August 19, 2009 Office of Pesticide Programs (OPP) Regulator Public Docket (7502P) Environmental Protection Agency 1200 Pennsylvania Ave., NW., Washington, DC 20460-001 Subject: Re-registration of fomesafen (Docket # EPA-HQ-OPP-2006-0239) Current proposed US Environmental Protection Agency (EPA) Re-Registration regulations for fomesafen will restrict vegetable production in Georgia. These regulations would eliminate the most effective tool to manage Palmer amaranth and morningglory in 67% of Georgia’s snap bean acreage (farm gate value of $22.6 million). These regulations will also eliminate the benefits of fomesafen currently being developed for fruiting vegetables and cucurbits (farm gate value exceeding $387 million), including its role as

Summary Current proposed US Environmental Protection Agency (EPA) Re-Registration regulations for fomesafen will cripple cotton and vegetable production in Georgia. These regulations in Georgia cotton alone would potentially reduce farm gate values in excess of $156 million. Additionally, these regulations would eliminate the most effective tool to manage Palmer amaranth and morningglory in 67% of Georgia’s snap bean acreage (farm gate value of $22.6 million). These regulations will also eliminate the benefits of fomesafen currently being developed for fruiting vegetables and cucurbits (farm gate value exceeding $387 million), including its role as a key herbicide in the development of methyl

October 30, 2008 Subject:  EPA’s Fumigant Cluster CommentsEPA-HQ-OPP-2005-0123 - Methyl Bromide Docket EPA-HQ-OPP-2005-0124 - 1,3-Dichloropropene Docket EPA-HQ-OPP-2005-0125 - Metam Sodium/Potassium Docket EPA-HQ-OPP-2005-0128 - Dazomet Docket EPA-HQ-OPP-2007-0350 - Chloropicrin Docket Thank you for the opportunity to submit comments and the associated attachment filed in response to the Reregistration Eligibility Decisions(REDs) released by the Environmental Protection Agency (EPA) on July 10, 2008.  The REDS include a series of risk mitigation measures intended to protect handlers, re-entry workers, and by-standers from risks due to exposure to soil fumigants including methyl bromide and chloropicrin.  While the purpose of the REDs are to reduce exposure,

SUMMARY Current proposed US Environmental Protection Agency (EPA) Re-registration Eligibility Decisions for fumigants, including chloropicrin, metam potassium, metam sodium and methyl bromide, will cripple vegetable production in Georgia. The adoption of these regulations in Georgia vegetable plasticulture production, at a minimum, would 1) reduce farmer income by $20.94 million or 15.3% of their total income; 2) reduce sales value or output impact by $73.13 million; 3) reduce labor income by $35.1 million; and 4) would eliminate at least 775 workers. In bareground vegetable production, these proposed regulations would completely eliminate fumigant use. Similar reductions in farmer income, labor income, loss