All comments pertinent to the Paperwork Reduction Act discussion found on
pages 56860-65864 should be sent to Lisa Grove at OMB and Don Hulcher at
USDA by January 16 -- 30 days after publication of the proposal!!!!
Lisa Grove explained to me that they must amend this section within 60 days
of the proposal (unless the proposed rule changes dramatically) so in order
to have an impact, OMB really needs to hear from us on this section by Jan
16. The Paperwork Reduction Act section discusses fees for certifiers,
exemptions from certification, the burden on certifers to comply with the
paperwork requirements of the program, information collection requirements
such as the National List, and OMB's projections as to how many farmers and
certifiers will participate in the program. Specifically, this section
poses four questions to the public" (1) is proposed information collection
necesary; (2) are USDA's estimates and assumptions accurate; (3) are there
ways to enhance information collection; and (4) what role should electronic
info collection play?
The comment deadline for the remainder of the rule remains March 16. You
can still comment on the above issues throughout the comment period, but it
may be advisable to adhere to this deadline on for maximum impact.
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