Statewide standards already put in place by DPR to protect schools, childcare facilities, and other difficult-to-evacuate sites are the strictest for pesticide regulation in the world.

There is NO scientific justification for the newly proposed additional regulations. Children are being used to further an anti-pesticide agenda at the expense of a safe and affordable food supply. Many of these same children go to bed hungry every night; imposing additional food insecurity on this sensitive population is not only unjustified but also incredibly irresponsible.

The proposed regulations are overly burdensome with no basis for arbitrarily determining a quarter mile buffer zone for all pesticide applications. The annual notification highlights a lack of understanding of how California agriculture functions and will result in a meaningless listing of every possible pesticide choice available.

Restrictions based on fear rather than science is unacceptable public policy.
There has not been sufficient review of the impact these proposed regulations will have on farms and ranches.
There are no emergency provisions in the proposed regulations. The dynamics of agriculture make the industry extremely vulnerable to weather and field conditions.
Arbitrary decision-making goes against all scientific frameworks used by the state and federal government.

Concerned Californians demand that regulations be based on scientific studies and measured outcome. Proposing unnecessary and burdensome regulations on California farmers and ranchers, will further push farming to countries that do not have a fraction of the safety and protection current California laws provide. Unsubstantiated concern and political pressure is not a premise for increased regulations.

I urge DPR to act responsibly and base regulations on the best available science. There is no need or justification for these new proposed regulations or notification requirements.

Sincerely,

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