The Navajo Nation Environmental Protection Agency Pesticide Program has an existing Federal Certification & Training Program, which has been in existance since 2007. The proposed rule will not greatly affect the Navajo Nation because:
1) currently, a majority of the applicators have Arizona licenses and they expire within one year, thus, applicators already renew their C&T cards every year;
2) there is a small number of applicators that actually need the certification;
3) other than the expiration dates, the C&T Program will not be affected.
The proposed rule is going to eliminate confusion about the different expiration dates and there will be less paperwork.
The NNEPA Pesticide Program has been a leader among other Tribes across the region when it comes to C&T as Navajo is the only Tribe with a Federal C&T Program. Based on experience, the regulated community will need to be educated not only on the proposed rule but also about C&T in general. Neighboring Tribes and Tribes across the Region has asked Navajo for their assistance and we have assisted in the past, however, future requests for assistance have to be done outside the workplan.
Thank you.
Comment submitted by G. Lee
This is comment on Proposed Rule
Synchronization of Expiration Dates: Pesticide Applicator Certificates With Underlying State or Tribal Applicator Certificates
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Public Submission Posted: 08/24/2011 ID: EPA-HQ-OPP-2011-0049-0002
Aug 23,2011 11:59 PM ET