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E-mail: tcfb@tulcofb.org • Web: www.tulcofb.org • Join Farm Bureau: www.joinfb.org

June 7, 2012

Submitted electronically

Linda Irokawa-Otani, Regulations Coordinator

Office of Legislation and Policy

Department of Pesticide Regulation

1001 I Street, P.O. Box 4015

Sacramento, California 95812-4015

Re: Comments on a Notice of Proposed Regulatory Action and Notice of Public Hearing

On a Proposed Ozone State Implementation Plan Amendment Regarding Amendment of Title 3, California Code of 

Regulations (3 CCR) sections 6452, 6452.2, and 6864; amend section 6452.4 and renumber to 6881; renumber section 

6890 to 6864; and adopt sections 6558, 6577, 6880, 6883, 6884, and 6886.

Dear Ms. Irokawa-Otani,

The Tulare County Farm Bureau [TCFB] is a non-governmental, non-profit, voluntary membership association whose 

purpose is to protect and promote agricultural interests throughout Tulare County and to find solutions to the problems 

of the farm, the farm home and the rural community. TCFB strives to protect and improve the ability of farmers and 

ranchers engaged in production agriculture to provide a reliable supply of food and fiber through responsible 

stewardship of California’s resources. TCFB represents over 2,500 member families in Tulare County.

We believe that additional restrictions on fumigant emissions, especially the implementation of an “allowance” system 

for fumigants at the County level, should be avoided. Administering the allowance program to meet emissions 

benchmarks requires substantial state and local government resources and is extremely burdensome on agricultural 

producers. The allowance system is costly, requires many hours of additional paper work and disrupts growers’ normal 

crop planning process. We recognize and understand that California is one of the most stringent and progressive states 

in administering pesticide regulatory laws and growers are already under a tremendous burden to comply with more 

strenuous laws in this arena than anywhere else in the United States or perhaps the globe. 

As stated the regulation would create certain restrictions on active ingredients that apply to certain high VOC products 

that will be used in the crops designated. If these products and the use patterns are adapted or changed over time, 

permanent restrictions may no longer be targeting the products that are the greatest contributor to VOC emissions. We 

support including a mechanism that allows for consideration of cropping pattern changes or the ability to de-list 

ingredients if they are no longer a major contributor to the emissions. 

We also support the need to make sure that licensed pest control advisors are informed and trained appropriately to 

manage the restrictions on products with high VOC concentrations, and we would support making sure that crop 

protection material dealers are also aware of these potential restrictions and work with growers to minimize their use 

when possible. Further, we support streamlining the regulation to make sure that only those materials that are directly 

correlated with emission reductions are being regulated to achieve necessary compliance.

Thank you for consideration of these comments.

TRICIA STEVER BLATTLER

Executive Director

TULARE COUNTY FARM BUREAU 

Mission: to promote and enhance the viability of Tulare County agriculture.