking public comments on its plans to request a 3-year approval of this collection of information. No comments were received from the public. However, there was a comment received during the 30-day comment period from a concern citizen, but her comment has no impact to the purpose of the collection or to slow the spread of the gypsy moth.

9. Explain any decision to provide any payment or gift to respondents, other than re‑enumeration of contractors or grantees.

This information collection activity involves no payments (other than appropriate, program-related payments) or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

No additional assurance of confidentiality is provided with this information collection. Any and all information obtained in this collection shall not be disclosed except in accordance with

5 U.S.C. 552a.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and others that are considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

This information collection activity asks no questions of a personal or sensitive nature.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-1.

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

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

APHIS estimates the total annualized cost to the respondents to be $156,689,549. APHIS arrived at this figure by multiplying the hours of estimated response time (2,711,543) by the estimated average hourly wage of the above respondents ($39.88) and then multiplying the result by 1.449 to capture benefit costs.

The average hourly salary wage has been corrected in this renewal. The average hourly rates used to calculate the estimate are $53.47 for state and local government employees; $39.10 for transportation inspectors (SOCC 53-6051); and $27.07 for individuals (SOCC 00-0000). The rates were found at the U.S. Bureau of Labor Statistics websites; https://www.bls.gov/news.release/ecec.htm and https://www.bls.gov/oes/current/
oes_stru.htm.

According to DOL BLS news release USDL-21-0437 released March 18, 2021, employee benefits account for 31 percent of employee costs, and wages account for the remaining 69 percent. Mathematically, total costs can be calculated as a function of wages using a multiplier of 1.449.

13. Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

There is zero annual cost burden associated with capital and start-up costs, maintenance costs, and purchase of services in connection with this program.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

See APHIS Form 79. The estimated cost for the Federal Government is $123,292.

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

	Requested	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate	Change Due to Potential Violation of the PRA	Previously Approved
Annual Number of Responses	7,500,250	0	0	0	0	7,500,250
Annual Time Burden (Hr)	2,711,543	0	0	0	0	2,711,543

There are no changes in estimates or burden for this request for renewal. Two activities, Gypsy Moth Checklist and Record of Your Self-Inspection (PPQ Form 377), and Self-home Inspection, have been combined into one activity.

APHIS is designing an online interface to simplify the mandatory briefing and inspection affirmation. The PPQ 377A is in development to replace the PPQ 377.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

APHIS has no plans to tabulate or publish the information it collects. However, results of DNA identification analysis are widely distributed using electronic mail via the PPQ and Asian GM bulletin boards.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

APHIS requests not to display the OMB approval expiration date on the forms. The PPQ 391 is used in two information collection requests with different approval expiration dates, and the PPQ 377 is available in different media such as PDF or an online reporting system. Moving companies might not download and use the most current versions of the forms and an expiration date would sow confusion on the form’s validity in the field.

18. Explain each exception to the certification statement identified in the "Certification for Paperwork Reduction Act."

APHIS is able to certify compliance with all the provisions under the Act.

B. Collections of Information Employing Statistical Methods.

Statistical methods are not used in this information collection.