Flutriafol; Receipt of Application for Emergency Exemption, Solicitation of Public Comment

ARA, 1156 15th NW, Suite 302, Washington, DC 20005 October 5, 2005 Carmen Rodia Registration Division (7505C) Office of Pesticide Programs Environmental Protection Agency 1200 Pennsylvania Ave, NW Washington, DC 20460-0327 Dear Ms. Rodia, RE: EPA Public Docket for Comment Period OPP2005-0241, OPP2005-0242, OPP2005-0243 flutriafol It has come to the attention of the Agricultural Retailers Association (ARA) that the Section 18 emergency exemption for a new fungicide tool in the fight against Asian Soybean Rust has been requested by a number of states. ARA fully supports these submissions and hopes that EPA grants the Section 18 for technical reasons and for support of American agricultural in general. First, Asian Rust is a new threat to America?s farmers, as it attacks soybeans, dry beans and other crops. As a new threat, very little is really known about the disease?s life cycle and how it will respond to our environment and cultural practices. At a time like this retailers and growers need all the tools possible to deal with this new unknown threat. The fungicide arsenal may appear full especially after the very limited infestation year we just experienced, but that season was hardly an indicator of things to come. Most experts agree that American farmers were just lucky during the 2005 season and that we all need to be ready to fight rust with all available technologies in 2006. On behalf of ARA, I testified before congress this year explaining the role that Ag retailers play in pest management. ARA has been an active supporter of the EPA?s Section 18 process to allow technologies to be used by growers to protect their livelihoods, as well as America?s food supply. I believe that the EPA has the same goal in protecting our food supply and that the agency has acted very responsibly in the total registration process this past season. Now is the time to continue building our arsenal of products by registering flutriafol,