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

Name: Indiana Avarado

I want the exact location poro poder prolegernos de los pesticidas es necesario la ubicacion exacta paro poder evitar esa area

Name Yoivia Lopez Avaya

I want the exact location Por que no se debe ocoltar a la poblaccon la ubicacion...↓ donde se tivan pesticidas ya que debemos saber para proteger a nuestros seres queridas. No exisle notificacion sin ubicacion

Name: Cecilia Lopez

I want the exact location Vivo en la comunidad de Bakersfield soy madre de 3 hijos 2 de ellos tienen asma y 1 tiene prolemas con piel a dicional a esto soy trabjadora del campo y tengo 2 afecciones eronicas cuando estaba embarazada del mayor de mis hijos ya trabajaba en el campo y mis 3 hijos nacion muy prematures y el mayor tambien tiene autismo es poo eso que pido saber la locacion y fecha exacta para protegernos y no ester en esas areas

Name: Agustina Rodriguez

I want the exact location estoy Pidiendo la ubicacion exacta de donde se estan Aplicando pesticidas haci yo me puedo cuidar y a mi familia.

Name: Alexa Rojas Alvarado

I want the exact location Queremos Exact ubicasion hoora para estar infomada cuando Aplique cuando secstan Aplicando Pesticidas

Name: Miguel Rojas

I want the exact location queremos la ubicasion Exacta cuando se Apliquen los Pesticidas

Name: Flor y Alvarado G

I want the exact location Estoy Pidiendo Exacta ubicasion cuando se Aplique un Pesticidas Notificasion Exsacta haora haora ya es tiempo que nos escuchen y paren los pesticidas no mas enfermedades, muertes, enuenenamientos queremos una ubicasion exacta. gracias.

Name: Luz Castellanos

No solo los materiales restringidos todos son daninos

I want the exact location Para mi es importante el saber cuando se aplica el pesticida y el lugar exacto para saber cuando no salir y estar en o cerca del lugar para no poher en peligro mi salud yo tengo asma y cuando estoy cerca de los luga res donde se ha aplicado pesticida empiezan a toser y mis pulmones se empiezan a poner mal. Mi padre trabajo muchos anos de bracero aqui en Shafter, Delano, Macfarland y el morio de cancer. =(

Name: Juan Castellanos

I want the exact location Soy padre de familia y trabajador del campo mi esposa y mi hija tienen asma y para mi es campor tante saber la locacion exacta donde se aplica el pesticida es primordial para la salud de mi familia. Importante saber cualquier pesticida esprallado no solo los que no estan permitidos todos son daninos para la salud.

Name: Grettel Sanjuan

I want the exact location Estoy aqui para exigir la ubication de los campos cuando se fumigan pestisidas quiero que dejes de enuenas a la comunidad. Danos la ubication exacta de los campos donde se aplicaran los pesticidas! Tenemos derecho a saberio! DETEN EL SECRETISMO!

Name Mauricio Sanjuan

I want the exact location No es joslo que no halla clavidad no deben ocoltormo la ubicacion nuestra salud importe y usted estan all para protegernos

Name: Estela Escoto

I want the exact location Queremos la hubicacion exacta por que asi podemos salir con nuestros ninos y mascotas sin tener el riesgo de vepirar el aire contamindao con pesticidas

Name: Jose A Ojeda

I want the exact location Queremos la localicacion o es imporante poque no se sabe cuando o donde se ban a aplicar los fumigantes yo y mi familia vivimos fren a la orillo del campo y fren te esta tambien la escuela elementaria donde estudian mis hijos y en uno ocacion rosiarun a los ninos de la escuela, por los tardes salen las familias a caluinar y sin saber que tipol de fumigantes is sprayaron por eso a hora exisives notificaciones gracias

Name: Sandra Angel

I want the exact location Queremos la hubicacion exact asi Podemos deadir salir de nuestra casa sin el peligro de respirar contaminante de pesticida

Name: Eloisa Fernandez

I want the exact location Chaster Calif Estoy de acuerdo a que fumigen es lmuy nesesario para estar de a cuderdo muchos grasias

Name: Felipa Trujillo

I want the exact location Quiero informacion exacta porque atra de mi casa hay arboles de almendra y cuando fumigan huele muy feo y duele la cabeza y se. nos informan bien pies ese dea no salimas a canienar y no abrer ventanas y que las ninos no salgan a jugar. Gracias

Name: Luis Casablanca

I want the exact location Que no avisen que tipo de pesticida es porque nos mienten que es espray de agua y son pesticidas danionos Nombre del pesticida

Name: Javier Lopez

I want the exact location poner letrevospara saber que tipo de pesticida es por si hay personas corriendo al rededor del los campos

Name: Jose Leyva

I want the exact location Que paren de estar contaminando la tierra con quimicos porque afecta la salud de trabajoador y etijos

Name: Raquel Sanchez Leon

I want the exact location Por favor es urgente nos informen la locasiones exatas para saber como protejer mos y protejer a todos nuestros companeros de trabajo y tambien para protejer a nestros hijos y personas de la 3 edad porque lla sean perdido muchas vidas inocentes y tambien ai muchas perdidas de embarazos y sobre todas la madres trabajadoras del campo como lo perdi lla mas de 6 embarazos y tambien familiar s y cono cidas en la cuales son trabajadoras del campo y aparte en mi persona e sufrido emfermedades como cancer y mas emfermedades

Name: Yesenia Acosta

I want the exact location por que emosidas rosiado en horas que estemos agiendo nuestros de veres y nuestros hijos an ida ala escuela esta en media de los campos

Name: Veronica Garcia

I want the exact location que senos notifique donde estan esprayando por el vienestar mio mi familia y mi comunidad.

Name: Emilio Sarmina

I want the exact location tienen abisar lugar donda ban o esprayar o fumigar y que close de quimicar si es peligroso ono depende de la quimica que es

Name: Felipe Perez

I want the exact location Los pesticidas mos matan lentamiente y eso si lo sumamos a las altas temperaturas es como encerarnos en camoras de gases como lo hacien los naciz

Name: Nestor Perez

I want the exact location cuando fumigan el algodón para secarlo es un problema de salud gi lo sentimos directamente en nuestro cuerpo

Name: Irene Gomez

I want the exact location estoy aqui para abogar en nombre de mi comunidad Nyeland Acres viace 2 anos en un comunidad seluplemento un Proyecto piloto como prueba y no funciono porque no incluyo la ubicacion exacta pero are pregunto cuando el DPR hara su trabajo

Name: Eulalia Mendoza

I want the exact location quiero la ubicacion exacta ya que como campesina he estado espuesta al quimico durante los 22 ano que trabaje en los campo Agricola donde nunca supe que podia hacer una denucia por que no si el idioma pero tamporo puedo dejar de trabar, por eso estoy aqui Exigiento la ubicacion exacta para poder cuidarme a mi y a mis nietos muchas Gracia

Name Berllio

I want the exact location ovicasio es iportante para cualquer ser umono

Name: Ofelia Ochos

I want the exact location es super importante la notificasion exsacta por que es el futuro de toda mivida y de mi familia para prebenir danos irebicibles por favor de ten er conciensia y ser mas bunerables de las vidas de los de mas y si sepuede gracias

Name: Carlola

I want the exact location poro mi y poro mi familia es muy inportante sober el dia y la noro que se ba a esprollora el ful o ohisor un dia ante poro no esponeme

Name: Julia Lopez

I want the exact location es importante tener la ubicacion exacta para evitar danos en mi persona y en mi familia de bido also pesticidas

Name: Estefhana Villalobos Ochoa

I want the exact location para evitar enfermedades no salir de casa tomar precausiones

Name: Maria Fernandez

I want the exact location Maria Fernandez queremos exacta locacion es nesesario quedigan donde exactamente ran a aplicar pestisidas para saver que no pueden estar personas ahi por el peligro

Name: Celia Acosta

I want the exact location yo quiero la ubicacion esaxta por que nos protege y asi prevenir una mala exsperencia para nuestra salud

Name: Humbertina Martinez

I want the exact location yo quiero la uvicaccion exata para una major protection y prevenir emfermedades

Name: Ana Mendoza

I want the exact location exigimos una uvicacion exacta donde se aplicara el pesticida ya basta de ocultar todo queremos ahora la uvicacion exacta en el campo. Es un probelma para la salud de todos los campesinos ninos Adultos uvicacion exacta ya ahora.

Name: Mana Perales

I want the exact location por que los Rancheros y los encargado de los Ranchos solo nos dicen que van aponer pesticides y nunca nos notifian. Que tan Fuertes y que tan daninos son ellos solo se en to can en sus cosechas pero no en los trabajadores que son los que rocojan sus cocechas sin importales el dano que nos ocacionan

Name: Joaquin Hernandez

I want the exact location yo quiero que nos deden la notificacion exacta es porque no es justo que rocien pesticidas tan cercas como donde estamos elaborando nuestra cosecha sin importer el impacta que puede afectarnos en nuestra salud y a nuestras familias al momento de llevara a nuestras casas con moleculas de pesticidas

Name: Maricela Mendez

I want the exact location para poder protejerme y poder protager a mi familia y mis muchachitas con el tiempo los pesticidas no hacer dano necesitamos la ubicacion exacta

Name: Olivia Perez

I want the exact location es importante saber la ubicacion esacta por los peligros que pueden afectar a las personas que trabajar en los campos agricolas

Name: Jayleen

I want the exact location queremos ubicacion exacta de donde aplican pesticidas yaque son muy daninos y malos para lasalud

Name: Noemi Hernandez

I want the exact location es imporante panuestra salud saver donde se aplican pesticidas y asi evitar pasar por ese lugar poreso es nesesario ubicacion exacta

Name: Lolita Diaz

I want the exact location 592 people population why do you give us pesticides -- do you not care our families are sick some already dead--pesticides are poisoning our families

Can you please alert us-- by text the address for schedule...↓d application--the chemicals you know are harmful--and its your mission to protect human health

Name: Deborah Paalman

I want the exact location Please have the farmers notify the workers where and when the pesticide is applied before applying pest

Name: Itzel Miranda

I want the exact location As a Fresno-born citizen, it is crucial to inform citizens of the exact location of pesticide application. Pesticides have affected not only the field workers that interact daily with the pesticide, but all of Fresno citizens as well.

Name: Tania Cornelio

I want the exact location It is very important to include the exact location of where the pesticides will be located. This is important for the safety of farmworkers and those who live in the Central Valley. We need this action NOW!

Name: Lourdes Medina

I want the exact location I have lived in Central Valley, CA since 1981 and have seen how pesticides changed the life and future of my friends who worked in the fields. Please know that it is important to include "Exact Location of Application" to the Notification to the CAC. Please know this is important not just for the workers. This important for business and residents near the areas of application. We can all work and live safe and Healthy.

Name: Analie Diaz

I want the exact location of application of pesticides. As this is something that directly affects our friends working in the fields. It is important to keep all our community members safe. Again we ask to have the exact location of application added.

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest management practices protect my community, my employees, my farm and the environment. Farmers, like so many other professions, have access and use many d...↓ifferent sources of technology to monitor different weather conditions. These systems monitor wind speed, temperature, humidity, and rain, just to name a few; and are used to make decisions when it comes to pest management.

Farmers are highly regulated, and must follow an abundance of laws and reporting requirements. The federal, state, and local oversight of pesticide use enforcements already in place to ensure the safety of my community, employees, farms, and the environment are more than adequate. Considering these rules and regulations, 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. Timeframes to submit Notices of Intent to County Agricultural Commissioners should remain as it is in current practice

3. Public notifications should only include information is absolutely necessary, such as:

a. product applied

b. intended date and time of application, and

c. 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 NOls 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.

If 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 Giannini, CEO

Giannini Farms, Inc.

Dear Director Henderson:

I am writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, I work hard to ensure my pest management practices protect my communi...↓ty, my farm and the environment. 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.

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.

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

Sincerely

Jeff Quaglino

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,

Jordan Qualls

Badger Farming /Sequoia Orange

Dear Ms. Otani:

On behalf of the Almond Alliance with the support of the Almond Board of California, we are providing the following comments and questions regarding the proposed prior notification draft regulation. The Alliance is a voluntary associat...↓ion representing almond growers, huller/shellers and handlers (processors). The Almond Board is a Federal Marketing order representing all almond growers and processors in California.

Almonds are grown on some 1.6 million acres in California representing $3 billion farm gate value. In addition to the over 7,000 almond growers there are some 400 huller/shellers who hull and shell almonds, and 100 handlers who process the nuts for entrance into the marketplace. Over 70% of the almond growers grow 100 A or less. Thus, the almond growers represent a diversity of size of operations as well as ethnicities in ownership, as well as abilities to manage the increasing regulatory compliance workload.

We appreciate CDPR asking for comments on the modifications to the new regulation. We are pleased to see that some of our previous comments have been incorporated.

We are adding some additional comments or observations for CDPR’s consideration as it moves forward with implementing the prior notification. These comments are in addition to the broader commodity provided comment letter.

1. DPR needs to make it clearer that the prior notification regulation addresses an effort to improve transparency to the public but that it is not about addressing safety. Safety is addressed through the risk assessment and enforcement processes. And given that a notice of intent covers an up to 4-day window for the possible application of a restricted use pesticide (RUP), it cannot be used to manage safety. Many, including ourselves, assumed this regulation was about improving safety.

a. The corollary to this regulation being about transparency is that it therefore does not make sense to know the specific location of the application and that a 1-mile section is adequate for transparency purposes.

2. In terms of communication about the pesticide regulatory process and safety, we highly recommend that DPR look to what the Pest Management Regulatory Authority (PMRA) of Canada has done in terms of communicating to the public about the pesticide regulatory processes. They provide plain language explanations of the risk assessment and enforcement processes. https://www.canada.ca/en/health-canada/services/consumer-product-safety/pesticides-pest-management/public/protecting-your-health-environment.html

3. We do have a concern particular to almonds and that is the definition of “production agriculture” when it comes to stockpiles. While the regulation is planned to only apply to RUPs used in production agriculture, that line is gray in the case of fumigation of stockpiles. Freshly harvested almonds are stockpiled awaiting hulling/shelling, that is placed in a pile and covered with a tarp. To stop insect damage coming in from the field, particularly critical with the new pest, Carpophilus truncatus, but also to arrest Navel Orangeworm damage, the stockpiles are typically fumigated under a tarp. Where those stockpiles are located varies: in some cases the nuts are stockpiled on a growers land; in some cases the nuts are transported for stockpiling to the huller/sheller who does not grow any almonds themselves; and in many cases a huller/sheller is stockpiling nuts grown on their own land will also stockpiling nuts from other growers. For these post-harvest uses of fumigations, since they can occur daily or every several days during the harvesting period, the NOI from the County Ag Commissioners is often for a month.

It sounds like if the nuts are stockpiled on the grower’s own land, then it would be considered a part of production agriculture and fall under the prior notification rule, but if purely a huller sheller then it is industrial and outside of the rule. But as noted above in many cases it is mixed and even if a grower is stockpiling on their own land, then the NOI may be for a period longer than 4 days.

Our recommendation is that any fumigation of stockpiles be considered a post-harvest activity, beyond the scope of production agriculture regardless of where the stockpiles occur.

We appreciate the opportunity to comment on the modifications to the proposed regulations. Should you have any questions or would like additional information, please do not hesitate to contact us.

Sincerely,

Blake Vann,

Chairman of the Board

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 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.

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, Edward Parra

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

July 30, 2024

To the Department of Pesticide Regulation:

Thank you for your work on the pesticide notification system. Many parts of it seem well planned to me, but you do not have the most important part included - giving the exact location.

Our organi...↓zation is 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.

Without this you are not being transparent to those who live or work or children who attend a school surrounded by agricultural fields.

It’s simply not just or helpful that adequate information is left out preventing effective proactive self protection.

Please provide information about where exactly the pesticide applications will occur so individuals know how close they are to homes, nearby schools, etc.

Thank you for your consideration.

Sincerely,

lauren Ornelas

Founder/General Programs Team Member

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.

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,

Daniel Stephens

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,

Penni Rogers

July 30, 2024

Ms. Lauren Otani, Senior Environmental Scientist (Specialist)

Department of Pesticide Regulation

1001 I Street

P.O. Box 4015

Sacramento, California 95812-4015

Subject:   Comments on the Department of Pesticide Regulation’s 30-day notice of...↓ modifications to the proposed restricted material use notification regulations.

Dear Ms. Otani:

Ratto Bros., Inc. is a family farm operating in California for the past 119 years. We appreciate 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 NOTIFICATION OF AGRICULTURAL USE OF RESTRICTED MATERIALS, dated July 2, 2024.

Our company 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).

Nevertheless, we have a few concerns that we would like DPR to consider while moving forward with the proposed changes. Our family has been farming leafy vegetables for many years. We have constantly adapted our techniques and operations with the changing times and increased regulations. One thing that has remained steadfast over the decades; our operation endures the challenge of growing crops outside. We are at the mercy of the weather every day; sun, cold, rain, fog and everything in between. While we can try to plan for each weather event, they are not absolute, requiring daily operational changes to fit the environment of that day. We believe there needs to be flexibility and relief in the regulations as it pertains to dates and times. If we submit a NOI for an operation in 2 or 3 days time, but the climate or weather do not support that application, that NOI should be valid until the work is completed, or at a minimum for 5 working days. We do not have the capacity to constantly submit NOIs as we navigate the weather (of which we have zero control).

We also believe that the grower specific information should remain private, or at a minimum, available only to the public in the immediate surrounding community. The actions and applications we perform are based on science, experience and issues we have in our growing operations. We believe in being good neighbors within our community, and there needs to be some level of communication. Statewide broadcasting of private information in the modern world of news cycles and social media, messaging can be construed based on individual interpretation and that is a huge fear among many farming families. Is it possible to consider an “opt in” system for the public that lives, works or attends school in a particular geographical area that could potentially be impacted by the applications. There is a risk to providing application data to the numerous groups in our State who unfortunately hold a negative perception of agriculture and farmers in our State.

In summary, I would like to thank DPR for the opportunity to comment. Making some slight adjustments or added flexibility to the NOI process or timeline would fit the realities of farming outdoors in California. Limiting the application data and details would also offer some security and safety to the farmers and employees who are responsible for the applications.

Thank you again,

Anthony Ratto

Ratto Bros., Inc. 

Dear Director Henderson:

I am writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, I work hard to ensure my pest management practices protect my communi...↓ty, my farm and the environment. 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.

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.

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

Sincerely,

Keith Ford, Manager

Socal Berry Growers, LLC

2112 Eastman Ave. Suite 102

Ventura, CA 93003

Dear Director Henderson,

I am writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, I work hard to ensure my pest management practices protect my communi...↓ty, my farm and the environment. 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.

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.

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

Sincerely,

Keith Ford, Manager

Vista Alegre Farms, LLC

2112 Eastman Ave. Suite 102

Ventura, CA 93003

Dear Director Henderson,

I am writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, I work hard to ensure my pest management practices protect my communi...↓ty, my farm and the environment. 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.

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.

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

Sincerely,

Keith Ford, Manager

Santa Clara Farms, LLC

2112 Eastman Ave. Suite 102

Ventura, CA 93003

To the California Department of Pesticide Regulation

Regarding Exact Locations of Pesticide Application

I am a physician specializing in Family and Community Medicine who cared for farmworkers and their families in the agricultural regions of the Salin...↓as and Pajaro Valleys for 34 years. I also participated in scientific research on the adverse health and environmental effects of agricultural chemicals. Pesticides are designed to be toxic and require scrupulous precautions and restrictions in their use. In the manufacturing, energy, medical, and academic setting, such chemicals would be used in a controlled environment with precautions against accidental release and contamination. Examples: a laboratory or a carefully constructed factory. Once released into the air, soil, and water, they cannot be retrieved or mitigated. Prevention is the only effective option. Yet the agricultural industry uses pesticides without regard to the safety and health of the workers, schools, and residential communities surrounding the fields.

Pesticides are a documented threat to public health and safety. I have witnessed the harm to my patients. At the very least, until pesticides can be phased out, the agricultural industry needs to follow strict guidelines and requirements.

I was pleased to see some progress over the years (since I was a young doctor and the agricultural fields were first posted with warning signs, forty years ago!). However, the Notification System still needs specificity in its warnings. The exact location of the pesticide application, the date, and the time must be in a format that is accessible to everyone who is potentially at risk. The current recommendations for location are too broad and vague to be useful to the people in the path of drift.

Thank you for reading my comment.

I hope to see a stringent and effective notification plan.

You will continue to hear from me until this mass poisoning comes to an end.

Sincerely,

Valerie Bengal MD FAAFP

Dear Director Henderson:

I am writing to you on behalf of the California Safflower Growers Association. We appreciate the effort CDPR has made to listen to concerns regarding the proposed pesticide application notification program.

The remote and in-pe...↓rson public listening sessions demonstrate a large knowledge gap between the interest groups. Agriculturalists are dedicated to the health of communities, farms, employees, neighbors, and the environment. Much of the feedback that has been presented at the various listening sessions would depict growers as haphazardly applying restricted use materials.

Federal EPA, DPR, and local County Agricultural Commissioners ensure that proper safety precautions are in place. 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.

Our comments regarding the proposed regulations are as follows:

• 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. This is crucial to the safety of the agricultural employees and applicators.

• 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.

County Agricultural Commissioners exercise extreme caution when granting restricted use permits. Being local, they have the benefit of intimate knowledge of sensitive areas and people. I fear much of their oversight will be undermined with a broad sweeping state-wide program. California has very diverse agricultural production, climates, and neighbor relations. For this reason, we do not support going forward with this policy of a state-wide notification program but if you must, I have additional concerns.

It is especially important that the anonymity of the farm be kept. As much as this proposal will establish fear of agricultural pesticide use, it also creates fear amongst farmers that they will be targets of the activist community. We know that missing an application period with a certain material could make the difference between a crop that can be harvested and one that must be mowed down.

According to current regulations, all NOIs must be filed within 24 hours of the start of the potential treatment. These NOIs are submitted to the CalAgPermits system, managed by County Commissioners. After submission, Commissioners review and approve permits, impose mitigations and applicators may begin within 24 hours and take up to 4 days. We support a 24-hour notification, at a maximum, to interested parties, but only if it results in no change to the NOI submission requirements.

We strongly believe that if the intent of a notification system is to support community members’ interest in knowing about applications, then the system must be geographically limited. Notifying individuals who are not impacted by a pending application serves no public or individual benefit and would only result in confusion or unnecessary fear from constant notification of applications hundreds of miles away.

Thank you again for careful consideration of these comments.

Sincerely,

Laura Brown

Executive Director

Dear Director Henderson:

I am writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, I work hard daily to ensure my pest management practices protect my c...↓ommunity, my farm and the environment.

I have confidence in the federal, state and local oversight of pesticide use enforcement, and work closely with the county ag commissioners to ensure that we're always working withing the regulatory framework that is designed to keep the public informed and protected. Considering these rules and regulations, I do not believe that statewide notification is necessary in anticipation of pesticide applications and will only serve to the means of activists that intend on delaying or stopping legal and safe pesticide applications. This regulation won't serve the intended purpose for the public that have a sincere interest in helping protect themselves and their families. I'm a strong believer that the best farmers are also the best neighbors.

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

Sincerely,

Chris Matthews

Dear Sirs and Madams at CDPR,

On behalf of the J. G. Boswell Company’s Kern Ranch, I am writing to express our opposition to the proposed Pesticide Notification System. CDPR and the County Ag Commissioners already have the most stringent pesticide con...↓trol 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,

Joey Mendonca

J. G. Boswell Company

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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. 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 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.

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,

Les Heringer

M&T Chico Ranch

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 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.

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,

Charlie Witrado

American West Aviation

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. (personal info here)

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,

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 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.

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,

Augustus Macy

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.

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)
• Personal 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. The safety of my employees and nearby communities is of utmost importance. Our ranch team is dedicated to safety and following the word of the label. 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,

[signature]

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. Considering these rules and regulations, I do not believe that thech...↓anges to the CDPR's Advance Pesticide Notification System are necessary in anticipation of pesticideapplications. 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 date and time of application, and general geographical location (base, meridian, township, ranger, and section) 4. Personally identifying information, such as acreage treated or exact location, should not be included thisis 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. These stalls have been seen already in the Monterey County farming area.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,Matt Bozzo

To whom it may concern,

On behalf of Bairos 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 proposa...↓l 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,

John Bairos

To WHOM IT MAY CONCERN:

On behalf of Del Rio Nut Company I wish to express my strong opposition to the proposed Pesticide Notification System being proposed by the CDPR.

Providing this sort of private information to anyone will allow those with social ...↓agendas to essentially control our plant protection applications with, at times,

rational that simply is without merit. Such delays will place our crops at risk and unnecessarily scare neighbors and those in the vicinity.

CDPR and our County Ag Commissioners already have very stringent control systems in place and these proposed changes will provide no more protection to

all those concerned. To provide such information to those not directly involved will only elevate people's fears but provide an avenue for outsiders to attack the

science that currently directs and leads the CDPR's decisions.

Again, we ask for the CDPR to maintain their existing authority to control and regulate pesticide applications thru trusted science and not allow this process to

become a social agenda.

Sincerely,

David Arakelian

Del Rio Nut Company

Dear Director Henderson:

I am writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, I work hard to ensure my pest management practices protect my communi...↓ty, my farm and the environment. 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.

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.

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

Sincerely,

Darwin Reich,

Director of California Operations

Wish Farms CA LLC

To whom it may concern:

On behalf of Las Nogaleras, 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 p...↓roposal 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?

1. We oppose the proposed pesticide notification system

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

3. 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.

4. 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,

Michael Wallace

CFO

Las Nogaleras, LP

To whom it may concern:

On behalf of Butte Vista, LLC 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 pr...↓oposal 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?

1. We oppose the proposed pesticide notification system

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

3. 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.

4. 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,

Clarke Ornbaun

Managing Partner

Butte Vista, LLC

To whom it may concern:

On behalf of Crain Orchards, 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 thi...↓s 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?

1. We oppose the proposed pesticide notification system

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

3. 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.

4. 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,

Elvin Bentz

Vice President

Crain Orchards, Inc.

To whom it may concern:

On behalf of Crain Walnut Shelling, 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, an...↓d 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?

1. We oppose the proposed pesticide notification system

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

3. 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.

4. 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,

Charles R. Crain, Jr.

President & CEO

Crain Walnut Shelling, LP

To whom it may concern:

On behalf of NuVista, 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 proposa...↓l 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?

1. We oppose the proposed pesticide notification system

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

3. 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.

4. 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,

Vice President, Finance

NuVista, LP

Dear Director Henderson:

I am writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, I work hard to ensure my pest management practices protect my communi...↓ty, my farm and the environment. 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.

California already has the most comprehensive notification regarding pesticide applications in the country. Along with adherence to federal pesticide regulations, California's agency Cal EPA 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.

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

Sincerely,

[signature]

Dennis Bowers On behalf of dennis bowers farnm jnc 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 prop...↓osal 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.

On behalf of JOHN DONDERO 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 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.

Regards,

Teri Dondero

Please consider my comments when finalizing these proposed new regulations:

• This new notification system appears to be based on responses received from people living in a couple of small farming communities in the Central Valley that are surrounded by...↓ intensive agriculture production including the use of restricted-use pesticides. Yet the state is proposing to implement this notification system statewide, impacting thousands of landowners involved in agricultural production, no matter how close their land is to homes, schools, towns, etc. The economic costs will be borne by the landowners alone.
• In the statement of reasons, it is mentioned that in these test communities, people wanted to especially know about applications near schools and homes. If that is the case, why doesn't DPR consider limiting the notification requirement to those areas within a certain distance of homes or schools? I have been involved in the forestry sector over my career (which as you know is considered agricultural production). Most forest land in the state that is in production is well removed from schools and homes, yet would still be required to take part in this notification system. For what purpose?
• In my forestry experience, the people that would be reading the posted notices would more likely be living in cities many miles from the actual application (maybe even out of state). Their purpose in gaining this information would not be out of concern for their home or their children's school, but rather to harass or otherwise try to disrupt the lawful application of a restricted-use pesticide that is occurring miles from them or the nearest homes or schools. Has DPR considered this?
• I call for DPR to consider placing a distance from schools, homes, etc., in the proposed regulations.

David Bakke

Dear Director Henderson:

I am writing in response to the July 2024 30-Day Comment Period on Pesticide Application Notification Regulation. As a member of the agricultural community, I work hard to ensure my pest management practices protect my communi...↓ty, my farm and the environment. 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.

California already has the most comprehensive notification regarding pesticide applications in the country. Along with adherence to federal pesticide regulations, California1s 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 DPR1s current communication methods and information accessibility for the public, the pesticide notification system is duplicative and not necessary.

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

Sincerely,

[signature]

As a 3rd generation farmer, I write to express my strong opposition to the proposed Advance 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, rather it would only serve to further infringe on the privacy of farmers. 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 for your attention to this matter

Caleb Gervase

Premier Ranches, Inc.

My name is Rob Scherzinger. I am with Aspen Helicopters in Oxnard, CA. We do aerialpesticide spraying.

In reference to ‘Spray Days California’ I would like to add my comment. California agriculture is our gift to the world. The farmers are hard workin...↓g, responsible land stewards and they do not spray pesticides unnecessarily. It’s an expensive necessity and nobody wants to do it…but that’s how we feed so many people. The media has made farming very difficult because they paint us as ‘gleefully spraying pesticides whenever and wherever we feel like it. In Ventura County, our primary summer target crop is avocados. Last year our company was not able to spray a lot of our customers for thrips for various reasons. Most of the growers that did not get sprayed had 30%-40% crop loss due to thrip damage. The point is, pesticides are a valuable tool in order to produce our avocados. Every year it becomes more difficult us to farm. Many of our farmers are giving up.

I understand the spot that the public and the media has put DPR in. Please do the best you can to help us farm-responsibly. We do not want to ruin California Agriculture. Help us please. Thank you

Rob Scherzinger, Past Chair, California Ag Aircraft Assoc.

Aspen Helicopters

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,

Penelope Worley

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.

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,

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.

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,

Carson Britz

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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. 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 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. 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,

Frederick M. Montgomery

Almont Orchards, Inc.

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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. Timeframes to submit Notices of lntent 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.

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,

Samuel W. Nevis

Double J Farms, LLC

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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. 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 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.

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,

Samuel W. Nevis

Sutter Land Company

P.O. Box 3775

Yuba City, CA 95992

(530) 674-2060

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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. 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 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.

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,

Samuel W. Nevis

Sutter Land Management, LLC

P.O. Box 3775

Yuba City, CA 95992

(530) 674-2060

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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. 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 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.

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,

Samuel W. Nevis

Melbay Farms, GP

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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. 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 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.

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,

Anthony Laney

Twin Peaks Agriculture, Inc.

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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:

I. 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 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.

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,

Dominic B. Nevis

Butte Basin Management Company, Inc.

To whom it may concern,

On behalf of Seth Van Dyke Farming, 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 t...↓his 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,

Ali Van Dyke

Bookkeeper

California Department of Pesticide Regulation

On behalf of Skittone Almond Sheller 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,

Raymond Aschwanden

President

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.

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)

• Personal 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. The safety of my employees and nearby communities is of utmost importance. Our ranch team is dedicated to safety and following the word of the label. 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,

Cameron Boswell

Board Director and Vice President, Finance & Administration

J. G. Boswell Company

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 pestic...↓ide use enforcement. Considering these rules and regulations, 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. 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 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.

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,

James Olson

Ring of Fire Agriculture, Inc. / Olson Trading Company, Inc.

To whom it may concern,

On behalf of Mike Jackson 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 t...↓his 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.

Thank you,

Mike Jackson

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 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.

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,

Brian chisum

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 pestic...↓ide use enforcement. Considering these rules and regulations, I do not believe that the changes to the CDPR’s Advance Pesticide Notification System are necessary in anticipation of pesticide applications and believe these changes will be detrimental to sustainable farming going forward in California.

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 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.

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.

Any delays in fumigation for our business will greatly disrupt the supply chain of walnuts, not to mention having devastating effects on the quality of the walnuts we shell and pack. The life cycle of these pests is very short and any delay could cause massive infestation problems with potential delays, quality issues, and returns from customers.

Thank you for your consideration in this matter.

Sincerely,

Grower and Packer Kevin Kajioka

General Manager, Turlock Walnut Company, Inc.

To whom it may concern,

On behalf of Kings River 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,

Sung Lin Wang

President

RE: Statewide Notification of Agricultural Use of Restricted Materials

July 25, 2024

Dear Director Henderson:

As a member of the agricultural community, I work hard to ensure my pest manager protect my community, my farm and the environment. I have conf...↓idence in the fed local oversight of pesticide use enforcement. Considering these rules and regula believe that statewide notification is necessary in anticipation of pesticide applicatio

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

• Notification should be limited to pesticide products that are already subjec Intent.

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

• Public notifications should only include what information is absolutely nece applied, intended date and t ime of application, and general geographical l meridian, township, range, and section).

• Personal identifying information, such as acreage treated or exact location, included- this is critical to grower, applicator and employee safety.

• Because advanced notice is highly likely to trigger appeals of NO ls and stall ap Department should prepare for these administrative burdens, act quickly top

to farm, and prepare for extended liability for crop loss.

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

Sincerely,

[signature]

In regard to DPR proposed notification system I would urge you to reconsider this well-intentioned but misguided proposal. You are about to unleash a storm of protest and mis information targeted at AG which is already reeling from over regulation al...↓l the while it is being forced to compete with unregulated foreign producers. This is my 45th year farming. Since my very first year I have practiced IPM and done my very best to protect the environment, my employees, our neighbors and customers. I farm both conventional and organic crops. I have found that no matter how safe of an operator you are, the public will always over-react when a spraying operation is occurring.

The craziest example of over-reaction I have experienced was after spraying Kaolinite next to our county jail.

I have always sprayed at night and this job was no exception. In the morning when the inmates and guards noticed the white residue on the crop, I received every sort of phone call imaginable. People were deathly ill; some went into shock others were vomiting. So... when the Ag Commissioner explained to the sheriff that the white clay that was responsible for the residue had been sprayed on the crop as a sunscreen; that the chemical was legal and nontoxic; and that in fact the chemical is the same material that makes up Pepto Bismol. A reasonable person would assume that a life lesson would have been learned and everyone could move forward. No, both inmates and guards doubled down on their complaints. Why is that? People do not understand science, in reality they barely read. If you watch the nightly news, it is very clear that the public has no interest in the truth if it does not support their position. My point is science is real, the news is not fake and just because someone disagrees with you, they are not evil. In the public's mind pesticides are bad period. Your proposed notification system is going to unleash the crazies on what is left of California Agriculture. For what purpose? To eliminate materials that we all depend on to keep the cost of producing our food reasonable. Please do not do this.

Jim Roberts

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 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.

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,

Lloyd Erlandson

July 25, 2024

Julie Henderson

Director

CA Department of Pesticide Regulation

1001 I Street, P.O. Box 4015

Sacramento, CA 95812

Dear Director Henderson:

The Latin Business Association represents the business interests of over 800,000 Latino-owned businesses ...↓in California and is the premier and largest Latin business organization in the country.

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.

The LBA acknowledges that Agriculture is the largest industry in the state of California. This economic driver influences so many local and Latino owned businesses and its impact is felt in Southern California particularly Ventura County where several of our board of directors live and work. Any disruptions will greatly harm the local workforce and the local economy. The work by DPR, our local county Agricultural Commissioner and her staff, works for all and should not be over regulated.

Sincerely,

Ruben Guerra

President/CEO

Latin Business Association

To whom it may concern,

On behalf of Grapeman Labor, 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 ...↓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.

Thank you,

George Rodriguez

President

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 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 NOls 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.

Ryan Della Nina

Owner

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 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:

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 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 NOls 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.

Kevin Gilmore

Applicator

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 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:

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 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 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

Steven Gilmore

Applicator

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 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:

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

2. 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 NOls 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.

Paul Arey

Pilot

Dear Director Henderson:

On behalf of the California walnut industry via the California Walnut Commission (CWC), I am writing to express formal comments regarding the statewide pesticide notification system. The CWC represents over 4,500 family farms ...↓and 69 handlers that generate over 85,000 jobs directly and indirectly, and almost $700 Million in farm gate product value. Walnuts are one of California’s largest agricultural commodities and 99% of English walnuts grown in the United States are produced in California.

As a member of the agricultural community, I work hard to ensure our industry’s pest management practices protect our communities, our workers, our farms and the environment. I have confidence in the federal, state and local oversight of pesticide use enforcement. Considering these rules and regulations, 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 (NOI)

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 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.

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,

Joshua Rahm

Director, Technical & Regulatory Affairs, California Walnut Commission

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.

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 lntent

• 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. 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,

Michael Kennedy

President/CEO

Green Valley Farm Supply

To Whom It May Concern,

On behalf of Parsons 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 propo...↓sal 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.

Julien Parsons

To Whom It May Concern,

On behalf of Parsons 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 prop...↓osal 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,

Julien Parsons

Partner

To Whom It May Concern,

On behalf of Parsons 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 prop...↓osal 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,

Meghan Parsons

Office Manager

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 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.

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 Edward Parra

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 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 NOls 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,

Roger Hewett

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 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 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,

Roger Hewett

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 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 NOls 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,

Roger Hewett

I would like to comment that the proposed regulation for the Spray Days system be limited to only those pesticides that currently require an NOI.  To try to extend the system to all chemicals would be an onerous task for my business. We spray approxi...↓mately 2400 fields a year and to submit an NOI for each field would take over 50 man days.

My second point is that currently there is a mechanism in place for the applicators that inadvertently drift on another crop or spray someone in a field.  There should also be a consequence mechanism for this program.  If someone enters a field during an application to try to disrupt the application, then that person(s) should be subject to fines and enforcement actions by the County Ag Commissioner. The law should treat all players equally.

A person entering a field while an application is being made with an airplane compromises the safety of that pilot.  A pilot cannot land safely with a load.  To land he would have to dump the load, causing a greater hazard in a different area, and then land.  There are enough deaths of Ag pilots every year, ( so far this year 10 in the US)  For one more death to be caused by someone deliberately entering a field to disrupt the application is unconscionable.

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 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 NOls 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.

Nicholas Beyer

Pilot

To whom it may concern,

On behalf of Tahmazian Farming 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 thi...↓s 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.

Thank you,

Bryan Tahmazian

July 24, 2024

Dept. of Pesticide Regulation

1001 I Street, P.O. Box 4015

Sacramento, CA 95812-4015

Director Henderson,

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 of 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.

My family and my extended family all live in Stanislaus County. Both of my granddaughters have asthma. So too many of their friends also have asthma. Farmworkers have asthma. They all are at risk and the pesticide sprays add to that health risk. I am urging you to rethink this proposal to include dates, times, places of spraying.

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,

Mary F. Rodgers

Dear Director Henderson:

I am the Executive Director of the California Specialty Crops Council. The California Specialty Crops Council (CSCC), a 501(c) 5 non-profit organization, is a trusted source of field-based information spanning horticultural cr...↓op production, pest management, food safety and stewardship activities in fruit, root, vegetable, and vine crops (fresh, dried, and processed). Combined, over 2,600 CSCC growers generate $5.0 billion annually on approximately 518,000 acres of California farmland. This represents 7% of the acreage in agricultural production in the state of California. Our members include:

CA Cherry Board, CA Celery Research Board, CA Prune Board, CA Fresh Carrot Advisory Board, CA Garlic and Onion Research Advisory Board, CA Leafy Greens Research Program, CA Melon Research Board, CA Pear Advisory Board, CA Pepper Commission, and the Artichoke Research Association.

We come forth because the membership of the California Specialty Crops Council works hard to ensure that our member commodities’ pest management practices protect our communities, our farms and the environment. Through our members’ assessments, they invest annually in research which explores alternatives to currently used pesticides, into the development of genetic resistance for our crops, into new types of ag automation that will reduce pesticide use and into the research infrastructure (primarily through the UC system) which we rely on to perform these trials and continue this important work. We do this because we want the industry to continue to thrive in California. 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.

Should the Department continue to move forward with this project, we ask that CDPR 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. Sometimes just a day can make the difference between saving a crop or losing a crop.
• Public notifications should only include what information is absolutely necessary: product applied, intended date and time of application, and general geographical location.
• Information that could potentially identify an individual farmer or farm location, such as acreage treated or exact location should not be included. This information is critical to grower, applicator and employee safety.
• Advanced notice could very likely trigger appeals of NOIs and delay applications. The Department should prepare for these administrative burdens, act quickly to protect the right to farm, and prepare diligently for extended liability for crop loss. We use these materials to protect our crop from major loss. Not making these applications at the right time, as IPM practices recommend, will have an impact on yield and system wide sustainability.

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

Sincerely,

Gary Van Sickle

Gary W. Van Sickle

Executive Director

California Specialty Crops Council

Hello - as a winery and vineyard owner, we believe that in the peak spraying season (roughly June-September), there are days when a 24 hour notice of spraying is not feasible. For example, if we notice an infestation of mealy bug, we would make an im...↓mediate determination to spray, thus unable to provide a 24 hour notice. In addition, the agriculture industry is inundated with requirements and restrictions, all of which are important for consumer/applicator protection, but also burdensome to implement in a very hectic and busy time period. It would seem that some type of compromise would be preferable.

Sincerely,

Brooke Carhartt

Carhartt Vineyard

Carhartt Family Wines

Dear Director Henderson:

As a PCA in 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 enforce...↓ment. 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 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. Such activities seem to be inviting unfair and probably unlawful activity by activist groups.

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,

Richard Wellman

Dear Director Henderson:

The membership of the California Tomato Research Institute works hard to ensure our pest management practices protect our communities, our farms and the environment. Through our assessment, these members invest annually in res...↓earch which explores alternatives to currently used pesticides, into the

development of genetic resistance for our crop, and into the research infrastructure (primarily through the UC system) which we rely on to perform these trials and continue this important work. We do this because we want the industry to continue to thrive in California. We 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 of Pesticide Regulation continue to move forward with this project, I ask that DPR 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.
• Personally identifying information, such as acreage treated or exact location should not be included. This information is critical to grower, applicator and employee safety.
• Advanced notice will very likely 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 diligently for extended liability for crop loss. We use these materials to protect our crop from major loss. Not making these applications at the right time, as IPM practices suggest, will have an impact on yield and system wide sustainability.

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

Sincerely,

Zach Bagley

Managing Director

California Tomato Research Institute, Inc.

www.tomatonet.org

About us: Founded in 1968, the CTRI is an independently funded, voluntary Board of processing tomato growers. As the industry's research sponsor, the Institute's purpose is to identify, fund and direct research to maintain and enhance the economic viability of California's processing tomato industry with

emphasis on production, product quality and the environment. In a given year the processing tomato growers of California are responsible for 95% of the total U.S. production of this crop; approximately one third of the world’s global production with an annual farm-gate value of over $ 1.5 Billion.

--

Zach Bagley

Managing Director

California Tomato Research Institute, Inc.

www.tomatonet.org

Dear Director Henderson:

The Carriere Family has been farming our land going on 5 generations. We use the latest technology and pest management practices in order protect our crops, our community, our employees, our neighbors and the environment. We h...↓ave confidence in the federal, state and local oversight of pesticide use enforcement. Considering these rules and regulations, We 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. 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 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 NOls and stall applications, the Department should prepare for these administrative burdens, act quickly to protect the right to farm, and for increased 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,

William D. Carriere, Owner

Carriere Farms

Are Human’s just as important as Honey Bees?

Apparently not.

If you have a honey bee hive, the Department of Pesticide, using a software called BeeWhere, will contact you if an agricultural poisonous spray is going to happen near your hive; so you can ...↓move it before the spraying takes place.

As I read the label, for 1,3-dichloropropene, this chemical is “Contact acute, Oral acute, Unknown mode acute LD50 (worst case from 24, 48 and 72 hour values- ug bee, therefore, as a beekeeper, I would be notified to move my bees from a field that had this poisonous chemical applied too.

If you're a human living in a house, school, etc., the Department of Pesticide does NOT have a system that will notify you that your house, school, etc. will be exposed to this drifting poisonous agricultural treatment.

In order to at least protect humans, you could change your rule to follow the official Prop 65 safe harbor level established by the California of Environmental Health Hazard Assessment by adding the EXACT LOCATION of the pesticide application.

But, as a beekeeper, it’s nice to know my "Honey Bees" are more important than “Humans".

Dale Hillard

Director Henderson,

On behalf of the West Berkeley Alliance for Clean Air and Safe Jobs, I am writing to address the fact that the new pesticide notification system lacks the most

crucial and effective component, the notification of the exact location ...↓of the pesticide spraying.

A one-square-mile radius notification does not provide sufficient information for the most impacted community members to take proactive measures to protect themselves, e.g. adjusting schedules and walking routes, ventilating and taking shelter, closing windows or moving indoors, assessing wind drift as well as other environmental factors.

Farmworkers are our very important essential workers. They are the most exposed to harmful pesticide sprays. With more specific location information they

can take extra safety precautions and perform additional safety measures if they know which fields have been sprayed. This vital information aids in faster

emergency preparedness in case of exposure due to pesticide drift.

By not providing more detailed, specific pesticide spray information, those most impacted are left at high risk of exposure which impacts their health and their

livelihood. Since pesticides drift with the wind, knowing exactly where they are being sprayed is crucial.

The West Berkeley Alliance also strongly encourages you to change the name “Spray Days” to "Pesticide Notification System”. The pesticides used are

restricted chemicals, many of which are carcinogenic. The name “Spray Days” downplays the severity of the harmful effects of these chemicals, the need for

community members to take safety precautions, and the fact that these pesticides are sprayed year-round.

We welcome you seriously considering integrating new languages into the notification system making it more accessible to all impacted community

members.

The West Berkeley Alliance urges you to take the right and moral action by providing more precise information in the notification system thus ensuring the

safety and well-being of all impacted communities.

Sincerely,

Janice Schroeder

Core Member

westberkeleyalliance@yahoo.com

Good Afternoon,

As someone who lives in the Central Valley, I am aware of the impacts that pesticide use can have on the health of our communities.

While I commend the DPR for the pilot program pertaining to the pesticide notification system knows as “...↓Spray Days,” I am concerned that the system is not meeting the needs of the community, nor is it achieving it’s stated goal of providing transparency to impacted communities.

First, this system must be called what it is in order to avoid confusion: “Pesticide Notification System” is much more clear and to the point.

Secondly, in order for this notification system to be useful to communities, the exact location of the application of pesticides as well as the type must be disclosed. This information is crucial to community members understanding the risks associated with spraying in their area and should not be left out.

Please implement these changes to ensure that the Pesticide Notification System remains true to its goal of providing transparent information to communities so that they can be informed and protect themselves and their families.

Thank you,

Gavin Bruce

California Department of Pesticide Regulation

I wish to express my 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. I did attend the hearing in Shafter yesterday, July 23 2024 and was listed to speak but seeing a generally less than respectful crowd, I elected to write in instead. Some in the crowd validates the very concern, that for CDPR to provide farm specific information 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 reminding them that our applications are not secret but are on file, subject to approval, controlled and recorded by the regulatory agency. I am very concerned what CDPR would do in the event 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.

Regards,

Bryan Bone

Bone Farms, LLC

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 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.

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,

Chris Jones

PCO and Chief Pilot of Jones Aviation

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 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.

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,

JOHN BRIGHAM

PRESIDENT BETTENCOURT FLYING SERVICE