Michael A. Devencenzi

Agricultural Pest Management / Consulting

338 Valley Oak Place

Woodbridge, California 95258-9323

209/368-5482

James R. Cranney Jr.

U.S Apple Association

8233 Old Courthouse Rd.

Vienna, Va. 22182

January 31, 2006

Dear Jim, 

	In looking over the 2005 Assessment of EPA-BEAD Grower Analysis of
Azinphosmethyl I would like to bring a few discrepancies and
inaccuracies to your attention.

	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. This is a far more real life scenario and is
actually used in this fashion in areas where AZM cannot be used. Similar
control would be expected. Costs though would be far higher as AZM 2005
going price is at $9.20 / lb. or $23 / acre @ 2.5 lbs / acre formulated
product. The phosmet at 5 lbs / acre / application at the 2005 price of
$6.44 / lb. cost $32.20. If you add the additional 3 application costs
of $20 / application the phosmet program would cost $184.20 / acre more
than the AZM one. Let us not forget that the 3 additional phosmet
applications would subject the orchard, applicator, and the environment
with 3 additional pesticide applications.

	Scenario 2 refers to the usage of newer, softer insecticides as an
alternative to AZM. Many of these newer products appear to be effective
on codling moth assuming the population is not high with in the field or
if a resistant population is not present. 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. Thiaclorprid has just received registration in
California and has not been used on an area wide basis as of yet.
Through a research authorization I was able to apply this product in
2004 to 2 different apple orchards. Bayer, the registrant, was
interested in how it may fit into California’s apple industry. It
preformed well on rosey apple aphid at both sites, codling moth control
was satisfactory in the low population orchard and was very poor within
the heavy population field. The PHI of 30 days with Thiaclorprid is also
an industry concern. This long PHI is a particular problem when trying
to control codling moth that is hatching into the harvest period, which
is very common in California. Novaluron is not registered in California
at this time with the earliest registration date being sometime in 2007
according to the registrant. The costs of these products per acre per
application will all exceed the 3 applications of AZM with out giving
the industry even close to the residual needed for acceptable codling
moth control.

	Scenario three refers to the usage of mating disruption (MD) with the
allowance of 1 application of AZM. In California it is not uncommon to
use MD in conjunction with 3 applications of AZM to achieve acceptable
control. MD is not a fit on many ranches due to their size being too
small or because of other adjacent hosts of codling moth within the
area. It is uncommon to use MD as a stand alone product, as even the
manufacturer suggests supplemental applications of insecticides if the
population or ranch requires it. One example of this would be an organic
apple grower of mine that had to use MD as his major means of codling
moth control for years. Damage was severe, over 75%, until spinosad was
registered for organic usage. The combination of the spinosad and the MD
resulted in a conservative 40%+ codling damage. When adding Cyd-X
(granulosis virus), through a research authorization, to the program we
have now brought our damage down to 20% plus or minus. This 20% percent
damage was achieved with a full complement of MD, 3 spinosad
applications and 9 virus applications. 

	As you can see, codling moth within the central valley of California is
and has been a challenge to manage. The industry here utilizes many
codling management tools and at this time AZM, like it or not, is
irreplaceable. 

	

	Please pass this information on to the proper agencies and let me know
if I can be of further assistance. 

Thank you.

Sincerely,

 

Michael A. Devencenzi

Agricultural Pest Management / Consulting

