Comment submitted by Robert M. Rosenberg, National Pest Management Association

I am writing on behalf of the National Pest Management Association. NPMA is a national trade association that represents approximately 7,000 firms engaged in the business of providing a wide range of structural pest management services. We are writing to acknowledge and support EPA's proposal to develop a voluntary stewardship program designed to recognize companies that provide IPM services to residential and commercial accounts. EPA's proposal is a thoughtful initiative that will provide incentives to pest management companies to provide IPM services and the ability to effectively communicate the availability of those services to prospective customers.