1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
April
25,
2006
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Impact
assessment
of
extensions
to
restricted
entry
intervals
for
highbush
blueberries
(
DP
#
296575)

FROM:
Nikhil
Mallampalli,
Entomologist
Biological
Analysis
Branch
Elisa
Rim,
Economist
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

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

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

Product
Review
Panel
date:
April
7,
2006
Summary
BEAD
conducted
a
preliminary
assessment
of
the
impact
to
growers
of
extending
the
restricted
entry
interval
(
REI)
for
phosmet
on
highbush
blueberries
from
24
hours
to
23
days,
primarily
due
to
worker
exposure
concerns.
Because
a
23
day
REI
for
phosmet
2
would
interfere
with
key
crop
production
and
protection
practices,
growers
would
likely
stop
using
phosmet
and
use
in
its
place
one
or
more
of
several
available
alternatives.
Based
on
its
2001
assessment,
as
well
as
recent
high
usage
of
phosmet,
and
the
lack
of
availability
of
new
alternatives,
BEAD
tentatively
concludes
that
quality
losses
are
likely
if
phosmet
were
no
longer
available.
BEAD
believes,
as
it
did
in
2001,
that
phosmet
would
probably
not
be
used
if
the
REI
exceeds
3
days
(
the
current
pre­
harvest
interval),
since
critical
phosmet
use
occurs
around
harvest
activities.
Losses
are
estimated
to
continue
to
be
at
the
level
discussed
in
BEAD's
2001
impact
assessment
(
Anderson
et
al.
2001).
These
losses
would
be
a
result
of
quality
reduction
(
due
to
insect
contamination
of
harvest)
and
there
would
probably
also
be
increases
in
production
costs
due
to
use
of
the
alternatives.
Increases
in
production
costs
were
not
quantified
in
this
assessment.
If
azinphos­
methyl
(
AZM)
use
were
also
unavailable,
quality
losses
and
production
costs
would
increase,
since
growers
may
face
additional
losses
from
fruitworms
targeted
by
AZM.
Since
this
is
a
preliminary
assessment,
BEAD
would
welcome
data
that
could
be
used
to
refine
this
assessment.

Background
Based
on
post­
application
worker
risk
assessments,
EPA
is
considering
extending
the
restricted
entry
interval
(
REI)
for
phosmet
use
on
blueberries
from
24
hours
to
23
days
due
to
worker
exposure
concerns.
The
purpose
of
this
assessment
is
to
provide
a
preliminary
assessment
of
the
impact
of
the
proposed
mitigation
on
the
blueberry
industry.

Recent
Use
of
Phosmet
In
2003,
30,300
pounds
of
phosmet
was
applied
on
highbush
blueberries
in
the
U.
S.
Table
1
(
below)
describes
usage
by
individual
states.
Phosmet
may
be
used
in
other
states
on
blueberries
but
usage
may
be
so
low
that
NASS
surveys
do
not
reflect
the
usage.
The
highest
phosmet
use
occurs
in
Michigan
and
New
Jersey
where
phosmet
use
appears
to
be
increasing
after
2001.
3
Table
1.
Phosmet
Usage
on
Blueberries
­
U.
S.
Total,
1997­
19991
and
2001­
2003.2
Bearing
Acreage
Total
Applied
per
Year
(
pounds)
%
Area
Treated
Rate
per
Application
(
lbs
a.
i./
acre)
Number
of
Applications
per
Year
State
1995­
1999
2001­
2003
1995­
1999
2001­
2003
1995­
1999
2001­
2003
1995­
1999
2001­
2003
1995­
1999
2001­
2003
Georgia
4,133
4,600
1,200
N/
A
12%
N/
A
1.03
N/
A
2.4
N/
A
Michigan
16,633
16,400
13,000
24,050
48%
74%
0.87
0.85
1.8
2.3
North
Carolina
3,100
4,200
No
Data
Available
New
Jersey
7,667
7,450
3,300
5,200
27%
47%
0.88
0.85
1.6
1.7
Oregon
2,250
2,900
No
Data
Available
U.
S.
Total
32,750
33,250
17,333
29,700
32%
52%
0.86
0.79
1.8
2.2
1
Source:
USDA/
NASS,
Agricultural
Chemical
Usage
1993,
1997,
and
1999
Fruit
Summary
2
Source:
USDA/
NASS,
Agricultural
Chemical
Usage
2001
and
2003
Fruit
Summary
Summary
of
2001
BEAD
Assessment
for
Phosmet
on
Blueberries
In
2001,
the
REIs
for
phosmet
use
on
blueberries
increased
from
24
hrs
to
3
days.
In
its
2001
assessment,
BEAD
estimated
the
maximum
feasible
REI
possible
for
phosmet
in
the
major
US
blueberry
production
regions.
BEAD
also
evaluated
the
impact
of
extending
REIS
beyond
this
maximum,
which
it
believed
would
effectively
result
in
loss
of
phosmet
use
for
most
growers
due
to
hand
harvesting
that
needed
to
occur
at
the
same
time
as
phosmet
applications.
The
reader
is
referred
to
BEAD's
2001
analysis
(
Anderson
et
al.
2001)
for
details
of
the
analysis.
A
summary
of
BEAD's
2001
evaluation
of
the
pest
management
and
economic
impacts
of
the
loss
of
phosmet
use
follows.

BEAD
evaluated
the
loss
of
phosmet
use
alone
or
concomitantly
with
unavailability
of
AZM,
since
AZM
registration
was
also
under
review
at
the
time.
While
AZM
and
phosmet
are
not
one
to
one
replacements
for
one
another,
AZM
is
used
to
target
early­
emerging
fruitworm
caterpillars
(
among
other
pests).
These
are
internal
fruit
feeders
and
harvest
contaminants
(
and
thus
cause
losses
similar
in
nature
to
the
blueberry
maggot
and
the
Japanese
beetle).
Based
on
available
literature
and
input
from
crop
experts,
BEAD
concluded
that
extending
phosmet
REIs
beyond
3
days
effectively
precluded
its
use.
BEAD
also
concluded
that
if
this
happened,
a
combination
of
available
alternatives
could
be
used
to
replace
phosmet,
but
with
some
quality
losses.
No
large
direct
yield
reductions
(
due
to
reduction
in
fruit
produced)
were
expected
from
the
pests
discussed.
The
levels
of
losses
estimated
by
BEAD
varied
depending
on
whether
or
not
AZM
use
was
also
made
unavailable
or
not,
and
whether
the
eastern
US
or
the
north
central
US
were
considered.
A
summary
of
the
losses
estimated
in
each
region
and
`
scenario'
is
presented
in
the
table
below.
4
Table
2.
Summary
of
BEAD's
2001
loss
estimates
for
scenarios
for
phosmet
and
AZM
loss
(
adapted
from
Anderson
et
al.
2001).
Region
Scenario
Eastern
US
(
mainly
New
Jersey)
North
central
US
(
mainly
Michigan)

1.
Phosmet
use
unavailable;
AZM
use
retained
 
3~
5
%
transfer
of
harvest
from
fresh
market
to
processed
fruit
market
AND
 
5~
15
%
transfer
of
harvest
from
processed
market
to
"
nosale
 
5~
10
%
transfer
of
harvest
from
fresh
market
to
processed
fruit
market
AND
 
10­
15
%
transfer
of
harvest
from
processed
market
to
"
nosale

2.
Both
phosmet
and
AZM
use
not
available
 
5~
7
%
transfer
of
harvest
from
fresh
market
to
processed
fruit
market
AND
 
10~
15
%
transfer
of
harvest
from
processed
market
to
"
nosale
 
5~
10
%
transfer
of
harvest
from
fresh
market
to
processed
fruit
market
AND
 
10~
15
%
transfer
of
harvest
from
processed
market
to
"
nosale

Quality
losses
were
viewed
as
the
transfer
of
the
aforementioned
proportion
of
fruit
from
the
fresh
fruit
(
premium
price)
market
to
the
processed
fruit
(
lower
price)
market,
or
as
the
transfer
of
fruit
from
the
processed
market
to
"
no
sale"
as
a
result
of
buyer
rejection.

For
western
US
highbush
blueberry
production,
an
extension
of
the
phosmet
REI
beyond
3
days
was
thought
likely
to
result
in
a
loss
of
feasible
phosmet
use,
for
the
same
reason
as
described
for
eastern
blueberries.
However,
no
yield/
quality
losses
were
expected
since
use
of
phosmet
was
so
low
in
this
region,
and
effective
alternatives
for
the
key
pests
appeared
to
exist.

Phosmet
Alternatives
In
the
eastern
and
north
central
regions,
a
critical
use
of
phosmet
is
later
in
the
season
to
control
blueberry
maggot
and
Japanese
beetle.
Alternatives
for
these
uses
include
imidacloprid,
methomyl,
spinosad,
and
carbaryl
(
depending
on
which
pest
is
considered).
Of
these,
spinosad
is
a
relatively
new
material,
having
been
registered
since
2001.
BEAD
notes
here
that
AZM
is
not
a
practical
replacement
for
late­
season
phosmet
use
against
Japanese
beetle
and
blueberry
maggot.
However,
AZM
is
sometimes
used
(
in
part)
to
target
early­
emerging
populations
of
these
insects,
particularly
on
early
maturing
blueberry
varieties.
Furthermore,
spinosad
is
easily
washed
off
by
rain
and
thus
can
quickly
lose
efficacy
(
Isaacs,
personal
communication,
2005).
Also,
and
perhaps
more
importantly
as
regards
phosmet's
critical
later­
season
use,
spinosad
is
not
effective
against
the
Japanese
beetle,
a
key
harvest
contaminant
pest
of
highbush
blueberries
in
the
east
and
north
central
US.
Nevertheless,
some
control
could
be
expected
from
spinosad
(
for
the
maggot)
and
imidacloprid
or
carbaryl
(
for
both
the
maggot
and
the
beetle),
but
quality
losses
could
occur,
at
least
to
the
extent
estimated
in
BEAD's
2001
assessment.

Regarding
alternatives
in
general,
BEAD
notes
that
in
recent
years,
broadspectrum
insecticides,
such
as
organophosphates,
are
being
replaced
by
insecticides
with
a
narrower
activity
spectrum.
The
older
chemicals
not
only
controlled
the
target
pest(
s),
5
but
also,
most
other
exposed
insects.
A
consequence
of
the
shift
to
newer
chemistries
is
that
crop
damage
from
insects
that
until
recently
were
considered
minor
pests
appears
to
be
increasing.
However
concomitantly,
the
shift
to
narrower­
spectrum
chemicals
may
result
in
less
mortality
for
beneficial
species,
including
natural
enemies,
which
should
in
turn
increase
natural
mortality
for
some
insect
pests,
ultimately
leading
to
less
pesticide
use.
To
the
extent
that
these
pest
dynamics
continue
to
evolve
and
remain
rather
difficult
to
predict,
this
analysis
examines
only
potential
short­
term
(
two
to
three
years)
impacts.

In
Oregon
and
Washington,
the
major
western
US
production
regions,
phosmet
is
listed
as
an
option
(
under
a
24(
c)
label)
for
aphids,
leafrollers,
and
winter
moth.
However,
more
effective
alternatives
are
available,
including
diazinon,
esfenvalerate,
imidacloprid,
and
malathion
(
USDA
2004).

Maximum
Feasible
REIs
Descriptions
of
highbush
blueberry
production
(
USDA
2004,
USDA
2005,
Garcia­
Salazar
2001)
indicate
that
worker
activities
remain
identical
to
those
described
in
BEAD's
2001
assessment.
Hand
harvest
continues
to
be
widely
practiced
for
fruit
destined
for
the
fresh
market
(
Isaacs,
personal
communication,
2005);
many
growers
target
most
of
their
harvest
for
the
fresh
market
as
it
brings
premium
prices.
Growers
must
often
schedule
harvests
at
3
day
intervals
to
keep
up
with
ripening
fruit
and
pick
marketable
fruit
(
Garcia­
Salazar
2001).
Therefore,
BEAD
believes
that
the
maximum
feasible
REI
for
most
growers
outside
the
western
US
regions
continues
to
be
3
days
(
which
is
also
the
current
pre­
harvest
interval).

Impacts
of
Extending
the
REI
Beyond
the
Maximum
Feasible
Length
For
growers
in
the
western
US,
BEAD
believes
that,
as
in
2001,
the
impact
of
extending
phosmet
REI
will
have
minimal
impact.
Growers
in
this
region
use
a
combination
of
hand
harvest
and
mechanical
harvest
(
Anderson
et
al.
2001),
and
overall
usage
of
phosmet
remains
low.
Thus,
growers
will
probably
either
replace
phosmet
with
one
of
the
alternatives
on
the
small
proportion
of
acreage
treated,
with
little
to
no
impact,
or
adapt
their
phosmet
use
around
harvesting
or
other
worker
activities.

A
23
day
REI
for
phosmet
would
interfere
with
hand
harvesting
in
the
eastern
and
north­
central
regions.
BEAD
assumes,
as
it
did
in
2001,
that
scouting
for
pests
and
irrigation
equipment
maintenance
is
exempted
from
such
an
REI
(
as
per
Worker
Protection
Standard
guidelines).
If
these
activities
are
not
exempted,
a
23
day
REI
would
probably
be
considered
infeasible
even
by
growers
who
do
not
hand
harvest
their
fruit.

Therefore,
BEAD
believes
that,
as
in
2001,
growers
in
these
regions
would
likely
stop
using
phosmet
altogether
and
turn
to
one
or
more
of
several
available
alternatives
if
the
REI
were
extended
to
23
days.
Given
the
narrow
pest
spectrum
of
spinosad,
the
only
alternative
newly
available
since
2001,
BEAD
believes
that
growers
would
probably
turn
to
the
combination
of
other
alternatives
that
was
discussed
in
the
2001
assessment.
These
alternatives
included
imidacloprid,
malathion,
and
methomyl,
if
phosmet
use
alone
were
to
be
unavailable.
If
phosmet
removal
coincides
with
AZM
removal,
growers
would
have
6
to
use
additional
alternatives
to
replace
that
insecticide
as
well
(
see
Anderson
et
al.
2001
for
details).
BEAD
tentatively
concludes
that
the
impacts
of
not
using
phosmet
continue
to
be
at
the
level
estimated
in
2001
(
see
Table
2
for
details
of
quality
losses
estimated).
An
investigation
of
the
economic
ramifications
of
these
impacts
is
described
below.

Economic
analysis
The
following
analysis
includes
two
highbush
blueberry
growing
regions:
North
Central
region
(
Michigan
and
Indiana)
and
Eastern
region
(
New
Jersey,
North
Carolina,
Georgia,
Florida,
New
York,
Arkansas,
and
Alabama).
It
does
not
include
the
Western
region
(
Washington
and
Oregon)
because
there
does
not
appear
to
be
significant
phosmet
use.
This
economic
analysis
only
estimates
the
gross
revenue
loss
due
to
quality
loss.
The
change
in
production
costs
is
not
quantified
in
this
analysis.
BEAD
expects
an
increase
in
production
costs
because
some
alternatives
may
not
be
as
effective
as
phosmet,
and
others
may
be
newer
materials
that
are
priced
higher
than
phosmet.
Production
cost
changes
may
include
but
are
not
limited
to
change
in
cultural
practices,
price,
quantity,
use
rate,
and
number
of
applications
of
the
alternatives.

North
Central
U.
S.

The
economic
analysis
attempts
to
assess
the
impacts
of
the
loss
of
phosmet
in
the
North
Central
region
highbush
blueberry
market.
With
74%
of
the
crop
treated
in
the
Michigan,
phosmet
is
an
important
chemical
in
controlling
target
pests.
BEAD
assumes
the
same
percentage
of
the
crop
is
treated
over
the
whole
north
central
region
growing
area.
Without
phosmet,
growers
would
have
effective
alternative
regimes
to
substitute
for
phosmet
but
may
face
increased
costs
and
quality
losses.

In
the
North
Central
region,
average
fresh
market
yield
is
40%
of
the
total
production
and
average
processed
market
yield
is
60%
of
total
production.
Gross
revenue
is
calculated
as
the
sum
of
the
yield
multiplied
by
the
price
in
each
market
category.

The
quality
loss
assumptions
used
in
this
analysis
are
described
in
Table
2
(
above).
The
loss
estimates
used
in
this
analysis
for
both
Scenarios
1
and
2
to
capture
the
lower
bound
losses
in
the
fresh
market,
include
the
lower
5%
estimate
of
quality
loss
from
the
fresh
market
to
not
being
marketable
("
no
sale"),
or
a
loss
of
81
pounds
per
acre
where
average
fresh
market
yield
of
1,627
pounds
per
acre
decreased
to
1,545
pounds
per
acre.
To
capture
the
lower
bound
losses
in
the
processed
market
this
analysis
also
assumes
the
lower
10%
estimated
quality
loss
from
the
processed
market
to
no
sale
or
a
loss
of
247
pounds
per
acre
where
average
processed
market
yield
of
2,468
pounds
per
acre
decreased
to
2,221
pounds
per
acre
(
see
Table
3).

The
assumptions
used
in
this
analysis
for
both
Scenarios
1
and
2
to
capture
the
upper
bound
losses
in
the
fresh
market,
include
the
higher
10%
estimate
of
quality
loss
from
the
fresh
market
to
no
sale,
or
a
loss
of
163
pounds
per
acre
where
average
fresh
market
yield
of
1,627
pounds
per
acre
decreased
to
1,464
pounds
per
acre.
To
capture
7
the
upper
bound
losses
in
the
processed
market
this
analysis
also
assumes
the
higher
15%
estimated
quality
loss
from
the
processed
market
to
no
sale,
or
a
loss
of
370
pounds
per
acre
where
average
processed
market
yield
of
2,468
pounds
per
acre
decreased
to
2,098
pounds
per
acre
(
see
Table
3).

Table
3.
Summary
of
Grower
Level
Blueberry
Gross
Revenue
Impacts
 
North
Central
Region
Grower
Level
Impacts
per
Acre
Current
Situation
Scenarios
1
&
2:
Lower
Bound
Scenarios
1
&
2:
Higher
Bound
Price
($/
lb)
1**
$
1.37
$
1.37
$
1.37
Yield
(
lbs/
A)
1**
1,627
1,545
1,464
5~
10%
Quality
Loss
to
No
Sale
(
lbs/
A)
­
81
163
Fresh
­
Average
2002~
2004
Total
($/
A)*
$
2,229
$
2,117
$
2,006
Price
($/
lb)
1**
$
0.78
$
0.78
$
0.78
Yield
(
lbs/
A)
1**
2,468
2,221
2,098
10~
15%
Quality
Loss
to
No
Sale
(
lbs/
A)
­
247
370
Processed
­
Average
2002~
2004
Total
($/
A)*
$
1,933
$
1,740
$
1,643
Total
Gross
Revenue
per
Acre*
$
4,162
$
3,857
$
3,649
($/
A)
$
0
$
305
$
513
Per
Acre
Impact
Decrease
in
Gross
Revenue
per
Acre
(%/
A)
0%
7%
12%
($)
$
0
$
3,
916,000
$
6,586,000
Regional
Impact***
Regional
Decrease
in
Value
of
Production
(%)
0%
5%
9%
1Source:
USDA/
NASS
Noncitrus
Fruits
and
Nuts
2004
Summary,
July,
2005.
*
Note:
Totals
may
differ
from
sum
of
components
due
to
rounding.
**
Note:
Data
is
average
yield
and
price
for
the
years
2002~
2004.
***
Note:
Regional
value
of
production
=
$
74
million.

BEAD
assumes
the
same
percent
crop
treated
in
all
the
acreage
in
this
region
(
17,350
acres
*
74%
=
12,839
acres).
According
to
BEAD
calculations,
at
the
regional
level,
the
lower
bound
impact
of
74%
of
the
acres
currently
using
phosmet
in
the
North
Central
region
in
Scenarios
1
&
2
are
estimated
to
be
an
decrease
in
gross
revenue
per
acre
of
about
7%
or
$
305/
acre,
which
amounts
to
$
3.9
million
($
305/
acre
*
12,839
acres
=
$
3,916,000).
The
upper
bound
impact
in
Scenarios
1
&
2
are
estimated
to
be
an
decrease
in
gross
revenue
per
acre
of
about
12%
or
$
513/
acre,
which
amounts
to
$
6.6
million
($
513/
acre
*
12,839
acres
=
$
6,586,000).
The
regional
value
of
production
is
approximately
$
74
million;
therefore
the
lower
bound
regional
loss
on
value
of
production
is
about
5%
and
the
upper
bound
regional
loss
is
about
9%.

Overall,
it
appears
that
in
the
North
Central
region,
highbush
blueberry
growers
without
phosmet
would
typically
face
some
loss
in
cash
returns
using
less
effective
alternatives
that
would
produce
lower
quality
levels.

Eastern
U.
S.

The
economic
analysis
attempts
to
assess
the
impacts
of
the
loss
of
phosmet
in
the
Eastern
region
highbush
blueberry
market.
With
47%
of
the
crop
treated
in
the
New
Jersey
alone,
phosmet
is
an
important
chemical
in
controlling
target
pests.
BEAD
assumes
the
same
percentage
of
the
crop
is
treated
over
the
whole
eastern
region
growing
8
area.
Without
phosmet,
growers
would
have
effective
alternative
regimes
to
substitute
for
phosmet
but
may
face
increased
costs
and
quality
losses.

In
the
Eastern
region,
average
fresh
market
yield
is
75%
of
the
total
production
and
average
processed
market
yield
is
25%
of
total
production.
Gross
revenue
is
calculated
as
the
sum
of
the
yield
multiplied
by
the
price
in
each
market
category.

Scenario
1
­
Phosmet
use
unavailable;
AZM
use
retained
The
quality
loss
assumptions
used
in
this
analysis
are
described
in
Table
2
(
above).

The
loss
estimates
used
in
this
analysis
for
Scenario
1
to
capture
the
lower
bound
losses
in
the
fresh
market,
include
the
lower
3%
estimate
of
quality
loss
from
the
fresh
market
to
not
being
marketable
("
no
sale"),
or
a
loss
of
138
pounds
per
acre
where
average
fresh
market
yield
of
4,600
pounds
per
acre
decreased
to
4,462
pounds
per
acre.
To
capture
the
lower
bound
losses
in
the
processed
market
this
analysis
also
assumes
the
lower
5%
estimated
quality
loss
from
the
processed
market
to
`
no
sale'
or
a
loss
of
40
pounds
per
acre
where
average
processed
market
yield
of
803
pounds
per
acre
decreased
to
763
pounds
per
acre
(
see
Table
4).
The
loss
estimates
used
in
this
analysis
for
Scenario
1
to
capture
the
upper
bound
losses
in
the
fresh
market,
include
the
higher
5%
estimate
of
quality
loss
from
the
fresh
market
to
not
being
marketable
("
no
sale"),
or
a
loss
of
230
pounds
per
acre
where
average
fresh
market
yield
of
4,600
pounds
per
acre
decreased
to
4,370
pounds
per
acre.
To
capture
the
higher
bound
losses
in
the
processed
market
this
analysis
also
assumes
the
higher
15%
estimated
quality
loss
from
the
processed
market
to
no
sale,
or
a
loss
of
120
pounds
per
acre
where
average
processed
market
yield
of
803
pounds
per
acre
decreased
to
683
pounds
per
acre
(
see
Table
4).

Table
4.
Summary
of
Grower
Level
Blueberry
Gross
Revenue
Impacts
 
Eastern
Region
Scenario
1
Grower
Level
Impacts
per
Acre
Current
Situation
Scenario
1:
Lower
Bound
Scenario
1:
Higher
Bound
Price
($/
lb)
1**
$
1.19
$
1.19
$
1.19
Yield
(
lbs/
A)
1**
4,600
4,462
4,370
3~
5%
Quality
Loss
to
No
Sale
(
lbs/
A)
­
138
230
Fresh
­
Average
2002~
2004
Total
($/
A)*
$
5,489
$
5,325
$
5,215
Price
($/
lb)
1**
$
0.84
$
0.84
$
0.84
Yield
(
lbs/
A)
1**
803
763
683
5~
15%
Quality
Loss
to
No
Sale
(
lbs/
A)
­
40
120
Processed
­
Average
2002~
2004
Total
($/
A)*
$
675
$
641
$
573
Total
Gross
Revenue
per
Acre*
$
6,164
$
5,965
$
5,788
($/
A)
$
0
$
199
$
376
Per
Acre
Impact
Decrease
in
Gross
Revenue
per
Acre
(%/
A)
0%
3%
6%
($)
$
0
$
1,840,000
$
3,476,000
Regional
Impact
Regional
Decrease
in
Value
of
Production
(%)
0%
2%
3%
1Source:
USDA/
NASS
Noncitrus
Fruits
and
Nuts
2004
Summary,
July,
2005.
*
Note:
Totals
may
differ
from
sum
of
components
due
to
rounding.
**
Note:
Data
is
average
yield
and
price
for
the
years
2002~
2004.
9
BEAD
assumes
the
same
percent
crop
treated
in
all
the
acreage
in
this
region.
According
to
BEAD
calculations,
at
the
regional
level,
the
lower
bound
impact
of
47%
of
the
acres
currently
using
phosmet
in
the
Eastern
region
in
Scenario
1
is
estimated
to
be
an
decrease
in
gross
revenue
per
acre
of
about
3%
or
$
199/
acre,
which
amounts
to
$
1.8
million
($
199/
acre
*
9,244
acres
=
$
1,840,000).
The
upper
bound
impact
in
Scenario
1
is
estimated
to
be
an
decrease
in
gross
revenue
per
acre
of
about
6%
or
$
376/
acre,
which
amounts
to
$
3.5
million
($
376/
acre
*
9,244
acres
=
$
3,476,000).
The
regional
value
of
production
is
approximately
$
122
million;
therefore
the
lower
bound
regional
loss
on
value
of
production
is
about
2%
and
the
upper
bound
regional
loss
is
about
3%.
Overall,
it
appears
that
highbush
blueberry
growers
without
phosmet
would
typically
face
some
loss
in
cash
returns
in
the
presence
of
effective
alternatives
that
would
produce
lower
yield
and
quality
levels
with
an
increase
in
production
costs.

Scenario
2
 
Phosmet
and
AZM
use
unavailable
The
quality
loss
assumptions
used
in
this
analysis
are
described
in
Table
2
(
above).

The
loss
estimates
used
in
this
analysis
for
Scenario
2
to
capture
the
lower
bound
losses
in
the
fresh
market,
include
the
lower
5%
estimate
of
quality
loss
from
the
fresh
market
to
not
being
marketable
("
no
sale"),
or
a
loss
of
230
pounds
per
acre
where
average
fresh
market
yield
of
4,600
pounds
per
acre
decreased
to
4,370
pounds
per
acre.
To
capture
the
lower
bound
losses
in
the
processed
market
this
analysis
also
assumes
the
lower
10%
estimated
quality
loss
from
the
processed
market
to
no
sale,
or
a
loss
of
80
pounds
per
acre
where
average
processed
market
yield
of
803
pounds
per
acre
decreased
to
723
pounds
per
acre
(
see
Table
5).
The
loss
estimates
used
in
this
analysis
for
Scenario
2
to
capture
the
upper
bound
losses
in
the
fresh
market,
include
the
higher
7%
estimate
of
quality
loss
from
the
fresh
market
to
not
being
marketable
("
no
sale"),
or
a
loss
of
322
pounds
per
acre
where
average
fresh
market
yield
of
4,600
pounds
per
acre
decreased
to
4,278
pounds
per
acre.
To
capture
the
higher
bound
losses
in
the
processed
market
this
analysis
also
assumes
the
higher
15%
estimated
quality
loss
from
the
processed
market
to
no
sale,
or
a
loss
of
120
pounds
per
acre
where
average
processed
market
yield
of
803
pounds
per
acre
decreased
to
683
pounds
per
acre
(
see
Table
5).

BEAD
assumes
the
same
percent
crop
treated
in
all
the
acreage
in
this
region
(
19,667
acres
*
47%
=
9,244
acres).
According
to
BEAD
calculations,
at
the
regional
level,
the
lower
bound
impact
of
47%
of
the
acres
currently
using
phosmet
in
the
Eastern
region
in
Scenario
2
is
estimated
to
be
an
decrease
in
gross
revenue
per
acre
of
about
6%
or
$
342/
acre,
which
amounts
to
$
3.2
million
($
342/
acre
*
9,244
acres
=
$
3,161,000).
The
upper
bound
impact
in
Scenario
1
is
estimated
to
be
an
decrease
in
gross
revenue
per
acre
of
about
8%
or
$
486/
acre,
which
amounts
to
$
4.5
million
($
486/
acre
*
9,244
acres
=
$
4,493,000).
The
regional
value
of
production
is
approximately
$
122
million;
therefore
the
lower
bound
regional
loss
on
value
of
production
is
about
3%
and
the
upper
bound
regional
loss
is
about
4%.
10
Table
5.
Summary
of
Grower
Level
Blueberry
Gross
Revenue
Impacts
 
Eastern
Region
Scenario
2
Grower
Level
Impacts
per
Acre
Current
Situation
Scenario
2:
Lower
Bound
Scenario
2:
Higher
Bound
Price
($/
lb)
1**
$
1.19
$
1.19
$
1.19
Yield
(
lbs/
A)
1**
4,600
4,370
4,278
5~
7%
Quality
Loss
to
No
Sale
(
lbs/
A)
­
230
322
Fresh
­
Average
2002~
2004
Total
($/
A)*
$
5,489
$
5,215
$
5,105
Price
($/
lb)
1**
$
0.84
$
0.84
$
0.84
Yield
(
lbs/
A)
1**
803
723
683
10~
15%
Quality
Loss
to
No
Sale
(
lbs/
A)
­
80
120
Processed
­
Average
2002~
2004
Total
($/
A)*
$
675
$
607
$
573
Total
Gross
Revenue
per
Acre*
$
6,164
$
5,822
$
5,678
($/
A)
$
0
$
342
$
486
Per
Acre
Impact
Decrease
in
Gross
Revenue
per
Acre
(%/
A)
0%
6%
8%
($)
$
0
$
3,161,000
$
4,493,000
Regional
Impact***
Regional
Decrease
in
Value
of
Production
(%)
0%
3%
4%
1Source:
USDA/
NASS
Noncitrus
Fruits
and
Nuts
2004
Summary,
July,
2005.
*
Note:
Totals
may
differ
from
sum
of
components
due
to
rounding.
**
Note:
Data
is
average
yield
and
price
for
the
years
2002~
2004.
***
Note:
Regional
value
of
production
=
$
122
million.

Overall,
it
appears
that,
as
in
the
North
Central
region,
Eastern
US
highbush
blueberry
growers
without
phosmet
would
typically
face
some
loss
in
cash
returns
using
less
effective
alternatives
that
would
produce
lower
quality
levels.

Request
for
Additional
Information
in
Stakeholder
Comments
As
part
of
the
request
for
comments,
BEAD
would
welcome
data
that
could
be
used
to
refine
this
assessment
if
necessary.
Useful
information
would
include:

 
particular
regional
or
pest
problems
leading
to
phosmet
use;
 
comparative
product
performance
data,
including
yield
and
quality
impacts;
 
costs
of
phosmet
products
and
alternative
insecticides;
 
non­
chemical
control
measures,
particularly
their
efficacy,
commercial
feasibility,
and
cost;
 
restrictions
or
other
constraints
on
the
use
of
alternatives;
and
 
timing
of
important
phosmet
application
across
the
season
for
different
growing
regions.

References
Anderson,
N.
Mallampalli
N.,
and
Kiely
T.
2001
Initial
Lowbush
and
Highbush
Blueberries
Benefits
Assessment
for
Azinphos­
methyl
and
Phosmet.
Available
on
the
web
at
http://
www.
epa.
gov/
oppsrrd1/
op/
azm.
htm.
11
Garcia­
Salazar.
C.
2001.
Crop
Timeline
for
Blueberries
in
Michigan
and
Indiana.
Available
on
the
web
at
www.
ipmcenters.
org.

Isaacs.
R.
2005.
Associate
Professor,
Department
of
Entomology,
Michigan
State
University,
East
Lansing,
MI.
Personal
communication
to
N.
Mallampalli,
USEPA/
OPP/
BEAD.

USDA.
2004.
A
Pest
Management
Strategic
Plan
for
Oregon
and
Washington
Blueberries.
Available
on
the
web
at
www.
ipmcenters.
org.

USDA.
2005.
Crop
Profile
for
Blueberries
in
North
Carolina.
Available
on
the
web
at
www.
ipmcenters.
org.

USDA/
NASS
Noncitrus
Fruits
and
Nuts
2004
Summary,
July,
2005.
Accessible
online
at:
http://
usda.
mannlib.
cornell.
edu/

USDA/
NASS,
Agricultural
Chemical
Usage
1993,
1997,
1999,
2001
and
2003
Fruit
Summary.
Accessible
online
at:
http://
usda.
mannlib.
cornell.
edu/
