					August 4, 2011

Ms. Elizabeth Craig

Acting Director, Office of Atmospheric Programs

U.S. EPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Avenue, N.W. 

Mail Code: 6201J 

Washington, DC 20460

Re:	Request for Extension of Time to allow Submission of Florida’s
Applications for Critical Use Exemptions

Docket ID No. EPA-HQ–OAR–2011–0431

Dear Ms. Craig:

Florida Fruit and Vegetable Association (FFVA) is a voluntary non-profit
trade association whose mission is to enhance the competitive and
business environment for producing and marketing fruits, vegetables and
other crops.  As part of this mission, we filed for and received
Critical Use Exemptions (CUEs) for the continued use of methyl bromide
since the inception of the CUE process.  Simultaneously, we have
continuously been directly involved in the discussions and research
surrounding the use of methyl bromide and potential alternative
chemicals as preplant soil fumigants in plastic-mulched culture of
vegetables and ornamentals, and their use as preplant fumigants in
nursery production of transplants necessary for propagation of
transplants in support of those industries.  We have been involved in
this ongoing effort and research since the filing of the 1991 petition
listing methyl bromide for regulation under the U.S. Clean Air Act.

In the June 14, 2011 Federal Register, the Agency published a notice
requesting applications for CUEs for 2014, (76 Fed. Reg. 34700-03). 
FFVA and its producer members are in the process of preparing a 2014
application for submission to the 

P.O. Box 948153, Maitland, FL 32794-8153 • 800 Trafalgar Court, Suite
200, Maitland, FL  32751

321.214.5200 • fax 321.214.0210 • www.ffva.com

E. Craig

August 4, 2011

Page 2 of 2

Agency.  However, because of the press of other business, including but
not limited to preparing for and participating in the meeting of the
Open-Ended Working Group under the Montreal Protocol, additional time is
needed to adequately prepare the requested application from Florida. 
FFVA respectfully requests an extension of slightly more than 30 days to
submit the applications, to September 16, 2011.  It is believed that the
additional time will not adversely impact the Agency’s judicious
review of the applications and will assist FFVA in preparing the most
robust applications possible.  Issuing such brief extension is
consistent with the public interest.

We would request that the Agency include this request in the docket.

Sincerely,

Daniel A. Botts

Vice President; Industry Relations

cc:	Drusilla Hufford

	Jeremy Arling

