Comment submitted by Jonathon D. Anderson, Washington Department of Fish and Wildlife

The Washington Department of Fish and Wildlife (WDFW) has reviewed the RED for antimycin A. This agency has conducted a safe and effective program of fish management activities using rotenone since 1940, and has considerable experience with the safe and effective use of rotenone products to enhance fish and wildlife populations and habitats. The WDFW has recently (May, 2005) completed a Washington State Environmental Policy Act review of the use of antimycin A, so that it might be used as a viable alternative, in appropriate circumstances, to piscicidal treatments that have historically used rotenone. In June, 2007, WDFW contracted with Compliance Serivces, Inc. to complete a risk assessment for piscicidal formulations of antimycin A in Washington. We have attached this risk asssessment as part of our comments. The WDFW appreciates the opportunity to provide comments on the Antimycin RED, and appreciates the efforts of the US EPA to provide safe and effective rules to protect applicators, the public, and fish and wildlife resources while allowing the safe and effective use of piscicides. We appreciate the opportunity to provide comments, suggestions, and alternatives to the proposed labeling language for antimycin-A products. Our response addresses general concerns, as well as specific comments on proposed risk mitigation measures and proposed labeling language. Sincerely, Jon. Anderson Fish Program, Fish Management Division Resident Native Species Fisheries Manager