1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES MEMORANDUM SUBJECT: BEAD's Response to Comments Submitted by Stakeholders on EPA's 2005 Impact Assessments for Azinphos methyl Use in Crops with Time Limited Registration ( DP 307589)

FROM: Nikhil Mallampalli David Brassard Donald Atwood Angel Chiri Entomologists Biological Analysis Branch Stephen Smearman TJ Wyatt Derek Berwald Elisa Rim Timothy Kiely Agricultural Economists Economic Analysis Branch Biological and Economic Analysis Division ( 7503P)

THRU: Arnet Jones, Chief Biological Analysis Branch Timothy Kiely, Acting Chief Economic Analysis Branch Biological and Economic Analysis Division ( 7503P)

TO: Diane Isbell, Chemical Review Manager Margaret Rice, Chief Reregistration Branch 2 Special Review and Reregistration Division ( 7508P)

BEAD Product Review Panel date: April 7, 2006 2 Introduction This memorandum comprises BEAD's response to comments submitted by growers, farm worker representatives, and other stakeholders, addressing EPA's 2005 re assessment of the risks and benefits ( to crop production) posed by azinphos methyl ( AZM) in ten crops. These crops are almonds, apples, blueberries ( highbush and lowbush), cherries ( sweet and tart), Brussels sprouts, nursery stock, parsley, pears, pistachios, and walnuts.

First, comments from farm worker representatives and Earthjustice are summarized and addressed as a separate group, since they focused on broad aspects of the ` benefits assessment' approach undertaken by BEAD. Then, BEAD briefly summarizes comments for each crop, grouping comments similar in content that were received from grower groups, individual growers, and the AZM registrant ( Bayer Cropscience). BEAD's response to each group of comments follows the summaries. Key points that BEAD agreed or disagreed with are discussed, as are any major changes to BEAD's assessment of the biological or economic implications of the removal of AZM registration. Where BEAD determined that a comment generated economic reanalysis, a description of such work and its results is provided in BEAD's response to the specific comment. As was the case with BEAD's 2005 impact assessments ( issued earlier for public comment), this discussion of comments received is intended to contribute to risk managers' understanding of the impact of the removal of AZM use in the crops involved.

BEAD Response to Comments Summary of comments from farm worker representatives and Earthjustice These comments, from Shelly Davis of Farm Workers' Justice, along with those received from Patti Goldman of Earthjustice, can be grouped into the following broad categories. Comments often focused in particular on AZM use in apples and pears:

( 1) BEAD did not appropriately evaluate the range of grower options available to replace AZM because it ` prematurely dismissed' the viability of organic production or other ` nonchemical strategies such as mating disruption.

( 2) Phosmet utility as an AZM alternative is ` overestimated' in apples and the value of other alternatives is underestimated. Furthermore, in pears in particular, BEAD's assessment ` makes clear that AZM is no longer [ necessary]'.

( 3) BEAD did not evaluate the economic impact of reducing risks to workers due to pesticide exposure as part of its benefits assessments process.

BEAD Response BEAD's response will be grouped as per the categories described above. 3 ( 1) In each of the Agency's assessments of the impacts to growers of no longer having AZM available for use, the Agency only evaluated the alternatives it believes are commercially feasible and efficacious in comparison to AZM ( e. g., conventional pesticides, and biological pesticides or pheromone mating disruption in conjunction with limited pesticide use in an IPM program, etc.) for the control of the pests targeted by AZM. We acknowledge that there are strategies other than those discussed in the assessments available to growers to control the pests targeted by AZM. However, based on the available crop production and pest control data and the Agency's discussions with crop experts, the strategies described in the assessments are those the Agency believes are the most viable or efficacious for growers who are currently using AZM.

The Agency agrees with the commenters that pheromone mating disruption can be a viable control strategy for some of the pests targeted by AZM. However, based on the Agency's review of the available crop production and pest control data and the Agency's discussions with crop experts, the Agency does not believe that it can be a stand alone strategy for controlling the pests targeted by AZM for most growers currently using AZM. The Agency agrees that growers will continue to use pheromone mating disruption where it makes economic and biological sense to do so.

We also agree that organic production can be a viable option for growers. However, based on the Agency's review of the available crop production and pest control data and the Agency's discussions with crop experts, the Agency does not believe the most cost effective choice for most growers is to switch to organic production practices if AZM is no longer available for use. ( See also " A Cost of Production Analysis of Conventional vs. Integrated vs. Organic Apple Production Systems", Jerry Glover, et. al.; Washington State University, Agricultural Research Center Publication # XB1041).

It is important to understand that EPA's benefits assessment are designed to estimate the discrete benefits of retaining the current uses of AZM. EPA believes the best means of measuring those benefits is to determine what the most cost effective alternative scenarios are and compare those to the current costs of using AZM. EPA is not suggesting that organic production is not an available alternative. Rather, EPA's assessment indicates that organic production will not be a realistic alternative to AZM for a great majority of commercial growers and therefore should not be used as a basis for measuring the benefits of AZM. To do otherwise would tend to overstate the benefits of AZM, since in most instances the costs associated with organic production practices will exceed the costs of switching to other alternatives. 4 The commenter stressed that in rejecting organic production as a possible alternative scenario for assessing the benefits of AZM, EPA asked only what growers would likely do in the absence of AZM, rather than asking whether they could feasibly switch to organic production. EPA's assessments were not in fact so limited. EPA's impact assessments identified a number of factors why organic production does not occupy a larger portion of the market currently and is not likely to be one of the most cost effective alternatives to AZM. These factors included non chemical pest control costs, increased transactional and transitional costs, and the uncertainty in produce marketability and sustainability of current price premiums for organic produce. These conclusions were drawn based upon a review of recent data, expert opinion and EPA's professional judgment. While there are, admittedly, limited data upon which to draw conclusions as to why organic production may not be greater than it is, the fact remains that it does not currently account for a large portion of the production of the commodities under evaluation in these assessments. Thus, even if EPA were to assume that the percentage of growers utilizing organic production for some of these commodities could feasibly increase by 25%, 50% or 100% in the next few years, it would still not likely have a statistically meaningful impact on the assessment of the benefits of AZM organic production.

( 2) In making the point that phosmet utility as an AZM replacement is overestimated, the stakeholders mention that growers in Michigan ( no other regions were included) are unlikely to use phosmet as an alternative because codling moth ( CM) has shown resistance to AZM and is thus likely to be resistant to phosmet as well. They also state, in effect, that BEAD underestimated the value of other alternatives available for apple growers, but seem to focus on lepidopteran pests exclusively, even though, as BEAD pointed out in its 2005 assessment, pests of other types such as plum curculio and apple maggot are also targets of AZM use in apples. They do acknowledge that BEAD considered some of these alternatives in the pest management scenarios it discussed in the 2005 assessment.

BEAD agrees that some apple growers might use pest management options other than phosmet to replace AZM, and as the stakeholders mention, BEAD explored this in some of the scenarios for AZM replacement in apples. However, BEAD continues to believe there is a high cost for these materials compared to phosmet ( and AZM) and many, such as the insect growth regulators ( IGRs) are quite specific in their efficacy against pests ( i. e., they are much more target specific than phosmet, and are thus less ` complete' alternatives than is phosmet). BEAD estimated in its 2005 assessment that the increase in production costs generated by non phosmet alternatives in apples was quite large relative to current grower revenues. This aspect, along with the frequent need to control multiple pests simultaneously, underlie BEAD's conclusion ( which remains unchanged) that most apple growers will switch to phosmet to replace AZM.

BEAD agrees that CM resistance to organophosphates is a factor that will drive some apple growers in Michigan away from phosmet as an AZM alternative. However, the extent of this resistance across the United States is unclear. Indeed the comments received did not explain to what extent this is a factor even for Michigan growers. BEAD continues to believe that for most apple growers, phosmet will be an effective ( and as discussed above, low cost) alternative that they will probably turn to first to replace AZM. 5 Regarding the stakeholder comments focusing on the lack of utility of AZM in pears, BEAD explored in some detail the availability of efficacious alternatives to AZM now available for this crop. BEAD notes that phosmet remains an important member of the suite of alternatives, for the same reasons as it is important in apples. While BEAD agrees with the general point that AZM use can be replaced with phosmet or a combination of other alternatives, a caveat should be mentioned. While some studies show good efficacy with the newer alternatives, others show lower efficacy as compared to AZM. The reader is referred to BEAD's response to comments from California pear stakeholders ( below) for further discussion of such studies. BEAD's consideration of those studies led to some revision of the impacts on production costs of using the non phosmet alternatives ( revisions are also discussed in BEAD's response to the pear comments below). This re analysis suggests that switching to non phosmet alternatives will increase production costs appreciably compared to its 2005 assessment, and may pose a hardship to some growers. For economically struggling growers, then, phosmet may be the only feasible option. As regards organic production as an alternative to AZM, BEAD refers the reader to its 2005 responses to citations submitted by plaintiffs in UFW vs. Johnson ( Wyatt et al. 2005). BEAD's position on the feasibility of organic production as an alternative is described in detail in that document.

The Agency agrees that there are instances where it has estimated the economic impact of reducing risks to workers and the environment as a result of Agency regulations. EPA's occupational and ecological risk assessments for cholinesterase inhibiting pesticides, such as AZM, do not, however, currently provide EPA with a basis for making predictions about how many people or non target organisms will suffer adverse effects from exposure to the pesticide. EPA is not aware of any scientifically sound methodology that would allow it to do so in this instance. Without the ability to quantify potentially affected individuals, EPA cannot quantify the discrete costs to workers and the environment that could be avoided by further regulating AZM. However, EPA's risk assessments do allow EPA to predict the potential for harm to workers and the environment from such pesticides.

When potential exposures exceed EPA's " level of concern" for a pesticide, EPA believes there is not an adequate margin of safety to ensure that there will not be adverse impacts and costs to exposed people and the environment. As a general matter, the greater predicted exposures exceed Agency " levels of concern," the greater the risk that adverse effects will occur that impose costs to workers or the environment. Thus, the potential for such costs is implicit in EPA's assessment when it finds that exposures exceed Agency levels of concern. Accordingly, when, as is the case for AZM, certain Agency levels of concern are exceeded for non dietary human risk or ecological risk, EPA balances these risks against the benefits of continued use, as required by FIFRA. EPA has conducted this balancing in proposing its decision regarding the group 3 uses of AZM and has through this process taken into account the potential for worker and environmental costs. 6 Summary of comments on pears and BEAD responses Several detailed comments on BEAD's assessment of AZM on pears were received from a few stakeholders. BEAD's responses to substantive comments for this crop are presented below.

Comments from Bob McClain, California Pear Advisory Board:

1. Comparative Costs of Phosmet and Azinphos methyl Comment:

" When projecting the cost differences of two applications of AZM vs three applications of Phosmet use the cost per pound provided in Table 3 of Broc Zoller's attachment to his comment: Pesticide Use in Mating Disrupted Pear Orchards 2001 2005. These prices represent actual 2005 costs. Also, application costs need to be included which is $ 20 to $ 25 per acre. These costs include labor ( applicator), depreciation on equipment and diesel fuel. Also, one quart to one gallon of buffering agent for Phosmet needs to be included. ( Gowan will be requesting growers to buffer the Phosmet tank mix to between a PH of 4.5 to 5.5 for maximum efficacy. This is lower than stated in the Assessment and on the label).

Phosmet at a 6 pound per acre rate ( actual 70% material) is $ 37.08 per application, plus $ 20 per acre application cost and say $ 5 for buffering agent. ( Note that the 6# rate is less than the maximum rate on the label.) This amounts to a single application cost of $ 62.08 per acre. Times three applications is $ 186.24. AZM at the three pound per acre max rate ( actual 50% material) is $ 29.01, plus $ 20 per acre application cost is $ 49.01 per application. Times two applications is $ 98.02."

BEAD Response:

The material ( insecticide) cost used in the assessment is an average based on the data BEAD had available at the time the assessment was written. The Broc Zoller document was made available to BEAD in 2006, after the 2005 impact assessments were developed. The information submitted is useful for comparison purposes and is similar to the information we have regarding the chemical price per acre. The buffer cost is an additional cost that was not included in the impact assessment calculations. However, data for 1991 2005 ( Phosmet: Summary of Efficacy Studies 1991 2005, R. Spitko, Gowan, Inc.) was recently submitted by the registrant that supports the cost per application of the buffering agent. The application costs were assumed to be included based on the UC Davis Cooperative Extension 2003 Sample Cost to Produce Pears document with the exception of the estimated $ 20 application cost for the third phosmet application. However, in light of the information on the buffering agent, there may be a question about the need for 2 AZM applications to be replaced by 3 phosmet applications. The purpose of adding the buffering agent is to enhance the efficacy of phosmet so that 2 applications of phosmet would be equivalent to 2 applications of AZM. This would eliminate the need for the additional phosmet application including the costs to buffer and apply the third application of 7 phosmet. However, BEAD recognizes that even with the buffering agent added that is possible that some growers will still require an additional application of phosmet to experience the control they are accustomed to with AZM.

If, for argument sake, a third scenario was considered where 3 applications of phosmet were applied, the assumption is that the material and application costs for 2 of the 3 applications are captured in the baseline cost estimate of $ 3,862. Add $ 10 for the buffering agent for the first 2 applications plus $ 62.08 for the additional application cost plus the material plus the buffering agent. This results in a total incremental cost increase of 72.08, an approximately 1.8% increase in operating costs due to the change in control costs and change the base operating cost assumption from $ 3,862 to $ 3,934.08. This result does increase the cost impacts slightly but does not change the overall impact assessment conclusion that operating costs are expected to increase if AZM is not available. It should be noted that pest control cost increases pale in comparison to the impacts to growers are likely to experience due to increases in the costs for fuel and irrigation.

2. Comparative Performance of AZM, Acetamiprid, and Methoxyfenozide in California Comment:

" CM [ codling moth] is the number one insect pest of pear in California. In the Northwest, pear psylla is the number one pest of pear followed by codling moth. The reason CM is the number one insect pest in California is that California has more CM generations than the Northwest. More generations mean higher trap catches and higher over wintering populations to deal with the following spring. More generations require more treatments."

" For example, pear growers experience about one generation of CM per year in the Okanogan Valley in Washington State. In northern California pear growing areas we have three generations of CM. Further south in the San Joaquin Valley ( Fresno and Tulare Counties), there are four generations of CM. Thus, CM pressure is much greater in California than in the Northwest. Our trap catches are as much as 300 percent higher in California than the Northwest. "

" In Attachment A [ of BEAD's analysis] there is no column that represents the efficacy of these alternatives in California. Due to the increased number of flights and population in California many of the newer reduced risk alternatives would move down to Poor or Fair from Fair to Good and Good to Excellent. You need to contact Bob Van Steenwyk at UC Berkeley to come up with a fair representation of the efficacy of these alternatives in California. Much of this efficacy work and how the alternatives affect mites and pear psylla populations is on our web site www. calpear. com."

BEAD Response:

BEAD acknowledges that codling moth populations in California are higher and potentially more damaging than those in Oregon and Washington. Attachment 1 of BEAD's original analysis ( Brassard and Smearman 2005) did include efficacy judgements in two columns 8 based on the review of California efficacy data. These judgements, listed under the column entitled " From Efficacy Data Submitted by Bayer ( White 2004)" were based on five California efficacy studies and one Washington State study. The studies reviewed and the efficacy judgements attained were listed in attachment 2 of BEAD's original assessment. BEAD also included efficacy judgments from the " Pest Management Strategic Plan for Pear Production in California" ( USDA 2003) in Attachment 1.

BEAD recently contacted Dr. Robert Van Steenwyk at UC Berkeley to obtain his current opinion on the effectiveness of alternatives to AZM for codling moth control. Dr. Van Steenwyk believes that, due to higher codling moth population pressures in California, acetamiprid and methoxyfenozide are not as effective as AZM. Dr. Van Steenwyk stated that growers would have to make four applications of acetamiprid plus 2 applications of methoxyfenozide or diflubenzuron to replace the grower's standard treatment of two applications of AZM and one application of phosmet on pears. Dr. Van Steenwyk cited his publications in the California Pear Advisory Board website and in Arthropod Management Tests as the basis for this opinion.

BEAD reviewed these data and disagrees with Dr. Van Steenwyk's conclusion that additional applications of acetamiprid and methoxyfenozide would be required to control codling moth in California. In one study, three applications of acetamiprid were as effective in controlling high populations of codling moths as two applications of AZM and one application of phosmet ( Van Steenwyk et al., 2003). In another study, two applications of acetamiprid were equal to or more effective in controlling high populations of codling moths as one application of AZM and one application of fenpropathrin ( Varela et al., 2003). In two other studies, 2 applications of thiacloprid ( a neonicotinoid with activity similar to acetamiprid) and one application of methoxyfenozide were as effective as 2 applications of AZM and one application of phosmet in controlling high populations of codling moths ( Van Steenwyk et al., 2004; Van Steenwyk et al., 2003).

However additional data ( reviewed by BEAD) from 33 heavily infested apple orchards in Washington do appear to support Dr, Van Steenwyk's statements ( Brunner et al., 2005). In these efficacy tests, the grower standard ( AZM and/ or phosmet) provided significantly better control of codling moth than acetamiprid in 20 out of 33 trials. AZM averaged 94% control in these trials compared to 82% control achieved by acetamiprid. These data suggest that two applications of acetamiprid plus one application of methoxyfenozide may be required to achieve levels of control equivalent to two applications of AZM.

The change from 1 application to 2 applications of acetamiprid plus 1 application of methoxyfenozide will increase control costs in California pear production by an additional $ 43 due to the cost of a second application of acetamiprid. The change in control costs without the availability of AZM would increase to $ 112. This would increase production costs from the base production cost of $ 3,863 ( revised in 2006 from the $ 4,129 2005 assessment; see response to number 3 below) to $ 3,975, an increase of approximately 2.8 percent. 9 3. California Pear Prices are much lower than BEAD estimate Comment:

The average price in 2004 for pears in California was not $ 503 per ton including fresh and processed pears. As Broc Zoller stated in his comment for the Late District ( Mendocino and Lake Counties) the returns for 2004 varied from $ 150 to $ 220 per ton. For the Early District ( Sacramento Valley) the 2004 returns varied $ 160 to $ 223 per ton with the average per ton price at $ 182. ( McClain, personal communication with Sacramento Valley growers and shippers.)

BEAD Response:

BEAD based the 2005 estimate on the average price per ton for pears using 2004 USDA data and University of California Cooperative Extension 2003 Sample cost to Produce Pears document to estimate the net impact of operating expenses for California pear producers. In determining the impacts for its 2005 reassessment, BEAD used available data to develop estimates for scenario impacts. BEAD realizes that prices and costs vary from region to region but BEAD uses the average for cost and price based on available data sources.

There is an alternative assumption BEAD could have used for its 2005 estimate of the average price per ton for pears. This involves using published USDA data ( for 2004) and the University of California data ( for 2003) on pear production costs ( UC Davis Coop Ext. 2003) , to estimate an impact net of operating expenses for California pear producers. This assumption is similar to the impact scenario estimate [ in the 2005 Assessment]. However, it would also assume that California producers average about 16 tons per acre with an average price of $ 298 per ton instead of $ 503 per ton for all pear production ( USDA 2005 Ag Stats). Using the 16 tons per acre production estimate, the operating costs are estimated to be $ 3,862 per acre instead of the average variable cost per acre of $ 4,129 ( UC Davis Coop Ext. 2003).

Under the second assumption, revenues are estimated to be $ 4,768 per acre with net revenues per acre estimated to be approximately $ 906 per acre. If we maintain the same operating costs assumptions as in the original scenario, variable costs would increase due to the increase in the number of applications from 2 AZM applications to 3 applications for phosmet. The percentage change to net revenue ranges from less than 1% under the first scenario to 4% under the second scenario. While this means that some growers would be more negatively affected than was suggested by BEAD's 2005 analysis, it should be noted here that this assessment is based on average price, production cost and yield estimates for California pear growers, which means that many other growers would not see the larger negative impacts.

A third scenario where there are 3 applications of phosmet to replace 2 applications of the AZM has been addressed above. ( See response to comment number 1) 10 4. Comments from Charles Goodman, California Department of Food and Agriculture Comment:

The grower impact assessments for apples and pears seem to incorporate some outdated assumptions. In pears, for instance, the analysis assumes that current practices include two AZM applications; the latest DPR pesticide use data shows that about half of California pear growers apply AZM just once. Moreover, the stated application rate and product price are incorrect. In addition, novaluron is not registered in California either for pears or apples. Accurate application costs should be obtainable by contacting University of California Cooperative Extension pest management experts. The suggestion that growers employ multiple phosmet applications seems inappropriate since that chemical, too, is under EPA review and thus could be lost. Finally, some of the impact assessment scenarios incorporate relatively costly insecticides and pheromones that could drive out marginal growers.

BEAD Response:

According to California Department of Food and Agriculture's 2004 Pesticide Usage Report ( CDFA, 2006) California pear growers apply an average of 1.6 applications of AZM to pears annually. The median number of applications is 2 and a small percentage of growers apply 3 applications annually. BEAD's previous analysis ( Brassard and Smearman 2005) did fail to mention that novaluron was not yet registered in California, ( although it was granted a U. S. EPA registration in May, 2004). BEAD, however, did not include novaluron in its likely replacement scenarios and, therefore, the absence of a California registration for novaluron does not materially affect BEAD's previous analysis or conclusions.

BEAD acknowledges that phosmet application rates are higher in California than in Oregon and Washington and recalculated grower level impacts in its response to Comment Number 1 above. The recalculation resulted in minor differences in production costs which do not significantly change BEAD's conclusions regarding the benefits of azinphos methyl for pears. BEAD acknowledges that some of the alternatives are costlier than azinphos methyl but does not believe that these cost increases alone ( 2.8% increase in operating costs) would be of sufficient magnitude to drive growers out of business compared to the cost increases for expenses such as fuel and irrigation.

5. Comments from Broc Zoller, PhD, The Pear Doctor, Inc Comment:

Some of the softer IGR materials such as Confirm ( tebufenozide), Intrepid ( methoxyfenozide), Success ( spinosad), and Esteem ( pyriproxyfen) are used to augment MD [ mating disruption] in preference to AZM. However, situations exist where the greater efficacy of AZM is critical to maintaining CM populations in problem areas. AZM augmentation of MD is often necessary in the transition process to MD plus purely softer alternatives. [ A better and preferred material for this use had been Penncap ( encapsulated methyl parathion), which had been the most effective adulticide against CM. However, this material may no longer be used, 11 and this transition burden falls on the currently less effective AZM.] Premature use in the transition process of the organophosphate Imidan [ phosmet] or of the less effective, newer IGR materials ( or no material at all to augment MD) have sometimes resulted in difficulties requiring AZM use the next season.

These favored IGR materials are used for their selectivity in augmentation of MD programs because of less likelihood for disruption of natural control of other pests such as pear psylla and spider mites. They are, however, the weaker alternative materials in CM efficacy and two of them, Esteem and Success, are somewhat disruptive to beneficials. Stronger alternatives, such as Assail ( acetamiprid) and Calypso ( thiacloprid), ( as well as organophosphates AZM and Imidan), increase the use of miticides and psyllacides in our MD programs. Another stronger alternative is Rimon ( novaluron) which is not yet registered for use on pears in California, in contrast to the analysis in the Memorandum, 2005 Grower Impact Assessment for Azinphos Methyl Use on Pears ( Brassard and Smearman 2005) . This material is likely a disruptive choice, as well. Some of the other materials listed as alternatives to AZM are not regarded as effective enough to be real choices in CM control. These include Agrimek ( abamectin) and Actara ( thiamethoxam). Applaud ( buprofezin) has no California registration for pears.

BEAD Response:

As stated previously ( in the response to Bob McClain's comment), BEAD's review of available product performance data led to the conclusion that the alternatives phosmet, methoxyfenozide, and acetamiprid are as effective as AZM in controlling codling moth, however growers may have to apply these materials more frequently.

Also stated in a previous response was the point that BEAD's previous analysis ( Brassard and Smearman 2005) did fail to mention that novaluron was not yet registered in California, ( although it was granted a U. S. EPA registration in May, 2004). BEAD, however, did not include novaluron in its likely replacement scenarios in 2005. Therefore, the absence of a California registration for novaluron does not materially affect BEAD's previous analysis or conclusions. Dr. Zoller also commented that AZM and its alternatives can be disruptive to beneficial insects and secondary pest populations. BEAD's review of the available data indicate that AZM was often more disruptive of beneficial insects and secondary pest populations than methoxyfenozide ( Van Steenwyk et al., 2003). BEAD believes it is not appropriate to assume that the alternatives will disrupt beneficial pest populations and therefore did not change its assumptions in the analysis described in other responses ( above).

6. Comments from Lamar Buckelew, Bayer CropScience Comments:

A program that relies solely on one class of chemistry or mode of action, such as in the case of scenario 1 [ 3 applications of phosmet replacing 2 applications of AZM], runs counter to IPM theory in general and resistance management specifically. Scenario 1 is therefore deemed not practically feasible. Scenario 2 can be considered certainly more biologically pragmatic than 12 scenario 1 but is also projected to increase chemical control costs by 24%. BEAD attempts to negate this somewhat by stating this is less than 1% of the total crop value. However, fact remains that the grower input costs budget for insecticides would need to increase by a minimum of $ 33 per acre treated under scenario 2.

BEAD Response:

One class of chemistry, organophosphate insecticides, has been the grower standard for codling moth control for many years. BEAD acknowledges the importance of IPM and its 2005 analysis presented two scenarios as examples of how growers are likely to respond in the absence of AZM. However, growers have many other control options available ( e. g. thiacloprid and diflubenzuron) and can mix and match several different classes of insecticide chemistries in order to achieve pest management and manage resistance. Operating costs are increasing not only because of the increase in control costs but also because of the rise in fuel and energy costs that have increased by as much as 75% over the previous production year.

7. Comment:

Scenario 2 ( acetamiprid and methoxyfenozide) does not take into account the possibility of the need for a miticide following acetamiprid use as well which will add the cost of the miticide and application costs.

BEAD Response:

BEAD acknowledges that any change in insecticide control strategies run the risk of causing secondary pest outbreaks and necessitating the application of other insecticides or miticides. BEAD's review of available product performance data led to the conclusion that mite outbreaks from acetamiprid application were uncommon and that AZM was as likely to cause secondary outbreaks of pear psylla or San Jose scale as were the alternatives discussed in the 2005 assessment. ( Brassard and Smearman, 2005).

Summary of comments on apples and BEAD responses Several detailed comments on BEAD's assessment of AZM in this crop were received. BEAD addresses the major comments with the responses immediately following ( the same format as was done for pears).

1. The following comments are excerpted from statements submitted by Dr. Arthur M. Agnello, Dept. of Entomology, Cornell University.

Comment:

" The primary target pests of AZM applications in NY are plum curculio and apple maggot  . codling moth and oriental fruit moth are generally of secondary importance or are assumed to be controlled by applications made against the former species." 13 BEAD Response:

BEAD acknowledges that the plum curculio and apple maggot are major pests in New York apple production. However, as the eastern region includes numerous unique local apple production systems with variation in primary and secondary pests between and within different production areas, BEAD provided information for all pests which may be of primary importance in the Eastern Region.

Comment:

" Use of pheromones in NY and other eastern locations  . Some orchards with chronically high CM [ codling moth] and OFM [ oriental fruit moth] population pressure do now receive MD treatments on a regular basis in this region, but the acreage represented by this tactic is still a very small percentage in most states ( 1 2% in NY, and probably not much more than 5% in PA or even MI); also, this is never a stand alone treatment, but rather is combined with selective insecticides, and is still in a relatively early assessment phase by most growers, who are in the process of determining the specific dispenser technology, application timing, trap monitoring details, and target efficacy levels applicable to their situations. Most apple plantings with an internal lep problem do not have only a single species present, and usually must direct their management efforts against both CM and OFM ( with the possible addition of LAW in some cases), which requires the application of 2 separate MD products, which often involve different application timings."

BEAD Response:

BEAD agrees that pheromone mating disruption is limited to areas with populations of codling moth and Oriental fruit moth which are largely secondary pests in New York apple production. The data provided are in agreement with the BEAD conclusion that pheromone mating disruption is limited to approximately 5% of eastern U. S. apple production. In its 2005 AZM assessment, BEAD also reflected the need for 2 mating disruption programs for codling moth and Oriental fruit moth which substantially increases the costs of these programs in the Eastern apple production region.

Comment:

" Alternative insecticides for internal Lepidoptera control  . In NY, as in the other eastern states, orchards under conventional insect management programs experiencing problems from internal lep species would likely go through a series of increasingly aggressive insecticide program modifications before MD was considered, including shorter spray intervals, higher rates, more sprays and increased coverage using conventional OP's, alternations with pyrethroids, followed by more selective specialty materials such as B. t., indoxacarb, methoxyfenozide, and neonicotinyls such as acetamiprid ( and thiacloprid, once it is registered in NY, as anticipated this spring). Kaolin clay is not generally used in most commercial NY 14 orchards, primarily because of its higher cost, frequent application requirements, and tendency to wash off during summer rain events. CM granulosis virus has only recently been registered and is not widely used; however, it would not be expected to represent a reasonable alternative because of its limited activity against OFM. Novaluron and clothianidin are not currently registered in NY."

BEAD Response:

BEAD appreciates the information regarding the alternative insecticides which would be used for Lepidoptera control in New York apple production. However, BEAD believes that the most likely alternative to AZM will be phosmet. This is based on grower familiarity with its use, its equivalent efficacy to AZM, and the ability to control secondary pests while targeting the primary pests, plum curculio and apple maggot. While Bt, indoxacarb, methoxyfenozide and acetamiprid do display good efficacy against the lepidopteran pests, control of these pests is more likely to occur through a phosmet spray program targeted at the primary pests in New York apple production without additional insecticide applications. In addition, it is not feasible for the BEAD analysis to develop scenarios which reflect all available potential spray programs and combinations. BEAD does agree that kaolin clay and CM granulosis virus are not potential alternatives for control of Lepidopterous pests in New York apple production due to higher cost, frequent application requirements, tendency to wash off during summer rain events. Also, their recent introduction for pest control in apple production has not provided sufficient experience to encourage their wide acceptance among growers.

Comment:

" Assessment of Proposed Scenarios if AZM were no longer available . First Scenario   In contrast to situations proposed in the western and other eastern states, the substitution of phosmet for AZM in summer spray programs would be a reasonable outcome in NY, inasmuch as phosmet is regarded as equivalent to AZM in efficacy against plum curculio and apple maggot, the two primary OP targets. Moreover, it is not envisioned that 4 applications of phosmet would be needed to replace 3 of AZM, and no measurable yield loss due to increased fruit damage would be anticipated. This spray for spray substitution is actually beginning to occur already in NY, as a result of increased AZM REI and use restrictions as well as greater scrutiny for AZM fruit residues by some buyers. It is acknowledged that phosmet is more expensive than AZM on a per use basis; NY estimates for commercial formulations are approximately $ 14/ A for AZM, and $ 16.50/ A for phosmet, based on the average rate use provided in Table 7; this would result in a 3 spray program of phosmet being only about 1.2 times greater than using AZM. These assumptions pertain to orchards in which CM or OFM were not problem pests."

BEAD Response:

BEAD agrees that the first scenario, which is phosmet alone as an AZM replacement, would be the most likely scenario in the absence of AZM for New York apple production. BEAD is in agreement with the commenter that phosmet can be a one to one replacement for 15 AZM. BEAD also appreciates the information provided as to no measurable yield loss due to increased fruit damage.

Comment:

" Assessment of Proposed Scenarios if AZM were no longer available . Second Scenario   Inasmuch as novaluron is not currently registered in NY, we would assume a comparable scenario using single applications of some of the other specialty insecticides that have activity against internal leps as well as other summer insect pests requiring treatment in NY ( plum curculio, oblique banded leafroller, and apple maggot), such as methoxyfenozide, indoxacarb, acetamiprid, and thiacloprid ( when registered). Because treatments for these pests vary according to local population pressure, it is difficult to generalize about the number of sprays of each product that would be applied. However, it is reasonable to propose a representative post bloom program that could consist of as many as 4 total applications using various combinations of these products. Depending on rates used, such a program would cost a maximum of between $ 123 and $ 141 per acre, which would be 2.9  3.3 times more expensive than the AZM program. No yield loss due to fruit damage would be anticipated in this scenario, as most CM/ OFM populations are still susceptible to these products."

BEAD Response:

BEAD was not aware that novaluron is not registered for use in New York State. However, this scenario was developed for all eastern production regions and should still be considered a viable option for other apple growers in the Eastern United States. BEAD, however, does agree with the commenter that other currently registered alternatives to novaluron, specifically methoxyfenozide and indoxacarb, would compliment a spray program incorporating the use of acetamiprid and thiacloprid."

Comment:

" Assessment of Proposed Scenarios if AZM were no longer available . Third Scenario   The proposal of substituting pheromone MD for 2 of the AZM sprays is not applicable in NY because these products would not affect plum curculio or apple maggot populations. A comparable scenario involving MD for internal leps in the summer would translate into application of two pheromone products for MD of OFM and CM, which would cost approximately $ 140 per acre, plus 1  2 applications of the neonicotinyl products noted above for apple maggot, which would add $ 72  83 to the spray bill, for a total increase of $ 212  223 per acre, which would be 5.0  5.3 times as expensive as a 3 spray AZM program ( but only 1.5  1.8 times more than the second scenario above)."

BEAD Response:

BEAD is in agreement that third scenario, mating disruption, is not a viable option for New York apple production due to the secondary pest status of codling moth and Oriental fruit moth at which it is targeted and the additional expense associated with these products. 16 2. The following comments are excerpted from statements submitted by Dr. Jay F. Brunner, Tree Fruit Research and Extension Center, Washington State University.

Comment:

" Spectrum of pests ( western US) controlled by AZM .. Leafrollers, San Jose scale and aphids are listed in the report as being targets of AZM. In Washington leafrollers are NOT a pest controlled by azinphos methyl ( AZM) and likely not used as a primary control of LR in CA or other western states. San Jose scale may be suppressed by AZM ( second codling moth cover spray) but it is not relied upon for the primary means of control of this pest. Aphids are NOT controlled by AZM."

BEAD Response:

BEAD's 2005 grower assessment indicates that leafroller, San Jose scale and aphids might be controlled by AZM. This information came directly from the 2001 impact assessment ( Anderson and Kiely, 2001). However, the 2005 grower impact assessment dealt only with the primary pests targeted with AZM application in the Western region, specifically codling moth and apple maggot.

Comment:

" Use of pheromones ( mating disruption   MD) in WA and other locations .. between 2000 2004, about 50 percent of apple acreage was treated with pheromones for CM control ( CMMD) in WA. The acreage treated with CMMD in WA in 2005 is estimated to be nearly 65% of the apple acreage ( 120,000 acres treated). Most pear acreage in CA is treated with CMMD but the percentage apple acreage treated with pheromone is likely much lower. In OR there is some use of CMMD in apple but the percent area treated is likely much lower than in WA. Cost of CMMD is a major concern in the western US, as it is elsewhere. The high cost has resulted in growers using less than full rates, which compromises the full effect of the technology and as a result requires increased use of supplemental insecticides to achieve acceptable commercial levels of crop protection. Very few orchards will be able to reduce CM populations to levels where CMMD will be a stand alone control for CM. It is possible with a concerted effort to reduce CM densities to levels where lower rates of pheromones can be used with one or two supplemental insecticides and this is a common management program in many WA orchards."

BEAD Response:

BEAD appreciates the update on percentage of acreage currently using MD in various areas of apple production in the Western US. As the BEAD assessment was limited to apple production in the total western region of the US, BEAD agrees that discrepancies will occur among individual production areas. BEAD is not in a position to conduct a discrete assessment of each individual apple production area in the Western production region. BEAD does agree that high codling moth population densities ( as influenced by availability of alternate hosts, meteorological conditions, geographic conditions, and distribution of MD use within an area) are a limiting factor in adoption of MD in some production areas. However, this information does not change the conclusions of the BEAD 2005 grower assessment. 17 Comment:

" Alternative insecticides for CM control .. The use of kaolin clay (" Surround") for CM control is not a practical approach. Seasonal use of this product results in increased spider mite problems and it also interferes with biological control of leafminers. The statement that CM granulosis virus ( CpGv) is not effective against first generation CM is not true. CpGv is effective against CM in the first generation and can be a very good fit in an integrated pest management program that incorporates bio pesticides. The use of CpGv in the second CM generation makes sense where highly effective larvicides and ovicides are used against in the first CM generation. CpGv is best used in conjunction with CMMD where it will provide suppression of resident CM population. The negatives associated with use of the CM virus in the second CM generation are high temperatures and high UVL intensity, both of which degrade the virus. Other alternatives for CM control not listed in the EPA BEAD review include methoxyfenozide, mineral oil and pyriproxyfen. All of these products are considered to have as high or higher efficacy than kaolin against CM with fewer negative side effects."

BEAD Response:

BEAD agrees that kaolin clay is not a practical approach for CM control in all areas of apple production, particularly in the western production region where apple maggot is not the primary pest. This was noted in the 2005 Grower Impact Assessment. BEAD acknowledges that CM granulosis virus ( CpGv) can be effective in a bio pesticide control program. However, as this is a newer technology, little information is available on its use. Numerous studies in the past have indicated highly variable results using CpGv. While BEAD does believe that CpGv has potential against CM, additional time will be needed for the development of acceptable control programs based on this product and for acceptance by the grower community. As such, BEAD does not believe sufficient information exists to conclude that CpGv is a viable alternative at this time. Although not discussed in depth in the document, as noted in Table 5 on page 7, BEAD did evaluate methoxyfenozide, mineral oil and pyriproxyfen as alternatives. Data obtained from the 2005 Washington State Fruit Production Guide does indicate that these 3 alternatives are more effective than kaolin clay. However, none of these products is rated better than good for CM control and therefore BEAD believes grower impacts would be greater if the alternatives were used.

Comment:

" Assumptions of statements relative to the use of AZM in western states .. In the Pacific Northwest switching to the use of phosmet is not the most likely scenario that would occur if AZM were not available. Increased use of phosmet would likely occur if AZM was no longer available but it is more likely that there would be a greater shift to newly registered alternatives due to the lack of the industries confidence in phosmet as an effective CM control and the cost of phosmet relative to newer insecticides that might be perceived as more efficacious or hold additional value in the control of other pests.

On average the substitution of 4 application of phosmet for 3 applications of AZM is a reasonable model to use in this kind of analysis, however, in some high pressure situations ( 15 18 20% of orchards) three applications of AZM is not sufficient to achieve acceptable levels of crop protection and therefore four applications of phosmet would not be sufficient to achieved acceptable control of CM. Using average usage patterns always represents a problem in dealing with other orchard situations that have high than average pest pressures and thus would not be able to achieve acceptable control with the " average" use of products."

BEAD Response:

BEAD presented Scenarios 1 and 2 ( phosmet only and alternative non OP insecticides, respectively) in an attempt to identify the most likely scenarios available to growers in the absence of AZM. While a large percentage of growers may move to an all non OP alternative insecticide solution, others would likely use the insecticide they are familiar with at this time. BEAD agrees that there are limitations in using average usage patterns in estimating number of pesticide applications and would appreciate any available data that would provide usage distribution information related to number of applications for the western region. However, data received from the phosmet registrant indicates that phosmet can be an exact replacement for AZM when buffered properly. BEAD believes that phosmet usage would not substantially differ from that of AZM and that 3 instead of 4 phosmet applications would provide sufficient control in most orchards. In addition, the fourth phosmet application supported in our first scenario would allow for the control necessary in orchards experiencing high codling moth densities Comment:

" Diversion of CM injured fruit from the yield loss category to the quality reduction category .. Processors have become almost as averse as fresh markets for acceptance of CM injured fruit. Therefore, the concept of diverting injured fruit into processing is not a very rational alternative given current constraints. CM injured fruit would more likely be discarded ( therefore reducing yield not shifting yield to a processing category) with NO value to the grower. The EPA BEAD report does note that if infestation rates were too high in processor lots these would be rejected. While this might have a greater impact on the eastern growers it is not without significant impact on the western apple growers. In addition the value of processing fruit for western growers, especially fruit, is way below the cost of production and thus any diversion to processing only reduces economic loss."

BEAD Response:

OPP's estimate is based on the yield and quality losses from the 2001 assessment, available published data and information from the regulated community. Without quantifiable alternative yield and quality loss estimates, BEAD will maintain the yield and quality loss assumptions presented in the impact assessment.

Comment:

" Comments relative to use of neonicotinyl insecticides in western orchards .. The use of two applications of neonicotinyl insecticides ( NNI) is an acceptable alternative to replacement of AZM in many but not all WA orchards. WSU recommends use of only two NNI in a year but 19 these should be used against the same generation of CM. The use of NNIs is complicated by availability of NNIs that are effective against other pests ( primarily aphids) that could be used at a time CM is active and therefore selected for resistance even though it is not the primary target of the treatment. The use of two NNIs in one season would not likely increase spider mite populations in treated orchards in one year, however, there is enough evidence in recent literature and from our experience to suggest that with other perturbation factors present in apple orchards it is likely that the long term use of more NNIs will lead to increased problems with spider mites [ Beers et al. 2005]. Increased problems with spider mites would result in the need to apply more specific miticides than has been true historically in WA. In addition, the use of NNIs with novaluron could lead to stimulation in spider mite problems ( E. H. Beers, personal communication). There is also evidence from eastern apple orchards novaluron can result in increased spider mite problems."

BEAD Response:

BEAD agrees that neonicotinyl insecticides ( NNI) should be targeted against the same generation of CM. However, BEAD is not in full agreement over the increase in mite populations over several years. One available publication indicates that use of NNI's and alternative insecticides did not result in increased problems with scale, aphids, mites or sucking bugs in 15 apple orchards over a 3 year period ( Brunner et al. 2004). However, any additional information that that the commenter can provide to indicate stimulation of spider mite problems by AZM alternatives would be appreciated.

Comment:

" Comments on use of novaluron .. The use of novaluron could reduce costs of leafroller control and offset, to some extent, the expense of the second scenario, but there is only limited experience using this product in commercial orchard situations and preliminary evidence suggests that it will add to the perturbation of spider mite biological control."

BEAD Response:

BEAD appreciates the information on the additional benefits of novaluron on leafroller populations. However, as the 2005 assessment was primarily concerned with control of the primary apple pests, this additional benefit will not change our conclusions but adds additional support to some percentage of growers switching to non OP alternatives ( Scenario 2). In addition, as pointed out, there is limited experience with this product in commercial orchard situations. Because of this, BEAD believes that many growers may choose to use phosmet in the place of alternative non OP insecticides.

Comment:

" Specific comments relative to the three proposed scenarios for AZM replacement  First Scenario   The assumption of a substitution of phosmet for AZM is not the most likely shift that would take place in WA orchards simply because phosmet is not perceived as an effective control for CM. However, for the sake of this analysis it is not an unreasonable 20 scenario to examine. Prices used for insecticides in the EPA BEAD analysis are not what WA growers would likely pay. Based on retail prices ( see table below) the cost of AZM is $ 12.41 per pound. Many growers using AZM at a rate of 3 pounds if used only one time but under a three application program only 2 pounds per acre would be used so the cost per application would be $ 25 per acre ($ 37 per acre for a three pound application). A three treatment program of AZM would cost the grower $ 75 per acre. Phosmet ( Imidan) costs about $ 8.75 per pound ( see table below). Growers in WA use the maximum rate allowed for CM control, which is roughly 5 pounds. Thus, the cost per acre for a phosmet application would be $ 44 ( 5 pounds * $ 8.75/ lbs.). Therefore a replacement program of phosmet ( 4 applications) would cost $ 176 per acre versus $ 75 per acre for a 3 AZM application program. In addition, there would need to be added the extra cost of an application of phosmet ($ 20 per acre) since there is an assumption of one more treatment per acre. The cost of this to the grower in the west would likely be a real increase since trips through the orchard are not as common as occurs in eastern apple orchards. Adding the cost of an extra application to the phosmet substitution program would make it $ 196 per acre compared to $ 75 per acre for AZM, or a difference of $ 121 per acre. The assumption of a substitution of phosmet for AZM is not the most likely shift that would take place in WA orchards simply because phosmet is not perceived as an effective control for CM. However, for the sake of this analysis it is not an unreasonable scenario to examine. Prices used for insecticides in the EPA BEAD analysis are not what WA growers would likely pay. Based on retail prices   the cost of AZM is $ 12.41 per pound. Many growers using AZM at a rate of 3 pounds if used only one time but under a three application program only 2 pounds per acre would be used so the cost per application would be $ 25 per acre ($ 37 per acre for a three pound application). A three treatment program of AZM would cost the grower $ 75 per acre.

Phosmet ( Imidan) costs about $ 8.75 per pound   Growers in WA use the maximum rate allowed for CM control, which is roughly 5 pounds. Thus, the cost per acre for a phosmet application would be $ 44 ( 5 pounds * $ 8.75/ lbs.). Therefore a replacement program of phosmet ( 4 applications) would cost $ 176 per acre versus $ 75 per acre for a 3 AZM application program. In addition, there would need to be added the extra cost of an application of phosmet ($ 20 per acre) since there is an assumption of one more treatment per acre. The cost of this to the grower in the west would likely be a real increase since trips through the orchard are not as common as occurs in eastern apple orchards. Adding the cost of an extra application to the phosmet substitution program would make it $ 196 per acre compared to $ 75 per acre for AZM, or a difference of $ 121 per acre . It appears in the EPA BEAD analysis the average rate of an insecticide from NASS surveys is used to help determine the cost of a treatment scenario. There is a logical flaw in this reasoning. Growers do not use an average rate for an insecticide treatment. If they are going to control CM they will use the most effective rate, usually the highest rate on the label. When comparing AZM with alternatives in an analysis of this kind the most efficacious rate for CM control for each insecticide should be used, not the average rate from a national survey. See the table above for the rates ( formulated product) that would most likely be used in WA orchards for control of CM. The cost information from Table 7 in the EPA BEAD analysis indicates that using the AZM alternative, phosmet, in the first scenario would cost $ 60 per acre and that the AZM would cost $ 42 per acre. Based on more realistic prices for these products the cost of the phosmet program should have been $ 196 ( including the cost of an extra application) compared to $ 75 per acre for AZM. Therefore the phosmet program is 2.6 times the cost of the AZM program very close to the 2.5 used in the EPA BEAD report. 21 This is only a small difference but the total cost of insect control is much higher than predicted given the scenario being analyzed."

BEAD Response:

BEAD presented the first scenario ( move to phosmet) to illustrate the range of options available to growers in the event that AZM is no longer available. Though it may not be the most likely shift from AZM, it is representative of a least a portion of the growers. BEAD is limited to using available data and expert opinion in the development of our impact assessments. BEAD assumed the material cost is an average based on the data BEAD has available. The control cost information submitted is useful for comparison purposes and is similar to the information we have regarding the chemical price. The phosmet registrant recently submitted data that compares the efficacy of AZM and phosmet and found that if phosmet is properly buffered using a buffering agent ( cost: about $ 5 per acre) that phosmet was equally as efficacious as AZM ( Spitko, 2006).

The application costs are already assumed to be included based on information on production economics from the University of California ( UC Davis, 2001). An exception to this is the estimated $ 20 application cost for the fourth phosmet application. However, in light of the recent buffer efficacy data, there is a question as to the validity of the BEAD scenario that assumes 3 AZM applications would be replaced by 4 phosmet applications. The purpose of adding the buffering agent is to enhance the efficacy of phosmet so that 3 applications of phosmet would be equivalent to 3 applications of AZM. This would eliminate the need for the additional phosmet application including the costs to buffer and apply the fourth application of phosmet. It is not clear why there would be the need for the additional application if the buffering agent is added. If a fourth scenario had been considered based on the using the buffering agent, it would be assumed that the buffering agent cost $ 15 ($ 5 x 3 applications) plus the difference in the material cost $ 24.21 ($ 8.07 x 3 applications) that BEAD estimated would result in a total incremental variable cost increase of $ 39.21 per acre for growers to transition to phosmet because the efficacy enhancement of the buffering agent would give phosmet the same control as AZM. This would eliminate the need for an additional 4th application and associated application costs. This amounts to a 1.6% increase in variable costs using the production cost of $ 2,411 as the base variable cost as outlined in the impact assessment.

BEAD acknowledges that there are limitations to its analysis, in that it includes the use of average rate of application information. As much as possible, BEAD uses publicly available data ( such as that provided by the USDA) in order to maintain the transparency of our analysis. However, we would greatly appreciate any distribution of rate information the commenter could provide in regards to apple production in the Western US to improve our analysis.

Comment:

" Specific Comments relative to the three proposed scenarios for AZM replacement  Second Scenario .. The products used in the second scenario as an alternative CM control program for AZM represents a possible, though maybe not the most logical, program for WA growers. Even so the assumptions used in the report are flawed based primarily on the prices of 22 the products. Novaluron is an insecticide that has been used for only one season in WA. Novaluron is priced at $ 1.70 per ounce and 32 fl. ounces ( or more) are used for CM control in WA orchards. Thus, the cost per acre is $ 54 not $ 20 as reported in Table 7 of the EPA OPP analysis. Since there is no data on novaluron use in apples prior to this report either the high label rate should have been used or the typical label rate from research trials should be used, that is the 32 fl. ounces per acre. Acetamiprid is used at a rate of 3.4 ounces for CM control in WA as a replacement of one AZM treatment. The cost of an application of acetamiprid would therefore be $ 52 per acre. Thiacloprid is used at a rate of 6 fl. ounces per acre for CM control at cost of $ 8.42/ fl oz, which results in a cost of $ 50 per acre per application. The rates used for the NNIs should be as shown in the table above. When the NNIs are used for aphid control the rates used are much lower ( about half) compared to those used for CM control. Therefore it is inappropriate to use an average rate per acre in NASS or other use surveys for determining costs of CM control programs.

The current best estimate for WA is that about 65% of apple growers are using CMMD of one kind of another. The lowest cost for this technology is about $ 100 per acre for a full use rate plus $ 15 20 per acre for application. A much more realistic second scenario should include CMMD at half to three quarter the full field rate for at least 50% of the acreage treated plus the cost of the alternative insecticides. This is the program that is currently followed for uses of AZM and is a much more realistic assessment for the economic cost of CM control programs in WA. Other products that could likely be used in the second scenario include methoxyfenozide, pyriproxyfen, mineral oil, and CpGv ( CM virus), all likely in conjunction with CMMD.

The cost information from Table 7 in the EAP BEAD [ 2005] analysis indicates that using the AZM alternatives in the second scenario would cost $ 105 per acre. However, based on real prices and rates the program would cost $ 212 per acre ( acetamiprid$ 52 + thiacloprid$ 50 + two novaluron$ 110). Like the first scenario the cost of an application ($ 20) should be included, putting the total cost to $ 234 per acre. The second scenario would therefore be about 3.1 times more expensive than the AZM 3 application program. The pest control cost increase would be $ 162 per acre not the $ 63 per acre stated in the EPA BEAD analysis.

The EPA analysis assumes that no yield or quality losses would accompany the use of AZM alternatives in the second scenario. However, there is really not sufficient commercial experience to confidently claim that there would not be losses of yield or quality. Evidence from numerous recent research field trials would suggests that all the alternative products used in the second scenario are close to AZM in control of CM but none provide an equal level of crop protection as AZM. In several years of field trials in WA, AZM under high pressure situations provided an average of 94.2% reduction in fruit injury relative to the untreated control. Acetamiprid and thiacloprid provided 82.2 and 71.0% reduction in fruit injury, respectively ( Brunner et al. 2005). Some of the differences in lower efficacy are related to experiments where lower rates were used in initial trials, especially with thiacloprid. However, there does seem to be an inherent weakness in these two NNI products relative to AZM in field tests where coverage and timing of treatments is precise. How these differences would be expressed in commercial orchards has yet to be determined, but the very best scenario is that there would be no loss in yield. It is possible that operational factors, such as spray coverage and timing issues, would reduce efficacy of commercial applications of the NNIs and novaluron relative to AZM. 23 Excellent coverage of the target is required for each of the alternative products because they have very little or no contact activity. When using an IGR like novaluron, timing of application must be more precise than with AZM, so there is an adaptive period while growers learn how to use new products. Taking these factors together it is likely that some yield losses could occur as new technologies are implemented in apple IPM systems.

In a three year study where AZM alternatives were compared with an AZM ( conventional) program there were no differences in the cost of controls or in the level of fruit loss due to CM injury. These studies were conducted in 15 grower orchards throughout WA and growers applied treatments. The key difference in this study and scenarios offered by the EPABEAD report is that all the orchards were treated with halfrates of CMMD ( primarily Isomate Cplus and AZM and AZM alternatives were applied as supplements. In addition, most of these orchards started out with very low CM populations and thus the study primarily points out that it is possible to achieve adequate control of CM over three years when starting at these low pest populations levels. This study should not be used as a typical representation for all WA apple orchards ( see the attached report on this project below).

Most effective specific miticides cost $ 50 60 per acre. The increasing evidence that use of NNIs and novaluron could increase spider mite problems resulting in the use of miticides on an additional 20% of apple acreage in WA suggests that these costs should be added to the AZM alternative program in the second scenario. It would be reasonable to add at least $ 15 per acre to the second scenario to take into account for the need to control spider mites.

The use of novaluron could reduce costs of leafroller control and offset to some extent the increased expenses caused by spider mites control of the second scenario. Since there is only limited experience in commercial orchards with this product, and preliminary evidence suggests that it will add to the perturbation of spider mite biological control, the reduced costs of leafroller control would probably be neutralized by the increased cost of spider mite control."

BEAD Response:

BEAD continues to believe that the second scenario is a logical choice for growers based on the currently available insecticides and research. The scenario is based on personal communications with experts in western apple production, review of appropriate scientific/ extension literature and USDA Crop Profiles and Strategic Pest Management Plans. BEAD assumed the material cost is an average cost based on the available data. The control cost information submitted is useful for comparison purposes and is similar to the information we have regarding the chemical price.

BEAD assumed no yield or quality losses based on available information and expert opinion. However, BEAD would welcome additional information that would provide commercial yield losses using the combined alternative insecticides regimen provided in this scenario. BEAD is aware of the impacts that spray coverage and timing can have on CM control programs based on alternative insecticides. However, BEAD believes that these activities should already be an important part of any environmentally effective spray program whether using conventional insecticides or alternative insecticides. 24 BEAD has reviewed the documents submitted with the comment above and notes that " there were no significant differences in average CM damaged fruit between treatments in any year with either the bin or on tree assessment method". However, as the commenter indicates that these trials were augmented with additional pesticides and MD to achieve low CM population levels, BEAD again believes this supports the validity of the first scenario in which growers would switch primarily to phosmet, particularly in areas of high CM densities and areas in which MD is ineffective. OPP's goal in constructing these scenarios was in part to illustrate the extremes in control strategies that could be implemented in the absence of AZM. While addition of MD would add to the costs associated with the second scenario, BEAD believes that the second scenario adequately illustrates the increased cost of an alternative insecticide program. It might also be considered that MD can also be used in conjunction with an OP based system as well.

BEAD appreciates the information on the additional benefit of novaluron on leafroller populations. However, as pointed out, there is limited experience with this product in commercial orchard situations. This in turn supports BEAD contention that many growers will likely choose to use phosmet in the place of alternative non OP insecticides and that the BEAD scenario is a more accurate measure of AZM benefits.

Comment:

" Specific Comments relative to the three proposed scenarios for AZM replacement  Third Scenario .. In reality this scenario is NOT a comparison that is appropriate for an orchard requiring 3 AZM applications to control CM. The third scenario would only be appropriate for a small proportion of WA growers, maybe 10% of the acreage, and these growers would not have been using 3 AZM sprays prior to adopting CMMD. Any orchard requiring 3 AZM applications could not achieve acceptable control of CM using CMMD plus one " rescue" AZM application. Therefore, all the analyses conducted under this scenario would seem to be inappropriate. Evidence from early work on CMMD use in WA apple orchards suggests that if used as a standalone technique it would not be able to provide adequate CM control in many orchards. In the paper by Gut and Brunner ( 1998), two of the five orchards using CMMD as a stand alone technology showed a serious increase in CM populations and crop ( yield) loss when compared to a conventional program ( see below page 392 from the publication). Other evidence from a nonpeer reviewed report   also shows that CMMD alone does not provide adequate control where CM densities are high. A high CM pressure orchard was described as having moth captures ( non pheromone treated orchard) greater than 50 moths per trap, use of 3 4 cover sprays, and greater than 1.5% crop loss at harvest ( Gut and Brunner, 1996). All these evidences plus grower experience in WA strongly indicates that the third scenario is not a realistic alternative for CM control.

The EPA BEAD assumption that there would be no yield or quality losses in the third scenario is not supported by experience. It might be possible to have no additional yield losses in the first or second year of a program like the third scenario but it is very likely that over time yield losses would equal or exceed that experienced in the first scenario. While there is historical evidence to show that pheromones plus AZM when used in an area wide program can 25 reduce the need for AZM applications from ca. 3 to less than less than one, it required 3 years to achieve this level of AZM reduction ( Brunner et al. 2002). In most situations replacing 3 AZM applications with a full rate of pheromone plus one AZM would lead to an increase in yield loss of 0.5 1.0% the first year and it would likely increase more in following years in many orchards. While it is possible to achieve acceptable commercial control of CM with pheromones plus one or two insecticides, even AZM alternatives, this would occur where CM populations have been driven to, or initially were at, low levels.

A more appropriate alternative scenario, one that would be an organic like approach, would include pheromones plus methoxyfenozide, spinosad, oil and virus. Such a program would avoid the perturbation of spider mite biological control experienced in the second scenario but would also be subject to high insecticide costs and yield losses similar or greater than in first scenario."

BEAD Response:

After further review and based on the comments provided, BEAD agrees that the third ` scenario' in its 2005 AZM assessment, involving MD and 1 AZM application, is not a realistic alternative control program for the majority of orchards. BEAD will advise SRRD accordingly in future team discussions.

3. The following comments are excerpted from statements submitted by Charles Goodman, California Department of Food and Agriculture.

" Apples and Pears .. In addition, novaluron is not registered in California either for pears or apples. Accurate application costs should be obtainable by contacting University of California Cooperative Extension pest management experts. The suggestion that growers employ multiple phosmet applications seems inappropriate since that chemical, too, is under EPA review and thus could be lost. Finally, some of the impact assessment scenarios incorporate relatively costly insecticides and pheromones that could drive out marginal growers."

BEAD Response:

BEAD was not aware that novaluron was not registered in California at the time of this assessment. However, there are a number of other insecticides including methoxyfenozide, indoxacarb, and pyriproxyfen which could substitute for novaluron in BEAD Scenario two. BEAD acknowledges that phosmet is also under Agency review. Nevertheless, as it is a registered insecticide, BEAD believes that it does represent a relevant scenario in the absence of AZM and should be included in the assessment. Furthermore, the phosmet registrant recently submitted data that compares the efficacy of AZM and phosmet and found that if phosmet is properly buffered using a buffering agent ( cost: about $ 5 per acre) that phosmet was equally as efficacious as AZM ( Spitko, 2006). 26 4. The following comments are excerpted from statements submitted by Adam J. Sharp, Ohio Farm Bureau Federation.

Comment:

"  with new pest control products comes more specific timing windows for acceptable applications."

BEAD Response:

BEAD notes that many of the new alternative insecticides do have a narrower application window than with AZM. However, BEAD believes that equivalent control can be achieved using Scenario One, phosmet alone, with no impact on application timing compared to that of AZM.

Comment:

" In tests reviewed by Ohio growers, new alternative chemicals give 65% to 85% control of critical pests instead of 99 100% control with organophosphate technology. This isn't acceptable to our growers. Azinphos methyl use is critical to Ohio apple production and must be retained."

BEAD Response:

BEAD has reviewed numerous published studies which indicate that alternative insecticides can provide acceptable control. Available data also indicates increasing control over a period of years, possibly as a result of improved usage as growers become more experienced with the alternative insecticides. Nevertheless, BEAD's Scenario one ( in its 2005 AZM assessment) involves alternatives that should provide control equivalent to AZM.

5. The following comments are excerpted from statements submitted by Michael A. Devencenzi, Agricultural Pest Management / Consulting, Woodbridge, CA.

Comment:

" Under the section referring to the alternatives for AZM within the Western United States; scenario one refers to the switching to phosmet over AZM. They rationalize the 3 AZM applications to be replaced by 4 phosmet. This is would not work in California as the current residual of AZM for codling moth control is around 21 days, phosmet has an effective residual of approximately 10 days at the high rate on the label. It would be far more realistic to compare 6 applications of phosmet to the 3 applications of AZM." 27 BEAD Response:

BEAD believes that Scenario One in its 2005 AZM assessment is a valid assessment. BEAD has reviewed numerous studies that indicate that phosmet can be a one to one replacement for AZM with equal efficacy. In addition, with proper tank buffering, the residual activity of phosmet has been shown to be comparable if not better than AZM. BEAD does note that there are limitations to our assessment. First, the scope of the assessment is for the Western and Eastern apple production regions and not individual states or production areas. Second, BEAD is using average use information provided by the USDA. The phosmet registrant recently submitted data that compares the efficacy of AZM and phosmet and found that if phosmet is properly buffered using a buffering agent ( cost: about $ 5 per acre) that phosmet was equally as efficacious as AZM ( Spitko, 2006).

Comment:

" My experience with acetamiprid shows it to be a very effective material for certain insects but codling moth has not been one of them. It has consistently failed to control moderate or heavy codling moth populations with in my area and as far as I know is not an insecticide that would be chosen by industry for controlling this pest."

BEAD Response:

BEAD acknowledges that all programs may not achieve the same results in different areas. However, as noted in Table 5 of the 2005 assessment, acetamiprid is rated as excellent for control of codling moth in the Western US apple production region. BEAD bases the impact assessments on the average yield, quality and cost information from knowledgeable experts from the production regions and other available data at the time the assessment is conducted to estimate the anticipated changes to the industry.

6. The following is a summary of a statement submitted by Dr. Larry Gut, Michigan State University.

Dr. Gut commented generally on the lack of effectiveness of the alternative controls to AZM and on the estimated increase in control costs for growers that would change to the newer material.

BEAD Response:

BEAD welcomes any additional information that addresses yield, quality, material choice and production costs that would enhance the assessment. However, BEAD is limited to using available verifiable data when impact assessments are developed. BEAD assumed the material cost is an average based on the data BEAD has available. The control cost information submitted is useful for comparison purposes and is similar to the general information we have regarding the chemical price. The commenter did not submit any specific control cost information by control that would be feasible for the impact assessment. However, the phosmet 28 registrant recently submitted data that compares the efficacy of AZM and phosmet and found that if phosmet is properly buffered using a buffering agent ( cost: about $ 5 per acre) that phosmet was equally as efficacious as AZM ( Spitko, 2006).

However, in light of the registrant submission, there is a question as to the validity of the BEAD scenario that assumes 3 AZM applications would be replaced by 4 phosmet applications because of the recent tank buffer efficacy data. The purpose of adding the buffering agent is to enhance the efficacy of phosmet so that 3 applications of phosmet would be equivalent to 3 applications of AZM. This would eliminate the need for the additional phosmet application including the costs to buffer and apply the third application of phosmet. It is not clear why there would be the need for the additional application if the buffering agent is added. If a third scenario was considered based on the using the buffering agent, it would be assumed that the buffering agent cost $ 15 ($ 5 x 3 applications) plus the difference in the material cost $ 24.21 ($ 8.07 x 3 applications) that BEAD estimated would result in a total incremental variable cost increase of $ 39.21 per acre for growers to transition to phosmet because the efficacy enhancement of the buffering agent would give phosmet the same control as AZM. This would eliminate the need for an additional 4th application and associated application costs. This amounts to a 1.6% increase in variable costs using the production cost of $ 2,411 as the base variable cost as outlined in the impact assessment.

7. The following comments are excerpted from statements submitted by Dr. Greg Krawczyk and Dr. Larry A Hull, Department of Entomology, Fruit Research Extension, Pennsylvania State University.

Comment:

" Scenario 1 suggests replacement of AZM applications with an equal number of phosmet applications. In Pennsylvania orchards, a single application of AZM can likely be replaced with a single application of phosmet, but with a rate that is at least 2.5 3.0 times higher than AZM ( i. e., AZM = 1.5 lb, phosmet = 3.75 4.5 lbs). Based on a PA local dealer price list ( UAP Northeast) such a substitution would cost $ 54 75 more per acre ( 4 applications of Guthion at 1.5 lb/ acre at $ 8.83 per lb replaced with 4 applications of Imidan at 3.75 4.5lbs/ acre at $ 7.15 per lb). Under this scenario, it is likely that the quality of fruit will decrease and actually more pounds of AI will be delivered to the environment."

BEAD Response:

Under Scenario 1 in its 2005 AZM assessment, BEAD expected that costs will increase and while the impact assessment will not measure the exact impact for every apple producing region believes that the assessment is an accurate estimated indicator of the expected impacts. In addition, BEAD is limited to using only available data when impact assessments are developed as BEAD assumed the material cost is an average based on the data BEAD has available. The control cost information submitted is useful for comparison purposes and is similar to the general information we have regarding the chemical price. The phosmet registrant recently submitted data that compares the efficacy of AZM and phosmet and found that if phosmet is properly 29 buffered using a buffering agent ( cost: about $ 5 per acre) that phosmet was equally as efficacious as AZM ( Spitko, 2006). The application costs are already assumed to be included based on the Pennsylvania State College of Agricultural Sciences publication " Pennsylvania Tree Fruit Production Guide, Tree Fruit Production Budgets 2004 2005" document.

However, there is a question as to the validity of the BEAD scenario that assumes 3 AZM applications would be replaced by 4 phosmet applications in light of the recent buffer efficacy data. The purpose of adding the buffering agent is to enhance the efficacy of phosmet so that 3 applications of phosmet would be equivalent to 3 applications of AZM. This would eliminate the need for the additional phosmet application including the costs to buffer and apply the third application of phosmet. It is not clear why there would be the need for the additional application if the buffering agent is added. If a third scenario was considered based on the using the buffering agent, it would be assumed that the buffering agent cost $ 15 ($ 5 x 3 applications) plus the difference in the material cost $ 24.21 ($ 8.07 x 3 applications) that BEAD estimated would result in a total incremental variable cost increase of $ 39.21 per acre for growers to transition to phosmet because the efficacy enhancement of the buffering agent would give phosmet the same control as AZM. This would eliminate the need for an additional 4th application and associated application costs. This amounts to a 1.6% increase in variable costs using the production cost of $ 2,411 as the base variable cost as outlined in the impact assessment.

Comment:

" Scenario 2 suggests replacement of AZM applications with one application of thiacloprid ( Calypso ® ) , two applications of novaluron ( Rimon ® ) and one application of acetamiprid ( Assail ® ) . The price difference between these treatments calculated based on the same local dealer price list will be $ 89.98 ( 1.5 lb Guthion ® replaced with 3.4 oz of Assail @ $ 12.60 per oz; 6 oz Calypso @ $ 6.79/ oz and two applications of 20 oz of Rimon @ $ 1.48 per oz)."

BEAD Response:

BEAD welcomes any additional information that addresses yield, quality, material choice and production costs that would enhance the assessment. However, BEAD is limited to using available data when impact assessments are developed as BEAD assumed the material cost is an average based on the data BEAD has available. The control cost information submitted is useful for comparison purposes and is similar to the general information we have regarding the chemical price. Under Scenario 2 ( of its 2005 AZM assessment) BEAD expects that costs will increase and that the while the impact assessment will not measure the exact impact for every apple producing region believes that the assessment is an accurate estimated indicator of the expected impacts and that the impact assessment should be viewed as such.

Comment:

" Scenario 3 suggests replacement of AZM with CM mating disruption along with a single rescue treatment of AZM. Such a scenario would be roughly $ 80 more expensive than 4 AZM applications depending on the kind of mating disruption materials used for the treatment. 30 Under this scenario the cost of control of other pests is completely ignored and not involved in the economic calculation. The single species MD material will not control other pest species present in Pennsylvania and mid Atlantic orchards."

BEAD Response:

After further review and based on the comments provided, BEAD agrees that the scenario 3 in the 2005 apple assessment is not a realistic alternative control program and will advise SRRD accordingly BEAD will advise SRRD accordingly in future team discussions.

Comment:

" The economic analyses of the various presented scenarios for AZM replacement assume that AZM is only used to control codling moth and completely ignores the other pests in the fruit system in the eastern U. S. It is an unrealistic and unacceptable assumption for the assessment of possible economic effects of AZM removal from the apple system. Other pests, as presented in the earlier part of this discussion, also need to be controlled. Thus, additional insecticide applications will have to be added to the cost analysis. Such additions would probably completely change the economic outcomes of the evaluated scenarios. Additionally, none of the scenarios take into account the additional costs related to the increased need for orchard monitoring and scouting required for proper applications of these new compounds. The change in the pesticide assortment is not a simple change in the names of the compounds, but it is rather a change in how growers need to think about pest management. The proper use of the recently registered chemistries requires a whole new set of knowledge about each single compound and how each can be used in the most effective manner."

BEAD Response:

BEAD developed its scenarios after consulting with experts in both the Eastern and Western apple production regions. Additionally, BEAD examined field trials, USDA Crop Profiles, and USDA Pest Management Plans. The Pest Management Strategic Plans for both mid Atlantic and New England apples ( USDA, 2003a, 2004) indicate that the combination of acetamiprid, novaluron, and thiacloprid are as effective as the other alternative insecticides for the major apple pests. Although there is no doubt that some variations in pest complexes exist between regions and even within regions, BEAD is not in a position to evaluate the effectiveness of the alternative controls for every possible scenario against localized secondary pests that may be currently controlled using AZM. However, BEAD does believe that only minimum effectiveness would be lost in control of secondary pest for growers who adopt Scenario one discussed in BEAD's 2005 AZM assessment. BEAD welcomes any additional information that addresses yield, quality, material choice and production costs that would enhance the assessment.

8. Comment from James R Cranney, Jr., Vice President, U. S. Apple Associates:

Mr. Cranney's comments were a general summary of supporting documents and analysis from technical experts regarding the apple impact assessment. 31 BEAD Response:

BEAD has provided individual responses to the compiled comments provided by US Apple ( see responses to all other comments, above).

Summary of comments on tart cherries and BEAD responses Several detailed comments on BEAD's assessment of AZM in this crop were received. BEAD addresses the major comments with the responses immediately following ( the same format as was done for pears).

Comment:

" It is also important to note that many growers in Michigan specialize in both tart and sweet cherries. These growers like to use products that can be applied to both cherry varieties. For these farmers AZM fulfills that role. However, Phosmet a competing crop protection tool which the Agency has identified as an alternative is phytotoxic to the leaves of sweet cherry trees. Phosmet may be an effective alternative for tart cherries. However history has taught us that relying on only one chemistry in an intensely managed production system will quickly lead to resistance." Philip J. Korson, Cherry Marketing Institute BEAD Response:

BEAD acknowledges that phosmet is phytotoxic to some ( but not all) varieties of sweet cherries. However, in order to provide a full analysis of alternatives, BEAD's assessment considered that fact that phosmet is not phytotoxic to some sweet cherry varieties. Furthermore, BEAD's review of available information led to the conclusion that phosmet should have no more resistance concerns than have been noted from the long term use of AZM. Effective long term IPM programs do not rely solely on a single insecticide class but on rotation of different insecticide classes.

Comment:

" Phosmet is not directly interchangeable with AZM. According to his research ( Mark Whalen) and expert opinion, AZM is much more efficacious than Phosmet. This is reflected as well by the tart cherry industry's reliance on AZM versus Phosmet. Almost all of the tart cherry acreage is treated annually with AZM to manage the cherry Fruit fly and Plum Curculio. Dr. Whalon projects that if AZM was lost, growers would have to spray 2   3 ½ times more to get the same control in tart cherries that they now achieve with a single AZM application." (# 0071.1) Philip J. Korson, Cherry Marketing Institute [ Related] Comment:

Phosmet is an organophosphate and it is not as effective as AZM for plum curculio control, but it may be adequate for cherry fruit fly management ( Michigan Fruit Management 32 Guide MSU E 154). If AZM were cancelled, phosmet use would probably increase from 2 x to 3 ½ x in tart cherries." (# 0081) Mark Whalon, Michigan State University BEAD Response:

BEAD's response here addresses both comments above. BEAD agrees that phosmet is not a one to one replacement for AZM. The efficacy table presented in the BEAD Grower Impact Assessment 2005 was developed from the Michigan State University Fruit Management Guide ( 2006) and indicates that both AZM and Phosmet provide excellent control of plum curculio and cherry fruit fly. Data submitted to the Agency by the registrant also show that the residual activity of phosmet is equal to that of AZM when the tank mix is properly buffered. Therefore BEAD believes that the 2   3 ½ times more sprays indicated by Dr. Whalen Dr. Whalon is an overestimate of the actual number of phosmet applications that would be required to achieve control of both pests. BEAD's assessment concluded that five applications of phosmet would replace three applications of AZM, which include control for both the plum curculio and cherry fruit fly ( Atwood and Wyatt, 2005).

Comment:

Several commenters suggested that OP alternatives would result in much higher impacts to tart cherry growers than suggested by BEAD's assessment.

BEAD Response:

BEAD agrees that many OP alternatives are more costly than AZM. However, tart cherry growers have the option of using efficacious alternatives, phosmet being one of them. BEAD's assessment reflects this assumption.

Comment:

Several commenters raised the issue of zero tolerance within the market for fruit infested with plum curculio and cherry fruit fly. Contaminated produce is rejected, essentially resulting in 100% loss of output. One commenter stated that he lost $ 12,000 one year when his shipment was rejected.

BEAD Response:

BEAD is aware of the zero tolerance requirements and the substantial penalties that can result if fruit is infested. Our assessment focused on identifying pest control methods that would provide equivalent control to AZM, including the necessity of multiple applications of phosmet. BEAD notes that the commenter whose shipment was rejected had treated his orchard with AZM, so the risk of treatment failure is always present. None of the comments provided data to suggest that this risk would increase measurably with the use of phosmet or other alternatives. . 33 Summary of comments on sweet cherry Almost all comments received on this crop were from Michigan stakeholders. The exception was a broadly framed comment from Bayer CropScience ( Buckelew 2006). Comments from Michigan stakeholders that mentioned sweet cherries were primarily focused on tart cherries and appeared to include sweet cherries as a secondary issue. There were no comments on AZM use in sweet cherries from stakeholders in the major western US growing areas. Most commenters highlighted, in general terms, the historical reliability of AZM as a pest control tool. They emphasized its utility against plum curculio ( PC) in particular, its low cost, and the novel status of recently registered insecticides such as neonicotinoids. One commenter claimed that residues of the more effective alternatives insecticides leave residues inside the fruit ( though details of which alternatives and to what extent this occurs were not given).

Bayer CropScience emphasized the broad pest spectrum utility of AZM and claimed that growers would need more than the one miticide application modeled by BEAD in its alternatives scenarios. They also suggested that the alternatives BEAD mentioned for western sweet cherries are not as efficacious as AZM.

BEAD Response BEAD agrees that AZM costs less than some of its alternatives, and ( like other organophosphate, carbamate, and synthetic pyrethroid insecticides) is effective across a broad spectrum of insects. BEAD's 2005 assessment explored in some detail the economic impact of shifting to higher cost alternatives. However, BEAD believes that several commenters' claims are not consistent with published studies and expert opinion that led to BEAD's conclusions. BEAD would need more detailed information on the following deficiencies in order to determine whether its assumption should be adjusted.

( 1) Scientific studies supporting the claims that alternatives discussed in BEAD's 2005 assessment are not as effective as AZM in terms of protecting from yield or quality loss. ( 2) More specific discussion of which alternatives, are problematic in terms of efficacy or leaving residues. ( 3) Scientific studies and/ or grower surveys showing how many additional miticides ( beyond the one modeled by BEAD) would be necessary with the alternatives. ( 4) If production cost increases need refinement, BEAD would need specific information concerning the alternatives in terms of cost of formulated product per application or a. i per application.

BEAD believes these additional details are necessary because commenters' claims stood in contrast to efficacy studies, cost information, and extension recommendations available to BEAD ( from published sources and market databases) and incorporated into the 2005 assessment. In order to adjust the assumptions contained in the 2005 assessment, BEAD needs information on specific alternative insecticides, with scientific research and/ or grower surveys with sample sizes, and a description of the basis of any cost figures supplied. This information was not provided in the comments received for sweet cherries. 34 Summary of comments on blueberry Almost all comments received on this crop were from Michigan stakeholders. The exception was a broadly framed comment from Bayer CropScience ( Buckelew 2006). There were no comments on AZM use in blueberries from stakeholders in the major eastern US growing areas, or from lowbush blueberry growing areas. Most commenters highlighted the historical reliability of AZM as a pest control tool in general terms. They emphasized its utility against a number of pests simultaneously ( though most agreed that fruitworms are the major target), its low cost, and the novel status of recently registered insecticides such as insect growth regulators.

Bayer CropScience also emphasized the broad spectrum nature of AZM and suggested that BEAD's estimates of quality losses in the absence of AZM were too low. They did not offer alternative estimates of levels of loss. A few other commenters also criticized BEAD's levels of loss estimates as being too low. Only one other commenter, the Michigan Blueberry Growers Association ( MBGA) sent a comment with some details on why they believe AZM is better than alternatives and offered an alternative loss estimate. To paraphrase, MBGA claimed that AZM is a low cost material efficacious with either aerial or ground applications, and claimed that about half the Michigan blueberry acreage would see quality losses in the 10 15% range without AZM. They also stated that quality losses were modeled unrealistically, in that fruit rejected from the fresh market cannot then be sold in the equally quality conscious processed blueberry market.

BEAD Response BEAD agrees that AZM costs less, relative to some of its alternatives, and, ( like other organophosphate, carbamate, and synthetic pyrethroid insecticides) is effective across a broad spectrum of insects. BEAD's 2005 assessment explored in some detail the economic impact of shifting to higher cost alternatives. However, as with comments on sweet cherries, BEAD believes that several commenters' claims are not consistent with published studies and expert opinion that led to BEAD's conclusions. BEAD would need more detailed information on the following deficiencies in order to determine whether its assumption should be adjusted.

( 1) Scientific studies backing up claims that alternatives discussed in BEAD's 2005 assessment are not as effective as AZM in terms of protecting from yield or quality loss. ( 2) Scientific studies and/ or grower surveys showing the basis on which loss estimates are obtained, the number of growers reporting such losses. ( 3) If production cost increases need refinement, BEAD would need specific descriptions of how much the alternatives discussed in the assessment cost, clearly described in terms of cost of formulated product per application or a. i per application.

These additional details are necessary because commenters' claims stood in contrast to efficacy studies, cost information, and extension recommendations ( from published sources and market databases) discussed in BEAD's 2005 assessment. In order to have confidence in adjusting that analysis , BEAD would need information on specific alternative insecticides, with scientific research and/ or grower surveys with sample sizes, and a description of the basis of any 35 cost figures supplied. Such details were absent in the comments received for blueberries.

Regarding the claim that fruit not sold on the fresh market cannot then be sold on the processed market, BEAD agrees that this may be an outcome for at least some growers. Therefore, BEAD re analyzed the economic impact of such an outcome using the loss estimates described in the 2005 assessment. The results of this re analysis follow below, presented separately for the North Central and Eastern US regions ( to reflect the format of BEAD's 2005 assessment).

North Central region BEAD made minor revisions to the economic sections due to public comments received. BEAD revised the transfer of the 2% quality loss from the fresh market to the processed market to a quality loss where 2% of the fresh market blueberries becomes unmarketable ( or " no sale"). Due to the quality loss from fresh market to no sale, harvesting costs remain the same, unlike with yield losses where the fruit is not harvested; in this case all of the fruit is harvested and then checked for quality.

The loss estimates used in this analysis to capture the lower bound losses in the fresh market, include the lower 1% estimate of quality loss from the fresh market to not being marketable (" no sale"), or a loss of 16 pounds per acre where average fresh market yield of 1,627 pounds per acre decreased to 1,610 pounds per acre. To capture the lower bound losses in the processed market this analysis also assumes the lower 1% estimated quality loss from the processed market to no sale, or a loss of 25 pounds per acre where average processed market yield of 2,468 pounds per acre decreased to 2,443 pounds per acre ( see Table 1). The assumptions used in this analysis to capture the upper bound losses in the fresh market, include the higher 2% estimate of quality loss from the fresh market to no sale, or a loss of 33 pounds per acre where average fresh market yield of 1,627 pounds per acre decreased to 1,594 pounds per acre. To capture the upper bound losses in the processed market this analysis also assumes the higher 2% estimated quality loss from the processed market to no sale or a loss of 49 pounds per acre where average processed market yield of 2,468 pounds per acre decreased to 2,419 pounds per acre ( see Table 1).

According to BEAD calculations, at the grower level ( see Table 1), the estimated impact in the North Central region of not having azinphos methyl available for use on highbush blueberries under normal pest pressure is an increase in variable costs of about 2% or $ 62 per acre ( from $ 3,320 to $ 3,382 per acre). The lower bound change in returns above variable costs ( net operating revenue) is a decrease of about 12% or $ 103 per acre ( from $ 841 to $ 738 per acre). The upper bound change in returns above variable costs ( net operating revenue) is a decrease of about 17% or $ 145 per acre ( from $ 841 to $ 696 per acre). Under high pest pressure, there is an increase in variable costs of about 3% or $ 84 per acre ( from $ 3,320 to $ 3,404 per acre). The lower bound change in returns above variable costs ( net operating revenue) is a decrease of about 15% or $ 125 per acre ( from $ 841 to $ 716 per acre). The upper bound change in returns above variable costs ( net operating revenue) is a decrease of about 20% or $ 167 per acre ( from $ 841 to $ 674 per acre). 36 Table 1. Summary of Grower Level Highbush Blueberry Impacts   North Central Region Lower Bound Lower Bound ( 1% Loss) Upper Bound ( 2% Loss) Lower Bound ( 1% Loss) Upper Bound ( 2% Loss) Grower Level Impacts per Acre Current Situation Normal Pest Pressure 80% of Region Higher Pest Pressure 20% of Region Price ($/ lb) 1** $ 1.37 $ 1.37 $ 1.37 $ 1.37 $ 1.37 Yield ( lbs/ A) 1** 1,627 1,610 1,594 1,610 1,594 Quality Loss to No Sale ( lb/ A)  16 33 16 33 Fresh Market Total ($/ A)* $ 2,229 $ 2,206 $ 2,184 $ 2,206 $ 2,184 Price ($/ lb) 1** $ 0.78 $ 0.78 $ 0.78 $ 0.78 $ 0.78 Yield ( lbs/ A) 1** 2,468 2,443 2,419 2,443 2,419 Quality Loss to No Sale ( lb/ A)  25 49 25 49 Processed Market Total ($/ A)* $ 1,933 $ 1,914 $ 1,895 $ 1,914 $ 1,895 Total Gross Revenue per Acre* $ 4,162 $ 4,120 $ 4,079 $ 4,120 $ 4,079 Variable Costs2,3 Fertilizer ($/ A) $ 75 $ 75 $ 75 Herbicides ($/ A) $ 73 $ 73 $ 73 Fungicides ($/ A) $ 86 $ 86 $ 86 Other Insecticides ($/ A) $ 62 $ 62 $ 62 Azinphos methyl ($/ A) $ 12 $  $  Tebufenozide ($/ A) $  $ 44 $ 66 Esfenvalerate ($/ A) $  $ 13 $ 13 Miticide ($/ A) $  $ 16 $ 16 Labor and Other ($/ A) $ 792 $ 792 $ 792 Harvesting ($/ A) $ 2,220 $ 2,220 $ 2,220 Total Variable Costs ($/ A)* $ 3,320 $ 3,382 $ 3,404 $ $  $ 62 $ 84 Change in Total Variable Costs ($/ A) % 0% 2% 3% Returns Above Variable Costs ($/ A)* $ 841 $ 738 $ 696 $ 716 $ 674 $ $  ($ 103) ($ 145) ($ 125) ($ 167) Change in Returns Above Variable Costs ($/ A)* % 0%  12%  17%  15%  20% 1Source: USDA/ NASS Noncitrus Fruits and Nuts 2004 Summary, July, 2005. 2Source: Brumfield: " Farm Management: Table 21: Costs and Returns for Blueberries, Per Acre: Mature Bushed   Years 6 20 Conventional Production Practices Northeastern United States, 1996" accessible at: http:// aesop. rutgers. edu/~ farmmgmt/ ne budgets/ conv/ Blueb Matu Plant. html 3Source: Personal communication from Rufus Isaacs of Michigan State University * Notes: ( i) Totals may differ from sum of components due to rounding. ( ii) Pesticide costs shown are for the chemicals used only. ** Data are average yields and prices for the years 2002~ 2004.

BEAD assumes the same percent crop treated in all the acreage in this region. According to BEAD calculations, at the regional level ( see Table 2), the impact of 78% of the acres currently using AZM in the North Central region not having AZM available are estimated to be an increase in variable costs of about 2% or $ 0.90 million (($ 62/ acre* 10,826acres) + ($ 84/ acre* 2,707acres) = $ 898,000). The lower bound change in returns above variable costs ( net operating revenue) is a decrease of about 13% or $ 1.46 million (($ 103/ acre* 10,826acres) + ($ 125/ acre* 2,707acres) = $ 1,460,000). The upper bound change in returns above variable costs ( net operating revenue) is a decrease of about 18% or $ 2.02 million (($ 145/ acre* 10,826acres) + ($ 167/ acre* 2,707acres) = $ 2,020,000). 37 Table 2. Summary of Regional Highbush Blueberry Impacts   North Central Region Regional Impacts Current Situation Normal Pest Pressure 80% of Region Higher Pest Pressure 20% of Region Regional Total Acreage 100% 17,350 13,880 3,470 AZM Acreage 78% 13,533 10,826 2,707 Regional Change in Total Variable Costs Change in Variable Costs ($) $ 0.67 million $ 0.23 million Regional Total ($) $  $ 0.90 million Change in Variable Costs (%) 2% 3%

Regional Total (%) 0% 2%

Regional Change in Returns Above Variable Costs & Value of Production Combined Normal and High Pest Pressure Lower Bound ( 1% Loss) Upper Bound ( 2% Loss) $  $ 1.46 million $ 2.02 million Regional Change in Returns Above Variable Costs 0% 13% 18% Regional Total Value of Production $ 74 million Regional Loss on Total Value of Production 2% 3% 1 Source: USDA/ NASS Noncitrus Fruits and Nuts 2004 Summary, July, 2005. 2 Source: USDA/ NASS, Agricultural Chemical Usage 2003 Fruit Summary, August 2004 * Totals may differ from sum of components due to rounding. ** Data are average yields and prices for the years 2002~ 2004.

The regional value of production is approximately $ 74 million; therefore the lower bound regional loss on the value of production is about 2% and the upper bound regional loss is about 3%.

Overall, it appears that highbush blueberry growers, without AZM in the North Central region, would typically face some loss in cash returns in the presence of effective alternatives that would produce lower yield and quality levels with a larger increase in production costs. However, recalculated losses ( above) are not substantially different from those discussed in BEAD's 2005 assessment.

Eastern region The loss estimates used in this analysis to capture the lower bound losses in the fresh market, include the lower 1% estimate of quality loss from the fresh market to not being marketable (" no sale"), or a loss of 46 pounds per acre where average fresh market yield of 4,600 pounds per acre decreased to 4,554 pounds per acre. To capture the lower bound losses in the processed market this analysis also assumes the lower 1% estimated quality loss from the processed market to no sale, or a loss of 8 pounds per acre where average processed market yield of 803 pounds per acre decreased to 795 pounds per acre ( see Table 3). The assumptions used in this analysis to capture the upper bound losses in the fresh market, include the higher 2% estimate of quality loss from the fresh market to no sale, or a loss of 92 pounds per acre where average fresh market yield of 4,600 pounds per acre decreased to 4,508 pounds per acre. To capture the upper bound losses in the processed market this analysis also assumes the higher 2% estimated quality loss from the processed market to no sale, or a loss of 16 pounds per acre 38 where average processed market yield of 803 pounds per acre decreased to 787 pounds per acre ( see Table 3).

According to BEAD calculations, at the grower level ( see Table 3), the estimated impact in the Eastern region of not having azinphos methyl available for use on highbush blueberries is an increase in variable costs of about 2% or $ 62 per acre ( from $ 4,072 to $ 4,134 per acre). The lower bound change in returns above variable costs ( net operating revenue) is a decrease of about 6% or $ 124 per acre ( from $ 2,092 to $ 1,968 per acre). The upper bound change in returns above variable costs ( net operating revenue) is a decrease of about 9% or $ 185 per acre ( from $ 2,092 to $ 1,907 per acre).

Table 3. Summary of Grower Level Highbush Blueberry Impacts   Eastern Region Grower Level Impacts per Acre Current Situation Lower Bound ( 1% Loss) Upper Bound ( 2% Loss) Price ($/ lb) 1** $ 1.19 $ 1.19 $ 1.19 Yield ( lbs/ A) 1** 4,600 4,554 4,508 Quality Loss to No Sale ( lb/ A)  46 92 Fresh Market Total ($/ A)* $ 5,489 $ 5,434 $ 5,380 Price ($/ lb) 1** $ 0.84 $ 0.84 $ 0.84 Yield ( lbs/ A) 1** 803 795 787 Quality Loss to No Sale ( lb/ A)  8 16 Processed Market Total ($/ A)* $ 675 $ 668 $ 661 Total Gross Revenue per Acre* $ 6,164 $ 6,102 $ 6,041 Variable Costs2,3 Fertilizer ($/ A) $ 75 $ 75 Herbicides ($/ A) $ 73 $ 73 Fungicides ($/ A) $ 86 $ 86 Other Insecticides ($/ A) $ 62 $ 62 Azinphos methyl ($/ A) $ 12 $  Tebufenozide ($/ A) $  $ 44 Esfenvalerate ($/ A) $  $ 13 Miticide ($/ A) $  $ 16 Labor and Other ($/ A) $ 792 $ 792 Harvesting ($/ A) $ 2,972 $ 2,972 Total Variable Costs ($/ A)* $ 4,072 $ 4,134 $ $ 0 $ 62 Change in Total Variable Costs ($/ A) 4 % 0% 2%

Returns Above Variable Costs ($/ A)* $ 2,092 $ 1,968 $ 1,907 $ $  ($ 124) ($ 185) Change in Returns Above Variable Costs ($/ A)* % 0%  6%  9% 1Source: USDA/ NASS Noncitrus Fruits and Nuts 2004 Summary, July, 2005. 2Source: Brumfield: " Farm Management: Table 21: Costs and Returns for Blueberries, Per Acre: Mature Bushed   Years 6 20 Conventional Production Practices Northeastern United States, 1996" accessible at: http:// aesop. rutgers. edu/~ farmmgmt/ ne budgets/ conv/ Blueb Matu Plant. html 3Source: Personal communication from Rufus Isaacs of Michigan State University * Notes: ( i) Totals may differ from sum of components due to rounding. ( ii) Pesticide costs shown are for the chemicals used only. ** Data are average yields and prices for the years 2002~ 2004. 39 BEAD assumes the same percent crop treated in all the acreage in this region. According to BEAD calculations, at the regional level ( see Table 4), the impact of 52% of the acres currently using AZM in the Eastern region not having AZM available are estimated to be an increase in variable costs of about 2% or $ 0.63 million ($ 62/ acre * 10,227acres = $ 634,000). The lower bound change in returns above variable costs ( net operating revenue) is a decrease of about 6% or $ 1.26 million ($ 124/ acre * 10,227acres = $ 1,260,000). The upper bound change in returns above variable costs ( net operating revenue) is a decrease of about 9% or $ 1.89 million ($ 185/ acre * 10,227acres = $ 1,890,000)

Table 4. Summary of Regional Highbush Blueberry Impacts   Eastern Region Regional Acreage AZM Acreage 52% 19,667 10,227 Regional Impacts Current Situation Lower Bound ( 1% Loss) Upper Bound ( 2% Loss) $ $ 0 $ 0.63 million Regional Change in Total Variable Costs % 0% 2% $ $ 0 ($ 1.26 million) ($ 1.89 million) Regional Change in Returns Above Variable Costs % 0%  6%  9% Regional Total Value of Production $ 122 million Regional Loss on Total Value of Production  1%  2% 1Source: USDA/ NASS Noncitrus Fruits and Nuts 2004 Summary, July, 2005. 2 Source: USDA/ NASS, Agricultural Chemical Usage 2003 Fruit Summary, August 2004 * Note: Totals may differ from sum of components due to rounding. ** Note: Data are average yields and prices for the years 2002~ 2004.

The regional value of production is approximately $ 122 million; therefore the lower bound regional loss on the value of production is about 1% and the upper bound regional loss is about 2%.

Overall, it appears that highbush blueberry growers in the Eastern region without AZM would typically face some loss in cash returns in the presence of effective alternatives that would produce lower yield and quality levels with a larger increase in production costs. However, as in the North Central region, recalculated losses ( above) are not substantially different from those discussed in BEAD's 2005 assessment Summary of comments received on tree nuts ( almonds, pistachios, and walnuts) and BEAD responses Several comments on BEAD's assessment of AZM in these crops were received from a few stakeholders. Since these writers made several points that BEAD would like to address, the major comments and BEAD response for this crop are presented separately below..

1. Comments from the California Farm Bureau Federation (" CFBF")

Comment:

CFBF supports AZM full registration on walnuts, almonds, and pistachios. AZM is necessary to manage navel orangeworm ( NOW) on tree nuts, as infested nuts become 40 unmarketable. Early harvest can reduce risk of NOW infestation. However almonds and pistachios are harvested sequentially, some orchards being harvested later than others, and this increases risk of infestation.

BEAD Response:

While acknowledging that the NOW is a pest of concern for tree nut growers, BEAD notes that several efficacious AZM alternatives are currently available for managing this insect ( for details, the reader is referred to the 2005 BEAD assessments for tree nuts).

2. Comments from the California Walnut Commission AZM is needed to maintain IPM programs for codling moth that emphasize the use of insect growth regulators, mating disruption, and natural enemies. In this system, AZM functions as a " fall back" insecticide for use whenever codling moth populations become out of control. Uncontrolled, this insect can cause damage in excess of 30%. The damage caused by codling moth can reduce the price the grower receives. To get equivalent control of codling moth may require two applications of chlorpyrifos, rather than one treatment of AZM. Because of its long residual activity AZM is the most effective and economic OP insecticide available for codling moth control. The 30 day REI interferes with key pruning activities when used to control second generation codling moth during mid June to early July.

BEAD Response:

BEAD acknowledges that AZM appears to have a special niche in the management of codling moth on walnuts, primarily because of its long residual activity. However, several alternatives can be used in its place, even if their residual activity may not be as long as AZM's. Although we are aware that multiple treatments of chlorpyrifos may be required to achieve control in some cases, our information indicates that there are other effective treatments available. Because the pest damage can be controlled, we do not expect increased damage to cause price reductions. If data exist on quality discounts resulting from the replacement of AZM when alternatives are used, we would appreciate it being brought to our attention. Pesticide use data provided by the Commission show a steady decline in AZM use ( decreasing dependence on AZM) since 1996, long before the new REI went into effect. If the California Walnut Commission has data showing the cost to the industry of shifting from AZM to one or more alternatives under conditions of high codling moth pest pressure, BEAD would be interested in reviewing it.

3. Comments from Bayer CropScience Extending the REIs in 2004 for almonds, pistachios, and walnuts has, in effect, removed AZM from practical use by growers, forcing growers to move to alternatives for target insect pest control. However, the use of some alternatives such as pyrethroids leads to mite outbreaks. AZM is an important tool for fruit nut growers and its removal does not seem prudent. 41 BEAD Response:

The new REIs for AZM on fruit nuts were established as a condition for time limited registration in as described in the 2001 interim Reregistration Eligibility Decision for AZM. While the longer REIs may have been a factor in lowering AZM use, it is not clear from Bayer's comment as to how it is relevant to BEAD's 2005 assessments of AZM use in tree nuts. BEAD was asked to investigate the current use of AZM and explore available alternatives with similar efficacy, and not to try to make the case that different REIs were ( or were not) necessary. As to the other part of the Bayer comment  while pyrethroids may indeed cause secondary mite outbreaks, there are several other AZM alternatives that are not associated with this problem such as insect growth regulators.

4. Comments from the California Pistachio Commission.

EPA's assessment incorrectly states that the pistachio industry can do without AZM. While AZM use has declined due to longer REIs, it is still the preferred alternative for control of the fourth NOW generation. AZM's long residual activity makes it essential for preventing NOW larvae from entering splitting hulls during this period. By enabling growers to effectively control the NOW, AZM contributes to the reduction of aflatoxin contamination in pistachios. Pistachio markets, including foreign markets, have very low aflatoxin allowable limits. Alternatives such as phosmet, carbaryl, methoxyfenozide, tebufenozide, and spinosad do not perform as well as AZM. Pistachios ripen at different rates leading to multiple, overlapping harvest cycles. Without AZM two applications of alternatives would be necessary, and this is not feasible. High volume fan jet sprayers used with methoxyfenozide would dislodge too many pistachios, and those on the ground would be lost.

BEAD Response:

BEAD acknowledges that AZM also appears to have a special niche in NOW management and, indirectly, on aflatoxin management on pistachios, primarily due to AZM's long residual activity. However, several alternatives are available, even when their residual activity may not be as long as that of AZM. BEAD would be interested in reviewing data showing costs to the industry due to increased application costs, reduced quality, or market losses from increased NOW infestation or aflatoxin contamination as a result of reduced use of AZM when alternatives are available.

Summary of comments on crops with little to no recent use of AZM ( Brussels sprouts, nursery stock, and parsley).

Comments on crops with little to no AZM use included general comments on the efficacy and broad spectrum of AZM use in Brussels sprouts and parsley, general statements of support for use in Brussels sprouts from the California Department of Food and Agriculture ( CDFA) and relatively more specific statements of support for AZM use in parsley from the Ohio Farm Bureau. Comments from the Ohio stakeholders discussed the use of AZM against the carrot weevil, a key pest of parsley and other field crops in the Great Lakes region. Comments from the 42 other stakeholders did not address specific pest situations. No comments on BEAD's 2005 assessment of AZM use in nursery stock were received.

BEAD response BEAD's 2005 assessment for Brussels sprouts described several alternatives ( for aphid control) to AZM that are currently available for this crop, virtually all of which is produced in California. These materials are recommended for pest control in extension literature from the University of California and USDA Crop Profiles written by regional crop experts. In its comment, CDFA expressed the concern that if both AZM and chlorpyrifos are removed from use, growers will be left with no effective options to control the cabbage root maggot. BEAD has already made a similar point in its 2005 assessment; the AZM assessments were written on the assumption that chlorpyrifos use will remain as is, and that the usual process of registering new insecticides that have shown efficacy against important crop pests will continue. Neonicotinoids such as imidacloprid have shown efficacy against soil pests such as the root maggot. BEAD recognizes this has not been added to the approved label.

Regarding the comments on parsley, BEAD points out that it acknowledged in its 2005 assessment the very limited range of alternatives to AZM currently available for carrot weevil control. However, of these materials, malathion is one alternative that has shown effective control of this pest. The stakeholder's comments included a summary of a study done by Ohio State University ( OSU) researchers that concluded that malathion was equivalent to AZM in carrot weevil control. A paper from OSU on integrated pest management of the carrot weevil ( cited by BEAD in its 2005 assessment) also recommends cultural controls such as removing crop debris to eliminate overwintering sites for the weevils, as another pest management approach. BEAD acknowledges that when pest populations are high such tactics may not be sufficient, in which case BEAD believes that malathion ( alone or in combination with repeated applications of less long lasting materials such as permethrin) should be adequate.

BEAD also notes that the Ohio Farm Bureau mentioned that fipronil   as yet unregistered for parsley   has shown good control of carrot weevil and is being considered for ` fast tracked' registration supported by the USDA IR4 program. Indeed, the stakeholders themselves commented that once fipronil is registered any need for AZM would be " eliminated". As a related issue, BEAD is aware of the danger of fostering resistance development if growers are forced to rely largely on malathion as an AZM replacement. However, if fipronil is registered, this risk should be reduced. However, as long as malathion and other alternatives ( detailed in BEAD's 2005 assessment) remain registered for parsley, BEAD believes that most parsley growers in Ohio should be able to continue to control the carrot weevil.

References Cited Anderson, N. and T. Kiely. 2001. Apple Benefits Assessment for Azinphos methyl and Phosmet. Available on the web at http:// www. epa. gov/ oppsrrd1/ op/ azm. htm.

Atwood, Donald W. and TJ Wyatt. 2005. 2005 Grower Impact Assessment of 43 Azinphos methyl Use on Tart Cherries ( DP 307589). Internal Document. Biological and Economic Analysis Division, Office of Pesticide Programs, U. S. Environmental Protection Agency, 1200 Pennsylvania Ave., NW, Washington, DC 20460 0001. Available on the web through www. regulations. gov and EPA Docket number EPA HQ OPP 2005 0061.

Beers E. H., Brunner J. F., Dunley J. E., Doerr M., and Granger K. 2005. Role of neonicotinyl insecticides in Washington apple integrated pest management. Part II. Nontarget effects on integrated mite control. Journal of Insect Science, 5: 16. Available on the web at www. insectscience. org/ 5.16).

Brassard, D. W., and S. Smearman. 2005. 2005 Grower Impact Assessment of Azinphosmethyl Use in Pears ( DP 307589). Internal Document. Biological and Economic Analysis Division, Office of Pesticide Programs, U. S. Environmental Protection Agency, 1200 Pennsylvania Ave., NW, Washington, DC 20460 0001 Brunner, J. F., Welter, S., Calkins, C., Hilton, R., Beers, E. H., Dunley, J. E., Unruh, T., Knight, A., Van Steenwyk, R., and VanBuskirk, P. 2002. Mating disruption of codling moth: a perspective from the Western United States. In: Witzgall, P., B. Mazomenos and M. Konstantopoulou, editors. IOBC WPRS Bulletin Vol. 25( 9): 207 215.

Brunner, J. F., Doerr, M., Beers, E. H., Dunley J. E., and Jones, V. 2004. Washington State University Tree Fruit Research and Extension Center, Proceedings of the 78th Annual Conference   Western Orchard Pest and Disease Management Conference   January 2004   http:// entomology. tfrec. wsu. edu/ wopdmc/ proceedings2004. html.