                       

								Brian R. Flood, Ph.D. 										 Integrated Pest Management –
Vegetables

             						 		 600 North 15th Street       

 Rochelle, Illinois 60168 - 1002

								Brian.r.flood@delmonte.com

Laura L. Parsons 

Team Leader, Special Review and Reregistration Division (Mail Code
7508C) 

USEPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

phone:  703-305-5776 

email:    HYPERLINK "mailto:parsons.laura@epa.gov" 
parsons.laura@epa.gov 

Dear Ms. Laura L. Parsons:

RE: Retention of Penncap-M, encapsulated methyl parathion for machine
harvested sweet corn

The Mid West Food Processors are acutely aware and fully support EPA’s
goals in the utilization of less toxic and more environmentally friendly
pest management materials.  We have participated as partners in
obtaining, developing, registering and utilizing these effective tools. 
The efforts have reduced our cost, increased our effectiveness and
removed organophosphate insecticides from our pea, green bean and sweet
corn program.  Without your timely and focused registrations of these
new materials, we would have been able to accomplish this goal.  In the
Second Edition of Vegetable Insect Management by R. Foster & B. R. Flood
we highlight your efforts as one of the reasons a second edition was
required. 

Regretfully, vegetable crop pest are impacted by events taking place in
field crop production.  Our vegetable crops receive pests from these
crops as we often become trap crops.  The significant shift in pests has
elevated the root worm beetle complex from a minor pest into major pest
status.  Rootworm pest population levels are increasing as a result of
GMO field crops. The increased utilization of Roundup Ready field corn
and soybeans has created a green bridge that allows rootworm eggs laid
in field corn to develop on volunteer field corn plants in soybeans the
following year.  The Roundup Ready volunteer field corn also serves as
an oviposition site. In addition, the northern and western corn rootworm
adults will now lay eggs in soybeans.  First year corn is now at risk
due to the egg laying.  The net result is the loss of soybean as a
rotational crop and root worm beetle numbers are increasing.  The adult
beetle feeding on the succulent sweet corn foliage and silks could
reduce yield, quality and recovery, if not managed.  The current
pyrethroid materials are at best weak on this pest complex; Penncap M is
used successfully in field crops to manage the adults. 

The second issue is the developing pyrethroid resistance of the corn ear
worm enhanced by the wide area use of cheap pyrethroid insecticides in
new southern crop systems. The pyrethroid materials are used in GMO
cotton and new field crop systems but not directed specifically toward
corn earworm control.  The more pyrethroid tolerant corn ear worm
disperses to our production area in mid to late summer. We are
initialing and evaluating new control options and will seek EPA help in
gaining registrations when we determine our best alternative.  The new
insecticides, if available, will be registered in 3 to 5 years after we
find a suitable replacement.  In addition, we are evaluating new sweet
corn varieties and processing equipment (PROCESS OUT) to help us manage
these pests with non chemical means. GMO sweet corn is not an option. 
In the near short term, we have a potential problem that could result is
loses / cost in excess of $100 per acre on portions of our production
schedule.  The same set of acres is also at risk to adult rootworm
beetles.

We have a need for an effective rootworm material that will not promote
corn earworm resistance.  Penncap M is not an effective corn earworm
material, but does offer outstanding adult corn root worm beetle
control.  The treatment period for rootworms and corn earworms can
overlap, but the rootworm beetles can be treated prior to the corn
earworm.

The purpose of this letter is to make you aware of our situation and
provide insight for the retention of Penncap M use as a sweet corn
resistance management tool.  The retained material will reduce the
exposure of corn earworms to sub acute levels of pyrethroid materials
directed towards a surface feeding beetle while providing better adult
rootworm beetle control. 

Thank you for your efforts in managing the tools for effective
integrated pest management. 

Yours truly,

Brian R. Flood, Ph.D.

815-562-1311

