National Agricultural Aviation Association
EPANonrulemakingEPA-HQ-OW-2010-0257

National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges from the Application of Pesticides

RIN
Last modified
May 22, 2023
Comment window
closed 5482d ago
National Agricultural Aviation Association filings
4

Activity

National Agricultural Aviation Association filed 4 comments on this docket between Jun 28, 2010 and Jul 25, 2011. 145 other organizations filed here. The comment window closed 5482d ago.

What National Agricultural Aviation Association filed (4)

Jul 25, 2011· Comment submitted by Andrew D. Moore, Executive Director, National Agricultural Aviation Association (NAAA)· EPA-HQ-OW-2010-0257-1191

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

Jul 20, 2010· Comment submitted by Andrew D. Moore, Executive Director, National Agricultural Aviation Association (NAAA)· EPA-HQ-OW-2010-0257-0453

Comments attached.

Jul 20, 2010· Comment submitted by Andrew D. Moore, Executive Director, National Agricultural Aviation Association (NAAA)· EPA-HQ-OW-2010-0257-0450

Comments attached.

Jun 28, 2010· Comment submitted by Cole Law, National Agricultural Aviation Association· EPA-HQ-OW-2010-0257-0180

To whom it may concern: My name is Cole Law, and i own an areial application business. I am new in the business and am learning all the time. I am very proud to be able to help supply the world with food and fiber. I have great concern about the possibility of more regualations. I have a small business outside Texarkana, AR. I also do some work in Texas. The only reason we have any farming here at all is because of the Red River, and like many rivers it is surrounded by many lakes and steams. I rarley do a job for a farmer that i am not in sight of the river. I contrac for around 20 farmers on a number of different crops including, rice, beans, corn, milo,wheat, pine trees, and even irrigation ditches. I have a very small business and only employ two other than myself. The nature of the business is differnt than most. I dont know from day to day what i will be expected to apply. Alot of the fields are found by air, which means i have never set foot on them. I dont have the advanced warning nor the expertise to conduct the environmental assesment or monitoring needed to comply with this reg. I would also not be able to afford to hire on or even train my employee to do so. I am also opposed to the EPA linking many thousands of decision-makers and for hire aieral applicators together in a legal "co-permitting" web of joint performance, recordkeeping and reporting requirments that would expose me to legal suits and regulatory actions. I go through hours of training and programs every year to ensure that all of my applications are in a safe and professinal manner. I take all the nessary precautions to avoid miss applications. I already have to comply with many state and federal regs as we speak and i cannot see how my business or anyone elses can sustain a regulation that would be put in place. Thank you for your time, and please take my concerns into consideration the next time you eat, buy cotton clothing or go home to your wood framed house.

Abstract

No abstract recorded.

View on regulations.gov →
National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges from the Application of Pesticides (EPA) — National Agricultural Aviation Association | OpenPolis