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
Comment submitted by Ray S. McAllister, Croplife America
This is comment on Notice
Review of Chemical Proposals for Addition under the Stockholm Convention on Persistent Organic Pollutants; Solicitation of Information for the Development of Risk Management Evaluations and Risk Profiles
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