Comment from CA Farm Bureau Federation and Western Growers, Cynthia Cory and Erin Field, on FR Doc # E8-08812

May 23, 2008 Mr. Raymond Chavira, Air Planning Office U.S. Environmental Protection Agency, Region IX 75 Hawthorne Street San Francisco, California 94105 Re: Docket No. EPA-R09-OAR-2008-0313 Dear Mr. Chavira: Western Growers and California Farm Bureau Federation support the proposed rulemaking that allows EPA to approve a revision of the California State Implementation Plan submitted by the California Air Resources Board on November 30, 2007 regarding reduction of emissions of volatile organic compounds in Ventura County. Western Growers is an agricultural trade association whose members from Arizona and California grow, pack and ship ninety percent of the fresh fruit, nuts and vegetables grown in California and seventy five percent of those commodities in Arizona. This totals about half of the nation’s fresh produce. California Farm Bureau Federation is California’s largest farm organization, comprised of 53 county Farm Bureaus currently representing approximately 91,000 members. Farm Bureau strives to protect and improve the ability of farmers and ranchers engaged in production agriculture to provide a reliable supply of food and fiber through responsible stewardship of California’s resources. We are appreciative of the California Department of Pesticide Regulation’s (DPR) efforts to authorize phased-in compliance for the Ventura Non-Attainment Area. The phase-in approach in the revised regulations and Appendix H is critical, as it will help mitigate adverse economic and environmental impacts in the Ventura region. The SIP revision would substitute emission reductions from other sources of reactive organic gases (ROG) for a portion of the emission reductions committed to in the 1994 SIP for pesticides. There would be no “backsliding” from the overall 1994 SIP commitments for Ventura County, because all of the ROG emission reductions committed to in the 1994 SIP would still be achieved. Without this proposed EPA rule-making economic harm to Ventura County’s agricultural community could likely occur this year. We do not believe further reductions can be achieved through further implementation of Best Available Control Technology, therefore, the only feasible and viable means of assistance to the Ventura County farming industry is the adoption and finalization of this proposed rule-making by the U.S. EPA in the most expeditious manner possible. Western Growers Association and California Farm Bureau Federation appreciate the opportunity to comment on the proposed rule making and respectfully request an expeditious implementation of the proposed action. Sincerely, Erin Field CA Government Affairs Manager Western Growers 1415 L Street, Suite 1060 Sacramento, CA 95814 Cynthia Cory Director, Environmental Affairs California Farm Bureau Federation 1127 11th Street, Suite 626 Sacramento, CA 95814