August __, 2008

Debra Edwards, Ph.D., Director 

	Office of Pesticide Programs 

Steven Bradbury, Ph.D., Director

	Special Review and Registration Division

USEPA Headquarters

1200 Pennsylvania Avenue, NW

Mail Code 7508P

Washington, DC 20460

	Re:	Chloropicrin RED  – Request for Extension of Time to Submit
Comments

Dear Dr. Edwards and Dr. Bradbury:

I am writing on behalf of grower’s of  The California Strawberry
Nurserymen’s Association  to request a 45-day extension of the comment
period on the Reregistration Eligibility Decisions (REDs) for
Chloropicrin, Dazomet, Metam Sodium and Methyl Bromide (73 Fed. Reg.
40871).  Chloropicrin and other soil fumigants are not only important,
but necessary for the successful cultivation of Nursery Strawberry
Plants ( which provides the California Strawberry Industry with plants
to replant the 30,000 acres of commercial fruit producing acreage
annually). Therefore, participation in the public comment process is
imperative for all growers.  However, since the current comment period
has occurred during one of the busiest time of year for growers, we do
not have sufficient time to review and analyze the multiple REDs and the
extensive technical support documents.   Many support documents,
including EPA’s response to previous grower comments were made
available by EPA for the first time on July 16. 

In particular, as proposed, the risk mitigation plans in the REDs will
greatly impact growers by adding considerable costs for each fumigation.
 In order to fully consider the feasibility of these mitigation plans,
as well as adequate alternatives, growers must consult with registrants
and other stakeholders.  Moreover, growers use multiple soil fumigants
and must consider the overall affects of the REDs.   Growers simply do
not have sufficient opportunity to do so in the given comment period.  

Growers realize that other affected groups have also requested
extensions and we join in their requests to extend the comment period by
additional 45-days.  Please call me at 530 527 6621 if you have any
questions regarding this request

Sincerely,

Bob Tipton

Strawberry Nursery Manager

Driscoll Strawberry Associates

22000 Bend Ferry Road

Red Bluff , Calif.

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