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EPANonrulemakingEPA-HQ-OPP-2009-0628

Pesticides; Draft Guidance for Pesticide Registrants on Pesticide Drift Labeling

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closed 5989d ago
National Agricultural Aviation Association filings
4

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National Agricultural Aviation Association filed 4 comments on this docket between Nov 13, 2009 and Apr 21, 2011. 126 other organizations filed here. The comment window closed 5989d ago.

What National Agricultural Aviation Association filed (4)

Apr 21, 2011· Comment submitted by Andrew D. Moore, National Agricultural Aviation Association· EPA-HQ-OPP-2009-0628-0647

Filed on regulations.gov — full text not in the inline record.

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Mar 5, 2010· Comment submitted by Andrew Moore, National Agricultural Aviation Association· EPA-HQ-OPP-2009-0628-0364

Comments attached from the National Agricultural Aviation Association on Draft PR Notice 2009-X.

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Mar 2, 2010· Comment submitted by Andrew Moore, National Agricultural Aviation Association· EPA-HQ-OPP-2009-0628-0191

I believe that the proposed wording for EPA's new drift mitigation language is unacceptable in its current form. It is far more restrictive than the currently accepted language put forth under FIFRA which has been universally accepted for a good many years. If this proposed language is adopted I firmly believe it will virtually eliminate the possibility of using commercial pesticide applications, which are an essential tool to agricultural production, due to the extremely high possibility of being found in violation of the label under virtually all application situations. This new verbage should not be adopted due to the fact that we already have an acceptable and proven system in place under FIFRA. We as an industry also use many other methods to minimize the possibiliy of drift such as buffer strips, dressing edges when wind conditions are favorable, GPS guidance, spray additives, continual improvements and checks of dispersal equipment. Thank you in advance for your consideration of this most important matter. Mike Bartholomew

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Nov 13, 2009· Comment submitted by Andrew D. Moore, National Agricultural Aviation Association· EPA-HQ-OPP-2009-0628-0008

November 12, 2009 Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P) Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460 RE: Request for Extension of Comment Period EPA-HQ-OPP-2009-0628 – "Draft Guidance for Pesticide Registrants on Pesticide Drift Labeling" EPA-HQ-OPP-2009-0825 – "Petition to Protect Children from Pesticide Drift" To Whom It May Concern: The National Agricultural Aviation Association (NAAA) appreciates the opportunity to comment on the Environmental Protection Agency's "Draft Guidance for Pesticide Registrants on Pesticide Drift Labeling," as well as the "Petition to Protect Children from Pesticide Drift." NAAA is writing to request an extension of the comment period on these documents by 90 days, from Jan. 4, 2010 until April 2010. NAAA represents more than 1,500 members in 46 states. NAAA supports the interests of small business owners and pilots licensed as commercial applicators that use aircraft to enhance food, fiber and bio-fuel production, protect forestry and control health-threatening pests. Furthermore, through its affiliation with the National Agricultural Aviation Research & Education Foundation (NAAREF), the NAAA contributes to research and educational programs focused on enhancing the efficacy, security and safety of aerial application. NAAA believes an extension of the comment period on both of these documents will serve to benefit both the Agency and other stakeholders and is important for several reasons. Firstly, several agricultural organizations—including NAAA—with legitimate interest in the proposed drift language and the petition will be holding their annual meetings and board meetings over the next several months both during and after the current comment period. These meetings will serve as important forums for stakeholders to meet and discuss the implications of these proposals. It is important that these groups are allowed ample time to discuss this issue with their

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Abstract

For further information contact: Cathryn O'Connell (703)-308-0136 Mail code: 7508P

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Co-filers (126)

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