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EPARulemakingEPA-HQ-OW-2003-0063

Final Rule on Application of Pesticides to Waters of the United States in Compliance with FIFRA

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Agricultural Retailers Association filings
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Agricultural Retailers Association filed 1 comment on this docket between Apr 1, 2005 and Apr 1, 2005. 131 other organizations filed here. The comment window closed 7785d ago.

What Agricultural Retailers Association filed (1)

Apr 1, 2005· Comment submitted by James D. Thrift, Vice President, Regulatory Policy and Corporate Relations, Agricultural Retailers Association (ARA)· EPA-HQ-OW-2003-0063-0627

jthrift@aradc.org 04/01/2005 03:17 PMTo Group Ow-Docket@EPA cc bcc Subject Stop Unnecessary EPA Permitting Water Docket EPA, Mailcode 4101T 1200 Pennsylvania Avenue, NW Washington, DC 20460 Dear Water Docket, EPA Docket ID No. OW-2003-0063 Comment from Feb. 1 - April 4, 2005 EPA's new proposed water rule states that EPA-registered pesticides do not require National Pollution Discharge Elimination System Clean Water Act permits for pest control applications into, over, on or near water if you follow the label; unfortunately, EPA stops short of ensuring that EPA CWA permits are not required for all registered and legal applications. EPA needs to issue the final rule covering these applications that are currently left out of the proposal. Agricultural Retailers Association Water Docket Environmental Protection Agency Mail code 4101 T 1200 Pennsylvania Ave., N. W. Washington, DC 20460 Attn: Docket ID No. OW-2003-0063 March 30, 2005 On behalf of the 6,000 dealer members of the Agricultural Retailers Association (ARA), we respectively request EPA to not allow NPDES permits to be required for all FIFRA approved pesticide applications. ARA respectfully submits the following comments regarding EPA?s February 1st proposed Clean Water Act ? Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) rule which attempts to clarify EPA?s longstanding position that the use of agricultural and other pesticides in accordance with approved label directions is not subject to NPDES permitting requirements. ARA supports the general approach that EPA registered pesticides do not require National Pollution Discharge Elimination System (NPDES) Clean Water Act permits for pest control applications into, over, on or near water if you follow the label. However, before the rule is made final, we strongly urge EPA to expand the proposed rule to cover all applications including agricultural applications that are applied in accordance with the FIFRA label. The rule must clearly state that if you apply a pesticide in accordance with the FIFRA approved label ? that you do not need an NPDES permit ? whether that application is near water or not. Without such clear protections in the proposed rule, activist group law suits will continue to use the cover of the Clean Water Act to ban the use of FIFRA approved pesticides that have already been rigorously tested and approved. Pesticides are already safely and effectively regulated by EPA under FIFRA and are among the most stringently regulated substances in the United States. Pesticides are important to everyday life. They are vital public health tools used to protect people from mosquitoes, help produce a safe, affordable and abundant domestic food supply, manage invasive plant species for species habitat conservation, and prevent forest fires. Adding a new EPA water permit for pesticide applications will needlessly delay this important work and add a significant unnecessary additional costs and burdens on an already regulated industry. Thank you for allowing ARA to submit comments on this key issue. If you have any further questions feel free to contact me. Sincerely, James D. Thrift VP, Regulatory Policy & Corporate Relations Agricultural Retailers Association 1156 15 Th ST NW Suite 302 Washington, DC 20005 Office 202-457-0825 FAX 202-457-0864 Sincerely, Jim Thrift 1156 15 th st NW Suite 302 Washington, District of Columbia 20005

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