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Greetings, 
A comment letter from the Californians for Pesticide Reform
(CPR) coalition and 51 co-signatories is attached. 
We call on CARB to: 1) Proactively assert its
authority to regulate smog-forming emissions from use of pesticides
classified as TACs, and 2) Include in the SIP meaningful and
enforceable measures to reduce use of pesticides that contribute to
VOC emissions. Specifically, we urge CARB to include a commitment
to reduce pesticide VOC emissions by 30% by 2030 and by 75% by 2037
from 2020 levels in high pesticide use non-attainment air basins,
with a focus on mandatory targets for reduced usage and adoption of
agroecological practices. 
At a minimum, if CARB proceeds with the inclusion of
the 1,3-D regulation as a measure in the SIP, we ask that CARB
exercise their admitted authority to regulate 1,3-D air emissions
by setting a SIP-enforceable 1,3-D emissions reduction
target. 
Sincerely,
Jane Sellen and Angel Garcia, CPR Co-Directors