Document VM1bwavzZ3J5ZRoXXZ55O4XZ

To: Dravis, Samantha[dravis.samantha@epa.gov] Cc: Rees, Sarah[rees.sarah@epa.gov]; Estreicher, Herb[estreicher@khlaw.com]; Novak, Michael[Novak@khlaw.com] From: Votaw, James G. Sent: Wed 4/26/2017 11:35:10 PM Subject: Keller and Heckman FIFIRA Coalition Request for Extension of Comment Period (Dkt. No.EPA- HQ-OA-2017-0190) removed.txt Keller and Heckman FIFRA Coalition Request for Extension of Comment Period.pdf Dear Ms. Dravis: We represent an ad hoc coalition of companies forming to develop recommendations for the responsible repeal or modification of particular regulations issued to implement the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and that are outdated, unnecessary, or unnecessarily burdensome or costly, including specific suggestions for repeal or modification (as applicable). This is to request a 30-day extension of the comment period. The process of bringing affected companies together, identifying and vetting the range of potential reform candidates, and developing thoughtful and appropriate, consensus reform proposals, requires significant coordinated effort among many people and is difficult to complete within the original 30-day period allowed. While work is underway to meet the original deadline, a somewhat longer comment period will provide the Agency with higher quality input from all groups and a much better basis for future decision-making. A reasonable extension is particularly appropriate here where there are no underlying legal deadlines, and EPA's substantive action on the recommendations may be months or years away. Thank you for your consideration. Very truly yours, James G. Votaw Partner Keller and Heckman lip tel: 202-434-4227 | m: 202-604-5461 | votaw@khlaw.com 1001 G Street, NW, Suite 500 West, Washington DC 20001 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00007881-00001 Visit our website at khiaw.com for additional information. If you print, please recycle. This message and any attachments may be confidential and/or subject to the attomey/client privilege, IRS Circular 230 Disclosure or otherwise protected from disclosure. If you are not a designated addressee (or an authorized agent), you have received this e-mail in error, and any further use by you, including review, dissemination, distribution, copying, or disclosure, is strictly prohibited. If you are not a designated addressee (or an authorized agent), we request that you immediately notify us of this error by reply e-mail and then delete it from your system. 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00007881-00002 I 1001 G Street N.W. Suite 500 West Washington, D.C. 20001 tel. 202.434.4100 fax 202.434.4646 April 26, 2017 Writer's Direct Access James G Votaw (202) 434-4227 votaw@khlaw.com Via Electronic Mail and Mail Samantha K. Dravis Regulatory Reform Officer and Associate Administrator, Office of Policy U.S. Environmental Protection Agency William Jefferson Clinton Building 1200 Pennsylvania Avenue, N. W. Mail Code: 1804A Washington, DC 20460 Re: 30-Day Extension of Comment Period Evaluation of Existing Regulations, 82 Fed. Reg. 17.793 (Apr. 13, 2017). Docket No. EPA-HQ-QA-2017-0190 Dear Ms. Dravis: We represent an ad hoc coalition of companies forming to develop recommendations for the responsible repeal or modification of particular regulations issued to implement the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and that are outdated, unnecessary, or unnecessarily burdensome or costly, including specific suggestions for repeal or modification (as applicable). This is to request a 30-day extension of the comment period. The process of bringing affected companies together, identifying and vetting the range of potential reform candidates, and developing thoughtful and appropriate, consensus reform proposals, requires significant coordinated effort among many people and is difficult to complete within the original 30-day period allowed. While work is underway to meet the original deadline, a somewhat longer comment period will provide the Agency with higher quality input from all groups and a much better basis for future decision-making. A reasonable extension is particularly appropriate here where there are no underlying legal deadlines, and EPA's substantive action on the recommendations may be months or years away. Thank you for your consideration. .A f Very truly yours, ! ' i /. ' James (t % otaw T""" Aw- cc: Sara Rees Docket No. EPA-HQ-OA-2017-0190 U.tj KurirtriA *<p`, /er^ ' ^n.rrn,, - / 17cv1906 Sierra Club v. EPA - 6/22 Production Pari. ED 001523 00007882-00001