VIA E-MAIL

March 15, 2006

Dr. Debbie Edwards, Director

Special Review and Reregistration Division (7506P)

U.S. Environmental Protection Agency

Office of Pesticide Programs

1200 Pennsylvania Ave., NW

Washington, DC 20460-0001

	Re:	Meeting with EPA regarding carbofuran IRED.

Dear Dr. Edwards:

This is to thank the EPA for meeting with the National Cotton Council
and other commodity organizations on March 5 to discuss the efficacy and
economic significance of carbofuran insecticide.  

In our meeting last week, the NCC sought to convey the complexity of
controlling multiple piercing-sucking insect pests with relatively few
classes of pesticides and increasing documentation of pest resistance. 
In particular, cotton producers are apprehensive that documented cases
of organophosphate resistant aphids in the late 1990s could be repeated
in the near future based on documentation during 2006 showing increased
tolerance of aphids to neonicotinoids and the reliance on these
chemistries to control other piercing-sucking pests throughout the
growing season.  Carbofuran as a niche, minor-use option would enhance
management capabilities to control aphids resistant to other chemistries
and would provide a different mode of action that should delay
resistance development overall.  Responsible and judicious use of
carbofuran protects the grower’s bottom line, avoids worker exposure,
and prevents ecological impact.

We understand that the registrant will soon be submitting additional
economic benefits studies to EPA.  The NCC continually appreciates the
agency meeting with us and conducting a full review of this important
product to cotton producers.      

Sincerely,

Angus R. Kelly

National Cotton Council 

cc: Rick Keigwin

      Allen Jennings

 

