Anonymous public comment

As a Florida resident, I am submitting this comment in response to EPA's notice of receipt for the above petitions, which request tolerances permitting residues of fenpropathrin and abamectin on all food/feed items when either chemical is used in food/feed handling establishments or as a wide-area mosquito adulticide. I support EPA's underlying public health objective. Effective mosquito control is a legitimate and important tool for protecting communities from vector-borne disease, and I recognize the practical need for a workable residue tolerance to support that use. However, I ask EPA to tighten the "wide-area mosquito adulticide" component of any tolerance it ultimately grants, rather than adopting the blanket authorization as petitioned. Both chemicals carry documented ecological risk. EPA's own 2020 registration review identified risks of concern to aquatic invertebrates, fish, birds, and bees from fenpropathrin, and abamectin carries comparable non-target toxicity as a member of the avermectin class. "Wide-area" application, by definition, extends exposure beyond deliberately treated acreage into pollinator habitat and waterways that a standard, single-crop agricultural tolerance would not reach. I therefore request that EPA use its authority under FFDCA § 408(d)(4)(A)(i) to condition any final tolerance on enforceable drift and exposure mitigation measures, including buffer distances from documented apiaries and open water, restricted application timing outside peak pollinator foraging hours, and defined droplet size and drift reduction standards specifically for wide-area applications. Absent such conditions, I do not believe the record supports an unrestricted wide-area tolerance at this stage. Thank you for the opportunity to comment. Respectfully submitted, Anonymous Florida Resident