DPR 23-003 Statewide Notification of Agricultural Use of Restricted Materials (Modified Regulations)

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enfo...↓rcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

1. Notification should be limited to pesticide products that are already subject to Notices of Intent

2. Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice

3. Public notifications should only include what information is absolutely necessary: product applied, intended dat and time of application, and general geographical location (base, meridian, township, range, and section)

4. Personally identifying information, such as acreage treated or exact location, should not be included--this is critical to grower, applicator and employee safety

5. Because of the high probability that advanced notice will trigger appeals of NO ls and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

HALEY FLYING SERVICE INC.

Gary Del Carlo

President

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Beatriz Bautista Cortes,

soy residente de la ciudad de Oxnard,

Y soy es esposo de un trabajado de campo , y

tambien soy un lider comunitario con e...↓l Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

Yo quiero que avisan cuanda expro paque mi esposo por que lenemos nino y lo precumos por ello no se acercan ello cunda ilega de trabajar

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Beatriz Bautista

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Blanca Estela Ruiz P ,

soy residente de la ciudad de Oxnard,

Y soy es trabajadora agricola, piscados de mora, y

tambien soy un lider comunitario c...↓on el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

yo quiero la exactitud de la aplicacion para saber cuando se usaran quimicos en mi area exacta

tengo una nina con problemas de asma y necesito saber lugar exacto para tener mas cuidado con su salud y poder protegerla de problemas con su salud, los quimicos pueden influir con problemas graves para su asma.

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Blanca E Ruiz P

Trabajadora campecina

piscador de mora

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Faraon Lopez Gonsalez,

soy residente de la ciudad de oxnard por la colejio,

Y soy es pizcador de la fresa y pasa la pistizida y me hace dani, y

ta...↓mbien soy un lider comunitario con el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

La peztisido me hace dano y hafecta mucho en la piel y cuando lo aplican aunque es lejos me irrita los ojo y me tia provocado dolor de cabeza. Mis campaneros dicen que el olor del liquido de pesticida afecta, le hace dano proque se marean y el olor es muy fuerte y feo. Cuando hueles el aire con pesticidas nos provora ganas de vomitar.

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Faraon Lopez Gonsalez

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Miguel Angel Mota Hernandez,

soy residente de la ciudad de oxnard California,

Y soy es travajador agricola, y

tambien soy un lider comunitario con...↓ el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

Miguel Angel Mota. yo me contamine con el pesticida. Era esprayador de la mora y me contamine, se me murio minina porque. Mi Sangre estava, contaminada muchos. veses no savernos que tipo - de pesticida. estan esprayardo lo que vemos. que los elicopteros siguen fumigando. Cuertas de aguacate y limon. on oviendo travajardores en una aria serca-sintener una notificacion

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Miguel A Mato Hernandez

Travajador agricola

condado Ventura

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Pancho Inez,

soy residente de la ciudad de Oxnard CA, resido en el area del Rio,

Y soy es trabajador agricola de la mora y el blueberry, y

tambien...↓ soy un lider comunitario con el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

Hace una semana se tiro un liquido de pesticidas que no tenia una etiquea (label) no decia que era pesticidas. Se derramo en el campo y alguien lo junto y sin saber que el liquido era un pesticida, se quemo las manos mi colega. Pedimos que porgan una nota y on label para saber. Necesitamos que nos den ubicacion exacta porque cuando tienen spray days las particulilas del pesticida nos provoda irritacion en la piel y en los ojos y me provoca picazon en la piel.

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Pancho Inez

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Margarita Gonzalez,

soy residente de la ciudad de Oxnard,

Y soy es campesina en el fil de la fresa, y

tambien soy un lider comunitario con el Comi...↓te de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

A mi me afects cuando me embaraze 2023, el pesticida paso por donde yo donde yo trabajo por el fil de donde yo estaba trabajando y alli no pusieron una senal de que van a poner ese liquido y el dano que causa ela pesticida. yo, senti que la afects mucho a mi bebe. Porque mi nino hacio con labio abierto y yo no quiero que mis otra companeros del campo y recino les pase lo momo que yo. Debende avijar donde espryan y por cuant tiempo ran a espiyar. El pesticida es un liuido spray que es muy fuelle y muy renenoso y toxico.

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Margarita Gonzalez

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Zenaida Mercenario,

soy residente de la ciudad de Oxnard por colejio de Oxnard,

Y soy es campesina de la mora y fresa, y

tambien soy un lider comu...↓nitario con el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

Yo ando en la mora y toda la basura de la pesticida me cai en los ojos. Aveces hace mucho viento cuando espreyan pesticida y me llorran los ojos. Una vez vi y le dijo a zurquero que espreya han pesticida y me afects en los ojos pero solo me dio gutitas para los ojos para que no me doliera pero dure una semana con dolor y rojo en los ojos como si fuera sangre.

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Zenaida Mercenario Espinoza

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Amando Ramirea ,

soy residente de la ciudad de ciudad de oxnar,

Y soy es mienbro de proyecto voluntario, y

tambien soy un lider comunitario con el...↓ Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

yo pienso ay pestizidas retardados todo tipo de pezticidas es danino yo vivi por a anos dendro de un de fresa esprayaban minimo 2 veces por semana y aveces no avisaban a ellos no les inportaba lo ninos ni persona que vivian dentro de casa y una temporada explayaron con elicoptero y tampoco nos avisaron usted se hima gina como estaremos yenos de pezticida

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Amando Ramirez

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Juan Manuel Juarez Juarez,

soy residente de la ciudad de Oxnard, CA por el area de Lemonwood,

Y soy es trabajador de la mora, y

tambien soy un lid...↓er comunitario con el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

Me preocupa porque yo como campesino exprayan liquidos muy fuertes, y cuando anda uno pizcando el liquido irrita la piel y arde mucho.

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Juan Juarez

Juan Juarez,

Trabajador del campo

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Joyita Jimene Juarez,

soy residente de la ciudad de Oxnard con dado de ventura,

Y soy es una persona membro de proyecto Mixteco, y

tambien soy un ...↓lider comunitario con el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

nosolo canceres infantiles es general yo pienso que es para todos de diferentes condados

yo estuve viviendo en un rancho en oxnard por 9 anos y exprayaban con elicoptero 4 nonca avisaban que hivan a explayar y regaba hasta el hogar el pesticida

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Jovita Jimenes Juarez

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Ismael Espinoza,

soy residente de la ciudad de Oxnard Ca,

Y soy es trabajador del campo piscando moras, y

tambien soy un lider comunitario con el ...↓Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

Ponen el peligro nuestra salud porque cuando estamos trabajando esprayan las plantas muy serca de nosotros e tenido sintomas de dolor de cabesa aveces dificuldad para respirar y irritacion de la piel

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Ismael Espinoza

llevo 19 anos trabajando

aqui en los campos de oxnard ca

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Marisol Torres,

soy residente de la ciudad de Oxnard,

Y soy es trabajadora agricola soy piscadora de moras, y

tambien soy un lider comunitario con...↓ el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

tengo a mi esposo que tambien es trabajador agricola y la mayoria de mis familiares son - trabajadores agricolas de la pisca de fresa y miesposo a enido problemas pasa respirar por tanto polvo a respira y tiene frecuente la duele mucho la cabeza tambien e mirado a is familiares con la piel lleno de ronchas rojas y les da mucha comezon

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

les agradesco que consideren esta

carta para mejoras la salud de todos

Marisol Torres

Estimada Directora Julie Henderson del Departamento de Regulacion de Pesticidas de California,

Mi nombre es Ana Mendoza Ramirez,

soy residente de la ciudad de la ciudad de oxnard,

Y soy es esposa y madre de un trabajador agricola, y

tambien soy un lider ...↓comunitario con el Comite de Salud del Proyecto Mixteco/lndigena que aboga por la salud y bienestar de nuestra comunidad lndigena, y hoy comento las inquietudes que tengo sobre el plan de notificacion de pesticidas y que quiero que aborde antes de implementar la notificacion a nivel estatal. Es importante que el sistema de notiftcacion incluya la ubicacion exacta de la aplicacion de pesticidas.

Es bueno ver que despues de anos, el DPR ha realizado muchas mejoras en su plan de notificacion de pesticidas. Sin embargo, todavia falta la informacion mas esencial que nos ayudaria a tomar precauciones contra las danos de los pesticidas: ese es el lugar exacto de aplicacion del pesticida. Sabemos que entre mas cerca esta el pesticida, mayor es el riesgo de ser afectados. Por eso es importante que la notificacion de pesticidas nos diga exactamente donde se estan aplicando los pesticidas. Cuanto mas cerca este una aplicacion, mas precauciones podremos tomar, mas cuidadosos podremos ser. Existe una gran diferencia entre una aplicacion que esta a 500 pies de distancia y una que esta a 5000 pies de distancia.

Sabemos que no podemos simplemente "refugiarnos en casa" coma durante lo peor de la pandemia, pero podemos tomar algunas medidas que, segun las cientificos, reducen las riesgos de danos por pesticidas, como:

o Cerrar ventanas y puertas.

o Recoger las juguetes de las ninos y traer ropa del tendedero

o Permanecer en casa si nose siente bien o si tiene problemas respiratorios coma asma.

o Mantener a las mujeres embarazadas alejadas de las aplicaciones, especialmente de pesticidas que estan relacionados con danos reproductives y de desarrollo, y canceres infantiles.

Mi preocupacion es la salud de mi familia al no saber que tipo de pesticidas se aplican y lo que pido al DPR una hubicacion eacta y nombres de los quimicos para que el doctor me de el medicamento correcto en casa de una intoxicacion.

Ya no queremos mas enfermos de cancer, si ban a dar a huvicacion exacta en diferentes idiomos mixtecos zapoteco triqui purepecha y audios para los queno saben leer, sies posible en todos los idiomas posibles huvicacion exacta y

En todos los casos posibles, queremos mantenernos alejados del lugar de aplicacion donde la concentracion de pesticidas en el aire tiende a ser mas fuerte. Si solo nos informan sabre el uso de pesticidas dentro de una milla cuadrada, aun la informacion de indicar una milla de parametro aun no es lo suficientemente precisa como para identificar en que lugar exacto se aplico, y si nos dan la ubicacion exacta entonces podriamos saber con mayor precision que tan cerca estamos de la region afectada en terminos de exposicion al pesticida.

Simplemente nos mantendras adivinando si no se nos informa exactamente, y eso no es util para nuestras comunidades. Por favor, les pedimos que agreguen la direccion del sitio de aplicacion de pesticidas al sistema de notificacion de pesticidas en su mayor exactitud.

Espero que el Departamento de Regulacion de Pesticidas de California (DPR par sus siglas en ingles) considere seriamente estas preocupaciones. Gracias por la oportunidad de comentar.

Sinceramente,

Ana Mendoza Ramirez

Esposa y madre de un trabajador agricola

Estimadxs DPR,

Espero que todxs se encuentren muy bien de salud, mi nombre es Juan Carlos Diaz, soy abogador comunitario con la organización comunitaria del Proyecto Indigena. Antes que nada quiero agradecer al Departamento de Regulación de Pesticidas...↓ por la iniciativa de desarrollar un sistema de Notificación de Aplicación de Pesticidas, gracias también por considerar un Comite Asesor para mejorar el sistema cada año. Sin embargo, todavía no se ha considerado una ubicación exacta. Yo vivo en Oxnard, California por el área de Lemonwood donde se puede ver muchos campos de cultivos cercas. Es por eso que escribo para pedirle que es importante que se notifique a las comunidades impactadas con exactitud de donde se está fumigando los químicos o pesticidas para que nuestra comunidad pueda mejor proteger su salud y su seguridad. También para prevenir enfermedades así como el cáncer o enfermedades respiratorias así como el asma. Quiero agregar que la mayoría de las comunidades impactadas son analfabetos que además hablan su propia lengua. La información aun traducción en escrito es difícil de comprender para ellos. Si la notificación de Aplicación de Pesticidas incluyeran junto con el mensaje un audio en sus propias lenguas así como el Mixteco, Zapoteco, Purépecha etc… la información será más accesible y tendrá mayor alcance a muchos. Espero que se tome en cuenta mi comentario, que por favor se considere una ubicación exacta.

Muchas gracias,

Juan Carlos Diaz

--

Juan Carlos Diaz

Community Advocate

Organización Comunitaria Proyecto Mixteco/Indígena (MICOP)

Dear California Department of Pesticide Regulation (DPR),

My name is Alondra Mendoza Martinez, I am a resident of the city of Oxnard and I am a Community Advocate with Mixteco/Indigena Community Organizing Project (MICOP). MICOP’s mission is to suppor...↓t, organize and empower the indigenous migrant communities in California’s Central Coast.

Today I'm addressing concerns I have about the pesticide notification plan that I want you to address before we implement statewide notification. It's important that the notification system include the exact location of pesticide application.

It's good to see that after years, DPR has made many improvements to its pesticide notification plan. However, the most essential information that would help us take precautions against pesticide harm is still missing: that is the exact location of pesticide application. We know that the closer the pesticide is, the greater the risk of being harmed. That's why it's important that pesticide notification tells us exactly where pesticides are being applied. The closer an application is, the more precautions we can take, the more careful we can be. There's a big difference between an application that's 500 feet away and one that's 5,000 feet away.

We know we can’t just “shelter in place” like we did during the worst of the pandemic, but we can take some steps that scientists say reduce the risks of pesticide damage, such as:

o Closing windows and doors.

o Picking up children’s toys and bringing in laundry from the line.

o Staying home if you don’t feel well or have breathing problems like asthma.

o Keeping pregnant women away from applications, especially of pesticides that are linked to reproductive and developmental harm, and childhood cancers.

I ask the California Department of Pesticide Regulation (DPR) to ensure the pesticide notification system is effective and includes the exact location of planned applications.

I hope that the DPR will seriously consider these concerns. Thank you for the opportunity to comment.

Sincerely,

Alondra Mendoza Martinez

Community Advocate

Mixteco/Indigena Community Organizing Project (MICOP)

Dear Ms.Henderson

While the Department of Pesticide Regulation proposed revised “spray days” notification system will provide increased public access to planned pesticide application it does not include identification of exact location.The California ...↓Nurses for Environmental Health are concerned about the impact of incomplete information regarding the application of pesticides in the communities where patients live. Notifications of intention to use pesticides within one mile as proposed does not suffice, the public needs to be able to access the exact location of planned pesticide application.

Accessible exact location is necessary for those residing, working and going to school in nearby communities being able to take precautions against pesticide harms. Having the information regarding the exact location of a pesticide application would be important for health care providers when patients present at health care facilities believing they have been exposed to pesticides. As health care providers nurses are particularly concerned for the most vulnerable including pregnant women, children, elderly and those with existing chronic health conditions.

First responders and medical personnel need immediate access to names of these chemicals, and where and how they were applied when patients report symptoms and/or significant exposures. The Department of Pesticide Regulation should consider a 24 hour hot-line for information access.Additional information on health concerns and follow up with pesticide exposures are needed beyond first aid measures provided on product labeling. Beyond Poison Control links to Safety Data Sheets and the National Poison Data System should be provided.

Emerging science is showing that both the timing of exposure and genetic factors can increase risk, sometimes without causing acute symptoms. Scientific research confirms, the threat of exposure to many pesticides tends to increase the closer one lives or comes in contact to pesticide application sites. A recent meta-review that assessed six studies noted “All [six studies] found that the greater the distance [from the pesticide application], the lower the levels in pesticide concentrations in dust, outdoor and indoor air.” 1

Thank you for your consideration

Vanessa Forsythe RN MSN Policy Committee Chair California Nurses for Environmental Health and

Justice

1Deziel et al., 2017, Gibbs et al., 2017, Gunier et al., 2011, Hogenkamp et al., 2004, Kawahara

et al., 2005, Ward et al., 2006

California Nurses for Environmental Health & Justice

CleanEarth4Kids

Climate Health Now

"Keep Marching...your ancestors are all the proof that you need that progress is possible not

guaranteed...keep marching on...the future demands that we fight for it now"

Dear Director, Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my workers, my farm, and the environment. I have confidence in the federal, state, and local oversight of pes...↓ticide use enforcement. Considering these rules and regulation, I do not

believe that the changes to the CDPR’s Advance Pesticide Notification System are necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

1. -Notification should be limited to pesticide products that are already subject to Notices of Intent.

2. -Time frames to submit Notice of Intent to County Agricultural Commissioners should remain as it is in current practice.

3. -Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

4. -Personally, identifying information, such as acreage treated or exact location, should not be included-this is critical to grower, applicator, and employee safety.

5. -Because of the high probability that advanced notice will trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and for extended liability for crop loss.

6. -There are already some of the toughest last regulations operating to protect the employees, the community, and the rest of the public.

7. -The use of such regulation is not a benefit to those who are unaware of applications happening around them but an annoyance. Again, we already have the toughest laws in the states.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Growers’ Choice Inc.

Robert Longstreth

Dear Director Henderson:

Members of the aerial application industry work hard to ensure that pesticide applications are made in a safe and effective manner. And we know that pesticides have rigorous evaluation from US EPA and DPR before being approved...↓ for use and that label language and county permit conditions add additional mitigation of potential impacts from pesticide applications. Considering the current rules and regulations that govern pesticide applications, we do not believe that statewide notification is necessary.

Should the Department continue to move forward with this project, we encourage the Department to consider the following:

1. Notification should be limited to pesticide products that are already subject to Notices of Intent (NOI). There is already a system in place to communicate proposed applications of these products with the county Ag Commissioners.

2. Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice to allow for timely control of pests that threaten yields.

3. Public notifications should be limited to: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section) as these are all currently included in the NOI process.

4. Specific location information or other identifying information, such as acreage treated, should not be included.

5. Because NOIs have triggered appeals and stalled applications, there needs to be a process in place to quickly address these appeals to mitigate crop loss and the likelihood of trespass on agricultural lands that impact application timing and efficiency.

As this system is implemented, we encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Terry Gage, CAE

California Agricultural Aircraft Association

To Whom It May Concern,

We appreciate this opportunity to comment on the proposed regulations for the Statewide Notification of California Restricted Materials applied in a production agricultural setting. The California Agricultural Commissioners and...↓ Sealers Association appreciates the dialogue and consideration of local practices, including the potential impact to county office workload, throughout the drafting of these regulations. In a continuation of the existing open dialog, we respectfully submit the following additional comments regarding the proposed regulations.

Per Title 3, California Code of Regulation (CCR) section 6434, Notice of Intent (NOI): We acknowledge and value the continued inclusion of a 24-hour notice period for non-soil fumigant pesticides and understand the requirement of a 48-hour notification for soil fumigants. We believe it is imperative to continue these same timeframes. A 24-hour NOI and a 48-hour NOI provide critical flexibility in order to maintain time sensitive pesticide applications. Applications can be unexpectedly impacted by weather, employee availability, equipment issues, or other local conditions.

Additionally, it is imperative to emphasize that these proposed regulations apply only to California restricted material use as defined in 3 CCR section 6400 and only for the production of an agricultural commodity. We are concerned that these regulations could cause confusion in communities and will increase unnecessary calls to the local Agricultural Commissioner’s offices due to a lack of understanding between not only federally restricted versus state restricted materials, but more crucially, restricted materials versus non-restricted materials and restricted materials that require a permit. We ask that every effort be made to clarify and emphasize to communities that DPR strictly controls the use of restricted materials (RM) in California. DPR should clarify, through outreach and education, the controls that they have in place to regulate Restricted Materials. These controls include, but are not limited to: A RM can only be sold to end users by pest control dealers licensed by DPR; Everyone who supervises the use of a RM is required to be a certified private or commercial applicator; A RM permit shall be obtained prior to the possession or use of a RM (with few exceptions); and a NOI is required to be submitted to the local CAC prior to making an agricultural application of a RM requiring a permit.

Previously, we shared our concerns regarding the possibility of a notification leading to an unintended identification of the site-specific location of an application. Such site-specific information may lead to the potential harm of an operator and/or their employees, violation of their privacy, or trespass upon their private property or businesses. Therefore, we are continuing to request that reconsideration be made on including acreage to be treated, as this may be a means of identifying site specific areas. We suggest that acreage ranges be utilized instead to provide information on the size and scope of the application, without giving exact acreage. The proposed regulations provide for the privacy of the public accessing the information, and similar consideration should be considered for protecting the privacy of property operators and their employees that work and reside at these locations.

In further relation to the proposed notification regulations, we have already seen an increase in RM permit challenges and community concerns on other pesticide use enforcement program activities, which we believe is not the intent of this new program. We anticipate the public inquiring about pesticide safety and risk analysis, which is the responsibility of DPR, not the local CAC. Such inquiries, although important, are concerning. They have the potential to increase staff workload and diminish the time spent in pesticide use enforcement program activities. These activities include time performing notice of intent reviews and field inspections to ensure pesticide use compliance for the safety, health and welfare of the environment and communities we serve. We strongly recommended that DPR is proactive about its outreach and education efforts to inform communities that RMs like non-restricted materials are legally registered for use and have undergone risk assessment evaluation by U.S. EPA and DPR for potential harm to human health and the environment to ensure safe and effective use. As previously mentioned, the use of a RM requires a permit and submittal of a NOI before the material can be applied increasing its oversight to ensure compliance with additional label or regulatory restrictions.

As a reminder, California’s Pesticide Use Enforcement program is the most active, comprehensive, and state-of-the-art system in the United States, if not the entire world. The local CAC offices have approximately 493 licensed Inspectors/Biologists. These dedicated individuals reflect a strong, statewide presence in the field. They conduct enforcement inspections for: pre-application site conditions; pesticide applications; worker safety; employee training; and recordkeeping. They also prioritize potential pesticide issues by investigating all pesticide related complaints and responding to pesticide related injury and illness notifications. As a direct result, licensed county staff perform over 30,000 field enforcement inspections per year on average, with our nearly 500 inspectors statewide.

In conclusion, we appreciate the opportunity to provide comments on these proposed regulations and look forward to collaborating with your office and continuing our discussion regarding this program. Thank you for your consideration.

Sincerely,

Juan Hidalgo

President

DPR,

When designing a Pesticide Notification System please be sure to implement a system with exact addresses. The public needs/ deserves a system that is practical/ usable.

Thank you for your consideration & efforts to protect the community.

Chris Webb...↓

Watsonville High School

Social Studies Teacher

NOI Comments, 8/1/24

Over the last eight or nine years, I’ve lost count of how many meetings I’ve attended, and how many oral and written comments I’ve submitted on sequential

developments in DPR’s sharing of pesticide use data. The school notification...↓ program was an important step, yet its limitations revealed the inadequacy of

focusing so narrowly. We expanded our efforts to include communities surrounding both the schools and the agricultural fields that are too often adjacent to both the school and community.

Yes, this notification program is novel, perhaps the first of its kind in the world. But does it meet the needs of communities such as mine? Residents and workers see themselves as unjustly exposed to the potentially toxic effects of the many synthetic chemicals used in modern agriculture. DPR’s stated intention for providing NOIs is “transparency and equitable access”. These are worthy goals, but DPR is also tasked with overseeing the work of the County Agricultural Commissioners (CACs), Pest Control Advisors (PCAs), and applicators. Protecting public health is also a stated part of DPR’s mission.

We are that public, “stakeholders” living near fields where pesticides are applied. We don’t just want transparent information, we want accountability. The irony is that, in making the information provided palatable to growers, applicators, and the ag industry in general, it becomes less transparent and undercuts accountability.

Location

Since location is the current focus of SASS and CPR, two of the organizations I work with, let’s start with that. After the pilot project in our Watsonville senior

neighborhood, I provided a long, detailed narrative describing why the one mile radius did not work and was not useful. You’ve heard the same from residents of other agricultural communities. What’s troublesome is the fact that the information we’re asking for is included in the permit requirements, but excluded from the notification.

DPR claims that one reason for this is the lack of a uniform reporting system. Yet DPR has been developing just such a system for years. The state’s online reporting system is used by CACs in multiple counties. In some of these counties, information on exact location is provided to other growers. It is provided under some circumstances to beekeepers, and it is (supposed to be) provided to schools. In Monterey and Santa Cruz counties, we can request and obtain maps of the fields within a quarter mile of schools, with the list of proposed pesticides for the following year and names and contact information for growers. Under the school notification project in Monterey County, that same information is also available to people who sign up for school NOIs.

Yes, there is a single legal challenge in progress, but agriculture has not been stopped; in fact, fumigation appears to continue unabated. Yet the hypothetical

concerns of the ag industry appear to outweigh the lived experiences of community members concerned about pesticide drift encroaching in their schools, their homes, and in the fields where they are working.

What’s in a name?

DPR added specification that besides the product brand name, the active ingredient will be identified. However, recipients of notification will still have to look it up and decipher information in highly technical form and/or specialized format, often incomprehensible even to those with a science background. DPR appears only willing to provide generic information on safety measures and on reporting possible exposure. Missing is information about acute symptoms, potential long-term effects, and cumulative and combined impacts of exposure to multiple chemicals, including adjuvants, which are not required to be named by the manufacture. And this is just for a very truncated list of only the chemicals currently identified as restricted based on their risks to human and environmental health. There remain many other highly hazardous chemicals in wide use in California which are not reportable under the current system.

Loopholes and Paradoxes

As stated in my January 2024 comments, the language of the regulation appears fraught with potential loopholes, manifest in fudge phrases like “undue hardship“ and “as soon as practicable”. These loopholes portend a lack of timeliness in reporting, and also to the prejudicial use of discretionary authority of the CACS, a topic of on-going concern. Both timeliness and discretionary authority are germane to what I’ll title the Paradox of the 24 hour rule.

As I understand it, a NOI paperwork must be submitted at least 24 hours before the intended pesticide application, 48 for fumigants. Per the regulation,that form must be reviewed and approved by the CAC, and submitted electronically by either the permittee or the CAC (insert both fudge phrases here). It is then posted to the notification system also electronically, in truncated form, by DPR. Is there a time machine involved? How can all three operations happen simultaneously? Where is the time allotted for the CAC to evaluate whether there are less toxic options available, and weigh the many variables (weather, wind speed, workers in neighboring fields, etc) that influence the likelihood of adverse events?

Checking Our Work or the Devil in the Details

DPR’s willingness to expand the evaluation process is appreciated. The two bodies tasked with assisting in evaluation, CDFA’s board and the EJAC, have potential to present a spectrum of interests. The list of stakeholders which DPR includes in describing changes to the regulation is refreshingly inclusive. CDFA appears well-position to represent the interests of growers, especially the larger ones, and is a body of long-standing, preceding the existence of DPR, and even CalEPA.

DPR’s EJAC has yet to be formed, with the funding, timing process and composition as yet uncertain. As a newly constituted committee, the EJAC will have a big job mustering a perhaps more diverse group of stakeholders to participate in the notification project, provide reviews, and give suggestions for improvement, while simultaneously developing a working process and sense of cohesion. And as the recent hearing has demonstrated, it’s not a matter of one

person, one vote. Those who want more complete information have to lobby much harder than those who want to withhold it.

Common ground on pesticide use can be hard to find. California’s governor and a former CalEPA head expressed the intent of addressing our agricultural system’s chemical dependency problem. Consumers and workers want this as well. It’s not a matter of “Just tell us what poisons you’re applying next to us!” Transparency must nurture accountability. We can only hope evaluation will be both informative and formative, because to build a useful notification system, we still have a ways to go.

Kathleen Kilpatrick, RN, MN, NP, PHN, CSN

Dear Director Henderson,

I want you to include the exact location of the application site in the upcoming statewide pesticide notification system.

I live in Santa Cruz County, where two-thirds of all pesticides by pounds are banned in the European Unio...↓n. If you won't protect our communities up to world standards, the least you can do is give us a heads up as to exactly where these highly hazardous pesticides are applied, so we can try to take precautions to protect our loved ones.

Sincerely,

Vanita Seth

Dear Director Henderson,

Safe Ag Safe Schools – Monterey Bay would like to add to our previous comments in earlier rounds of the pesticide notification hearings and to the many individual comments of our members.

We want to see the exact location of th...↓e upcoming pesticide application in the pesticide notification system. It’s not notification without location.

Your current draft still keeps the most important information about the pesticide application secret from our communities: exactly where these highly hazardous restricted pesticides will be applied. The closer the application, the larger the threat, the more precautions we need to take for our loved ones. A one-mile square just does not give us enough information, as 500 feet is far different than 5,000 feet, yet DPR’s plans do not allow us to know the difference.

We’d like to address some of the complaints or concerns we’ve heard against including exact application location information in the proposed system.

No standardized location information? Standardize it.

DPR has argued that the lack of a standardized way to record location information in NOIs prevents inclusion of location in the notification system. Our members say: Then standardize it! The regulation calls for growers to submit NOIs online; it could also standardize how the location box is filled out. Short of that, DPR could certainly include the current location box information, even if not standardized.

It violates growers’ privacy? No, NOIs are public documents.

NOIs upon which the pesticide notification system is based are public documents.

Our members pushed for and have eight years of experience with a fumigant notification system for ten schools in Monterey County, based on NOIs that include the exact location as well as maps indicating the farm’s name and proximity to the schools. Exact location has been part of notification for eight years. It should continue going forward.

Also, if a neighbor sprayed poison into your yard, they can’t claim the right to privacy to do that. Similarly, we know harmful pesticides drift from farms onto our properties, schools, and workplaces. Pesticide drift is illegal; it’s not protected by privacy rights.

It would create mass confusion? No, exact location addresses current confusion in farmworker communities.

The confusion is now: we don’t know what, when, or where pesticides will be applied. We assume DPR will make clear that the application information is a notice of intent and not a guarantee of pesticide use, of course. One of the main reasons for the need for exact location is to avoid confusion about where the most potential health harm is located. This was a concern of many participants in the Santa Cruz County pilot notification project -- that there were so many notices, they couldn’t differentiate between those in the field behind their house versus those a mile away. Fear was heightened without knowing exactly where the application would happen.

The activists will protest in the fields? No, the activists want to avoid the source of potential harm to their communities.

Of all the crocodile tears expressed in the media and sometimes even in the hearings, these were the most disingenuous. A number of County Ag Commissioners and Big Ag representatives have pushed the lie that in Monterey County activists went into the fields to stop a fumigation. In the fourteen years of SASS’ existence, we have never, nor would we ever put our members in harms way by exposing them to pesticide applications. The whole point is to keep as safe as possible and as far away and protected as possible from these restricted pesticides.

Grower representatives at the Turlock hearing expressed concerns about activists “trespassing” onto their fields, if we knew where pesticides would be applied. The trespass issue is in the reverse direction: highly hazardous pesticides trespass into our homes, schools, and workplaces.

There is no good excuse. DPR must include the exact location of the pesticide application in its statewide pesticide notification system.

Sincerely,

Yanely Martinez

Safe Ag Safe Schools (SASS) Organizer

Dear DPR,

We need to know the exact location in which pesticide application will take place. Generalized locations, such as “somewhere within a mile radius” are not helpful if we are to protect our health and children.

Please be more specific. You have...↓ a responsibility to do so.

Dr Ann Lopez, Director

Center for Farmworker Families

Sent from my iPhone

Dear Ms. Otani:

The Chloropicrin Manufacturers’ Task Force (CMTF) appreciates the opportunity to comment on the Department of Pesticide Regulation’s (DPR) modified text for the proposed regulation DPR 23-003, Statewide Notification of Agricultural Use...↓ of Restricted Materials. The CMTF represents registrants of chloropicrin, a pre-plant soil fumigant which is a restricted material in California. Chloropicrin improves soil health, helping California growers produce abundant fruits and vegetables.

The CMTF is providing comments on three issues related to the proposed modifications. First, CMTF addresses location information regarding the application site. Second, CMTF discusses the importance of participation from all stakeholders in the evaluation process. Finally, CMTF comments on the name of DPR data base “Spray Days.”

Field Location Information. The proposed regulations provide communities with the base, meridian, township, range, and sections of the area to be treated. Despite this, some commentators have requested the exact location of the application site. The CMTF encourages DPR to maintain the currently proposed location information. First, the DPR proposal provides for a standardized location description throughout the state. The current location information specifies a one square mile area that aligns with the existing Public Land Survey System. This allows DPR to provide consistent location information throughout the state. Second, providing the exact location could negatively impact public health and safety, as individuals may show up at an application site to protest or otherwise interfere with the application, creating potential hazards that would cause the delay of the application and divert valuable County Agricultural Commissioners’ (CAC) resources to address the protesters’ actions. In addition, the timing of applications can be time sensitive, and delay could increase burdens on CAC staff and decrease the benefits of the application to growers. While many residents have stated that they do not intend to protest, since the information is public others may use the information with intent to disrupt an application. For example, protesters caused a delay during one of the pilots. Finally, growers expressed privacy concerns related to providing the exact location. These issues were noted by the UC Davis Center for Regional Change in its analysis of the pilot projects for notification system.1 1 UC Davis Center for Regional Change, Outcome and Process Evaluation for Four Pilot Projects for the Statewide

Notification System at 15, https://www.cdpr.ca.gov/docs/pesticide_notification_network/outcome_process_evaluation_four_pilot_projects.pdf

Review of the Program. The modified proposal requires DPR to issue an annual status update about (1) its system and process for making information about intended applications available to the public, (2) feedback received, and (3) changes to its system and process. DPR must receive feedback from the Department of Pesticide Regulation Environmental Justice Advisory Committee, the State Board of Food and Agriculture, and the public via a public comment period until DPR issues a draft report on its system three years after the regulation becomes effective. The CMTF reaffirms our belief that property owners, applicators and CACs must be consulted in the evaluation process, along with representatives of farmworkers and residents. It is important to receive feedback from all parties involved to craft the most effective system.

Database Name. We appreciate that DPR has shared the beta version of the proposed notification system, called “SprayDays.” However, the CMTF is concerned with the name chosen for the system, as it does not accurately reflect the variety of pesticide applications. For instance, chloropicrin is injected directly into the ground and is not sprayed. The current title risks misleading the public into believing that all restricted material pesticides are “sprayed” near them when, in reality, various application methods have been developed over the decades to better protect human health and the environment. The CMTF request that DPR rename the notification system to avoid misleading the public.

Thank you again for the opportunity to comment on the proposed regulation.

Regards,

Stephen Wilhelm

Chairman

Chloropicrin Manufacturers Task Force

I am opposed to the California Department Of Pesticide proposed regulation to send notification to everyone. There are plenty of existing safeguards in place that protect the public. This is an unnecessary proposal that actually endangers farm worker...↓s and the public. If people show up to observe a chemical application that are not familiar with the area and the buffer zones, there could be chaos and misunderstanding of what is actually happening. This could cause farm workers and farmers to be exposed to elements that they would normally be accustomed to handling. Farmers are already required to notify sensitive areas of an application. This new requirement serves no purpose.

Dear Director Henderson:

Thank you for the opportunity to provide public comment on the revised draft of the statewide pesticide notification regulation. We appreciate the inclusion of a review process to ensure that the notification program is workin...↓g as intended. We strongly support inclusion of acres treated in the notification, because with larger applications there is more pesticide available to drift. We also strongly support inclusion of the pesticide product names and all active ingredients,

because some people are more familiar with commercial names and others know the chemical names.

However, this latest version of the regulation continues to deny Californians the crucial location information that is the cornerstone of an effective public health notification system. Providing only the square mile in which a planned application is located is inadequate and cannot be justified, given that the exact location is known by the County Agricultural Commissioners in advance and can easily be made public.

Farmworker communities, including those involved in the various pilot notification programs, have repeatedly called for exact location information so that they can better protect their families from highly hazardous pesticide drift. The threat of harm is more severe if the application is in the field behind your home or across the street from your child’s school, than if it’s a mile away or at the distant corner of the Public Land Survey section.1

DPR has not wavered from its claim that it cannot provide the exact application location in its proposed regulation for a pesticide notification system because this information is not standardized. DPR has the authority to require standardized reporting and has a multi-million dollar notification budget to do so. There is no justification for continuing to withhold this information.

The proposed system will require standardized electronic submission of all Notice of Intent (NOI) information for use in the state’s notification system. DPR should standardize exact application location as part of that new requirement.

If DPR continues to refuse to require NOIs to include standardized application location information, at the very least the non-standardized location must be included in the notification system such as the site ID number, the address of the site, or other location description.

Scientific research confirms that within a mile, the threat of exposure to many pesticides tends to increase the closer one lives to pesticide application sites. A recent meta-review2 that assessed six studies3 noted: “All [six studies] found that the greater the distance [from the pesticide application], the lower the levels in pesticide concentrations in dust, outdoor and indoor air.”4

The exact location of pesticide applications is essential information in allowing for individuals and communities to respond appropriately to protect their health from drifting pesticides. DPR has access to that information and must provide it in the pesticide notification system.

Sincerely,

Jane Sellen and Angel Garcia, Co-Directors

Californians for Pesticide Reform

Alicia Acevedo, Creative Director

Acevedo Media LLC

Katie Huffling, Executive Director

Alliance of Nurses for Healthy Environments

Hardy Kern, Director of Government Relations

American Bird Conservancy

Cailin Dendas, Environmental Health Senior Coordinator

As You Sow

Cheryl Auger, President

Ban SUP (Single Use Plastic)

David F. Gassman, Co-Convenor

Bay Area System Change Not Climate Change

Constance Beutel, Member

Benicia Good Neighbor Steering Committee

Sara Grantham, Science, Regulatory, and Advocacy Manager

Beyond Pesticides

Arnedra Jordan, Project Manager

Black Women For Wellness

Jacob Sandoval, State Director

CA League of United Latin American Citizens (LULAC)

Ellen Marks, Director

California Brain Tumor Association

Nan Wishner, Board Member

California Environmental Health Initiative

Thomas Helme, Coordinator

California Environmental Justice Coalition (CEJC)

Clarissa Ramirez, Policy Manager

California Latinas for Reproductive Justice

Vanessa Forsythe, RN MSN

California Nurses for Environmental Health and Justice

Larry Hanson, Board President

California River Watch

Anne Katten, Pesticide and Work Health and Safety Project Director

California Rural Legal Assistance Foundation

Kathleen Kilpatrick, Founding Member

Campaign for Organic and Regenerative Agriculture

Sandra Garcia, President

Campesinas Unidas del Valle de San Joaquin

Teresa Gomez, Community Organizer

CAPS 805

Raul Garcia, Community Organizer

CAPS Tulare County

Jonathan Evans, Environmental Health Legal Director

Center for Biological Diversity

Thomas R. Fox, Senior Legislative Counsel

Center for Environmental Health

Dr. Ann Lopez, Executive Director

Center for Farmworker Families

Dashel Murawski, Policy Coordinator

Center for Food Safety

Grecia Orozco, Staff Attorney

Center on Race, Poverty, & the Environment

Kevin Hamilton, Senior Director of Government Affairs

Central California Asthma Collaborative

Nayamin Martinez, Executive Director

Central California Environmental Justice Network

Catherine Garoupa, Executive Director

Central Valley Air Quality Coalition

Daniel O'Connell, Director

Central Valley Partnership

Sarait Martinez, Executive Director

Centro Binacional para el Desarrollo Indigena Oaxaqueño (CBDIO)

Autumn Johns, Executive Assistant to the CEO & Policy Coordinator

Ceres Community Project

Natalia Deeb-Sossa, Professor

Chicana/o/x Studies at UC Davis

Colleen Corrigan, Health Policy Associate

Children Now

Ken Szutu, Director

Citizen Air Monitoring Network

Felipe Perez, Council member

City of Firebaugh

Andria Ventura, Legislative and Policy Director

Clean Water Action/Clean Water Fund

Renee Donato Nelson, President

Clean Water And Air Matter (CWAM)

Suzanne Hume, Educational Director and Founder

CleanEarth4Kids.org

Bill Magavern, Policy Director

Coalition for Clean Air

Felipe Aguirre, Director

Comite Pro Uno

Dennis Rosatti, Executive Director

Conservation Action Fund for Education

Lindsey Zehel, Executive Director

Defend Them All

Cynthia Babich, Director

Del Amo Action Committee

Dolores Huerta, President

Dolores Huerta Foundation

Dan Silver, Executive Director

Endangered Habitats League

Laura Deehan, State Director

Environment California

Bill Allayaud, California Director of Government Affairs

Environmental Working Group

Yolanda Whyte, MD, President

Ethical And Respectful Treatment of Humans

Lendri Purcell, President

Families Advocating for Chemical and Toxics Safety

Anna Hopkin, Executive Director

Farm2People

Lauren Ornelas, Founder

Food Empowerment Project

Christine Farren, Executive Director

Foodwise

Jim Lindburg, Legislative Consultant

Friends Committee on Legislation of California

Malaika Elias, Food and Agriculture Campaigner

Friends of the Earth

Juan Valladolid, Director

Fundación Valladolid

Victor Torres, Co-Founder Youth Leader

Future Leaders of Change

Michelle Perro, MD, CEO

GMOscience.org

Patti Wood, Executive Director

Grassroots Environmental Education

Arlene Blum, PhD, Executive Director

Green Science Policy Institute

Bradley Angel, Executive Director

Greenaction for Health and Environmental Justice

Lucia Sayre, Western Regional Director of Innovation and Community Resilience

Healthy Food in Health Care, Health Care Without Harm

Jennifer Tanner, Leader

Indivisible CA Green Team

Susan Morgan, Founder

Indivisible Marin

Kimberly Baker, Executive Director

Klamath Forest Alliance

Emma De La Rosa, Regional Policy Manager

Leadership Counsel for Justice and Accountability

Gloria Alonso Cruz, Environmental Justice Advocacy Coordinator

Little Manila Rising

Richard Moore, Co-Coordinator

Los Jardines Institute

Belita Cowan, President

Lymphoma Foundation of America

Sydney Cook, Director of Science & Research

MADE SAFE

Linette Lomeli, Executive Director

Madera Coalition for Community Justice

Leah Segedie, Founder

Mamavation

Terrie Green, Executive Director

Marin City Climate Resilience

Lynn Kersey, Executive Director

Maternal and Child Health Access

Vanessa Terán, Director of Policy

Mixteco/Indígena Community Organizing Project (MICOP)

Zen Honeycutt, Founding Executive Director

Moms Across America

Francisco Rodriguez, Secretary Treasurer

Monterey Bay Central Labor Council, AFL-CIO

Catherine Crockett, President, Board of Directors

Monterey Peace and Justice Center

R. Brent Lyles, Executive Director

Mountain Lion Foundation

Kathleen Mulligan, Executive Director

National Association of Environmental Medicine

Erika Alfaro, San Francisco Bay Area NAHN Chapter President

National Association of Hispanic Nurses

Diana Carpinone, President

Non-Toxic Communities

Kim Konte, Founder

Non-Toxic Neighborhoods

Dave Henson, Executive Director

Occidental Arts and Ecology Center

Margaret Reeves, Senior Scientist

Pesticide Action Network

Martha Dina Argüello, Executive Director

Physicians for Social Responsibility, Los Angeles

Matthew Marsom, Chief Program, Policy & Government Relations Officer

Public Health Institute

Mackenzie Feldman, Project Director

Re:wild Your Campus

Gopal Shanker, President

Récolte Energy

Brandon Kitigawa, Senior Policy Associate

Regional Asthma Management and Prevention

Yanely Martinez, Community Organizer

Safe Ag Safe Schools

Oscar Ramos, Migrant Program Director

Salinas Elementary School District

Robert M. Gould, MD, President

San Francisco Bay Physicians for Social Responsibility

Ted Schettler MD, MPH, Science Director

Science and Environmental Health Network

Martha Camacho Rodriguez, Director

SEE (Social Eco Education)

Kevin Bayuk, Treasurer

SF Permaculture Guild

Membership

Sonoma County Climate Activist Network (SoCoCAN!)

Shoshana Wechsler, Co-Coordinator

Sunflower Alliance

Lupe Cipres, Community Outreach Representative

Terra Bella Voice 4 Change

Ana Parras, Co-Director

Texas Environmental Justice Advocacy Services

Liz Barris, Director

The People's Initiative Foundation

Herman Barahona, Lead Community Organizer

The Sacramento Environmental Justice Coalition

Patricia Pagaling, Executive Director

Transition to Organics

Jassy Grewal, Legislative Director

UFCW Western States Council

Akashdeep Singh, Western States Policy Advocate

Union of Concerned Scientists

Bianca Lopez, Co-Founder

Valley Improvement Projects

Emily Schwing, Acting Executive Director

Veggielution

Janice Schroeder, Core Member

West Berkeley Alliance for Clean Air and Safe Jobs

Dr. Elizabeth Dougherty, Executive Director

Wholly H2O

Randa Solick, Member

Women's International League for Peace and Freedom, Santa Cruz

Stephen Knight, Executive Director

Worksafe

__________________________________________________

1. The threat of exposure to fumigants, of course, varies more widely at longer distances and

times.

2 Dereumeaux, C., Fillol, C., Quenel, P., and Denys, S. (2020). Pesticide exposures for residents

living close to agricultural lands: A review. Environment International, 134, 105210

3 Deziel et al., 2017, Gibbs et al., 2017, Gunier et al., 2011, Hogenkamp et al., 2004, Kawahara

et al., 2005, Ward et al., 2006

4 “Outdoor air concentrations of trichlorfon within 50 m of paddy fields were five times higher

than those measured further away (Kawahara et al., 2005), and high levels of chlorpyrifos in

outdoor air were identified at households located within 100 m of crops (Gibbs et al., 2017).

Chlorpyrifos, chlorthal-dimethyl, iprodione, phosmet, and simazine dust concentrations were

higher in residences located between 500 m and 1250 m from treated lands (Gunier et al.,

2011). Similarly, the decrease in concentrations of chlorpropham in house dust was borderline

statistically significant with increased distance from agricultural fields (Hogenkamp et al., 2004).

The meta-analysis performed in 2017 confirmed the sharp decrease in house dust pesticide

concentrations with increased distance from treated fields (between 3 m and 1125 m) (Deziel et

al., 2017)”

Dear DPR Director Henderson:

Our group of teenagers from the Monterey Bay would like to add to the many comments our members have made over the course of all three Department of Pesticide Regulation (DPR) hearings last month.

We demand the exact locati...↓on of the pesticide application be included in the statewide pesticide notification system. We believe it is not notification without location. Your current draft keeps pesticide applications secret.

We were outraged when Roger Isom of the Cotton Ginners and Growers Association said at the July 12 Turlock hearing: “There’s concern that people are being exposed to pesticides when they spray them … The fact of the matter is … no way in the world would DPR or any ag commissioner in this room ever allow pesticides to be sprayed that would affect a farmworker or resident or innocent bystander. It just wouldn’t happen.”

What alternative universe is Mr. Isom living in?

The members of FLOC live in the Salinas and Pajaro Valleys, so we know we are exposed to pesticides that are harming us!

One of our members, Victor Torres, ended up in the emergency room for a severe asthma attack brought on by exposure at school to as many as 7 different hazardous pesticides.

The quarter-century CHAMACOS study of mothers and their children in the Salinas Valley has found harm from pesticide exposure – especially organophosphate exposure – that has included developmental, brain, and lung damage. A quarter of all organophosphate use in California is applied in the Salinas Valley.

The US EPA finds that current DCPA labels and use levels allow for exposure “10 to 1,500 times greater than what is considered safe,” yet neither you nor our Ag Commissioner has done a thing to restrict its use in over a year, despite half of all DCPA use in this state is in Monterey County and has been found on pesticide-detecting wristbands of teenage Latinas by the CHAMACOS team.

Every time DPR has tested for 1,3-D air concentrations in Monterey County – whether in Salinas or Chualar or up in the Pajaro Valley at Ohlone Elementary School -- you have found levels above the lifetime cancer risk amounts set by our State’s Office of Environmental Health Hazard Assessment.

So, as for exposing us to highly hazardous pesticides, “no way in the world”? “It just wouldn’t happen?”

We need to know the exact location of pesticide applications, so we can do all we can to avoid the sites where they are applied and to take appropriate precautions, given the proximity of the applications to our homes, schools, and workplaces.

We wish Roger Isom was right, but the reason we need exact location in the pesticide notification system is because he is wrong. Completely wrong. You allow us to be exposed to chemicals that harm and even permanently damage us. The bare minimum is to give us a heads up as to exactly where the threat is coming from.

Sincerely,

Victor Torres

Future Leaders of Change

Greenfield - Watsonville

Dear Ms. Otani:

I am submitting this letter on behalf of the Western Plant Health Association (WPH) in regards to “DPR 23-003 Statewide Notification of Agricultural Use of Restricted Materials” dated July 2, 2024. WPH appreciates the opportunity to co...↓mment on this proposal and looks forward to participating in continued discussions on the Pesticide Application Notification System. WPH represents the interests of pesticide and fertilizer manufacturers, agricultural biotechnology providers, and agricultural retailers in California, Arizona, and Hawaii.

WPH thanks DPR for the measured approach that DPR has utilized when considering both the needs of farmers and the wants of other stakeholders in this process. We would be remiss in not noting the necessity of DPR’s measured approach in developing this system when considering the ongoing costs of development and implementation. The ongoing staff and financial resources that will be required by the state and at local levels to implement the proposed system, provide system updates, and respond to the consultation requirements must be considered part of the Pesticide Application Notification System. Because of these costs and that this is a legislatively mandated program, WPH strongly believes that future costs should be borne by the State General Fund through budget change proposals, rather than at the expense of DPR’s tax and fee payers.

WPH supports modifications that provide greater clarity for when notice of intent information will be required. We are concerned that the 48-hour notice for soil-applied fumigants is unnecessary and will create confusion. DPR has explained at recent public hearings that restricted use products (RUPs), including fumigants, are thoroughly evaluated prior to registration approval. Precautionary mitigations are mandated at the federal, state, and county level when needed in relation to the use of all RUPs. As a result, WPH does not believe that an additional 24-hour notification for fumigants, built on top of the already planned 24-hour notification for RUPs is warranted. In addition, as has been expressed previously, the application of a pesticide is based on a variety of factors including weather, atmospheric, or pest conditions which change on an ongoing basis. WPH is concerned that these changing conditions will result, when utilized in a 48-hour notification framework, in unintended confusion in communities as notifications are issued, cancelled, and then reissued, potentially multiple times over a 48-hour period. If DPR’s intent is to simply issue the notifications, but not the cancellations, than DPR will not only confuse the public with multiple notifications in the same application grid, but create fear of excessive applications as community members will be unaware that applications were cancelled.

WPH supports the currently proposed 1-mile spatial grids for the notification framework. We believe that this will provide an appropriate level of notification for interested parties, while protecting the privacy of farmers and applicators. WPH is unsure of DPR’s intention of providing product names as part of the Pesticide Application Notification System. We are concerned that simply releasing product names will not provide useful information to the public. Unless DPR includes factual information about the product, including the safeguards required by DPR so the public can make informed decisions, then we don’t believe that the release of this information is appropriate or beneficial.

WPH opposes the release of exact addresses of application sites and the names of businesses who apply RUP products. This information should remain in the custody of Agricultural Commissioners who oversee applications and safeguard all segments of the public. California has taken tremendous steps to assure that members of the public’s names and addresses are not commonly accessible to protect community member’s privacy. We believe that this same right should be applied to farms and businesses who have a right to have their privacy protected. WPH thanks DPR for their consideration of the need to protect the privacy of all stakeholders impacted by the Pesticide Application Notification System.

WPH supports the proposed modifications that specifically require that DPR provide updates and receive feedback from identified stakeholder groups. WPH acknowledges the intent of DPR to consult with, and receive feedback from, the DPR Environmental Justice Advisory Committee and the CDFA State Board of Food and Agriculture. WPH appreciates DPR including an agricultural entity to receive updates on the system. However, we ask that the Office of Pesticide Consultation and Analysis (OPCA) Advisory Board be included to receive DPR’s updates. The OPCA Advisory Board consists of farm group representatives who interact more directly with farmers on an ongoing basis. WPH believes this group will be better suited to evaluate agricultural impacts from the Pesticide Application Notification System. The OPCA Advisory Board could then provide to the State Board of Food and Agriculture an agricultural assessment of the System. Again, while WPH supports the State Board of Food and Agriculture’s involvement, we think it is unrealistic, from a time and resource standpoint, for the State Board of Food and Agriculture to engage in the kind of review the OPCA Advisory Board could provide.

Finally, we continue to encourage DPR to develop effective educational resources for those communities who will be recipients of the pesticide notifications. While agricultural interests have developed the knowledge and expertise to understand the use and built-in safeguards of RUPs, the general public will require ongoing education through non-traditional delivery systems. WPH recognizes the efforts DPR is taking in this area, and we thank you for your continued commitment to provide these resources to communities. We thank you for your consideration of our comments. If you have any questions, please feel free to contact me.

Sincerely,

Renee Pinel

President/CEO

Dear Ms. Otani:

The California State Board of Food and Agriculture appreciates the opportunity to provide public comment on DPR 23-003 Statewide Notification of Agricultural Use of Restricted Materials. The Board held a virtual meeting on July 25th fo...↓r the purpose of receiving public comment on the statewide pesticide notification system and proposed regulatory modifications.

We received 20 comments and had approximately 92 attendees. Comments reflected viewpoints of agricultural associations, community organizations and individuals.

A number of comments reiterated public comment submitted by the Board to DPR on January 12, 2024 (attached). The Board offers further recommendations for the proposed regulatory modifications and the statewide pesticide notification system.

Availability of Data

The Board continues to encourage DPR to carefully consider the concern about non-regional individuals or organizations accessing notification information which should be available to address local questions or concerns. The “use” of system data is a consistent concern expressed by agricultural stakeholders for the legal, regulated and approved use of restricted materials.

The specific purpose of the proposed amended regulation was identified within the Initial Statement of Reasons and Public Report as, “increasing public interest in obtaining equitable and routine access to information on agricultural pesticide applications prior to the applications occurring.”

Allowing individuals (with address verification) from a local area to sign-up for notifications in their area versus a publicly available statewide website accessed by an individual (California/non-California based) aligns, and does not conflict, with the intent of regulation.

The Board also heard, from a number of individuals, as part of comments received in the virtual meeting that the “exact location” of application in the statewide notification is needed for community protection within the statewide notification system. The Board appreciates and advocates for transparency, but recognizes a public safety need to protect privacy and safety as part of the notification system. By focusing on critical details of the application, the

community can concentrate on essential information.

Further, the system as proposed expands beyond a health protection measure by providing the opportunity for those not within a local radius of application to receive notifications. Individuals with a general or global concern about the use of restricted materials can now receive notifications for purposes that are undefined and ambiguous. Farmers are operating under a legal and regulated system (local, state, federal) and have established protections (i.e. Public Records Act, et. al) to use restricted materials that should be recognized as part of the proposed system.

System Design

There was strong consensus by the Board that the proposed statewide pesticide notification system needs to be refined and updated prior to public release and use because of the potential distribution of inaccurate and incomplete data. It is important for California to provide a “first in the nation” system that is respected by the public and agricultural community.

We need to get the system “right” before implementation.

The current system iteration does not account or reconcile that not every notice of intent (NOIs) equates to an application. Notifications are provided to users in multiple non-use scenarios, including, but not limited to:

• NOIs that are not acted upon for various reasons (i.e. weather)

• Multiple subscriber notifications for the same NOIs when farmers are delayed in application and new NOIs are needed

• NOIs that are modified or rejected

Further, primary integration of the County Agricultural Commissioner’s (CAC) system and SprayDays notification system is needed to provide a two-way feed of NOI information to further minimize inaccurate and incomplete information.

Guidance/Public Interest

Clear and established guidelines between DPR and CAC need to be established in regard to the permit process for restricted materials, specifically as it relates to appeals. With the implementation of a statewide notification system, the potential for increased appeals and holds of pesticide use associated with these appeals, can have significant impact on agricultural operations. Balancing local public interest on the reasons of review with the right of individuals to produce food for commercial sale is critical. The Board encourages

DPR to coordinate with the California Department of Food and Agriculture (CDFA) and CAC in developing enhanced guidance related to implementation of the statewide pesticide notification system.

Further, the economic impact associated to individual growers and CACs for increased public interest in pesticide applications (appeals, education, application times, holds) is not adequately quantified. Increased costs can negatively impact public services (CACs) and private entities (farm operations).

The Board appreciates the ongoing cooperation with DPR on this important issue. As emphasized, California needs to get the system “right” before implementation and have a system that is respected by the public and agricultural community. The consensus of the Board was to take the time needed to develop a notification system that is complete to avoid confusion with the public. DPR has made great strides in this process and continued engagement and collaboration with all stakeholders is encouraged as this process moves forward.

Thank you for the opportunity to comment.

Sincerely

Don Cameron

Dear Ms. Otani,

CropLife America (CLA) and Responsible Industry for a Sound Environment (RISE) would like to thank you for the opportunity to provide comments regarding the Department of Pesticide Regulations’ Notice of Modifications to Text of Propos...↓ed Changes in the Regulations Pertaining to Statewide Notification of Agricultural Use of Restricted Materials.

While we support the goal of transparency in pesticide regulation and believe that the public has a right to understand pesticide regulations, we have concerns about implementation of the Notices of Intent (NOIs) and the proposed changes to the information provided in these NOIs. Without proper context, NOIs are likely to be confusing to the public and will not add additional safety benefits. Detailed information about the pesticide's intended use, the targeted pest, and the precautions taken to minimize exposure are essential to understand the rationale behind the applications and to determine any potential risk from application. Without this information the NOIs, and the additional information proposed for inclusion in the NOIs, offer no information for the evaluation of risk from a specific pesticide application.

It is essential to recognize that there is a robust risk assessment process through the California Department of Pesticide Regulation and Federally under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). These processes evaluate the safety of pesticides when they are used according to the label instructions. The risk assessments ensure that pesticide products pose minimal risk to human health and the environment when used properly and consider safety precautions such as re-entry intervals, drift control, and other routes of exposure. It is also important to note that NOIs do not account for compliance with regulations or adherence to pesticide label instructions. The mere submission of an NOI does not infer that the pesticide application is unsafe; therefore, these types of notifications can lead to a fundamental misunderstanding by the public of their safety risk. Therefore, the focus should also be on ensuring strict compliance with existing regulations and label instructions.

Additionally, the publication of private information, which can be used to identify specific use sites should be absolutely avoided, as this could impede individual privacy and lead to the identification and targeting of growers and applicators during legal applications of restricted materials. Protecting the privacy of individuals and businesses is crucial to avoid any potential misuse of this information which if abused could lead to not only physical threats to growers and applicators, but creates additional opportunities for unnecessary appeals, leading to crop loss and potential liability.

We fundamentally support transparency, but greatly value the benefits from implementation of a robust pesticide safety education program for the public. Such a program should equip community members with the resources to understand the pesticide registration process and how mitigations on pesticide labels are designed to ensure safety. This education can help demystify pesticide use and reassure the public that rigorous safety standards are in place when the products are used in accordance with label instructions.

Furthermore, we suggest an exemption from the reporting requirements for certain pesticide formulations or application methods such as baits, granular products, or spot treatments. These products do not result in spray drift and generally have limited routes of exposure when used according to label instructions. Exempting these products would reduce the administrative burden and consider a scientifically motivated, risk-based approach.

In summary, we appreciate the efforts to enhance transparency and public awareness regarding pesticide applications and encourage efforts to educate on the safe use of registered pesticides; yet we are unclear how this notification system, including the proposed modifications to the notification system, will increase public health and safety. We recommend these proposed changes to the text for the notification regulation:

•Ensure that information provided in NOIs has the appropriate context for the public, the inclusion of active ingredients is not justified without a full explanation of pesticide regulation and robust risk assessment these products go through to obtain registration with both EPA and in California.

•Develop and promote a comprehensive pesticide safety education program for the public.

•Protect the safety and privacy of individuals by not publishing detailed information that could identify specific use sites.

•Focus on ensuring compliance with existing regulations and pesticide label instructions.

•Consider exemptions from reporting requirements for certain formulations, such as baits, granular products, and spot treatment applications due to their limited exposure risk from spray drift.

Thank you for the opportunity to comment on this important regulatory proposal. We look forward to the successful implementation of these regulations in a manner that balances public transparency, safety, and environmental protection.

Sincerely,

Megan J. Provost

President

RISE

4201 Wilson Blvd.

Arlington, VA 22203

202-872-3860

Alexandra Dunn

President and CEO

CropLife America

4201 Wilson Blvd.

Arlington, VA 22203

202-296-1585

RISE (Responsible Industry for a Sound Environment)® is the national trade association representing manufacturers, formulators, distributors, and other industry leaders engaged with specialty pesticides and fertilizers used by professionals and consumers. Learn more at www.pestfacts.org.

CropLife America (CLA) represents the manufacturers, formulators, and distributors of crop protection products in the United States. CLA member companies produce, sell, and distribute virtually all the crop protection products used by American farmers. Learn more at www.croplifeamerica.org.

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enf...↓orcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications. 

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

·        Notification should be limited to pesticide products that are already subject to Notices of Intent.

·        Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice. 

·        Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

·        Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety.

·        Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss. 

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed. 

Sincerely,

Dear Ms. Otani,

Merced County Farm Bureau is a non-profit, non-governmental, grassroots organization that advocates for farmers, ranchers and dairy families who live and work in Merced County. We represent approximately 1,000 members who have an activ...↓e concern for the proposal as presented. MCFB has been engaged on this topic since DPR released the tentative proposal. We appreciate the opportunity to provide feedback.

We are concerned with the notification system as proposed. We understand providing information to the public on acres, type of material and location may seem helpful, yet it will in turn increase the level of mistrust and fear amongst community members as they do not understand the precautions growers take nor the process the materials have been through to ensure their safety. This will ultimately increase the number of calls to the local Ag Commissioners office and delay treatment to the impacted crop, potentially resulting in entire crop loss.

We are also concerned with the area to which an individual can make a request for information. Providing information to individuals who do not live within the area encourages misuse of vital details. We have already incurred substantial issues in individuals trespassing on property and have growing concern that our members will be targeted for yet another reason. We encourage DPR to take proactive steps in protecting the details of growers as this is an evolving program that has yet to show success or how that will be measured.

We again appreciate the opportunity to comment on a matter that will change how growers operate. MCFB looks forward to continuing to engage on the topic and trusts that DPR takes all comments into consideration. Please reach out if there are any additional questions we can answer.

Sincerely,

Breanne Vandenberg

Executive Director

Aug 1st 2024

Dept. of Pesticide Regulation

1001 I Street, P.O. Box 4015

Sacramento, CA 95812-4015

Director Henderson,

Hello, my name is Laura Plascencia, and I am a resident of Stanislaus County and a community organizer with Valley Improvement Projects...↓, a local non-profit organization focused on social and environmental justice issues. We are very grateful for farmers efforts to grow our food and for the advancements in the statewide pesticide notification system and thank you all for your efforts in getting us to this point. California is leading these efforts for better transparency and accessibility regarding pesticide use, and we are proud of that. But we are not at the finish line, because we continue to hear our communitys needs for better protections.

The town of Grayson in our county participated in one of the beta tests. The community was able to test its use and see its benefits, including knowing what pesticides are being sprayed and when. However, as the community mentioned during the beta testing to provide the utmost protection, especially to the most marginalized communities who live, work, or go to school in areas surrounded by agricultural fields, knowing the exact location of pesticide applications is crucial. Not knowing this information places a large burden on these communities, leaving them at high risk of exposure.

Unfortunately, I vehemently disagree with your new pesticide notification system that does not contain the MOST important component, the exact location. I am deeply concerned that the system only provides partial information about the location of proposed pesticide use,describing a one-square-mile area rather than giving detailed information. If you live or work or your children attend a school surrounded by agricultural fields, if you are told everyday that within a square mile there was a pesticide application; how helpful would that information truly be, when you already know that you are surrounded by ag fields? It’s simply not just or helpful that adequate information is left out preventing effective proactive self protection.

The town of Grayson in Stanislaus County participated in one of the pilot tests. Participants voiced their need for an exact location for an effective system. To provide the utmost protection, especially to marginalized communities near agricultural fields, knowing the exact location of pesticide applications is crucial. Not knowing this information places a large burden on these communities, leaving them at high risk of exposure, impacting their health and their livelihood. Considering pesticides can and do drift with the wind, knowing exactly where they are coming from is crucial.

A one-square-mile radius notification does not provide sufficient information for the most impacted community members to take proactive measures to protect themselves. These measures include:

●    Adjusting schedules and walking routes

●    Ventilating and taking shelter, such as closing windows or moving indoors

●    Assessing wind drift and other environmental factors

Farmworkers, who are the most exposed, can take extra safety precautions and perform additional safety precautions if they know which fields have been sprayed. This aids in faster emergency preparedness in case of exposure to pesticide drift, which has been demonstrated by 2 recent school drift incidents in our community in the last two years.

Lastly, I am dissatisfied with the name “Spray Days.” These are restricted chemicals, many of which are carcinogenic, and the name downplays the severity and need for safety concerns. The term “days” misrepresents the year-round use of pesticides. I suggest renaming it to the "Pesticide Notification System" to better reflect the program and avoid confusion.

Additionally, I am happy to hear that DPR will be looking into integrating new languages into the system, making it more accessible for all community members. Looking forward to seeing that be represented based on demographics.

Many of my community members that live the closest to agricultural fields have experienced some level of pesticide drift, higher depending on proximity and wind patterns. Knowing exactly when and where pesticides will be used allows people to know exactly from where pesticides are coming given a specific wind pattern and understanding the directions. WIthout knowing exact location, one cannot make the correct important assessment of where drift could be coming from that in a way defeats the purpose of the program, when it is not protecting those most put at harm's way. Given the $10 M dollars invested in this program, it would be a shame to see it fail the people who are most at threat from this exposure. With that money you guys should be able to provide the information necessary for people to protect themselves.

Thank you for considering my concerns. I urge you to provide more precise information in the notification system to ensure the safety and well-being of our communities.

Sincerely,

Laura Plascencia

Dear Director Henderson,

The California Hispanic Chambers of Commerce is the leading Hispanic and ethnic business organization in the Nation. The CHCC and its network of over 125 chambers and associations represent the interest of California’s 815,000...↓ Hispanic-owned businesses. Through its advocacy, education, and empowerment programs, the CHCC brings California’s small business community’s issues and needs to the forefront of the California and National economic agendas.

We understand that local farmers throughout the state, ensure the pest notification practices currently in place are there to protect our community, workers, farms and the environment. We also know that in California the federal, state and local oversight of pesticide use enforcement is stricter and more regulated than anywhere in the United States.

Any new processes and regulations to the existing notification system will create anxiety and uncertainty for our farmers, workers and local residents. Developing unnecessary requirements will generate fear that the existing system is unsafe to farming communities. A disruption to the delicate agriculture timeline will likely damage farming operations resulting in a negative economic impact.

Feeding the world isn’t easy, and through the work of DPR and the local county Agricultural Commissioners the current system works for everyone and should not be overly regulated.

Sincerely,

Julian Canete

President & CEO

Dear Ms. Otani,

Stanislaus County Farm Bureau is a grass-roots organization dedicated to promoting and preserving agriculture in Stanislaus County. We represent nearly 1500 members who produce our food and fiber.

We would like to thank Director Henders...↓on and her staff for coming to Stanislaus County twice in 2023 to learn more about potential local impacts and solutions to the proposed rule. It is important to hear from those that will be directly affected because quite often the loudest voices come from people and organizations that have no stake in the implementation of new regulations. We hope that those visits were educational for all of the regulatory staff involved.

At the initial meeting with Director Henderson, we were asked what some of our reservations were and why there was a lack of grower participation. Many growers have been through these hearing exercises with the California Air Resources Board, local Air Pollution Control Districts, the State Water Resources Control Board, Regional Water Quality Control Boards, CalEPA and DPR in the past. While the intention is to get public input for the good of the program, agriculture has often felt that they are:

1) seen but not heard;

2) advocacy groups receive greater credence and

3) these are simply box-checking exercises where a pre-determined result and regulation framework is already in place.

We participated in one online hearing (Ventura) and one in-person hearing (Turlock). The online hearing in early 2023 was abominable. We encouraged our members to listen in. Following that hearing, and the way it was conducted and not controlled, we encouraged our members to stay away from this process. When a speaker is doxed while he is speaking, with his name, employer, phone number and employer address posted in the Chat Room and the participants encourage other participants to harass him and his employer, the process is seriously flawed. There was absolutely no control. We have heard that other hearings, such as in Tulare, had similar outcomes, only the participants were in-person. Fast forward to June 2024 and the Turlock hearing was very well organized and all participants were respectful and cordial. We appreciate the changes that DPR staff made to make it welcoming to growers and advocates alike.

Many of the comments addressed lack of training and their main focus, exact location. There are current rules in place for all of their concerns. The testing and continuing education of applicators for multi levels of licensing never stops. The use of the term “Spray Days” sounds very reminiscent of a term used in the Eastern US called “Farming Days” which are days that farmers can or cannot farm and work their ground. Growers do not necessarily have the ability to wait for a “Spray Day” in many situations. Weather conditions, such as moisture and wind speed, are taken into account with every application. It is conceivable that a crop could be lost while waiting for a “Spray Day.” Additionally, “Spray Days” isn’t a true reflection of pesticide applications, not all pesticides are applied via a spray, contributing to the continued misinformation to the public.

The proposed requirement to disclose additional details, such as product names, active ingredients, and acres treated, has been at the forefront of our concerns and opens the potential to identify individual growers before they apply restricted use materials. This identification could expose growers and farmworkers to targeted harassment, even when they comply with all regulations. The department addressed this concern during public hearings and explained there would be an evaluation of the system, and if excessive protesting and harassment occurred, the program would undergo substantial changes. While the NOI system is to receive a yearly evaluation and three-year report, there does not seem to be clear markers to identify whether the program is successful, only indicators that it is harming growers. For these reasons, we encourage DPR to protect the sensitive information of growers before the misuse of the notification occurs, not after.

Moreover, providing specific details and granting broad access to pending applications beyond a one-mile radius does not offer any tangible public or individual benefit. Instead, it creates unnecessary fear and confusion. We propose that the information disclosed should be limited to active ingredients, application date range, and relevant label information, without detailing the method of application, the acres treated or exact location.

Throughout this process we have been concerned with the lack of education provided by this proposed system. Providing only the label to the public requesting notification, is misleading. The label is written for hazards to the handler and fieldworker. The label does not provide guidance for persons living within a mile of an application. Does this guidance, based on science, even exist? Additionally, pesticide application does not equal pesticide exposure. California has the most rigorous pesticide use enforcement requirements in the world. In listening to the comments at the public hearings, this has not been conveyed by DPR, and it completely misunderstood by community members.

Last year, DPR staff attended and spoke at our local Spray Safe seminar. Each year we host nearly 200 farm workers for safety and regulatory training in conjunction with nearly 300 permit and license holders for DPR approved topics, current events and continuing education. Ironically, some of the organizations and individuals that spoke at the Turlock hearing in favor of “Exact Location” have been invited to the last two Spray Safe events (2022 & 2023) and chosen not to attend. This adds to our frustration of claims of ‘untrained farm workers’ and ‘spraying around schools.’ Each year we train farm workers and each year growers are reminded of when and where they can apply near schools. A spray permit is not taken for granted because it is necessary education and husbandry practice for a grower to remain in business. Perhaps DPR grant funds for more ‘Spray Safe’ events is an opportunity to continually educate rather than regulate.

We ask that regulations be based on science and facts and not emotion. Many of the proposals with this rule are already covered under current regulation. There is no need to add additional layers and costs when those mechanisms already exist.

We appreciate your consideration, and we look forward to the department addressing these recommendations and concerns in a subsequent public notice of modifications to the proposed regulation.

Sincerely,

Kelly Fogarty

Stanislaus County Farm Bureau President

Dear Ms. Otani,

The Sacramento County Farm Bureau is a grassroots membership organization focusing on preserving and protecting our agricultural economy and rural lifestyle since 1917. Area growers work hard to supply consumers with high quality produ...↓cts while battling such obstacles as increased production costs and water availability. As the earth’s original conservationists, farmers and ranchers have a keen interest in preserving our precious land for future generations. Farmers are concerned with natural resources, animal health, water, and air quality, among other imperative topics. Farm Bureau’s voluntary elected leaders and professional staff work hard for all Californians to ensure the rural economy’s growth, to protect the family farm, and to maintain the priceless natural resources that are so important to this state’s vitality and lifestyle.

The Sacramento County Farm Bureau is concerned with the long-term repercussions to this NOI system, as releasing personal information to the public is likely to result in a surge of unfounded appeals against NOIs, delaying essential pesticide applications. This delay can cause significant crop loss, further pest outbreaks, increased legal reviews, and slower response times from DPR. The provisions allow any individual to appeal against an NOI which heightens the likelihood of these negative outcomes. Excessive appeals, as well as many other complications, will be addressed by the County Agricultural Commissioner first, and will impose an undue administrative burden at our local level. The proposed regulations will require the County Ag Commissioner’s office staff to allocate more time on in-office permit reviews, pesticide use report entries, the 24-hour deadline to submit reports once received, and an increase in public record requests. Restricted Materials Permit reviews would require more licensed staff and would take inspectors out of the field to conduct this work that they normally do not do. The importance of the current pesticide use enforcement program is in the field time of enforcing current regulations, educating applicators and pesticide handlers, and helping to ensure the safe and effective use of legal, registered pesticides. Increasing the County Ag Commissioner’s office workload with paperwork that requires quick turnaround times, is not going to strengthen the program. The intent to notify nearby community members so that they can make decisions on where they want to be when a pesticide is being applied is their personal decision, but they should not be able to appeal prior to an application. The growers who are applying the pesticide have already gone through extensive training, consultation with a PCA, and have followed all regulatory requirements in order to apply a pesticide at a particular point in time on a particular crop. It is a process that includes prior analysis and reporting, not a random decision. If a grower does not go through this proper protocol, the enforcement component of the County Ag Commissioner’s department is the appropriate process to investigate and correct violations of use. This system is already working well. If the public has issues with an application that they think was incorrectly applied, then they are allowed to file a report. But to hinder an essential application based on fear that will cause larger issues is not a reason to create this overreaching system.

The proposed modifications also require DPR to consult with a specific set of groups; DPR Environmental Justice Advisory Committee and the State Board of Food and Agriculture. This review process does not fairly represent all stakeholder’s concerns and recommendations. DPR needs to include additional groups with relevant expertise, such as the Agricultural Pest Control Advisory Committee.

We appreciate your consideration, and we look forward to the department addressing these recommendations and concerns.

Sincerely,

Amber McDowell Executive Director

Dear Ms. Otani:

This coalition, representing a variety of agricultural stakeholders, appreciate this opportunity to comment on the Department of Pesticide Regulations’ (DPR) NOTICE OF MODIFICATIONS TO TEXT OF PROPOSED CHANGES IN THE REGULATIONS PERTAI...↓NING TO STATEWIDE NOTIFICATION OF AGRICULTURAL USE OF RESTRICTED MATERIALS, dated July 2, 2024.

This coalition generally supports the proposed modifications that provide clarity to growers regarding the required timeframes for submitting notice of intent (NOI) information to DPR depending on the type of pesticide being applied (e.g., fumigant pesticides applied to soil). We also support the proposed 30-day extension of the effective date of the proposed regulations to provide sufficient time for DPR to address potential “technological issues” with the electronic notification system, which seem likely given that the current version is untested at scale.

However, we are concerned that the additional information required by the proposed modifications moves the notification system one step closer to identification and targeting of individual growers prior to intended application of restricted use materials, regardless of whether those applications actually occur, and regardless of growers’ compliance with applicable regulations and permit conditions. While we appreciate that DPR may not intend for the system to be misused in this manner, it is important to recognize the potential for such misuse, which has been demonstrated in counties with similar systems, and DPR should be prepared to take any action that may be necessary to protect growers acting in good faith and operating within the confines of applicable statutory and regulatory requirements.

In particular, we believe the new requirement to disclose product names and active ingredients, coupled with information on the number of acres treated, allows those that would misuse the notification system to draw inferences regarding the exact location of the proposed application and by extension, the responsible grower. In the absence of context regarding mitigation measures required to protect potentially exposed individuals, and how those measures reduce potential health and ecological risks - especially risks associated with off-site exposures - this additional information could be used as the basis for organized efforts to obstruct legal applications of restricted materials. We remain concerned that such actions would place grower owners, employees, and members of the public at greater risk of harm, without providing any additional public health benefit. Beyond the potential for physical harm, misuse of the system to share personal information with the public will likely result in increased baseless appeals of NOIs, thereby postponing essential applications. This sequence of events may lead to significant crop loss, further pest outbreaks, more frequent legal reviews by DPR and slower response times. The provisions of AB 2113 (Garcia, Chapter 60, Statutes of 2024) that allow for any “interested person” to appeal an NOI will surely increase the probability of these outcomes. We also ask the Department to consider potential state liability for releasing sensitive personal information. For all of these reasons, we encourage DPR to resist pressure to continue down the path of requiring additional information that spotlights specific locations and growers.

We are also concerned about how DPR has framed the public engagement process regarding the potential need for notification system “improvements.” The proposed modifications specifically require that DPR consult with, and receive feedback from, the DPR Environmental Justice Advisory Committee and the State Board of Food and Agriculture on: 1) annual status updates of the system and the process of making information about intended applications available to the public, and changes to the current system and process, and 2) a comprehensive three-year report reviewing the entire system and process, “including improvements made to the system, over time.” These proposed changes inappropriately elevate the concerns and priorities of the identified stakeholders over all other stakeholders. We question the necessity of identifying these groups in the regulation, since they would have the same opportunity to participate in the system review process as any other stakeholder. Moreover, it is inappropriate to direct input from one subset of stakeholders intended for DPR through a separate agency (the California Department of Food and Agriculture) and a governing board made up of gubernatorial appointees. However, if DPR chooses to retain these specific consultation requirements, then it should expand the current

list to include other stakeholder groups with relevant experience and expertise, such as the Agricultural Pest Control Advisory Committee or the Office of Pesticide Consultation and Analysis.

Furthermore, these proposed changes appear to contemplate periodic course corrections within the three-year timeframe for system and process review, but there is no language in the proposed regulations describing the process for such periodic updates. We expect that any adjustments to the notification mechanisms, content, or process that depart in any way from the requirements in the final regulations would need to be implemented through subsequent amendments to the regulations, which would entail a formal rulemaking process. We ask that DPR confirm our interpretation in its responses to public comments on the proposed regulations and propose additional language in a 15-day notice describing the process for updating the regulations.

Finally, we would be remiss to not express concerns about the ongoing staff and financial resources that will be required at the state and local levels to implement the existing system, provide system updates, and respond to the aforementioned consultation requirements. We are of the strong opinion that additional and ongoing costs should be borne by the State General Fund through budget change proposals, rather than at the expense of DPR’s tax and fee payers. We would also caution that a public notification system of this scale, without proper context regarding how the public should interpret a notice, will likely be met with a hyperbolic public response. County Agricultural Commissioners will be the first point of contact for label interpretations, public inquiries and expressions of concern, and confusion about notification requirements and system functionality. The resources they will need to expend to respond to these, and other issues, will mean less resources for use enforcement, education, pest detection and community engagement.

We request that DPR address the above issues and recommendations in a subsequent public notice of modifications to the proposed regulation.

Sincerely,

Will Scott, Jr., President

African American Farmers of California

Emily Rooney, President

Agricultural Council of California

Blake Vann, Chair

Almond Alliance of California

Nicole Helms, Executive Director

California Alfalfa and Forage Association

Ruthann Anderson, President/CEO

California Association of Pest Control Advisers

Brooke Palmer, Executive Officer

California Association of Wheat Growers

Michael Miiller, Director of Government Relations

California Association of Winegrape Growers

Tyler Rood, Research Director

California Cherry Growers and Industry Association

Casey Creamer, President

California Citrus Mutual

Roger Isom, President/CEO

California Cotton Ginners and Growers Association

Western Agricultural Processors Association

Christopher Reardon, Director of Legislative Affairs

California Farm Bureau Federation

Daniel Hartwig, President

California Fresh Fruit Association

Debra Murdock, President

California Pear Growers Association

Donna Boggs, Associate Director

California Seed Association

Gary W. Van Sickle, Executive Director

California Specialty Crops Council

Rick Tomlinson, President

California Strawberry Commission

Mike Montna, President/CEO

California Tomato Growers Association

Robert Verloop, Executive Director/CEO

California Walnut Commission

Ann Quinn, Executive Vice President

California Warehouse Association

Christopher Valadez, President

Grower-Shipper Association of Central California

Manuel Cunha, Jr., President

Nisei Farmers League

Katie Swift, Chair

Rodenticide Task Force

Matthew Allen, Vice President, State Government Affairs

Western Growers Association

Dear Director Henderson:

The Tulare-Kings Hispanic Chamber of Commerce seeks to promote business development and growth of business within the Hispanic Community for the purpose of mutual economic benefit. Through its network of Hispanic chambers and ...↓business associations, the TKHCC represents the interest of over 10,000 Hispanic businesses around Tulare and Kings counties. Our membership benefits provide active and visible advocacy'. We support businesses, entrepreneurs, and individuals dedicated to the economic growth of the Central Valley.

We know that in California, the federal, state and local oversight of pesticide use enforcement is stricter and more regulated than anywhere else in the United States. We understand that local farmers throughout the state abide by the pest notification practices currently in place to protect our community, workers, farms and the environment

Any new processes and regulations to the existing notification system will create anxiety and uncertainty for our farmers, workers and local residents. Developing unnecessary requirements will generate fear that the existing system is unsafe to farming communities. A disruption to the delicate agriculture timeline will likely damage farming operations resulting in a negative economic impact.

Agriculture is such a large and necessary industry both in Tulare and Kings Counties. In California, Tulare County is the 2nd largest and Kings County is the 10th largest when it comes to agricultural production. The work by DPR, our local county Agricultural Commissioner and her staff, works for all and should not be over regulated.

Sincerely,

Rogelio Caudillo, Chair

The TKHCC Government Affairs Committee

Dear Julie Henderson,

On behalf of the Indigenous and migrant farmworking community, the Mixteco/Indigena Community Organizing Project (MICOP) serves in the California

Central Coast; we strongly support the effort to provide Californians with advance n...↓otice of hazardous pesticide use1. We urge you to ensure that the new regulation is as effective as possible to ensure that impacted residents can protect themselves from harm. The system must include the exact location of planned pesticide applications to be truly effective.

MICOP was established in 2001 to support, organize, and empower Ventura County’s 20,000 Indigenous immigrants; since then, it has grown to serve Santa Barbara County and San Luis Obispo County. MICOP is a preeminent organization addressing the unique needs of indigenous immigrants living in Ventura County. MICOP serves approximately 7,000 indigenous families in Ventura County annually. The Indigenous farmworkers population and community is overwhelmingly employed in the extremely difficult row crop agricultural sector, indigenous unwritten languages and limited literacy skills present tremendous barriers to access in the health, education, and social services sectors. The Mesoamerican Indigenous community is considered one of the

largest agriculture workforces in the state of California.

The UC Merced Farmworker Health Study assessed the health of Californian agricultural workers focused on the long-term health of agricultural workers, the ability to access high quality health care, and more. In terms of healthcare coverage and healthcare utilization, more than half (51%) of farmworkers did not have health insurance coverage. However, only 43% of farmworkers claimed they had visited a doctor's clinic within the past year. The study found that 62% of Indigenous Farmworkers in California do not have health coverage.

The lack of healthcare coverage, combined with the effects of pesticide exposure and inaccurate information regarding pesticide application, significantly increases the risk to our farmworking community and the general public. Applications near residential areas are particularly concerning and warrant additional precautions compared to those applied at a greater distance.

Eight out of the ten most commonly applied pesticides in Ventura County have significant health impacts on farmworkers. One of the most toxic pesticides,

Chloropicrin, classified as a restricted material, was applied to 1,849,170 pounds of Ventura County crops in 2016. Chloropicrin, originally used as a tear gas in WWI, is a potentially fatal fumigant. Its use today poses serious health risks, including neurodegeneration, and can reduce the life expectancy of farmworkers. Additionally, in 2010, 13,000 students in Ventura County attended classes within a quarter mile of areas heavily treated with potentially harmful pesticides2, more than in any other county in the state.

To further evidence the need for the exact location of pesticide applications, we present written testimony from 13 Indigenous leaders from MICOP’s Policy and Advocacy Department and Indigenous Health Committee, many of whom are farmworkers or former farmworkers still living and working in the fields of California. Their stories underscore the damaging effects of pesticides and the necessity for the DPR to provide precise locations of pesticide applications to ensure the safety, protection, and well-being of the community that sustains California's agriculture.

We respectfully request that the California Department of Pesticide Regulation (DPR) consider these public comments on the revised draft rule that will provide advance public notice of applications of the most hazardous pesticides and require the exact location of a pesticide application to be identified, rather than only providing identification within a square mile. People deserve the right to know what is being used near their homes, schools, and places of work.

If you have any questions, please contact me or our Executive Director, Arcenio J. Lopez at arcenio.lopez@mixteco.org.

Sincerely,

Vanessa Terán

Director of Policy

Mixteco/Indigena Community Organizing Project (MICOP)

1 https://www.cdpr.ca.gov/docs/legbills/rulepkgs/23-003/dpr_23-003_oal_text_modified.pdf

2 https://causenow.org/content/fields-toxic-pesticides-surround-schools-ventura-county%E2%80%94are-the

y-poisoning-students

To whom it may concern,

On behalf of P-R Farms, Inc., we write to express our opposition to the proposed Pesticide Notification System. CDPR and the County Ag Commissioners already have the most stringent pesticide control system in place and this pro...↓posal will not provide any more protections. In fact, we are concerned that CDPR will provide farm specific information which will allow anti-pesticide activists to oppose our applications. CDPR should not give in to activists and should instead actively defend the already protective system currently in place. What will CDPR do in case an application is appealed and delayed unnecessarily?

• We oppose the proposed pesticide notification system

• We oppose providing acreage information that could be used to identify the exact parcel where the pesticide is being applied

• CDPR needs to explain the pesticide registration process and how application rates, buffer zones, and allowed uses are determined to prevent exposure to workers, residents, and innocent bystanders.

• If CDPR moves forward, notification should be limited to only those who are immediately adjacent to the proposed application and not open to just anyone who so desires.

Thank you,

Patrick V. Ricchiuti

President

Director Julie Henderson,

Dear DPR Director Julie Henderson,

We strongly support the effort to provide Californians with advance notice of hazardous pesticide use. We urge you to make sure the new regulation is as effective as possible to ensure that i...↓mpacted residents can protect themselves from harm. To truly be effective, the system must include the exact location of planned pesticide applications.

Scientific research confirms that the public is in greater risk of harm the closer they are to a pesticide application. An application next to one's house is of even greater concern than an application a mile away and would require more precautions.

Greetings,

I am writing to support the implementation of a Pesticide Application Notification System in our communities throughout the state. This system is vital for ensuring the health and safety of our residents, environment, and local ecosystem.

I...↓ am deeply concerned about the current regulatory stance that prevents citizens from accessing detailed information about the exact locations of these pesticide applications. This lack of transparency undermines public trust and prevents residents from taking necessary precautions to protect their health and the environment.

The most affected people of pesticide poisonings are the families of those who to the work to feed our nation, and they are often the most underserved and disregarded. I know Safe Ag Safe Schools has been advocating and lobbying for this basic protection for well over a decade, and are no closer to resolution. They deserve protections and they deserve justice. Please wait no longer and implement a pesticide application notification system with proper

buffers, ample notification, and exact locations of applications.

Thank You,

Colleen Ingram (she, her)

“On Earth, everyone loved butterflies, but I trusted

the caterpillars more. I trusted the ones who knew

they were not done growing.”

-Andrea Gibson

I am the President of Tulare LULAC council, and I am writing to express my support. The public notification system must include the exact location of the pesticide application. This is a public health priority. The community must have the necessary t...↓ools to protect itself and make critical decisions for their families. Not providing the exact location to farmers is not beneficial. The government must be open and transparent, especially when spraying dangerous chemicals.

Thank you,

Hello,

I am a resident of Hughson and living in the Central Valley has become a health struggle for my young family and I. I recently complained to the Ag. Commissioner about frequent chemical odor/drift and my 7 year old complaining of weakness and h...↓eadache after playing outside breifly during a span of 3 days with long hours of foliar spraying. The spraying would begin around 3am (while we're sleeping) and be heard and odor smelled outside until about 10 am. When I called to ask the Ag. Commissioner about finding out which chemicals are being used, they had no information. I was directed to a public database, where I found the information hasn't been updated since April. I took my son to the pediatrician who said they have no knowledge or testing of health effects and exposures of these unknown chemicals. I was directed to call Poison Control, who also stated they have no information about the unknown chemicals being sprayed at massive amounts in our area. I asked the Ag. Commissioner for information regarding the public notices that were going to be sent through text messages for residents nearby, and I was told that program didn't go through because of lack of interest. I am very concerned with the amount and frequency of our exposures and health issues that can not be addressed after so many doctors visits. There are many research articles about these side effects, but as a resident, I feel helpless, especially as a mother of a child that is chronically unwell. Please do all you can to disclose the location and chemicals being used nearby our precious residents prior to spraying so we all have the opportunity to learn about these chemicals and avoid them when necessary.

Thank you!

Mandie Spinelli

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enf...↓orcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications. 

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

·        Notification should be limited to pesticide products that are already subject to Notices of Intent.

·        Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice. 

·        Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

·        Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety.

·        Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss. 

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed. 

Sincerely,

Matthew Caviglia, California Citrus Grower

Dear Director Henderson:

As a member of the agricultural community, the California Fresh Fruit Association (CFFA) has confidence in the federal, state, and local oversight of pesticide use enforcement to robustly protect communities and the environmen...↓t in California. Rules and regulations have been developed and improved over decades in our state. Therefore, statewide notification is not necessary in anticipation of pesticide applications.

Should the Department of Pesticide Regulation continue to move forward with this project, CFFA asks the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.
• Timeframes to submit Notices of Intent (NOI) to County Agricultural Commissioners should remain as they are in current practice.
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).
• Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to the safety of growers, applicators, and employees.
• Because of the high probability that advanced notice will trigger appeals of NOIs, stall otherwise safe applications by properly certified applications, and interfere with timely agricultural operations, the Department should prepare for these administrative burdens, particularly on counties, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, CFFA encourages the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Adam Borchard

Director of Government and Public Policy

California Fresh Fruit Association

Dear Director Henderson:

We are writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, we work hard to ensure our pest management practices protect my com...↓munity, my farm and the environment. We have confidence in the federal, state and local oversight of pesticide use enforcement. Considering these rules and regulations, we do not believe that statewide notification is necessary in anticipation of pesticide applications.

California already has the most comprehensive notification regarding pesticide applications in the country. Along with adherence to federal pesticide regulations, California's agency CalEPA has created unparalleled pesticide regulatory programs, including the requirement for local permitting authorities to review pesticide application requests. In addition to local authority oversight of pesticide applications, each application request must be recommended by a state licensed pesticide control advisor. The state pesticide regulatory program offers the public the ability to appeal a permit decision with local authorities. All pesticide applications are recorded by DPR and are available to the public. With DPR's current communication methods and information accessibility for the public, the pesticide notification system is duplicative and not necessary.

If this system is implemented, we encourage DPR to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Betty Rodriguez

Royal Oaks Farms LLC

Rancho Royal Oaks LLC

Dear Director Henderson:

We are writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, we work hard to ensure our pest management practices protect my com...↓munity, my farm and the environment. We have confidence in the federal, state and local oversight of pesticide use enforcement. Considering these rules and regulations, we do not believe that statewide notification is necessary in anticipation of pesticide applications.

California already has the most comprehensive notification regarding pesticide applications in the country. Along with adherence to federal pesticide regulations, California's agency CalEPA has created unparalleled pesticide regulatory programs, including the requirement for local permitting authorities to review pesticide application requests. In addition to local authority oversight of pesticide applications, each application request must be recommended by a state licensed pesticide control advisor. The state pesticide regulatory program offers the public the ability to appeal a permit decision with local authorities. All pesticide applications are recorded by DPR and are available to the public. With DPR's current communication methods and information accessibility for the public, the pesticide notification system is duplicative and not necessary.

If this system is implemented we encourage DPR to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Felipe Villalobos

Royal Oaks Farms LLC

Rancho Royal Oaks LLC

August 1, 2024

Ms. Julie Henderson, Director

Department of Pesticide Regulation

1001 I Street

P.O. Box 4015

Sacramento, California 95812-4015

dpr23003@cdpr.ca.gov

RE:    DPR 23-003 Statewide Notification of Agricultural Use of Restricted Materials

Dear...↓ Director Henderson:

Thank you for this opportunity to provide comments regarding the proposed DPR Statewide Notification System. As a member of the agricultural community, my first priority is to ensure my pest management practices protect my community, farms, and the environment. As a person who grew up on a farm and has worked in agriculture my entire life, including nearly 20 years as a licensed agricultural Pest Control Adviser, safety is and should be the top priority. I take pride in the fact that the countless pesticide applications I have recommended and/or supervised have been done so safely. It is important to me that all those involved in application, as well as the nearby communities are not harmed. It has been my experience that when applications are made according to DPR laws and label restrictions, we are able to protect our crops without causing harm to anybody.

While I recognize that the legislature has directed DPR to implement a notification program, I ask that you continue to consider the safeguards already built into the regulation of pesticides while developing this program. As DPR has stated itself in its recent public hearings, prior to the approval of any pesticide, products are thoroughly evaluated for human health and environmental safety, and in consultation with other agencies, safety mitigations are established and enforced.  

With this in mind, I ask the Department to consider the following:

• Notification should continue to be limited to pesticide products that are already subject to Notices of Intent
• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as originally proposed of 24 hours.
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and spatial geographical location (base, meridian, township, range, and section)
• Personally identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety

Thank you for your consideration of my comments.

Sincerely,

Nick Cooper

Dear Director Julie Henderson,

I am writing to you today as a community member to ask you to strengthen the draft regulation for a statewide pesticide notification system to include the exact location of planned pesticide applications, and a process f...↓or ensuring that the regulation will be revised in response to community feedback.

I fully support DPR’s precedent-setting proposal to provide Californians with the basic right to know about planned use of toxic chemicals in our neighborhoods, but there is still more work to do.

I urge DPR to include the exact location of applications of restricted material pesticides, and to commit to establishing and convening an annual community advisory panel, composed of impacted community members tasked with making enforceable recommendations for improvements to the program.

Thank you for taking this step toward transparency in agriculture.

Sincerely,

Rachelle Panganiban

To whom it may concern,

On behalf of Baggie Farms, we write to express our opposition to the proposed Pesticide Notification System. CDPR and the County Ag Commissioners already have the most stringent pesticide control system in place and this propos...↓al will not provide any more protections. In fact, we are concerned that CDPR will provide farm specific information which will allow anti-pesticide activists to oppose our applications. CDPR should not give in to activists and should instead

actively defend the already protective system currently in place. What will CDPR do in case an application is appealed and delayed unnecessarily?

• We oppose the proposed pesticide notification system
• We oppose providing acreage information that could be used to identify, the exact parcel where the pesticide is being applied
• CDPR needs to explain the pesticide registration process and how application rates, buffer zones, and allowed uses are determined to prevent exposure to workers, residents, and innocent bystanders.
• If CDPR moves forward, notification should be limited to only those who are immediately adjacent to the proposed application and not open to just anyone who so desires.

Thank you,

Mitch Bagdasarian

Dear Director Henderson

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enfor...↓cement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.
• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).
• Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety.
• Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

David Mabs

Patterson Enterprises, LP

To whom it may concern @ DPR,

It is with great sadness to say that my father died due to pesticides he worked in the fields and while working in the fields pesticides were being sprayed by plains over the field workers heads feeling the mist of pestic...↓ides while the plains were spraying pesticides plus other times going into fields in less than half hour of fields being sprayed. When Drs. diagnosed our family that Dad had Cancer we asked Dr. Gish if this could be due to pesticides that were being sprayed in the fields. Dr. Gish response was possible but it would be hard to beat the system. My dad passed in 1989.

I am now caring for a dear friend of mine that has been diagnosed with breast cancer and sad to say one of her breast has been removed due to the cancer. She has been given 3 weeks + of life. She is in her last days of her life I asked the same question to her Dr. can this be due to pesticides I got the same response as I did for my Dad. My dear friend worked in the grapes and many other farm working fields.

Please, please find it in your heart ♥ that PESTICIDES is killing to many lives. I am begging you in order to save Lives we need the exact location where PESTICIDES are being sprayed.

Enough with all this deaths due to PESTICIDES.

My nights are sleeplessness because I don’t know when my friend will take her last breath all because of this STUPID PESTICIDES!

Asking ’ers for her.

Thank you,

Beatriz V. Diaz

Dear Director Henderson:

We are writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, we work hard to ensure our pest management practices protect my com...↓munity, my farm and the environment. We have confidence in the federal, state and local oversight of pesticide use enforcement. Considering these rules and regulations, we do not believe that statewide notification is necessary in anticipation of pesticide applications.

California already has the most comprehensive notification regarding pesticide applications in the country. Along with adherence to federal pesticide regulations, California's agency CalEPA has created unparalleled pesticide regulatory programs, including the requirement for local permitting authorities to review pesticide application requests. In addition to local authority oversight of pesticide applications, each application request must be recommended by a state licensed pesticide control advisor. The state pesticide regulatory program offers the public the ability to appeal a permit decision with local authorities. All pesticide applications are recorded by DPR and are available to the public. With DPR's current communication methods and information accessibility for the public, the pesticide notification system is duplicative and not necessary.

If this system is implemented, we encourage DPR to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

CJ Miller

Royal Oaks Farms LLC

Rancho Royal Oaks LLC

Director Julie Henderson,

Dear DPR Director Julie Henderson,

We strongly support the effort to provide Californians with advance notice of hazardous pesticide use. We urge you to make sure the new regulation is as effective as possible to ensure that i...↓mpacted residents can protect themselves from harm. To truly be effective, the system must include the exact location of planned pesticide applications.

Scientific research confirms that the public is in greater risk of harm the closer they are to a pesticide application. An application next to one’s house is of even greater concern than an application a mile away and would require more precautions.

Also, most of the impact community are illiterate, the system of notification of application of pesticides needs to accessible in indigenous languages such as Mixteco, Zapoteco, Purépecha, and Spanish in audio or text to speech (TTS).

Sincerely,

Juan Carlos Diaz

Community Advocate with MICOP

Juan Carlos Diaz

Dear Director Henderson:

Thank you for this opportunity to provide comments regarding the proposed DPR Statewide Notification System. As a member of the agricultural community, my first priority is to ensure my pest management practices protect my com...↓munity, farms, and the environment. My name is Cole Silva and I have been a part of this industry for 12 years now. I have always taken tremendous pride in protecting anyone and everyone when spraying pesticides. I always stay current with my educational requirements. I do not take this responsibility lightly.

While I recognize that the legislature has directed DPR to implement a notification program, I ask that you continue to consider the safeguards already built into the regulation of pesticides while developing this program. As DPR has stated itself in its recent public hearings, prior to the approval of any pesticide, products are thoroughly evaluated for human health and environmental safety, and in consultation with other agencies, safety mitigations are established

and enforced.

With this in mind, I ask the Department to consider the following:

• Notification should continue to be limited to pesticide products that are already subject to Notices of Intent

• Timeframes to submit Notices of lntent to County Agricultural Commissioners should remain as originally proposed of 24 hours.

• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and spatial geographical location (base, meridian, township, range, and section)

• Personally identifying information, such as acreage treated or exact location, should not be included- this is critical to grower, applicator and employee safety

Thank you for your consideration of my comments.

Sincerely,

[signature]

Dear Director Henderson,

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enfo...↓rcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.
• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).
• Personal identifying information, such as acreage treated or exact location, should not be included--this is critical to grower, applicator and employee safety.
• Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

[signature]

Ms. Julie Henderson, Director

Department of Pesticide Regulation

1001 I Street

P.O. Box 4015

Sacramento, California 95812-4015

dpr23003@cdpr.ca.gov

RE: DPR 23-003 Statewide Notification of Agricultural Use of Restricted Materials

Dear Director Henderson:

Tha...↓nk you for this opportunity to provide comments regarding the proposed DPR Statewide Notification System. As a member of the agricultural community, my first priority is to ensure my pest management practices protect my community, farms, and the environment.

While I recognize that the legislature has directed DPR to implement a notification program, I ask that you continue to consider the safeguards already built into the regulation of pesticides while developing this program. As DPR has stated itself in its recent public hearings, prior to the approval of any pesticide, products are thoroughly evaluated for human health and environmental safety, and in consultation with other agencies, safety mitigations are established and enforced.

With this in mind, I ask the Department to consider the following:

• Notification should continue to be limited to pesticide products that are already subject to Notices of Intent

• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as originally proposed of 24 hours.

• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and spatial geographical location (base, meridian, township, range, and section)

• Personally identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee

safety

Thank you for your consideration of my comments. I appreciate DPR engaging with agricultural stakeholders and encourage you to continue to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Chelsea Dirks

CAD Farms LLC

Ms. Julie Henderson, Director

Department of Pesticide Regulation

1001 I Street

P.O. Box 4015

Sacramento, California 95812-4015

dpr23003@cdpr.ca.gov

RE: DPR 23-003 Statewide Notification of Agricultural Use of Restricted Materials

Dear Director Henderson:

Tha...↓nk you for this opportunity to provide comments regarding the proposed DPR Statewide Notification System. As a member of the agricultural community, my priority is to ensure my pest management practices protect my community, farms, and the environment. I have been a PCA/Agronomist since 1984 in both Sacramento and San Joaquin valleys.

While I recognize that the legislature has directed DPR to implement a notification program, I ask that you continue to consider the safeguards already built into the regulation of pesticides while developing this program. As DPR has stated itself in its recent public hearings, prior to the approval of any pesticide, products are thoroughly evaluated for human health and environmental safety, and in consultation with other agencies, safety mitigations are established and enforced.

I ask the Department to consider the following:

• Notification should continue to be limited to pesticide products that are already subject to Notices of Intent
• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as originally proposed of 24 hours.
• Public notifications should only include product applied, intended date and time of application, and spatial geographical location (base, meridian, township, range, and section)
• Personally, identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety

Thank you for your consideration of my comments.

Sincerely,

David P. McEuen

Hanford CA

To whom it may concern,

On behalf of Markarian Family LP we write to express our opposition to the proposed Pesticide Notification System. CDPR and the County Ag Commissioners already have the most stringent pesticide control system in place and this ...↓proposal will not provide any more protections. In fact, we are concerned that CDPR will provide farm specific information which will allow anti-pesticide activists to oppose our applications. CDPR should not give in to activists and should

instead actively defend the already protective system currently in place. What will CDPR do in case an application is appealed and delayed unnecessarily? •

• We oppose the proposed pesticide notification system

• We oppose providing acreage information that could be used to identify the exact parcel where the pesticide is being applied

• CDPR needs to explain the pesticide registration process and how application rates, buffer zones, and allowed uses are determined to prevent exposure to workers, residents, and innocent bystanders.

• If CDPR moves forward, notification should be limited to only those who are immediately adjacent to the proposed application and not open to just anyone who so desires.

Sincerely,

Robert Markarian, Owner

Markarian Family LP

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal , state and local oversight of pesticide use enf...↓orcement. Considering these rules and regulations, I do not believe that statewide

notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of lntent.

• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.

• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

• Personal identifying information, such as acreage treated or exact location, should not be included--this is critical to grower, applicator and employee safety.

• Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the .Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Dear Director Henderson:

As a member of the citrus ag community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enforc...↓ement. I participated in the trial run of this and was floored that I received no notices at all. I do not think what they have now is ready for roll out. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications. 

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

           •          Notification should be limited to pesticide products that are already subject to Notices of Intent.

           •          Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice. 

           •          Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

           •          Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety. Sharing detailed information allows radical groups to target in a very aggressive and inappropriate way specific producers. 

           •          Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss. 

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed. 

Sincerely,

Julia Inestroza

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. l have confidence in the federal, state and local oversight of pesticide use enfo...↓rcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.

• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.

• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

• Personal identifying information, such as acreage treated or exact location, should not be included-this is critical to grower, applicator and employee safety.

• Because advanced notice is highly likely to trigger appeals of NOls and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Mark E. Golden

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enfo...↓rcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.

• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.

• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

• Personal identifying information, such as acreage treated or exact location, should not be included-this is critical to grower, applicator and employee safety.

• Because advanced notice is highly likely to trigger appeals of NOls and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Nancy B. Lange, farmer

Dear Director Henderson:

As a small family farmer in an area where agriculture overlaps with residential areas I am fully aware of the publics concern about chemicals, machinery and labor used in agriculture. We all work to ensure our pest management...↓ practices protect crops, employees and family. I have confidence in the federal, state and local oversight of pesticide use enforcement which should continue to be based on science. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications. 

Will we also need to notify the public when we move trash bins, porta-potties and other equipment that can potentially pose a hazard to neighbors? More often than not on trash day there is a dispersion of insects and rodents that undoubtedly pose hazards to neighbors as well. Notification should continue to be based toxicity data (science!).

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

·        Notification should be limited to pesticide products that are already subject to Notices of Intent.

·        Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice. 

·        Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

·        Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety.

·        Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss. 

·        All of these notices is an extreme burden on tax payers and our agricultural commissioners offices. 

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed. 

Sincerely,

Emily Ayala

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enfo...↓rcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.
• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).
• Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety.
• Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Very truly yours,

John B. Lamb, President

Camlam Farms, Inc.

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have confidence in the federal, state and local oversight of pesticide use enfo...↓rcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.

• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.

• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).

• Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety.

• Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Scott Reynolds / Reynolds Ranches Inc.

Dear Ms. Otani:

The California Strawberry Commission (CSC) appreciates this opportunity to comment on the Department of Pesticide Regulations’ (DPR) NOTICE OF MODIFICATIONS TO TEXT OF PROPOSED CHANGES IN THE REGULATIONS PERTAINING TO STATEWIDE NOTIFIC...↓ATION OF AGRICULTURAL USE OF RESTRICTED MATERIALS, dated July 2, 2024.

The Commission represents all of California’s strawberry farmers, shippers, and processors. The California strawberry industry has a long history of safe use of pest management tools focusing on protecting workers, the public, food safety, and the environment. Throughout the development of the statewide notification system, we have actively participated by providing feedback during public comment periods to share the concerns of our members. We ask that in finalizing this regulation, DPR consider the following key concerns that have been voiced by members of the public and the regulated community:

• Unnecessary duplication: Redundancy of the notification system with currently existing notification processes takes resources away from other necessary areas of pesticide regulation, such as registration, re-evaluation, and enforcement.

• Lack of consistency: This proposed notification system only applies to agricultural pesticide applications, which are only a portion of the state’s pesticide applications, and completely ignores structural pesticide use.

• Fails to achieve intended outcome: As the system is currently designed, the notifications create confusion and panic for notification recipients as the notices do not explain the purpose of the notification as it pertains to protection of their health and safety. Furthermore, the notifications do not indicate what steps or actions the public would need to take after receiving a notification.

• Erosion of trust: The system reinforces the public’s mistrust of safe and regulated pest management by implying the need for a notification to prompt the public to take measures to protect their health and safety. As designed, the system creates confusion regarding the safety of the pesticides that DPR evaluates and registers. This undermines DPR’s scientific review and authority, as well as the effectiveness of DPR’s certification and training program for pesticide applicators.

The Sustainable Pest Management (SPM) roadmap highlights DPR’s response to the public’s request for more transparency on how DPR is protecting human health and the environment. As such, in addition to adoption of new technologies and novel communication methods such as the notification system, DPR should communicate its longstanding efforts, expertise, and sound scientific decisions regarding pesticide use, including the additional layers of safety and protection CalEPA places on U.S. EPA regulations.

We believe the new requirement to disclose product names and active ingredients, coupled with information on the number of acres treated, allows those that would misuse the notification system to draw inferences regarding the exact location of the proposed application and by extension, the responsible grower. In the absence of context regarding mitigation measures required to protect potentially exposed individuals, and how those measures reduce potential health and ecological risks - especially risks associated with off-site exposures - this additional information could be used as the basis for organized efforts to obstruct legal applications of restricted materials. We remain concerned that such actions would place grower owners, employees, and members of the public at greater risk of harm, without providing any additional public health benefit. This sequence of events may lead to significant crop loss, further pest outbreaks, and more frequent legal reviews by DPR resulting in delays for needed applications. We also ask the Department to consider potential state liability for releasing sensitive personal information.

We are concerned about the substantial ongoing costs to state and local agencies for implementing, maintaining, and supporting the proposed system. These costs should be covered by the State General Fund, not by DPR taxpayers. Additionally, a public notification system without clear guidance is likely to cause unnecessary alarm. County Agricultural Commissioners, already overburdened, will be inundated with public inquiries, straining their ability to focus on essential tasks like enforcement, education, pest control, and community outreach. We request that DPR address the above issues and recommendations in a subsequent public notice of modifications to the proposed regulation.

Sincerely,

Mark Martinez, Vice President of Public Policy

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my farm and the environment. I have been a licensed Pest Control Adviser as well as a Qualified Applicator for...↓ over 25 years now. I have confidence in the federal, state and local oversight of pesticide use enforcement. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications.

Should the Department continue to move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.
• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).
• Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety.
• Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.

As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Andrew Brown

AB Farming Co/A&A Ag Services

Dear Ms. Henderson,

On behalf of the over 180 tree nut hullers and processors of almonds, pecans, pistachios and walnuts that we represent, the Western Agricultural Processors Association (WAPA) wants to thank you for the opportunity to provide commen...↓ts on the California Department of Pesticide Regulation’s (CDPR) Statewide Pesticide Application Notification System. We remain deeply concerned with this proposal and the potential abuse of the system and overarching impact it may have on the agricultural industry’s ability to conduct its day-to-day business. We adamantly oppose this proposal as currently set forth, as we feel strongly that CDPR and EPA already have the necessary protections in the application of pesticides, and where necessary have already imposed notification requirements to those who might be impacted.

We believe CDPR has the most robust and restrictive pesticide use system in the United States, if not the world. There are numerous pesticides registered in the other 49 states, but not in California due to its more rigorous pesticide regulatory system, and higher more restrictive standards. Anyone can rest assured, pesticide applications in California are the most highly regulated applications in the country. This is especially true for restricted use pesticides. We must already file a Notice of Intent (NOI) with the county ag commissioner prior to any application of a restricted use pesticide. It must also be recognized the County Ag Commissioners throughout this state employ 500 inspectors and conduct more than 30,000 inspections each year of farms, ranches and other operations to make sure we are following CDPR’s pesticide regulations, pesticide label restrictions and worker protection standards. No one else in the world can take credit for such a protective system for pesticide applications.

CDPR is proposing to allow anyone who wants to be notified access to search for and/or be notified on any pesticide application where they can provide an address. We find this to be unwarranted, and frankly unjustified. If someone does not live at that address or is not impacted by the potential pesticide application within that area, what is the purpose of the notification? We are very concerned this proposal will be a mechanism used to disrupt, possibly even stop, pesticide applications. As evidenced by the pilot project in Monterey County, where more than 60% of the people signed up to receive notifications live outside of the state of California (far outside of any possible impact zone), and multiple pesticide applications have been temporarily stopped due to appeals by anti-pesticide activists, the notification system proposed by CDPR will ultimately cause statewide panic, and widespread delays in necessary pesticide applications. Without scientifically supported justification, we simply do not support unlimited notification.

CDPR is proposing to allow users to “anonymously” enter a valid address to access notifications. This is not acceptable in any way. As stated above, we believe this will allow anti-pesticide activists to access this information even when they are nowhere near the pesticide application or more importantly, impacted by the pesticide application. By providing this type of access, CDPR is setting up growers for unwarranted appeals and protests by activists, without justification or even any possible exposure to the pesticide application. For that reason, we also adamantly oppose this provision. If a notification system is implemented it is imperative that it is strictly limited to only those actually and physically potentially subject to exposure.

In closing, we thank you for the opportunity to provide comments and urge you to give every consideration to the comments provided herein. Should you have any questions, please feel free to contact me at (559)455-9272 or via email at roger@agprocessors.org.

Sincerely,

Roger A. Isom

President/CEO

Dear Ms. Henderson,

On behalf of the over 300 cotton growers and 15 operating cotton gins in California, the California Cotton Ginners and Growers Association wants to thank you for the opportunity to provide comments on the California Department of P...↓esticide Regulation’s (CDPR) Statewide Pesticide Application Notification System. We are deeply concerned with this proposal and the potential abuse of the system and overarching impact it may have on the agricultural industry’s ability to conduct its day-to-day business. We adamantly oppose this proposal as currently set forth, as we feel strongly that CDPR and EPA have already built in the necessary protections in the application of pesticides, and where necessary have already imposed notification requirements to those who might be impacted.

We believe CDPR has the most robust and restrictive pesticide use system in the United States, if not the world. There are numerous pesticides registered in the other 49 states, but not in California due to its more rigorous pesticide regulatory system, and higher more restrictive standards. Anyone can rest assured, pesticide applications in California are the most highly regulated applications in the country. This is especially true for restricted use pesticides. We must already file a Notice of Intent (NOI) with the county ag commissioner prior to any application of a restricted use pesticide. It must also be recognized the County Ag Commissioners throughout this state employ 500 inspectors and conduct more than 30,000 inspections each year of farms, ranches and other operations to make sure we are following CDPR’s pesticide regulations, pesticide label restrictions and worker protection standards. No one else in the world can take credit for such a protective system for pesticide applications.

CDPR is proposing to allow anyone who wants to be notified access to search for and/or be notified on any pesticide application where they can provide an address. We find this to be unwarranted, and frankly unjustified. If someone does not live at that address or is not impacted by the potential pesticide application within that area, what is the purpose of the notification? We are very concerned this proposal will be a mechanism used to disrupt, possibly even stop, pesticide applications. As evidenced by the pilot project in Monterey County, where more than 60% of the people signed up to receive notifications live outside of the state of California (far outside of any possible impact zone), and multiple pesticide applications have been temporarily stopped due to appeals by anti-pesticide activists, the notification system proposed by CDPR will ultimately cause statewide panic, and widespread delays in necessary pesticide applications. Without scientifically supported justification, we simply do not support unlimited notification.

CDPR is proposing to allow users to “anonymously” enter a valid address to access notifications. This is not acceptable in any way. As stated above, we believe this will allow anti-pesticide activists to access this information even when they are nowhere near the pesticide application or more importantly, impacted by the pesticide application. By providing this type of access, CDPR is setting up growers for unwarranted appeals and protests by activists, without justification or even any possible exposure to the pesticide application. For that reason, we also adamantly oppose this provision. If a notification system is implemented it is imperative that it is strictly limited to only those actually and physically potentially subject to exposure.

In closing, we thank you for the opportunity to provide comments and urge you to give every consideration to the comments provided herein. Should you have any questions, please feel free to contact me at (559)252-0684 or via email at roger@ccgga.org.

Sincerely,

Roger A. Isom

President/CEO

July 31, 2024

Ms. Julie Henderson, Director

Department of Pesticide Regulation

1001 I Street

P.O. Box 4015

Sacramento, California 95812-4015

dpr23003@cdpr.ca.gov

RE: DPR 23-003 Statewide Notification of Agricultural Use of Restricted Materials

Dear Director ...↓Henderson:

Thank you for this opportunity to provide comments regarding the proposed DPR Statewide Notification System. As a member of the agricultural community, and as an employee-owner of an agriculture retail business, nothing is more important than to ensure our pest-management practices protect our community, farms, and the environment.

While I recognize that the legislature has directed DPR to implement a notification program, I ask that you continue to consider the safeguards already built into the regulation of pesticides while developing this program. As DPR has stated itself in its recent public hearings, prior to the approval of any pesticide, products are thoroughly evaluated for human health and environmental safety, and in consultation with other agencies, safety mitigations are

established and enforced.

With this in mind, I ask the Department to consider the following:

• Notification should continue to be limited to pesticide products that are already subject to Notices of Intent
• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as originally proposed of 24 hours
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and spatial geographical location (base, meridian, township, range, and section)
• Personally identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator and employee safety

Thank you for your consideration of my comments. I appreciate DPR engaging with agricultural stakeholders and encourage you to continue to engage early and often with the agricultural community to be sure that negative consequences are managed.

Sincerely,

Brian Lish

President/Chief Executive Officer

AG RX

Dear Ms. Henderson:

Re: DPR 23-003 Statewide Notification of Agricultural Use of Restricted Materials

(Modified Regulations) Proposal

The California Citrus Quality Council (CCQC) represents approximately 3,000 citrus growers and 80 packinghouses in Cali...↓fornia, who’s total farmgate value of production including oranges, lemons, mandarins and grapefruit in the 2022-23 marketing year was $2.2 billion. The California citrus industry employs over 21,000 people on a full-time basis. We appreciate the opportunity to comment on the California Department of Pesticide Regulations’ (CDPR) proposed modified regulations on statewide notifications for restricted use pesticides. We believe that the proposal needs to be refined before it is finalized.

It should be acknowledged by CDPR that current pesticide application requirements and agricultural practices including for example, spray drift label restrictions and the use of best management practices, already provide substantial protection to bystanders from potential pesticide residues. However, our industry is not opposed to consideration of other practical measures that could be implemented to provide an additional margin of safety to bystanders as

long as a grower and applicator’s ability to make pesticide applications in accordance with the law, are protected.

When considering the additional notification system, CCQC strongly recommends that the specific site where a pesticide application may be conducted is not identified. Any notification requirement to identify the application site should not be less than one mile from the application site. This limitation would protect growers and applicators from the type of harassment that they have already experienced when pesticide application sites are specifically identified.

The expressed intent of the notification system is to provide potential bystanders notice of applications so, if they choose, they can take additional steps to limit or avoid potential exposure. We would note that the substantial safety reviews by CDPR and the U.S. Environmental Protection Agency associated with evaluating the use of a chemical, already include requiring use restrictions to help assure that bystanders are adequately protected from potential exposures.

We support CDPR and EPA conducting these assessments and creating label requirements that reflect protecting the health of potential bystanders.

However, we know from previous experience that some members of the public intend to misuse the notification system, to identify growers or applicators for bullying and harassment with the intent of disrupting or stopping pesticide applications. Since the notification process will put growers and applicators at risk for this type of behavior, we strongly recommend that CDPR include a mechanism in the notification regulations to both protect the identities of the growers

and applicators to help minimize the potential for them to be harassed in their activities, as well as implement measures to discourage abuse such as establishing fines for disrupting lawful applications.

We appreciate this opportunity to comment on this important matter.

Sincerely yours,

James R. Cranney, Jr.

President

Dear Director Henderson and all concerned,

As a member of the production agricultural community for many years, I continue to work hard to ensure my pest management practices protect my community, my farm, and the environment. Considering the above no...↓ted rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications. The labeled uses of these products already provide the framework for effective use of the product ensuring the safety of the user, our neighbors, and the environment.

Should the Department continue to add even more bureaucracy and move forward with this project, I ask the Department to consider the following items:

• Notification should be limited to pesticide products that are already subject to Notices of Intent.
• Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice.
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location (base, meridian, township, range, and section).
• Personal identifying information, such as acreage treated or exact location, should not be included—this is critical to grower, applicator, and employee safety.
• Because advanced notice is highly likely to trigger appeals of NOIs and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare for extended liability for crop loss.
• As this system is implemented, I encourage the Department to engage early and often with the agricultural community to be sure that negative consequences are managed.

I apologize for using a template for this letter, but I am already so busy complying with regulations and my mother in the hospital, that this was the quickest way for me to be heard on this subject. I fully and strongly support the comments above.

Sincerely,

Jay Gillette

Gillette Citrus Inc.

Summit Farms Inc.

July 31, 2024

DPR: Attention Mr. Weller and Ms. Martinez:

Testimony Regarding the Pesticide Notification Plan

Thank you both for the outreach efforts and for ensuring that the voices of those most impacted have an opportunity to express the injustices p...↓resented in this plan.

As a representative deeply engaged in our community, I speak not only for myself but for countless others who labor tirelessly in the fields and live in the surrounding areas. These individuals are the backbone of our agricultural industry, and their health and well-being must be prioritized, even in the face of objections from the Mega Pesticide Industry and certain segments of the farming community.

Sincerely,

Anthony Noriega

Testimony on Pesticide Notification Plan

Hello, my name is Anthony Noriega, and I am a member of the League of United Latin American Citizens. We are deeply concerned about the ongoing use of harmful pesticides and their severe impact on our farmworkers and minority communities living near agricultural fields.

For years, advocates, farmworkers, and environmental justice groups have been urgently demanding a comprehensive statewide pesticide notification system. Our ultimate goal is to eliminate the use of dangerous pesticides in agriculture entirely. However, in the meantime, it is absolutely imperative that

communities are notified well in advance of any pesticide applications to protect their health and safety.

The Department of Pesticide Regulation (DPR) is developing an online notification system, which is a step forward. However, the current draft fails gravely by omitting a crucial detail: the exact location of pesticide applications. Providing only a vague area within a one-square mile radius is wholly inadequate. We demand precise information to safeguard ourselves and our families effectively from these hazardous chemicals.

For years, I labored alongside my family and fellow farmworkers, tirelessly harvesting tomatoes in San Jose.Firebaugh, Mendota, Gilroy, and various locations across the San Joaquin Valley. During those long days in the fields, we often witnessed crop-dusters spraying pesticides indiscriminately, sometimes mere

feet away from where we worked. The fact that we continue to face this hazardous practice in 2024 speaks volumes about the disregard for the safety and well-being of farmworkers who sustain our nation with their labor. It is an urgent call to action to prioritize the protection of those who literally put food on our tables.

We, you and I, have a responsibility to ensure that our Latino communities and farmworkers are protected from dangerous pesticides and chemicals. Without exact location details, we are left helpless in protecting our homes, our schools, and our work environments. The vague, broad information leaves us in a state of constant alarm and uncertainty, unable to take the necessary precautions to safeguard our health and wellbeing.

The pesticide industry continues to neglect the needs of the most vulnerable among us—farmworkers and low-income communities—who lack the means to protect themselves from these dangerous chemicals.

Growers, pesticide producers, and sellers are primarily driven by profit, prioritizing their financial interests over the health and safety of the very people who sustain our agricultural industry. Their relentless push to minimize regulatory safeguards and reject comprehensive notification measures is not just a lapse in

judgment; it is a blatant disregard for human life.

This industry’s persistent refusal to address the crucial issue of precise pesticide notification reveals a profound and troubling indifference to our well-being. It demonstrates a callous disregard for the families and communities at risk, whose lives and health are jeopardized by their actions. The industry's focus on

limiting protective measures while maximizing their profits highlights a systemic problem: they are willing to sacrifice the health of our communities for financial gain.

The lack of precise information in the current pesticide notification system poses a grave threat to our ability to safeguard our families and children. Without exact location details, we are left defenseless against the harmful effects of pesticide exposure. This omission endangers our most vulnerable members, including pregnant women, children, and individuals with pre-existing health conditions. They are at the highest risk and deserve full protection from these toxic chemicals.

LULAC strongly urge the Department of Pesticide Regulation (DPR) to mandate the inclusion of exact addresses for pesticide application sites in the notification system. The current one-mile radius standard is woefully inadequate and fails to provide the critical information needed to protect our communities effectively. It is imperative that the DPR prioritize health and safety over the interests of the pesticide industry. We must move beyond this outdated and insufficient notification measure.

It is time for DPR to make a decisive choice between life and death. We need an immediate shift towards transparency and rigorous safety standards to ensure that every Californian, especially our most vulnerable populations, is fully informed and protected. The health of our communities and future generations depends on this fundamental change.

Thank you for your attention to these urgent concerns and for the opportunity to voice them. Our collective well-being and the future of our communities are at stake.

Sincerely,

Anthony Noriega,

Director, District 5 LULAC de Inland Empire

Dear Director Julie Henderson,

Dear Director,

I am writing to you today to ask you to strengthen the draft regulation for a statewide pesticide notification system to include the exact location of planned pesticide applications, and a process for ensur...↓ing that the regulation will be revised in response to community feedback.

For many years now, residents of farmworking communities have been calling for advance warning of pesticide use near their homes and schools. The draft regulation represents a significant and welcome step toward transparency regarding chemical use by the agricultural industry.

However, a series of pilot notification projects in 2022 confirmed that, without exact location of planned applications, it is difficult to take steps to prevent exposure to pesticides. Your Department received extensive feedback from the pilots calling for detailed location information, but has refused to standardize the location information so that it can be provided to the public.

This regulatory process is the perfect opportunity to standardize this information. It?s impossible to justify designing a public health notification system that deliberately fails to disclose known location information. I ask you to revise the regulation to include the exact location of all pesticide applications included in the system.

Furthermore, DPR has repeatedly stated that the regulation represents a first step toward a robust notification system, and that the regulation will include a process for community feedback and improvement. However, the current draft includes only a report on the regulation by DPR staff after three years.

I ask you to honor your commitment to establishing a truly iterative process for the regulation, by establishing an annual community advisory panel and including a commitment to make needed changes to the regulation based on the panel?s feedback.

Thank you for taking this step toward transparency in agriculture.

Sincerely,

Sincerely,

Kali Krishnan

Email message:

I have critical concerns about the proposed NOI public system.

I believe in investing in safer pesticide products, and practices to safeguard growers, employees, and the public. But I also believe that California currently has the most t...↓ransparent pesticide regulatory system in the world. Currently, the public can inquire at any California Agricultural Commissioner’s office throughout California when a restricted use material will be applied in that respective county on any given day. The State and therefore the Department should feel confident in this system too.

I agree that it is very reasonable for notification to include active ingredients, permit and county number, application date range, and relevant label information but should not include, method of application, acres applied, or exact location. Farmers and applicators who would be subject to notification are reasonably concerned that applicator-specific information could be found by activists to motivate protest events, on-farm trespass, and could encourage significant appeals of NOIs, leading to possible crop loss, and pest outbreaks. If DPR cannot scientifically validate what health protective behavior should result following notification, and if there is no difference in health impacts between an immediate neighbor and one mile away, then the risk of identifying site of application is too great.

Therefore, we encourage the regulations not specify acreage covered as we do believe that though there is no inclusion of address, in rural areas specifically, applicator specific information can be found. We also encourage the Department to consider the complications that may arise for the Agricultural Commissioner's Office, who will be responsible for dealing with concerns from all stakeholder groups.

Name: Alexandria Vazquez

I want the exact location we want healthy babies, better health for our community, families, children, grandparents. Stop pesticides we want exact location.

Name: Danny Galbiso

I want the exact location Orosi town and across the...↓ road from palm school elementary

Name: Irma Arredondo

I want the exact location Because I do not want more children born with missing limbs. The pesticide is very harm to our children & elderly people & all communities in the whole San Joaquin Valley I lived that horible time when we the farmworkers were worked not even a peny to the ranchers and companies and still those kind of pesticide abuse, but we will stil lifting our voices

Name: Maria Fraire

I want the exact location

Name: Jocelyne Villegas

I want the exact location Because its to protect everybody Healthy Adults teens and little children including new born babies and babies still in the whomb. That's the Reason why we want the Exact Location so we can know when and where. Those harsh chemicals are dangerous for all of us Its harming our health and the air we breath outside therefore we want the Exact location.

Name: Emmanuel

I want the exact location For my family so they could be safe.

Name: Gloria Herrera

I want the exact location iT is sTill missing the most essenTial InformaTion that would help us thake precautions against pesticides harms! We want Notification Now! sTop making people get cancer, asma respiratory problems! Don't make money ove peoples health

Name: Jazmin Castellanos

STOP THE SECRECY I want the exact location For me is important to know the exact location of pesticide spray is because I have Astma and if I know if pesticide is being sprayed close to where I live or I'm going to be working I have time to prepare myself to be safe and not to have a crisis of asthma and to have my air purifier working inside my house. Or not to be outise. Not only the restricted materials all the pesticides notification