Comment Submitted by John Robert Peters, J.R. Peters, Inc.

My name is Jack Peters and I am the president of J.R. Peters, Inc. We are a small manufacturing business located in PA. Our business is blending fertilizers for the commercial horticulture market serving customers in the US, Canada and foreign countries. Our end user customers are large and small commercial greenhouse growers, hobbyists and homeowners who use our water soluble fertilizer products to grow and maintain their plants. The proposed definition of ammonium nitrate would have serious impact upon our customers as well as the greenhouse and nursery industry in the US as well as products blended for export to Canada and other foreign countries. We do not sell ammonium nitrate directly to anyone. The problem arises because the definition would include blends that contain more than 30% ammonium nitrate. More than half of the water soluble fertilizer products that are used to grow the major horticultural crops in the US and Canada as well as numerous foreign countries utilize fertilizer product blends that contain over 40 % ammonium nitrate. Our company sells these fertilizer blends through horticultural distributors who then sell these products directly to growers in almost every state. There are at least 10 regional producers like us and many small blenders. There are 50 - 100 distributors who sell to 10-20,000 greenhouse growers. Tracking the sales of these blended products would be a difficult task which escalates as you move from the producers to the distributors and finally to the growers. The record keeping and tracking of all the customers and their customers and volumes would place a significant burden on the industry These expenses would have to be passed along to the customers eventually raising the prices of all the flowers, vegetables being produced. I would ask that you take this situation into consideration as you finalize your program. I can be reached at my office 866 522 5752 x 15 or my email to discuss this further. Thank you.