August 26, 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 forest tree seedlings 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 forest seedlings. 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 919-731-7988 if you have any
questions regarding this request. 

Sincerely,

James West

North Carolina Forest Service

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