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.

Brunner
JF,
Beers
EH,
Dunley
JE,
Doerr
M,
Granger
K.
2005.
Role
of
neonicotinyl
insecticides
in
Washington
apple
integrated
pest
management.
Part
I.
Control
of
lepidopteran
pests.
10pp.
Journal
of
Insect
Science,
5:
14,
Available
online:
http://
www.
insectscience.
org/
5.14/
Brunner_
et_
al_
JIS_
5_
14_
2005.
pdf
Buckelew,
L.
2006.
Bayer
CropScience
Response
to
EPA
Request
for
Public
Comment
on
Azinphos­
methyl
Uses
on
Apple,
Almond,
Cherries,
Walnuts,
Pear,
Pistachio,
Blueberries,
and
Brussels
Sprouts.
REPORT
NUMBER
LB12606.
Bayer
CropScience,
2
T.
W.
Alexander
Drive,
Research
Triangle
Park,
NC
27709
CDFA.
2006.
Usage
of
Agricultural
Pesticides
in
California:
2004
Pesticide
Usage
Report.
California
Department
of
Food
and
Agriculture,
Sacramento,
CA
95814,
http://
www.
ipm.
ucdavis.
edu/
PUSE/
puse1.
html
Goodman,
C.
2006.
Comments
Regarding
Azinphos­
Methyl
use
on
Apples
and
Pears,
Docket
No
EPA­
HQ­
OPP­
2005­
0061
Research
Manager,
Department
of
Food
and
Agriculture,
Pesticide
Consultation
&
Analysis,
1220
"
N"
Street,
Room
444,
Sacramento,
CA
95814,
Tel
:
(
916)
657­
4956,
Fax:
(
916)
657­
5016
44
Gut,
L.
J.
and
Brunner
J.
F.
1996).
Mating
Disruption
as
a
Control
for
Codling
Moth
in
Washington
Apple
Orchards.
Wash.
State
Univ.
Tree
Fruit
Research
and
Extension
Center
Info.
Series
No.
1,
March
1996.
The
Good
Fruit
Grower,
Yakima.
8
p.).

Gut,
L.
J.
and
Brunner,
J.
F.
1998.
Pheromone­
based
management
of
codling
moth
(
Lepidoptera:
Tortricidae)
in
Washington
apple
orchards.
J.
Agric.
Entomol.
15(
4):
387­
406.)

McClain,
B.
2006.
Comments
regarding
2005
Growers
Impact
Assessment
of
Azinphosmethyl
Use
on
Pears.
Research
and
IPM
Coordinator,
California
Pear
Advisory
Board,
1521
I
Street
Sacramento,
CA
95814,
Phone:
916­
441­
0432,
Web
Address:
bob@
calpear.
com
Michigan
Fruit
Management
Guide.
2006.
Michigan
State
University.
pp
79­
89.
Available
on
the
web
at
http://
web1.
msue.
msu.
edu/
pestpubs/
E154/
16­
Tart_
Cherries.
pdf
Spitko,
R.
2006.
Phosmet:
Summary
of
Efficacy
Studies
1991­
2005.
Submitted
on
behalf
of
Gowan,
Inc.
to
Diane
Isbell,
EPA/
OPP/
SRRD.
Internal
unpublished
document.

UC
Davis.
2001.
"
Sample
Cost
to
Establish
an
Apple
Orchard
and
Produce
Apples".
A
publication
of
the
University
of
California
Cooperative
Extension,
Davis,
CA.

USDA.
2003a.
New
England
Apple
Strategic
Plan.
Available
on
the
web
at
www.
ipmcenters.
org.

USDA.
2003b.
A
Pest
Management
Strategic
Plan
for
Pear
Production
in
California.
http://
www.
ipmcenters.
org/
pmsp/
pdf/
CAPear.
pdf
USDA.
2004.
Mid
Atlantic
Apple
Pest
Management
Strategic
Plan
­
2003.
Available
on
the
web
at
www.
ipmcenters.
org.

Van
Steenwyk,
R.
A.
2006.
Personal
Communication
with
David
W.
Brassard
on
March
21
and
March
28,
2006.
Entomologist,
University
of
California,
Berkeley,
California.
510­
643­
5159,
bobvanst@
nature.
berkely.
edu.

Van
Steenwyk,
R.
A.,
R.
Nomoto,
and
S.
Zolbrod,.
2004.
Codling
Moth
Control
in
Pears,
2003.
Arthropod
Management
Tests,
Vol
29,
Report
A32
Van
Steenwyk,
R.
A.,
R.
Nomoto,
and
S.
Zolbrod.
2003.
Codling
Moth
Control
in
Pears,
2002.
Arthropod
Management
Tests,
Vol
28,
Report
A28.

Varela,
L.
G.,
C.
Ingels,
and
R.
Van
Steenwyk.
2003.
Evaluation
of
Assail
for
Control
of
Codling
Moth.
California
Pear
Advisory
Board
website:
www.
calpear.
com
Wyatt,
TJ,
T.
Kiely,
and
N.
Mallampalli.
BEAD
assessment
of
citations
submitted
by
45
plaintiffs
(
Case
2:
04­
cv­
00099­
RSM)
in
regard
to
EPA's
2001
Benefits
Assessments
for
Azinphos­
methyl
(
DP
307589).
Available
on
the
web
through
www.
regulations.
gov.

Zoller,
B.
2006.
Current
Use
and
Importance
of
Azinphos­
Methyl
(
AZM)
in
California
Pear
Production.
Broc
Zoller,
PhD,
The
Pear
Doctor,
Inc.,
P.
O.
Box
335,
Kelseyville,
CA
95451.
