Comment submitted by D. Royal

Document ID: EPA-HQ-OPP-2012-0631-0009
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: January 18 2013, at 12:00 AM Eastern Standard Time
Date Posted: January 22 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: November 21 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: January 22 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-836k-c01n
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I have been born and raised in the crop dusting business. 30,000 hours of actual spraying. The truth to reducing drift is that it is impossible to eliminate. Equiptment and drift reduction additives help. What is needed is a change in outlook by the Epa and the States Department of Ag. What is happening since most of the truley experienced pilots are retiring, is presuure being put on the pilots by the aircraft owners to do things they should not be doing. Farmers and chemical salesmen or not helping either. They are putting pressure on the owners to spray now. This will all be denounced but I assure you it is very true. California had this figured out long ago. The pilot, the operator, the consultant and the farmer himself are all held respnsible. With just the pilot being held responsible, they just do not give him all the info he needed to make a good desission. All the training in the world can not stop the pilot from being in trouble the more he has to tell the people signing his checks no! Times are tuff right now for everybody. Pressure of making a living is causing some very bad ideas. Farmers and their ground rigs are not out of this either. 30 mph winds cause a ground rig to drift also.

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