Hey Butch,
You da man!!
Dan DiGiacomandrea
Bayer CropScience
68 Chadwick Manor
Fairport, NY 14450
585-330-3263
Fax 585-425-8774
[EMAIL PROTECTED]
http://www.bayercropscienceus.com/rep/~dan.digiacomandrea
| "W.H. \"Butch\"
Palmer" <[EMAIL PROTECTED]>
Sent by: <[email protected]> 10/25/2006 08:17 AM
|
|
The U.S. apple industry will be put at even more of a competitive disadvantage with the loss of ANY of the pest control products/practices we now have. Responsible growers, with the help of the Extension Service and university research people, have learned how to judiciously use products like azinphos methyl with minimum or no adverse effects on beneficials or the environment.
As commercial tree fruit growers and independent research folks, we are now looking at many mating disruption programs. One thing that is quickly apparent is that we can’t afford to loose any of our present insecticides without delaying our commercial use of mating disruption since mating disruption can’t stand alone. Since we are a family operation, we need all the good products we now have to remain in the fruit growing business.
We are also starting organic apple production. It looks feasible as long as we can get our processing customers to accept 15% insect damage and triple the price.
One thing that is apparent is that opinions about sensitive issues like “pesticides”, “organic”, etc. are often based on our preferential values determined completely outside of any scientific evidence. (By the way, I came out of a liberal Ivy League university and worked for the first company to commercialize attractants and insect growth regulators for insect control in apple orchards.)
Finally, I remember my dad spraying DDT, parathion, etc. with an airblast sprayer (first one in the state), no cab on the tractor, and he didn’t even know what “PPE” was. He’ll be 96 next week.
W. H. "Butch" Palmer
Cell: 315-945-0945
Alternate e-mail: [EMAIL PROTECTED]
-----Original Message-----
From: [email protected] [mailto:[EMAIL PROTECTED]
On Behalf Of Stina Booth
Sent: Tuesday, October 24, 2006 9:22 PM
To: Apple-Crop
Subject: Re: Apple-Crop: Azinphos Methyl (Guthion ®) Phase Out
Its high time Guthion was phased
out. The sooner the better. The industry will benefit by no longer being
associated with big-gun broad spectrum products like Guthion.
On Monday, October 23, 2006, at 11:06 AM, Dan Digiacomandrea wrote:
Here is an update on what's happening with Guthion. USApple is fighting
hard for an extension with the support of Bayer but it's an up hill battle!
Any support from industry is greatly appreciated. Forward your comments
to me and Jim Cranney.
Dan DiGiacomandrea
Bayer CropScience
68 Chadwick Manor
Fairport, NY 14450
585-330-3263
Fax 585-425-8774
[EMAIL PROTECTED]
http://www.bayercropscienceus.com/rep/~dan.digiacomandrea
-----Original Message-----
From: Jim Cranney [mailto:[EMAIL PROTECTED]
Sent: Friday, October 20, 2006 6:25 PM
To: Administrator
Subject: Azinphos Methyl (Guthion®) Phase Out
M E M O R A N D U M
TO:
USApple Science Advisory Subcommittee
CC:
USApple Board of Trustees
State and Regional Producer Organizations
FROM: James R. Cranney,
Jr.
SUBJECT: Azinphos Methyl (Guthion®) Phase Out
DATE: October
20, 2006
The U.S. Environmental Protection Agency’s (EPA) Assistant Administrator
Jim Gulliford has reached a decision regarding azinphos methyl and is proposing
to phase out the use as proposed, but over a slightly longer period to
2012. The Assistant Administrator has directed EPA staff to work
with agricultural commodity groups to develop a phase out plan, which is
expected to be finalized later this month or in early November.
EPA has proposed to phase out azinphos methyl using sharp regional use
reductions that do not meet grower needs. USApple is attaching EPA’s
proposal language for your information as follows:
Apples
The current label rate is 1.0-1.5 lbs ai/A/application with seasonal max
of 4.5 lbs ai/A.
Nationally, the average rate is 0.78 lbs ai/A/application with 2.4 applications.
The seasonal average application rate is 1.88 lb ai/A/year. However,
in the Western apple production region, the average rate is 0.99 lb ai/A/application
with 1.8 applications and a seasonal average of 1.78 lb ai/A/year. In
the Eastern production region (in contrast), the average rate is 0.63 lb
ai/A/application with 3.4 applications and a seasonal average of 2.05 lb
ai/A/year. (All figures from USDA NASS, 2006)
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Under the approach outlined in the table above, the 2008 seasonal max application
rate would be reduced to 2 lb ai/A West of the Rocky Mountains and to 3
lb ai/A East of the Rocky Mountains. The seasonal max in the Eastern
region would decline to 2.0 lb ai/A in 2009 and 1.0 lb ai/A in 2011. The
Eastern production region option offers the most flexibility to growers.
Limiting the number of applications does not offer as much flexibility
to growers as the limiting the seasonal maximum application rate option.
It’s possible that limiting the number of applications would lead
growers in the Eastern US to increase rates above what they are currently
using (0.63 lb ai/A) to the maximum allowable. Limiting the number
of applications would have a bigger (initial) impact on PA and MI than
WA.
USApple and the Northwest Horticultural Council’s Mike Willett met with
EPA today to propose an alternative plan that would maintain more of the
use over the period of the phase out.
USApple proposed a framework for an agreement which included the following
issues:
I. Use
reduction proposal
II. MRL review
before the 2010 growing season to evaluate the availability of international
MRLs for azinphos methyl alternatives. (top 15 markets)
III. Apple pest management
summit in 2010 or 2011 to evaluate the state of apple pest management to
consider any need for adjustment of the schedule based upon critical need
for the chemical.
IV. Request EPA to allow
Section 18 permits or other similar regulatory mechanism for azinphos methyl
use after 2012 in cases where there is a critical need.
V. Ask EPA to reduce
its proposed 100 foot buffer to 60 feet from permanent bodies based on
data submitted showing that apple orchards have extensive vegetative buffers
which reduce runoff.
USApple proposed the following alternative schedule for phase out of the
apple use:
2008, 2009 3
lbs. a.i. maximum annual use per acre
(6 lbs. formulated product)
2010, 2011, 2012 2 lbs. a.i. maximum annual
use per acre
(4 lbs. formulated product).
EPA acknowledged that USApple’s proposal was reasonable, but further discussion
was necessary to finalize some of the issues in the agreement. A
primary concern was the need for a mechanism to demonstrate that progress
would be made in reducing the use. USApple has agreed to meet with EPA
staff on Friday, Oct. 27 to try to finalize the agreement. USApple
will continue to do everything possible to maintain the use according the
USApple proposal.
Please contact me by telephone at (800) 781-4443 or via e-mail at [EMAIL PROTECTED]
if you have questions or need additional information.
Dan DiGiacomandrea
Bayer CropScience
68 Chadwick Manor
Fairport, NY 14450
585-330-3263
Fax 585-425-8774
[EMAIL PROTECTED]
http://www.bayercropscienceus.com/rep/~dan.digiacomandrea
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