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
19,
2005
Ms.
Debra
Edwards
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
Ms.
Edwards:

The
U.
S.
Apple
Association
(
USApple)
is
the
national
trade
association
representing
all
segments
of
the
apple
industry.
Members
include
36
state
apple
associations
representing
7,500
apple
growers
throughout
the
country,
as
well
as
over
300
individual
firms
involved
in
the
apple
business.
We
are
contacting
you
to
request
additional
time
to
evaluate
the
azinphos
methyl
risk
assessment
and
to
develop
information
related
to
the
need
for
azinphos
methyl
in
the
apple
industry.

USApple
is
asking
the
U.
S.
Environmental
Protection
Agency
(
EPA)
to
extend
the
deadline
for
comments
on
the
azinphos
methyl
ecological
risk
assessment
and
benefits
assessment
to
March
31.
Azinphos
methyl
is
one
of
the
most
important
and
widely
used
crop
protection
tools
in
the
apple
industry.
The
issues
regarding
the
use
of
azinphos
methyl
are
complex
and
will
require
significant
consultation
with
our
state
and
regional
partners.
That
process
is
time
consuming.

USApple
has
participated
in
various
segments
of
the
azinphos
methyl
review
process
and
provided
significant
information
regarding
the
use
of
azinphos
methyl,
which
has
been
helpful
in
the
evaluation
of
this
product.
We
would
like
to
continue
our
participation
in
the
review
process.
However,
we
are
concerned
that
the
sixty
day
comment
period
established
by
the
agency
will
not
provide
sufficient
time
for
the
apple
industry
to
develop
important
information
that
could
impact
agency
decisions
regarding
the
use
of
azinphos
methyl
on
apples.
Additionally,
the
holiday
season
will
also
serve
to
shorten
the
available
time
for
comment.

We
appreciate
your
willingness
to
consider
this
request,
especially
considering
the
importance
of
azinphos
methyl
to
our
nation's
apple
growers.

Please
contact
me
by
telephone
at
(
703)
442­
8850
or
via
e­
mail
at
jcranney@
usapple.
org
if
you
have
questions
or
need
additional
information.

Sincerely
yours,

James
R.
Cranney,
Jr.
Vice
President
