Comment submitted by Ray S. McAllister, Croplife America

Document ID: EPA-HQ-OPPT-2006-0794-0048
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: January 02 2007, at 03:52 PM Eastern Standard Time
Date Posted: January 8 2007, at 12:00 AM Eastern Standard Time
Comment Start Date: December 20 2006, at 12:00 AM Eastern Standard Time
Comment Due Date: January 4 2007, at 11:59 PM Eastern Standard Time
Tracking Number: 801f1ac7
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CropLife America requests that the comment period be extended for at least 90 days to provide adequate time for individuals and organizations to consider the extensive materials on which comment is requested, and their appropriate responses. The request for comments was published on December 20, 2006, and allows a mere 15 days (through January 4, 2007) for public comment. This is wholly inadequate, especially considering that it covers the Christmas-New Years holiday period when many people take extended time off from work. Furthermore, the period includes an extra work day when federal government offices are closed (January 2, day of mourning for President Ford). I understand that the Stockholm Secretariat has set an early February deadline for receipt of comments on this matter. Furthermore, U.S. influence in the matter is limited by its status as "observer" to the Stockholm Convention. However, the U.S. Government must comply with its own laws regarding public input on regulatory matters, in particular the Administrative Procedures Act. We do not believe that an abbreviated comment period of 15 days on such a weighty matter with voluminous background documentation meets the spirit or letter of the law. EPA must make this clear to its colleagues in the Stockholm Secretariat and prevail upon them to allow adequate time for public comment. Ray McAllister, Ph.D. CropLife America 1156 15th St NW, Suite 400 Washington DC 20005 202-872-3874 rmcallister@croplifeamerica.org

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