September
7,
2005
Via
E­
Mail
and
Facsimile
edwards.
debbie@
epa.
gov
Fax:
703­
308­
8005
Debra
F.
Edwards,
Ph.
D.
Director
Special
Review
and
Reregistration
Division
Office
of
Pesticide
Programs
United
States
Environmental
Protection
Agency
Ariel
Rios
Building,
MC:
7508C
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Re:
Soil
Fumigants
­­
Revised
Risk
Assessments
Dear
Dr.
Edwards:

On
behalf
of
the
North
Carolina
fruit
and
vegetable
production
community
who
rely
on
soil
fumigants
and
thus
have
a
strong
interest
in
the
soil
fumigant
cluster
risk
assessment
process,
we
write
to
request
an
extension
of
at
least
30
days
to
comment
on
the
revised
soil
risk
assessments
that
the
U.
S.
Environmental
Protection
Agency
(
EPA)
made
available
on
July
13,
2005.
Comments
on
four
of
the
fumigants
currently
are
due
on
September
12,
2005.
We
ask
that
this
deadline
be
extended
at
least
to
October
12,
2005.
The
risk
assessments
are
hundreds
of
pages
of
highly
technical
material.
The
existing
comment
period
does
not
provide
an
adequate
opportunity
to
comment
on
these
complex
and
interrelated
documents,
which
involve
extensive
technical
issues
and
documentation.
As
EPA
has
assured
growers
and
other
stakeholders
that
our
input
is
important,
we
hope
EPA
will
allow
an
adequate
opportunity
to
provide
that
input
on
this
large
and
complex
dataset.
EPA
has
yet
to
release
the
assessment
for
one
of
the
most
critical
fumigants,
chloropicrin.
As
EPA
knows,
chloropicrin
is
frequently
used
in
combination
with
other
soil
fumigants.
Grower
groups
cannot
comment
adequately
in
the
absence
of
all
information,
including
the
chloropicrin
assessment.
Review
of
docket
materials
to
date
indicates
that
EPA
does
not
adequately
understand
current
use
patterns
for
the
other
soil
fumigants.
To
assist
EPA
in
preparing
these
assessments,
we
would
like
to
provide
input
that
would
give
EPA
an
accurate
understanding
of
these
use
patterns,
as
well
as
other
issues
critical
to
North
Carolina
producers,
but
do
not
have
an
adequate
opportunity
to
do
so
under
the
current
deadline.
Page
2
September
7,
2005
Dr.
Debra
Edwards
The
North
Carolina
production
community
is
committed
to
working
with
EPA
to
meet
its
obligations
with
regard
to
each
of
the
soil
fumigants,
and
believe
an
extension
will
help
EPA
meet
this
goal.
It
would
also
serve
the
public
interest
by
lessening
the
confusion
that
would
be
presented
by
EPA's
circulation
of
a
revised
draft
that
remains
without
critical
data
that
are
relevant
to
decisions
stated
in
the
document
and
thus
that
could
greatly
affect
the
conclusions
in
the
document
and
the
continued
availability
of
these
important
soil
fumigants
to
meet
our
nation's
food
demands.

We
appreciate
your
attention.

Sincerely,

Larry
B.
Wooten
President
North
Carolina
Farm
Bureau
Federation
