Richard Keigwin/DC/USEPA/US
12/10/2007 09:00 PM	To
	"Mr. John Thompson" <thompsonje2@state.gov>, Christine 
Augustyniak/DC/USEPA/US@EPA, Aaron Levy/DC/USEPA/US@EPA
	cc
	Ross Brennan/DC/USEPA/US@EPA, Jeremy Arling/DC/USEPA/US@EPA, "Hodayah H 
Finman" <finmanhh@state.gov>, Elisa Rim/DC/USEPA/US@EPA, Nikhil 
Mallampalli/DC/USEPA/US@EPA
	bcc
	
	Subject
	Re: slightly revised iodomethane uptake
	
	


John--

Thanks for your comments.  A couple of thoughts:

--In the third paragraph, I think we should be careful about using the 
word "collect".  Perhaps we should use the term "seek" or "solicit".  
"Collect" could trigger ICR requirements unless the idea is that the 
Agency would use its CAA section 114 authority.

--In section 3, I appreciate your concerns about the uptake rate.  That 
being said, I think we need to take special care that we not prescribe how 
we might do a future analysis and what data we will use.  The methodology 
used for this rule was developed bearing in mind the limited information 
available and the time constraints.  With the fullness of additional time 
and data, we might want to use a different approach.  I would hope we 
could find a way to provide the Agency with some flexibility in our future 
approach.

--Rick


Rick Keigwin
Director, Biological and Economic Analysis Division
Office of Pesticide Programs
US Environmental Protection Agency
(703) 308-8200
\Sent by EPA Wireless E-Mail Services.


----- Original Message -----
From: "Thompson, John E \(OES\)" [ThompsonJE2@state.gov]
Sent: 12/10/2007 02:31 PM EST
To: Christine Augustyniak; Aaron Levy
Cc: Ross Brennan; Jeremy Arling; "Finman, Hodayah H \(OES\)" 
<FinmanHH@state.gov>; Elisa Rim; Nikhil Mallampalli; Richard Keigwin
Subject: RE: slightly revised iodomethane uptake



Christine, appreciate the revised draft based on your additional cross
check.  While it seems to me some overlap remains in applying these
factors, I'm ok with moving forward on this basis, and would suggest we
should choose something in the middle of the range to give us a
reasonably defensible case that we are not being overly optimistic on
MI, but at the same time we are being reasonable in not assuming a
minimum market penetration.

I have added some text to make it clear that this process was done in
relatively short order to account for recent registrations, so it
doesn't serve as a precedent for future analysis that we are tied to as
we collect additional information.  I took a shot at some text, but
given my relative lack of knowledge of preferred language from a
domestic regulatory perspective, I'm very open-minded on how we word
things.  My thanks to you for all your work.

John T.



-----Original Message-----
From: Augustyniak.Christine@epamail.epa.gov
[mailto:Augustyniak.Christine@epamail.epa.gov] 
Sent: Friday, December 07, 2007 10:18 PM
To: Levy.Aaron@epamail.epa.gov
Cc: Brennan.Ross@epamail.epa.gov; Arling.Jeremy@epamail.epa.gov;
Thompson, John E (OES); Finman, Hodayah H (OES);
Rim.Elisa@epamail.epa.gov; Mallampalli.Nikhil@epamail.epa.gov;
Keigwin.Richard@epamail.epa.gov
Subject: slightly revised iodomethane uptake


after some discussions with DoS I have revised the anticipated uptake
slightly (it seemed a reasonable cross check that the EUP use level fall
within the technical range of the estimate).

I am attaching the revised draft.  Before this draft is included in the
rulemaking docket some boilerplate should be added and the document may
need clarification.

All of the changes/new material are in the last 2 paragraphs.  let me
know what you think.

(See attached file: Uptake of iodomethane--allocation rule revised 7 DEC
2007.doc)


Christine Augustyniak, PhD
Methyl Bromide CUE Technical Team
Office of Pesticide Programs
US Environmental Protection Agency (7503P)
1200 Pennsylvania Ave., NW
Washington, DC  20460-0001

Deliveries:
Potomac Yard One
Room 9782
2777 Crystal Drive
Arlington, VA  22205
augustyniak.christine@epa.gov
703 308 8094
