703
442­
8850
800
781­
4443
fax
703
790­
0845
Web
site
www.
usapple.
org
8233
Old
Courthouse
Road,
Suite
200

Vienna,
VA
22182­
3816
USA
December
20,
2005
Ms.
Margaret
Rice
Office
of
Pesticide
Programs
Registration
Division
(
7508C)
1200
Pennsylvania
Ave.,
N.
W.
Washington,
D.
C.
20460
Re:
EPA­
HQ­
OPP­
2005­
0061;
Azinphos
methyl
Ecological
Risk
Assessment,
Grower
Impact
Assessments;
Notice
of
Availability
Dear
Margaret:

The
U.
S.
Apple
Association
(
USApple)
is
disappointed
that
the
U.
S.
Environmental
Protection
Agency
(
EPA)
has
denied
our
request
for
more
time
to
evaluate
and
comment
on
the
azinphos
methyl
ecological
risk
assessment
and
apple
benefits
assessment
in
response
to
the
agency's
Dec.
7,
2005
Federal
Register
notice.

As
we
discussed,
this
is
a
complex
national
issue
that
requires
considerable
communication
and
coordination
with
our
regional
partners
and
growers
across
the
country.
We
had
hoped
the
agency
would
recognize
the
difficulty
the
short
response
time
imposes
on
the
apple
industry,
especially
since
the
holiday
season
would
shorten
the
comment
period.

While
you
indicated
in
our
telephone
conversation
that
the
agency
would
not
extend
the
comment
period,
you
also
indicated
that
EPA
has
the
ability
to
accept
and
consider
information
submitted
to
the
agency
after
comment
period
has
closed.
USApple
will
make
every
effort
to
meet
the
Feb.
6
deadline
for
submission
of
regulatory
comments.
However,
we
wanted
to
inform
you
that
we
may
not
be
able
to
provide
all
of
the
information
by
that
deadline.
As
such,
based
on
my
conversation
with
you,
it
is
our
understanding
that
EPA
will
accept
and
consider
information
USApple
submits
on
this
matter
after
the
proposed
deadline.

Please
contact
me
by
telephone
at
(
800)
781­
4443
or
via
e­
mail
at
jcranney@
usapple.
org
as
soon
as
possible
if
the
agency
will
not
accept
and
consider
information
we
provide
after
the
Feb.
6
deadline.

Sincerely
yours,

James
R.
Cranney,
Jr.
Vice
President
