Dear Ms. Trossbach:

Thank you for the opportunity to provide comments to the Virginia Department of Agriculture and Consumer Services (VDACS) regarding proposed increases to the state’s pesticide product registration fee, commercial applicator certificate fee, registered technician certificate fee, and business license fee. We appreciate VDACS’s efforts to include stakeholders throughout its decision-making process.

We understand VDACS’s Office of Pesticide Services must be appropriately funded to operate efficiently and to effectively regulate pesticide products and their application. Increased regulatory fees can be challenging for pesticide registrants, particularly small businesses, that may have many product registrations and tight budgets. Fee increases can put financial pressure on companies and lead to increased prices for pesticide product consumers and applicators.

However, we understand that VDACS has not raised its certification and licensing fees since 1990, and its pesticide product registration fees since 1999, and that the Office of Pesticide Services is facing difficulties acquiring appropriate funding with the current fee schedule. As a result, we support the modest proposed fee increases as long as funds from pesticide fees remain accessible to the Office of Pesticide Services and are not taken from the office to support Virginia’s general fund or other activities unrelated to pesticides. Because the fee increases have been proposed as a remedy to the Office of Pesticide Services’ recent resource challenges, it is reasonable to give those paying the fees certainty that their money will accomplish its stated objective to ensure the efficient operation of the Office of Pesticide Services.

Likewise, we also ask VDACS to ensure that the special projects the pesticide office supports are truly within the office’s purview. Projects that only apply to a specific product, group of products, or a special activity that benefits a particular market segment should be addressed through alternative funding mechanisms.

Finally, we recommend VDACS implement the fee increases in phases. By gradually increasing pesticide fees over a period of time, VDACS will give businesses time to budget for the increase and will ensure a smooth transition to the new fee schedule.

Thank you for reviewing our comments on VDACS’s proposal to increase its pesticide fees. We support the proposed increases and request that additional funds generated from these increases remain in the Office of Pesticide Services for use by the pesticide program. Please contact us with any questions or for additional information.

Sincerely,

Aaron Hobbs
President
RISE, Responsible Industry for a Sound Environment
1156 15th Street, NW, Suite 400
Washington, DC 20005
(202) 872-3860

Bucky Kennedy
Director of State Affairs
Southern Crop Production Association
211 B Gilmer Street
Reidsville, NC 27320
(336) 394-4871

RISE is a national not-for-profit trade association representing more than 220 producers and suppliers of specialty pesticide and fertilizer products to both the professional and consumer markets. RISE member companies manufacture more than 90 percent of domestically produced specialty pesticides used in the United States, including a wide range of products used on lawns, gardens, sport fields, golf courses, and to protect public health.

Southern Crop Production Association is the regional trade association for the manufactures, dealers, and distributors of crop production products in the 16 Southeastern States from Oklahoma to Delaware. The purpose and goals of the association are to provide essential information and services to its members and to provide a unified regional view from our industry to legislators and regulatory agencies at both the federal and state levels.