4500 S. Laspina * Suite 214 * Tulare, CA  93274

October 24, 2008 

Ms. Debbie Edwards, Director

Office of Pesticide Program 

United States Environmental Protection Agency (EPA)

One Potomac Yard

Arlington, VA

Dear Ms. Edwards:

We are writing to acknowledge the professionalism and hospitality of
your staff at the October 14, 2008 meeting between your office and the
California Specialty Crops Council.  Last week nine members of the
California Specialty Crops Council participated in dialogue with a
variety of staff including Ms. Lois Rossi, Mr. Rick Keigwin, and Ms
Margaret Rice.  One of the issues discussed was EPA’s Fumigant
Reregistration Eligibility Decision (RED) - Risk Mitigation Measures to
Address Inhalation Exposures from Soil Fumigant Applications (Docket ID:
EPA-HQ-OPP-2007-0350).  Based upon that discussion we request that you
extend the comment period for 30 days and conduct a workshop in
California.

During our discussion about the Fumigant RED we learned that EPA has
offered to conduct workshops to help inform the regulated community
about the new requirements of the RED.  We were advised that workshops
have been conducted in the Northwest and in Florida, but that no such
workshops have been conducted in California.  EPA’s proposed
mitigation measures will affect thousands of farmers in California and
millions of acres.  These changes will have a significant impact on
fumigation practices in California.  We would be pleased to organize a
workshop immediately and invite your staff to present the proposed
Fumigant RED.  We request that the comment period be extended to allow
time for such a workshop to be conducted.

During our discussion we also learned for the first time that EPA is
considering case studies as part of the public comment process.  Ms.
Margaret Rice explained that EPA is learning that the proposed Fumigant
RED will affect different commodities and regions in ways that were not
expected and that EPA is considering case studies to better understand
these impacts.  The request for case studies was not included in the
public notice for comment.  We would like the opportunity to submit a
case study to describe how the proposed Fumigant RED will impact
California.  We request that the comment period be extended to allow
more time for us to prepare and submit such case studies.

During our discussions we were also told that EPA will be considering
input beyond the October 30, 2008 deadline for public comments.  Given
this statement, we would appreciate EPA extending the public comment
period so that our comments can be formally included into the record.  

Thank you for considering our request.  If you or your staff has any
questions, please do not hesitate to contact us at (559)688-5700.

Sincerely,

Jim Culbertson

Jim Culbertson,

Chairman of the Board

