Comment submitted by Andrew D. Moore, National Agricultural Aviation Association

RE: Request for Extension of Comment Period EPA-HQ-OPP-2009-0628 – “Draft Guidance for Pesticide Registrants on Pesticide Drift Labeling” EPA-HQ-OPP-2009-0825 – “Petition to Protect Children from Pesticide Drift” To Whom It May Concern: The National Agricultural Aviation Association (NAAA) appreciates the opportunity to comment on the Environmental Protection Agency’s “Draft Guidance for Pesticide Registrants on Pesticide Drift Labeling,” as well as the “Petition to Protect Children from Pesticide Drift.” NAAA is writing to request an extension of the comment period on these documents by 90 days, from Jan. 4, 2010 until April 2010. NAAA represents more than 1,500 members in 46 states. NAAA supports the interests of small business owners and pilots licensed as commercial applicators that use aircraft to enhance food, fiber and bio-fuel production, protect forestry and control health-threatening pests. Furthermore, through its affiliation with the National Agricultural Aviation Research & Education Foundation (NAAREF), the NAAA contributes to research and educational programs focused on enhancing the efficacy, security and safety of aerial application. NAAA believes an extension of the comment period on both of these documents will serve to benefit both the Agency and other stakeholders and is important for several reasons. Firstly, several agricultural organizations—including NAAA—with legitimate interest in the proposed drift language and the petition will be holding their annual meetings and board meetings over the next several months both during and after the current comment period. These meetings will serve as important forums for stakeholders to meet and discuss the implications of these proposals. It is important that these groups are allowed ample time to discuss this issue with their