January 15,2009 

Via U.S. Mail and Electronic Mail 

Mary-Ann Warmerdam, Director 

Department of Pesticide Regulation 

1001 I Street 

Sacramento, CA 958 12 

Re: Comments on Proposed Amendments to Section 6452.2 and Proposed 

Revision to the Pesticide Element of the California State 

Implementation Plan 

Dear Ms. Warmerdam: 

These comments are submitted on behalf of the Center on Race, Poverty and 

Environment, California Rural Legal Assistance Foundation, Pesticide Action Network 

North America and the below listed member groups of Californians for Pesticides 

Reform and additional organizations. 

In 1994 and again in 1996, the Department of Pesticide Regulation ("DPR") and 

the Air Resources Board ("ARB) promised to reduce low-level ozone pollution - also 

known as "smog" - in California by reducing, inter alia, pesticide-related volatile organic 

compound ("VOC") emissions. EPA approved these promises into the State 

Implementation Plan ("SIP") as described in the November 15, 1994 Pesticide Element 

and the June 13, 1996 letter f?om James Boyd to David Howekamp ("Howekamp 

Letter"). See El Comitipara el Bienestar de Earlimart v. Warmerdam, 539 F.3d 1062, 

1070 (9th Cir. 2008).' 

We call on you to honor those promises. There is no basis whatsoever in either 

the Pesticide Element or in the Howekamp Letter to proceed as your staff have proposed. 

We therefore call on you to decline to adopt the proposed amendment to section 6452.2 

and the proposed State Implementation Plan revision for the reasons set forth below. 

I. The Proposed Regulation Violates the State Implementation Plan. 

DPR's proposed amendments to section 6452.2 (hereafter "proposed regulation") 

violate the SIP in three important respects. First, the proposed regulation includes a 

benchmark for the San Joaquin Valley nonattainment area that oqly reflects a 12% 

reduction from 1990 levels, instead of the 20% reduction from 1990 levels to which DPR 

and ARB committed in the Howekamp Letter. Second, the proposed regulation seeks to 

delay imposition of fumigant emission limits until 201 1, which violates the SIP because 

' This decision is not yet final, as a Petition for Rehearing with a Suggestion for 

Rehearing en Banc is pending at the Ninth Circuit Court of Appeals. The Plaintiffs- 

, Appellees respectfully disagree with the decision. 
such reductions were to occur by 2005. Third, the proposed regulation violates the SIP 

because the 1994 Pesticide Element commits to year-round reductions, not only 

reductions during the so-called ozone season. 

Should DPR finalize the proposed regulation under pressure from pesticide users and 

manufacturers, then members of the public will likely file a lawsuit authorized by 

Congress against DPR in Federal District Court to enforce the terms of the Howekamp 

Letter. DPR mistakenly believes the proposed regulation is necessary to mitigate the 

economic burden on those who use and sell pesticides. DPR's duty is to honor the 

promises in the SIP and protect public health, not the economic interests of pesticide 

users and merchants. The public overwhelmingly supports strong measures to clean up 

air pollution in the Valley: 59% of Central Valley residents surveyed by the Public Policy 

Institute of California support more stringent regulation of agricultural air pollution.2 

A. The Proposed Regulation Violates the State Implementation Plan because the 

SIP requires a 20% reduction from 1990 levels by 2005 in the San Joaquin 

Valley, and DPR proposes a mere 12% reduction. 

DPR's Initial Statement of Reasons incorrectly states that the 1994 Ozone SIP 

requires a 12% reduction from 1990 levels in the San Joaquin Valley, and cites to the 

preamble of EPA's final rule approving that SIP. ISOR at 2, citing 62 Fed. Reg. 1 150, 

1 170 (Jan. 8, 1997). The ISOR fails to cite any provision of the SIP itselfthat purports to 

only require a 12% reduction in the Valley. 

Under the Ninth Circuit's decision that vacated the district court order referenced in 

the ISOR, EPA's preamble has no interpretative value when the plain language of the SIP 

is unambiguous. El Comite para el Bienestar de Earlimart v. Warmerdam, 539 F.3d 

1062, 1070 (9th Cir. 2008). When the Ninth Circuit held that the "Wells Memorandum" 

was not in the SIP, the Ninth Circuit recognized that the Howekamp Letter was in the 

SIP. Id. at 107 1. The Howekamp Letter requested that EPA delete the table "Reductions 

from 1990 Pesticide Emissions Baselines," stated that the pesticide "commitment is for a 

20% reduction from 1990 levels by 2005 in each SIP area, except [San Diego]," and 

stated "we only took credit in the attainment year: SJV 1999 = 12%, Sac 2005 = 20%' 

Ven 2005 = 20%' SED 2007 = 20%, SC 2010 = 20%." Letter from James Boyd to David 

Howekamp dated June 13, 1996 ("Howekamp Letter") at A-2, attached as Exh. 2. 

The plain language of the Howekamp Letter, codified as part of the SIP at 40 C.F.R. $ 

52.220(~)(236)(i)(A)(l), confers a federally-enforceable commitment upon DPR to 

achieve a 20% reduction by 2005 in the valley? EPA has recently interpreted the 

Public Policy Institute of California Statewide Survey: Californians and the 

Environment, July 2008 at 1 1, attached as Exh. 1. 

' Indeed, DPR's interpretation of the SIP advanced in this proposed rulemaking directly 

contradicts DPR's litigation position in the Ninth circuit, where DPR argued that the 

Howekamp Letter was the operative SIP document and that the Court should not rely on 
Pesticide Element to impose a dual obligation on DPR to achieve the percentage 

reduction and the tonnage used in the 1994 Ozone SIP'S attainment demonstration for the 

Valley (13 tons per day in 1994 SIP currency 1999~). 

The EPA's proposed and final rules approving the Ventura Pesticide SIP revision 

interprets the pesticide commitment in the 1994 Ozone SIP. See 73 Fed. Reg. 21885, 

21 886 (Apr. 23,2008); 73 Fed. Reg. 41277,4 1281 (July 18,2008). EPA states that the 

commitment is to adopt any rules necessary by June 15, 1997 to achieve a percentage 

reduction in 2005 and a tonnage reduction in the attainment year. 73 Fed. Reg. at 41281 

("our interpretation of the original Pesticide Element commitment as having both a 

tonnage reduction commitment in addition to the percent reduction commitment"). EPA 

then describes the commitment as including that June 15, 1997 date to adopt "any 

regulations necessary." Id. 

Under the original Pesticide Element, for the Ventura County 

nonattainment area (Ventura), the California Department of Pesticide 

Regulation (DPR) committed to adopt and submit to EPA by June 15, 

1997, any regulations necessary to reduce VOC emissions from 

agricultural and structural pesticides by 20 percent of the 1990 base year 

emissions by 2005. 

Id. at 41277. EPA also explained what makes the pesticide strategy enforceable. 

Commenters and EPA both agree that the State's SIP commitment (from 

the 1994 Ozone SIP) with respect to VOC emissions reductions from use 

of pesticides in Ventura County is defined in terms of percent reduction 

from base year emissions. The point of disagreement is that EPA states in 

the proposed rule that the commitment is a two-fold commitment defined 

in terms of both a percent reduction and a tonnage reduction. 

Our interpretation of the original Pesticide Element commitment as having 

both a tonnage reduction commitment in addition to the percent reduction 

, commitment rests on general and specific grounds. First, EPA has 

traditionally found committal measures, such as the commitment to reduce 

VOC emissions in the Pesticide Element of the 1994 Ozone SIP, to be 

enforceable, and thus approvable, only if such measures identify the 

responsible party, adoption dates for rules, implementation dates, and 

emissions reductions in terms of emissions rates (such as tons per day) 

equal to the credit taken in the RFP or attainment plan for the committal 

measure. The tonnage specification provides the essential link between 

the committal measure and the RFP or attainment demonstration. See the 

general discussion of committal measures in EPA's final rule approving 

EPA's language in the preamble of the final rule. DPR now cites the preamble for the 

claim that the pesticide commitment for the Valley is 12% from 1990 levels. ISOR at 2. 

62 Fed. Reg. 11 50, 1169-1 170 (Jan. 15, 1997). 
the 1994 Ozone SIP at 62 FR 1 150 (January 8, 1997), at 1 155-1 157, and 

the specific discussion of the committal measures submitted as part of the 

1994 Ozone SIP at 1 157, column 3. In this case, the tonnage commitment 

(for 2005) links the original Pesticide Element commitment to the 

approved attainment demonstration for Ventura County. Each specific 

element of a committal measure, once the measure is approved by EPA, is 

considered to be enforceable. Thus, we believe that EPA would not have 

found the original Pesticide Element commitment for Ventura approvable 

unless the measure included the 2.37 tons per day reduction in pesticide 

VOC emissions in 2005 that was credited to the measure in the 1994 

Ozone SIP. 

Id. at 41281. 

The plain language of the Howekamp Letter states that the pesticide commitment 

is for a 20% reduction from 1990 levels by 2005 in each SIP area, except San Diego. We 

fully expect DPR to honor this commitment. 

B. The Proposed Regulation Violates the State Implementation Plan because the 

SIP Requires Reductions by 2005, not 2011. 

The proposed regulation violates the SIP by deferring the imposition of fumigant 

emission limits to 201 1, instead of maintaining the current 2008 implementation. As 

written, the SIP requires a 20% reduction in all areas by 2005. Howekarnp Letter at A-2, 

attached as Exh. 2. Deferral of the backstop if fumigant use restrictions fail will allow 

more VOC emissions than the SIP allows. 

DPR should have adopted these regulations in 1997, and achieved the reductions by 

2005. The proposed regulation reflects a pattern and practice by DPR of delay and 

inaction instead of protecting public health. DPR should implement the fumigant 

emission limits now and not defer the already late implementation until 201 1. We 

therefore call on DPR to remove language from the proposed regulation that defers the 

limits to 20 1 1. 

C. The Proposed Regulation Violates the State Implementation Plan because DPR 

Restricts Applicability of Fumigant Emission Limits to the May 1 to October 31 

Time Period. 

The fumigant emission limits are proposed for only May 1 through October 3 1 of 

each year. See Draft § 6452.2. The 1994 SIP mandates annual reductions of VOC 

emissions, not seasonal reductions. See State Implementation Plan for Agricultural and 

Commercial Pesticides, November 15, 1994 at 6-10, attached as Exh. 3. As written now, 

there is an incentive to increase fumigant use in the unrestricted months, which is 

inconsistent with the State Implementation Plan. Moreover, pushing fumigant use into 
the winter months will increase VOC emissions that contribute to fine particle pollution 

(~~2.5).~ 

11. The Proposed State Implementation Plan Revision Interferes with Attainment of 

the 1-Hour Ozone Standard. 

DPR proposes a substantial revision to the SIP, which EPA may not approve unless 

EPA finds that the revision does not interfere with attainment, reasonable further 

progress, or any other requirement of the Act. See 42 U.S.C. $ 7410(1). Even though 

EPA has rescinded the 1-hour standard, all mandatory and discretionary measures to 

attain the 1-hour standard remain in place subject to section 1 lO(1) of the Act. See 69 

Fed. Reg. 2395 1,23972-23974 (April 30,2004); see also South Coast Air Quality 

Management District v. U.S. E.P.A., 472 F.3d 882 (D.C. Cir. 2006). DPR has made no 

effort to demonstrate that the SIP revision, including the proposed deferral of fumigant 

emission limits in section 6452.2, will not interfere with any requirement associated with 

the 1-hour ozone National Ambient Air Quality ~tandard.~ 

111. The Proposed State Implementation Plan Revision Relies on Control Strategies 

that are not SIP-Approved Rules. 

EPA has not approved the 2008 fumigant regulations as a part of the SIP. Moreover, 

DPR does not plan on submitting the proposed regulation to EPA for inclusion in the 

SIP.' The failure of DPR to include the adopted strategies in the SIP violates the Clean 

Air Act, which mandates that any control measures to attain the National Ambient Air 

Quality Standards must be part of the SIP. 

One of the fundamental principles of the Clean Air Act is that State Implementation 

Plans must contain the emission limitations and control measures to provide for 

attainment of the health-based NAAQS by the applicable deadline, provide reasonable 

further progress, and comply with any other applicable requirement of the Act. 42 U.S.C. 

$ $ 74 IO(a)(2)(A), 7502(c)(6). In addition, California must demonstrate that "the plan, as 

VOC is not only an ozone precursor, but also a fine particle (PM2.5 precursor) which 

ARB and the San Joquin Valley Unified Air Pollution Control District included as a 

PM2.5 precursor in the 2008 San Joaquin Valley PM2.5 Attainment Plan. See 2008 

PM2.5 Plan, Appendix F, attached as Exh. 4. DPR has made no effort to demonstrate 

that increasing VOC emission in winter months will not interfere with attainment, 

reasonable further progress, or any other requirement related to PM2.5, as required by 

section 1 lO(1) of the Act, 42 U.S.C. $ 7410(1). 

Deferring the fumigant emission 'limits in section 6452.2 until 201 1 dire~tly interferes 

with attainment of the I-hour standard in the San Joquin Valley, which has a November 

15, 2010 attainment deadline as an extreme 1-hour ozone nonattainment area. In order to 

attain by that deadline, the Valley must not have more than one violation per year per 

monitoring station (averaged over the three year period preceding the deadline). 

' Phone conversation with Polly Frenkel, DPR Counsel, and Brent Newell, dated 

November 17,2008. 
revised, will provide for attainment of the ozone national ambient air quality standard" by 

the deadline for an extreme area. 42 U.S.C. 8 75 1 1 a(c)(2)(A). Section 1 82(b)(l)(C) 

mandates that "emissions reductions are creditable . . . to the extent that they have 

actually occurred from the implementation of measures required under the applicable 

implementation plan, rules promulgated by the Administrator, or a permit under 

subchapter V of this chapter." 42 U.S.C. 5 751 la(b)( l)(C) (emphasis added). 

EPA's regulations implement the requirements of the Act and echo its mandates. 

Already-adopted regulations on which a plan relies must be included in the plan itself. 

"Revisions of a plan, or any portion thereof, will not be consideredpart of an applicable 

plan until such revisions have been approved by the Administrator in accordance with 

this part."9 40 C.F.R. 8 5 1.105 (emphasis added). "Each plan must demonstrate that the 

measures, rules, and regulations contained in it are adequate to provide for the timely 

attainment and maintenance of the national standard that it implements." 40 C.F.R. 5 

5 1.1 12(a). EPA's regulations plainly require that 

Emission limitations and other measures necessary for attainment and 

maintenance of any national standard, including any measures necessary 

to implement the requirements of subpart L must be adopted as rules and 

regulations enforceable by the State agency. Copies of all such rules and 

regulations must be submitted with the plan. 

40 C.F.R. 8 51.281 (emphasis added). 

The General Preamble, EPA's guidance on implementation of Title I of the Act, 

further demonstrates that the state's already adopted measures must be submitted to EPA 

and included in the State Implementation Plan in order to satisfy the requirements of the 

Act. 

One purpose of a SIP is to perform demonstrations of how various goals 

will be achieved. These goals are of three types: Attainment of the 

NAAQS, maintenance of the NAAQS once attainment occurs, and 

prescribed rates of progress. . . . These assumptions, control strategies, and 

measures are developed as necessary to meet the attainment objectives for 

the area and the Act's requirements (e.g. RACT). These assumptions and 

measures are key components of the SIP. It is important to note that 

projections of the effect of planned air pollution control measures 

' "The term 'applicable implementation plan' means the portion (or portions) of the 

implementation plan, or most recent revision thereof, which as been approved under 

section 7410 of this title, or promulgated under section 7410(c) of this title, or 

promulgated or approved pursuant to regulations promulgated under section 7601 (d) of 

this title and which implements the relevant requirements of this chapter." 42 U.S.C. 3 

7602(q). 

"Plan means an implementation plan approved or promulgated under section 1 10 of 172 

of the Act." 40 C.F.R. 3 51.100Cj) ("1 10 of 172" in original). 
contained in the SIP'S are not merely assumed but are enforced by 

regulations adopted as part of the SIP. Therefore, if the control measures 

are not implemented sufficiently to result in required reductions, the State 

or local agency, or EPA, can take action to enforce implementation of the 

regulations. This provides a means of achieving, at least, in part, the goals 

of attainment and f?urther progress required in the Act. 

57 Fed. Reg. 13498, 13567 (April 16, 1992) (emphasis added). 

The General Preamble sets forth what it calls four "fundamental principles for 

SIPS": SIP measures must be quantifiable, enforceable, replicable, and accountable. Id. 

at 13567-13568. These principles apply to all SIPS and control measures. Id. at 13568. 

Of importance here, the second principle (enforceable measures) means that the measures 

are "duly adopted, and specify clear, unambiguous, and measurable requirements." Id. 

"A legal means for ensuring compliance must also exist for a measure to be enforceable." 

Id. The practicality of determining compliance is a factor. "A regulatory limit is not 

enforceable if, for example, it is impractical to determine compliance with the published 

limit." Id. EPA fixher explains the concept of enforceability in the General Preamble: 

In general, for a SIP regulation to be enforceable, it must clearly spell out 

which sources or source types are subject to its requirements and what its 

requirements (work practices, emission limits, etc.) are. The regulation 

also needs to specify the time frames within which these requirements 

must be met, and must definitively state recordkeeping and monitoring 

requirements appropriate to the type of sources being regulated. The 

recordkeeping and monitoring requirements must be sufficient to allow 

determinations on a continuing basis whether sources are complying. An 

enforceable regulation must also contain test procedures in order to 

determine whether sources are in compliance. 

Id. at 13502. 

The Proposed SIP Revision also relies on DPR's discretionary authority to impose 

restrictions on non-fumigants and on total VOC emissions from pesticides to ensure that 

Valley emissions do not exceed a specific level of emissions. See Attachment A, 

Department of Pesticide Regulation Proposed SIP Commitment of San Joaquin Valley 

("Attachment A") at 1-2. Those provisions of state law have not been submitted to EPA 

for inclusion in the SIP nor have they been approved by EPA as a part of the SIP. These 

measures must be enforceable and in the SIP, and not merely in the sole discretion of 

DPR. 

IV. The Proposed SIP Revision is Unenforceable. 

The Proposed SIP revision does not commit to achieving any tonnage reduction 

from fumigant or non-fumigant regulations. By its own terms, the Proposed SIP revision 

leaves the total tonnage at the discretion of DPR. The "measure may provide more or 
less reductions than the amount shown." Attachment A at 2. Under the terms of the 

Proposed SIP revision, the "commitment" is not an enforceable commitment, but a 

measure to achieve reductions at DPR's unfettered discretion. 

V. The Proposed Regulation should Account for EPA Action to Define Methyl 

Bromide or other Pesticide Products as Non-VOC. 

Currently pending before the EPA is a petition by an industry group to delist methyl 

bromide as a VOC." We are concerned that the proposed regulation's use of a tonnage 

benchmark rather than a percentage of the 1990 base year emissions will allow DPR to 

claim that the target has been met if EPA grants the methyl bromide petition. In other 

words, removing methyl bromide from the inventory would reduce the tons per day 

emitted in the five air basins and create the impression that emissions targets have been 

met. 

To maintain the integrity of the 1994 Pesticide Element, any deletion of a pesticide 

product from the definition of VOC should also remove that product's emissions from the 

base year inventory. Thus, deletion of methyl bromide won't create a statistical lie: 

keeping the fixed benchmark which was calculated using methyl bromide in the base 

year. Since changing the VOC-exempt list is a realistic possibility, and since it would 

have a dramatic effect on both the baseline inventory and all subsequent years, any new 

SIP language should anticipate such changes and plan for them. We suggest the following 

language be incorporated into the SIP: 

If the U.S. Environmental Protection Agency takes final action to list any 

pesticide or pesticide ingredient (active or inert) as VOC-exempt, for 

example methyl bromide or MITC, then within 30 days of such final 

action DPR shall recalculate the 1990 baseline inventory and 

corresponding emission limitation to eliminate the amount of VOC that 

the pesticide contributed in the base year inventory. 

Furthermore, the estimates of VOC emissions are affected by a wide variety of 

factors, each with uncertainties, and each of which are in a process of ongoing 

refinement. For example, the emissions potentials (EPs) are regularly revised. Examples 

and details which might make these points are footnoted below." 

'O Petition by Chemtura to EPA, dated August 16,2007, attached as Exh. 5. 

11 As a major, non-hypothetical example, suppose the commitment to reduce emissions in 

the San Joaquin Valley is frozen at 18.1 tons per day, as DPR proposes in 6452.2(a) and 

the proposed SIP revision. Suppose that subsequently U.S. EPA lists methyl bromide as a 

non-contributor (exempt compound) for VOC formation. This will abruptly and 

substantially reduce the VOC inventory for any year under consideration. However, if the 

base year "benchmark" is fixed at 18.1 tons per day and it is not recalculated based on 

this exemption, a non-meaningful tonnage reduction will appear to have been achieved. 

DPR has suggested it would propose a SIP revision to correct this, despite having very 

little incentive to do so and a well-established track record of delay and inaction. 
One of the key principles of the commitment to reduce VOC emissions to a below 

80% the base year, is to calculate the base year and subsequent years using the same 

methodology and factors. This means retrospectively adjusting the estimate of VOCs 

emitted in the base year. While it has been suggested that this is confusing, to do anything 

else immediately introduces non-comparable calculations. Non-comparable calculations 

render the concept of a percentage reduction far less meaningful and invites 

"compliance" arguments based on illusory "reductions." 

In summary, regulations and the SIP should confirm that the base year, the 

reduction targets (80% of the base year) and subsequent years will always be compared 

using the same methodology and factors. 

VI. Conclusion. 

We urge DPR to retain the current 20% reduction requirement in the San Joaquin 

Valley, to not defer the imposition of fumigant emission limits to 20 11, and to require 

annual reductions of pesticide-related VOC. DPR has an over-due obligation to regulate 

pesticide VOC emissions and should honor its promise to Californians. 

Sincerely, 

Brent Newel1 Dr. Brian Hill, Ph.D. 

Center on Race, Poverty & the Environment PANNA 

Anne Katten 

CRLA Foundation 

Frequent SIP revisions to change benchmarks based on new EPs or new U.S. EPA 

listings of VOC exempt compounds would not be an efficient process and take years to 

complete. 

As a more minor example, but one which will repeatedly affect the calculations as new 

EP data comes in, suppose that the EP of any of the hundreds of pesticide formulations is 

revised, and the formulation in question was used in both the base year and the present 

year. If the benchmark is frozen at 18.1 tons per day, and the new estimate is applied to 

the present year, another illusory, non-meaningful percentage change will appear. This 

will look like a setback if the revised EP is higher, and look like progress if the revised 

EP is lower. 
Martha Dina Argiiello 

Executive Director 

Physicians for Social Responsibility- Los 

Angeles 

Los Angeles, CA 

Davis Baltz, M.S. 

Special Projects Advisor 

Commonweal 

Bolinas CA 

Jose T. Bravo 

Executive Director 

Just Transition Alliance 

Chula Vista, CA 

Barbara A. Brenner 

Executive Director 

Breast Cancer Action 

San Francisco, CA 

Luis Cabrales 

Senior Campaign and Outreach Associate 

Coalition for Clean Air 

Los Angeles, CA 

Caroline Cox 

Research Director 

Center for Environmental Health 

Oakland, CA 

Teresa Deanda 

Founder/Director 

El Comite para el Bienestar de Earlimart 

Earlimart, CA 

Christopher Gavigan 

Executive Director 

Healthy Child Healthy World 

Los Angeles, CA 

RenC L. Guerrero 

Legislative Advocate 

Planning and Conservation League 

Sacramento, CA 

Bill Magavern 

Director 

Sierra Club California 

Rosenda Mataka 

Grayson Neighborhood Council 

Grayson, CA 

M. Suzanne Murphy 

Executive Director 

Worksafe, Inc. 

Oakland, CA 

Renee Nelson 

President 

Clean Water and Air Matter (CWAM) 

Bakersfield, CA 

Joan Poss 

Secretary 

FresCAMP (Fresno Coalition Against the 

Misuse of Pesticides) 

Fresno, CA 

Jeanne Rizzo, R.N. 

President and CEO 

Breast Cancer Fund 

San Francisco, CA 

Yarnmilette G. Rodriguez 

Central Valley Regional Director 

Latino Issues Forum 

Fresno, CA 

Sarah Sharpe 

Environmental Health Director 

Fresno Metro Ministry 

Fresno, CA 

Scott Smithline 

Director of Legal and Regulatory Affairs 

Californians Against Waste 

Sacramento, CA 
Mary Milner Haffner 

Board member 

Community and Children's Advocates 

Against Pesticide Poisoning (CCAAPP) 

Ventura, CA 

Kevin D. Hamilton, RRT,RCP 

Founding Member: Medical Advocates for 

Healthy Air 

Fresno, CA 

Isabelle Jenniches 

Co-founder: StopTheSpray.ORG 

Carmel Valley, CA 

Rey Leon 

Executive Director 

Latino Environmental Advancement and 

Policy Institute (LEAP) 

Fresno. CA 

Linda MacKay 

President 

TriCounty Watchdogs 

Grapevine Region along Interstate 5 

Executive Director 

California Institute for Rural Studies 

Davis, CA 

Paul Schramski Towers 

Pesticide Watch 

Sacramento, CA 

Mitzi Shpak 

Executive Director 

Action Now 

Los Angeles, CA 

Ron Sundergill 

Pacific Regional Director 

National Parks Conservation Association. 

Fresno, CA 

Mily Trevino-Sauceda 

Executive Director 

Lideres Campesinas de California 

Pomona, CA 

Andria Ventura 

Program Manager 

Clean Water Action California 

Nan Wishner 

Stop the Spray East Bay 

Oakland/Berkeley, CA