  SEQ CHAPTER \h \r 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460



  SEQ CHAPTER \h \r 1 OFFICE OF

PREVENTION, PESTICIDES AND TOXIC SUBSTANCES

MEMORANDUM

SUBJECT:	Response to Public Comments Received in Response to the Interim
Reregistration Eligibility Decision for Formetanate Hydrochloride
(Docket Number EPA-HQ-OPP-2004-0032, DP Barcode 320463)

FROM:	David W. Brassard, Senior Entomologist

Biological Analysis Branch 

Biological and Economic Analysis Division (7503P)

THRU:	Arnet Jones, Chief

		Biological Analysis Branch

		Biological and Economic Analysis Division (7503P)

TO:		James Parker, Chemical Review Manager

		Laura Parsons, Team Leader

		Susan Lewis, Chief, Reregistration Branch 1

Special Review and Registration Division (7508P) 

PRODUCT REVIEW PANEL DATE: 10/25/06  

INTRODUCTION

This document represents BEAD’s responses to public comments on the
Agency’s proposed decisions published in the “Interim Reregistration
Eligibility Decision for Formetanate Hydrochloride” that were received
in the EPA docket (EPA-HQ-OPP-2004-0032).   Three organizations
submitted benefits related comments: California Citrus Mutual,
California Grape & Tree Fruit League, and the Northwest Horticultural
Council.  In general the commenters stated that the prohibition of
formetanate hydrochloride application by aircraft or in open cabs would
pose a hardship to growers.  None of the comments included
substantiating evidence regarding the effect that switching to closed
cabs or substituting alternative insecticides would have on crop yield,
quality, or grower revenues.

BEAD has not conducted an impacts assessment on the impacts of extending
restricted entry intervals or eliminating the use of open cab ground
equipment and aerial application from formetanate hydrochloride
labeling.  BEAD did conduct a preliminary qualitative alternatives
analysis.

COMMENTS AND RESPONSES

Comment  “The continued availability of formetanate hydrochloride as a
tool for thrip control in citrus ensures acceptable fruit appearance for
exporting citrus to markets using a product with established MRLs  in
place.  Current label restrictions on timing of application and worker
reentry as well as limits on the amount that can be applied in a growing
season greatly narrow the window of use. Even so, Carzol SP remains a
valuable tool in the grower’s pesticide rotation.  Eliminating Carzol
SP would reduce grower’s options; require more applications of other
products increasing the risk of pest resistance and even more
applications of pesticide and disruption of growers IPM programs.”

“California Citrus Mutual on behalf of California citrus growers urges
the agency to 

complete RED and approve the reregistration of formetanate
hydrochloride.” (California Citrus Mutual, 2006).

Response  The Agency acknowledges the importance of formetanate
hydrochloride as a tool for thrips control on citrus.   The Agency’s
Interim Reregistration Eligibility Decision for Formetanate
Hydrochloride allows for continued use of formetanate hydrochloride on
citrus.

Comment  “Under the risk mitigation measures the Environmental
Protection Agency (EPA) made the proposal to prohibit aerial
applications on orchard crops. Aerial applications are not commonplace
in the stone fruit industry but there are circumstances when aerial
applications are needed. On occasion the need arises for aerial
applications when excessive rains leave orchards too wet to use a ground
rig.  The League supports the prohibition of aerial applications if a
contingency is made to permit aerial applications when ground rigs
cannot be used due to a wet orchard floor.”  (California Grape & Tree
Fruit League. 2006)

Response  The Agency acknowledges the importance of aerial applications
of formetanate hydrochloride on stone fruit when ground application
equipment cannot be used due to a wet orchard floor.  In these
situations, growers would still have the option to apply an alternative
insecticide (such as spinosad or pyriproxyfen) by air to control stone
fruit pests.

Comment  “EPA’s proposed stipulation to require the use of closed
cab rigs with an air blast sprayer is not practical in most instances.
First, there are environmental restrictions with the use of closed cab
tractors because of the equipment size.  Many nectarine growers
establish higher density plantings which mean the trees are planted
closer together making it difficult, if not impossible, to maneuver a
closed cab rig in the orchard without damaging tree limbs. Higher
density plantings are important to the operation because the practice
results in higher production per acre and more efficient water use. In
addition, most nectarine growers don’t own or lease closed cab rigs
making it an economic burden to be required to purchase such equipment
to use carzol.”

“The League opposes the closed cabs requirement because the majority
of stone 

fruit growers do not own or lease closed cab equipment and the height of
such 

equipment can damage the orchard (California Grape & Tree Fruit League,
2006).   Less than 5% of the area orchardists own closed cab systems. 
In addition, the cost of purchasing closed cab tractors given the
limited use of formetanate hydrochloride is difficult to economically
justify.” (Northwest Horticultural Council, 2006)

Response  The Agency acknowledges that many growers do not own or lease
closed cab airblast equipment and that buying or leasing closed cab
equipment will result in some growers incurring additional costs.  The
Agency also acknowledges that some closed cab equipment is larger than
open cab airblast sprayers and may necessitate additional pruning costs
in order to accommodate enclosed cabs.  Growers who cannot afford to
make the transition would still have the option to apply an alternative
insecticide (such as spinosad for thrips control) in open cabs to
control tree fruit pests.  Since BEAD has not conducted an impacts
assessment on the impacts of eliminating the use of open cab ground
equipment from formetanate hydrochloride labeling, BEAD can only address
this comment qualitatively.

References

California Citrus Mutual.  2006.  Comment from Robert D. Blakely,
Director of Grower Services, California Citrus Mutual, 512 North Kaweah
Avenue, Exeter, CA 93221.

California Grape & Tree Fruit League. 2006.  Comment from Marcy Martin
Gabrielle, Director, Trade Services Director, Environmental and
Regulatory Affairs, California Grape & Tree Fruit League, Kirkland, CA.

Northwest Horticultural Council. 2006.  Comment from Dr. Michael J.
Willett, Vice President for Scientific Affairs, Northwest Horticultural
Council, 105 So. 18th Street, Suite 105, Yakima, Washington 98901 (509)
453-3193   www.nwhort.org

