![](media/image1.jpeg){width="1.3763888888888889in"
height="1.1006944444444444in"}**[New Mexico Farm & Livestock
Bureau]{.smallcaps}**

[P.O. Box 20004 ● L]{.smallcaps}as Cruces, New Mexico 88004 [● (505)
532-4700 ● FAX (505) 532-4710]{.smallcaps}

January 14, 2008

Office of Pesticide Programs

Regulatory Public Document (7502P)

Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington DC 20460-0001

RE: DOCKET ID NUMBER EPA-HQ-OPP-2007-0944

Dear Ms. Schnackenbeck:

On behalf of the New Mexico Farm & Livestock Bureau (NMF&LB) and our
14,000 family members we would like to comment on the published request
for comment on the Petition to issue a notice of Intent to Cancel the
Registrations of M-44 Sodium Cyanide Capsules and Sodium Floroacetate.

We are requesting that the U.S. Environmental Protection Agency (EPA)
dismiss the Petition filed in July 2007 by Sinapu and others (see
Petition) to discontinue the use of M-44 Sodium Cyanide Capsules and
Sodium Fluoroacetate. These are very essential tools that many of our
members utilize on their operations to control predators that
potentially have a devastating affect on their businesses. This petition
is flawed and speculative, and does not accurately assess actual risk
posed by the highly regulated use of M-44s and Compound 1080.
Responsible wildlife and predator management are vital to livestock
operations. We strongly urge the EPA to evaluate the Petition based on
facts, and continue the licensing and registration of M-44s (sodium
cyanide capsules) and Livestock Protection Collars (LPCs used with
Compound 1080 or Sodium Fluoroacetate).

The U.S. Department of Agriculture (USDA) Animal & Plant Health
Inspection Service (APHIS) Wildlife Services (WS) and certified private
applicators rely on these chemicals to selectively remove wild canids in
proximity to livestock only when and where they can be safely used. On
public land, only WS personnel can administer M-44s and LPCs and
interagency meetings between the land managing agencies and WS are held
annually to help identify when and where they can be safely used.

The re-registration and use of these chemicals has subjected them to
more restrictions than chemicals with far greater environmental impact.
At that time, the EPA determined that the use of M-44s did not pose
unreasonable, adverse effects to humans or the environment. None of the
information presented in the Petition demonstrates any reason to reverse
the agency's earlier determination. There is no data to substantiate

the claim that "people and pets are routinely exposed and harmed by
these toxicants." This is baseless and calls into question the
legitimacy of other claims made in the petition. When considered on the
whole, there is far less sodium cyanide or Compound 1080 used than
virtually any other pesticide. One would question the validity of their
claims. If their pets are being exposed to these toxicants one would
assume that they are not in control of their pets and are failing to
read the warning signs that are posted near these toxicants. Any pet on
National public lands is supposed to be leashed and under their control
at all times. If they are not then they themselves are in violation of
our laws.

It should be emphasized that certification of applicators for M-44s
and/or LPCs are performed by appropriate regulatory agencies. To become
a certified applicator for the use of M-44s and/or LPCs, the applicant
must first attend an approved certification course, complete an
application, and take and pass a certification exam to verify proper
knowledge of the use and safe handling of M-44s and LPCs. Therefore
prior to certification, each applicator receives training in safe
handling of the chemicals and devices, proper first aid treatment,
proper placement of the devices, and necessary record keeping.

In summary, there is nothing in the petition or other records which
indicate that the use of either of these pesticides causes any
environmental harm or legitimate human safety concerns. We ask the EPA
to evaluate actual, reasonable risk and not be drawn into the rhetoric
contained in the Petition. We recognize that many do not appreciate the
role of agriculture in their lives, nor do they see the need for
predation management. However, it is important that we keep as many
management tools in the toolbox, and constantly strive to use them more
effectively, to ensure that we can safely and efficiently provide the
public with the agricultural commodities they purchase at the store. We
urge the EPA to follow the sound science which supported the
registration of the chemicals and still support their continued use.

Thank you for your time and the opportunity to make comments on this
issue.

Respectfully,

Joel A. Alderete

Regional Director

New Mexico Farm & Livestock Bureau

PO Box 20004

Las Cruces, NM 88004

\(505\) 866-7382