Dr. Katrina White 
Environmental Fate and Effects Division 
Office of Pesticide Programs 
Environmental Protection Agency 
1200 Pennsylvania Ave. NW 
Washington, DC 20460-0001 

Submitted via regulations.gov: 

Re: Analysis of Subsurface Metabolism in Groundwater Modeling; EPA-HQ-OPP-2021-0241 

Dear Dr. White: 

Established in 1933, CropLife America (CLA) represents the developers, manufacturers, formulators, and distributors of pesticides and plant science solutions for agriculture and pest management in the United States. CLA represents its members by, monitoring legislation, federal agency regulations and actions, and litigation that impact the pesticide and pest control industries and participating in such actions when appropriate as well as communicating the benefits of pesticides to a variety of audiences. CLA’s members produce, sell, and distribute virtually all the pesticide and biotechnology products used by American farmers. 

CLA’s comments are presented as a cover letter followed by an executive summary and specific comments to the analysis of subsurface metabolism in groundwater modeling released in the EPA-HQ-OPP-2021-0241 docket. 

CLA appreciates the opportunity to comment on the Agency’s effort to address longstanding concerns with the degree of conservatism within groundwater assessment tool. Should you have any questions or comments, please feel free to contact me at mbasu@croplifeamerica.org or (202) 296-1585. 

Read the full comments.