Attachment C - Public Comment from WY Dept. of Agriculture

Wyoming
Department of Agriculture

Dave Freudenthal, Governor
John Etchepare, Director

2219 Carey Ave., Cheyenne, WY 82002 Phone: (307) 777-7321 Fax: (307) 777-6593

November 16, 2006
RE: Docket ID No. EPA-HQ-OPP-2006-0631. Recordkeeping Requirements for
Certified Applicators Using 1080 Collars for Livestock Protection

The Wyoming Department of Agriculture submits the following comments in reference
to Docket ID No. EPA-HQ-OPP-2006-0631.
The Department recognizes the need to properly maintain records regarding the
application and use of all pesticides. As the requirement for additional recordkeeping and
reporting of use of Livestock Protection Collars (LPC) has been in place for 23 years, the
Department does not contest the renewal of this ICR.
However, the Department does strongly encourage EPA to maintain confidentiality of the
certified applicators, their addresses or other personal information contained within any
report made to the Agency. In support of this position, the Department references the
following state law:
Wyoming Statute § 11-6-104(b) states “Any information regarding the
number or nature of rodents or predators legally taken within the state
pursuant to this section shall only be released in its aggregate form. The
identity of any person legally taking a rodent or predator within this state
is solely for the use of the responsible agency or appropriate law
enforcement agency, shall not be released without the individual's written
consent and is not a public record for purposes of W.S. 16-4-201 through
16-4-205.”
Thank you for the opportunity to comment.

Sincerely,

Hank Uhden
Manager – Technical Services Division