September 15, 2006

Ms. Debbie Edwards

Director, Reregistration Division

Environmental Protection Agency

Ariel Rios Building

1200 Pennsylvania Avenue, NW

Washington, D.C. 20460

Re: Docket ID Number EPA-HQ-OPP-2004-0202

Dear Ms. Edwards:

On behalf of the potato growers represented by the National Potato
Council (NPC) I want to request that the Agency extend the comment
period on the Reregistration Eligibility Document for
Pentachloronitrobenzene (PCNB).  As you know PCNB is an important
product used by potato growers to control soil fungi impacting potatoes.
 The product is used on more than 135,000 acres national which is
roughly ten percent of total potato acres. 

The NPC is working with growers in the areas where PCNB is used to
obtain further information on the use patterns and efficacy of PCNB and
its information on the applicability of the Agency’s assumptions and
findings on use patterns and the efficacy and costs of alternative
products.  NPC respectfully requests that the Agency extend the comment
period until December 2, 2006 to allow the opportunity to gather this
information.

Sincerely,

John Keeling

Executive Vice President and CEO

Ms. Debbie Edwards

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