In their comments to CPDA, EPA highlighted the importance of a detailed submission cover letter so that they can be quickly assigned to the appropriate reviewer. This will expedite the review. RD staff also mentioned that their annual NCP receipts of $5.25 million were thanks to PRIA V's 12.5% registration fee set-aside. This exceeds RD's capacity to process NCP submissions.
To reduce the number of incoming NCPs, EPA suggested CPDA members take the following actions:
- Combining minor actions for a given product with a critical NCP or PRIA action, rather than submitting a new non-critical NCP; and
- Take advantage of RD's new electronic CSF capability, wherever possible. In response, CPDA expressed some frustration with the eCSF.
EPA and CPDA each took homework assignments away from the meeting. CPDA will provide examples of some of the problems we raised in our PowerPoint presentation (watch for information requests). In turn, RD staff said they will outline useful content for a cover letter.
A discussion of PRIA V was also a key part of last week's Annual Meeting where Nathan Ehresman and Laurie-Ann Flanagan (the PRIA Coalition Coordinator) discussed some of the challenges of implementing PRIA V. Topping the list of challenges is a lack of funding for EPA's Office of Pesticide Programs which, in turn, has prevented them from hiring enough staff. To keep pace with all PRIA submissions and backlogged items, OPP needs more than $165 million annually. Earlier this year, CPDA submitted appropriations requests with multiple Congressional offices for full OPP funding. While a FY 2024 federal budget has yet to be approved, it appears that Congress won't be fully funding OPP. However, CPDA members can expect an increase in OPP funding from current levels. This highlights the importance of CPDA's regular meetings with OPP to seek efficiencies and ways to streamline the regulatory process.
A special thanks goes to Nathan and Sherry for their leadership and to Laurie for being an invaluable resource.