Comment submitted by John Cornely, The Trumpeter Swan Society

Re: Petition to Revoke Import Tolerances of 13 Pesticides We strongly support the petition from American Bird Conservancy to ban the importation of crops containing any residues of the following 13 pesticides: cadusafos, cyproconazole, diazinon, dithianon, diquat, dimethoate, fenamiphos, mevinphos, methomyl, naled, phorate, terbufos, and dichlorvos. These pesticides are highly toxic to birds, and are used on crops throughout Latin America where many species of U.S. migratory birds spend the winter months. In addition to the environmental risks to birds, several of these chemicals also pose a risk to agricultural workers. The EPA has an obligation to protect migratory birds, whether they are in the US or wintering in Latin America. We believe that EPA, in granting import tolerances for these pesticides, is sanctioning the use of these pesticides throughout Latin America, and thus assisting in the harm to migratory birds. EPA has already conducted risk assessments for these pesticides, and has identified the environmental hazards and risk to birds resulting from their use. Many Latin American countries currently using these pesticides export food to the United States. Agricultural areas – in particular shade coffee farms – provide valuable habitat for migratory birds, and so pesticide use in these areas can pose a significant threat to bird populations. The EPA must protect U.S. migratory birds on their wintering grounds by preventing these pesticides from being imported on food products. Doing so will encourage the use of safer pesticides and organic farming practices by foreign growers, at least for those crops that are imported into the U.S. In conclusion, we request that EPA revoke the import tolerances for cadusafos, cyproconazole, diazinon, dithianon, diquat, dimethoate, fenamiphos, mevinphos, methomyl, naled, phorate, terbufos, and dichlorvos. These pesticides are toxic to birds and present an unacceptable