1,3-Dichloropropene Risk Assessment; Notice of Availability

August 25, 2008 Dr. Steven Bradbury, Ph.D. Director, Special Review and Reregistration Division Office of Pesticide Programs OPP Regulatory Public Docket (7502P) Environmental Protection Agency Room S-4400 One Potomac Yard (South Building) 2777 South Crystal Drive Arlington, VA 22202 Re: Request for Extension of Time: Chloropicrin, Dazomet, Metam Potassium, Metam Sodium and Methyl Bromide (EPA-HQ-OPP-2007-0350; EPA-HQ-OPP- 2005-0128; EPA-HQ-OPP-2005-0125; AND EPA-HQ-OPP-2005-0123, respectively) Reregistration Eligibility Decisions ("REDs") Dr. Bradbury: On behalf of the potato growers throughout the United States, the National Potato Council (NPC) joins the Minor Crop Farmer Alliance (MCFA) in requesting an additional 60 days to provide comments on the RED for the fumigant cluster listed above. The continued effective use of these products is essential to maintaining the ability to produce potatoes in key production areas within the United States. In order to provide the EPA with the likely real world impacts of the proposed mitigation measures for the listed fumigants, growers will need additional time to evaluate this very complicated proposal that will have significant impacts on current use patterns. While the complexity of the proposed regulations is sufficient reason to allow an additional 60 days for analysis and comment; the time of the year is also of real importance. Potato farmers are beginning the harvest season both for potatoes and other rotational crops. The demands of harvest activities do not allow adequate time to evaluate the proposed mitigation measures. Developing application standards for the fumigants that provide both adequate public health protection and product use patterns that are workable at the farm level is very important to the NPC. Allowing additional time for public review and comment will provide a better opportunity to achieve a solution that balances these issues. Sincerely, John Keeling Vice President and CEO