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

WASHINGTON D.C., 20460



May 15, 2006

  SEQ CHAPTER \h \r 1 OFFICE OF

PREVENTION, PESTICIDES AND TOXIC SUBSTANCES

MEMORANDUM

SUBJECT:	Preliminary Alternatives Analysis for Aldicarb on Cotton (DP
299886)

FROM:	Angel Chiri, Entomologist 

William L. Gross, Jr., Entomologist

		Biological Analysis Branch 

		Biological and Economic Analysis Division (7503C)

Derek Berwald, Economist	

Economic Analysis Branch

Biological and Economic Analysis Division (7503C)

THRU:	Arnet Jones, Chief 	

Biological Analysis Branch

Timothy Kiely, Acting Chief 	

Economic Analysis Branch

Biological and Economic Analysis Division (7503C)

TO:		Sherrie Kinard, Chemical Review Manager

		Robert McNally, Chief

		Special Review Branch

Special Review and Reregistration Division 

Peer Review Panel:  April 26, 2006

Summary

Aldicarb is a systemic carbamate pesticide used on cotton primarily for
control of thrips.  As part of the risk-benefit analysis for
reregistration, BEAD conducted an analysis of possible alternatives to
aldicarb used on cotton in the major cotton growing areas.  There appear
to be several alternatives to aldicarb for control of thrips.  We
estimate the costs of alternative chemicals for thrip control to be from
$2 – 10 per acre per year, which is less than the cost of aldicarb, at
about $14 per acre.  However, aldicarb also provides control of several
other cotton pests, and it provides protection for a longer time than
any of the alternatives.  Because of its long residual activity, in many
cases growers can apply one treatment of aldicarb, rather than multiple
treatments of other chemicals for equivalent control.  As a result, the
cost of controlling thrips will be higher if alternatives must be used. 


Background

As part of the Reregistration Eligibility Decision (RED) process, BEAD
conducted an analysis of potential alternatives for aldicarb.  Aldicarb
(Temik® 15G) is a systemic carbamate pesticide used to manage several
insects, mites, and nematodes, but its primary use on cotton is to
control thrips.  Agency risk assessments have raised concerns about
acute and chronic exposure for terrestrial and aquatic organisms.  

  

 Analysis

Crop Production

Cotton is a major crop in the United States, with a total value of
production averaging over $4.5 billion per year (see Table 1).  The
primary growing region for upland cotton (Gossypium hirsutum) is from
Texas in the west, throughout the southeast to the Atlantic Coast,
extending as far north as Kansas and Missouri, although it is also grown
in California and Arizona.  Pima cotton is a more valuable cotton, with
longer fibers.  Pima cotton requires a longer growing season than upland
cotton; it is grown in California, Texas, Arizona, and New Mexico. 
Depending on geography, climate, and cultural practices, cotton may be
planted as early as February through June and is generally harvested
September through December.  

Table 1 shows the area harvested, production, and the value of
production for both types of cotton, averaged over the years 2001 –
2005.    Texas is the largest producer of cotton, both in terms of
acreage and value.  California has the second largest value of
production, although the acreage is much lower than 4 other states.  The
high value of production in California reflects higher yields than other
states, as well as higher value cotton grown.  



Table 1.  All Cotton Area Harvested, Production, and Value: 2001 - 2005
Average  

 	Area Harvested	Production	Value of Production

 	(1,000 Acres)	(1,000 Bales1)	(1,000 Dollars)

Texas	4,810      	5,955      	1,221,090

Georgia	1,324      	1,971      	431,468

Mississippi	1,228      	2,191      	451,680

Arkansas	974      	1,917      	410,207

North Carolina	838      	1,261      	267,356

California	734      	2,088      	677,228

Louisiana	590      	961      	204,751

Tennessee	567      	958      	201,810

Alabama	548      	795      	167,303

Missouri	395      	744      	156,329

Arizona	242      	649      	148,033

South Carolina	239      	338      	73,504

Oklahoma	195      	258      	54,325

Florida	101      	122      	27,058

Virginia	92      	152      	30,906

Kansas	66      	71      	15,841

New Mexico	62      	114      	29,828





	United States	13,003      	20,547      	4,568,718

Source:  United States Department of Agriculture, National Agricultural
Statistics Service: Crop Production 2003 Summary, Crop Production 2005
Summary, Crop Values 2003 Summary, Crop Values 2005 Summary.

1 A standard bale weighs 480 pounds.  



Use and Usage of Aldicarb on Cotton

Aldicarb is a systemic and contact carbamate insecticide and nematicide.
 TEMIK® brand 15G aldicarb is a restricted use pesticide which is used
on cotton primarily for control of thrips, although it also controls
other insect pests, such as as mites.  Aldicarb is applied at planting,
in the furrow with the cotton seed, or it can be side-dressed to planted
cotton, 8 inches from the plants, two or three inches deep.  Although
Texas is the largest producer of cotton, it uses less aldicarb, both in
terms of active ingredient applied per acre, and the percent of the crop
treated  than most other states.  Most of the Texas cotton acres are
located in the High Plains and Rolling Plains areas of the state that do
not experience a lot of thrips activity in seedling cotton. 

Table 2 shows the average use of aldicarb on cotton for each state for
which NASS reports data, from 1991 – 2003.  The information in Table 2
should be viewed with caution, because not every state is sampled every
year, and if the data quality is low, results are not reported for a
state in a given year.  For example, data on aldicarb use for Texas are
reported 12 times over the period 1999 – 2003, while data for South
Carolina were reported only for 2003 and 2001.  Despite these issues,
the data from USDA NASS are the best publicly available data.    The
table shows that aldicarb is widely applied to cotton, and it is used in
all of the large cotton growing states.    Use of aldicarb on cotton has
been increasing over time as shown in Figure 1.  Most of the increase
occurred in the early 1990s; since the mid-90s, use has been highly
variable, without a clear trend.      

Table 2:  Aldicarb Use on Cotton, 1991 - 2003 Average

State/Area	Active Ingredient Applied (thousand pounds per year)	Percent
Acreage Treated	Application Rate (pounds per acre)

Georgia	394	46	0.61

Texas	278	11	0.46

North Carolina	268	47	0.69

California	261	24	1.27

Mississippi	200	27	0.61

Alabama	151	42	0.64

Arkansas	147	25	0.61

South Carolina	142	68	0.83

Missouri	121	48	0.65

Louisiana	101	26	0.50

Tennessee	54	18	0.58

Arizona	42	10	1.29

Source:  Calculated from USDA NASS database, which can be queried here:
http://www.pestmanagement.info/nass/

Note:  USDA NASS does not report data for every state for every year.
The number of observations is the number of years for which USDA NASS
reports use in a state. 



Important Cotton Pests Controlled by Aldicarb

Thrips are the primary target pest for aldicarb on cotton.  Aldicarb has
historically been used to control thrips on very young or seedling
cotton. Thrips are very small insects with rasping and sucking mouth
parts that rasp the tissue of young cotton plants and feed on the
exudates.  This damage causes silvering and stunting of the leaves in
young cotton, delayed maturity, and ultimately yield loss.  Usually
thrips infestations occur during cool and wet springs.  Aldicarb is
applied in granular form, usually at the same time as planting, and it
can also provide protection against nematodes.  A systemic pesticide,
aldicarb is taken up by the plant, where it provides long term
protection against thrips, nematodes, and other early season pests.   

Alternatives for Aldicarb Use on Cotton to Control Thrips and Nematodes

If aldicarb were not available, growers would likely use a combination
of acephate, chlorpyrifos, dicrotophos or imidacloprid to control
thrips.  Acephate, dicrotophos and imidacloprid are excellent
alternatives for thrips control.  Acephate is probably the most feasible
and flexible.  It can be applied at planting as a seed treatment and as
a planter box treatment.  Phorate, methamidophos, disulfoton,
chlorpyrifos and esfenvalerate can also be used for thrips control. 
Like aldicarb, many of the alternatives give incidental control of
spider mites, aphids, and lygus bugs.  The determination of aldicarb
alternatives and related information is based on analyzing the
information in the crop profiles and pest management strategic plans
from the cotton growing states.  These documents are listed in the
references.  

Table 3 shows the alternatives to aldicarb that have been identified for
insect control.  The table also shows the current use on cotton, as well
as the average cost of the alternatives.  As shown in Table 3, aldicarb
is more widely used than the proposed alternatives, both in terms of
pounds applied, and the percent of the cotton crop treated.  The
alternatives to aldicarb are less expensive, ranging in cost from two to
ten dollars per acre.  Because cotton growers have access to these
chemicals now, but choose not to replace aldicarb with a cheaper
alternative, we infer that there are agronomic benefits to using
aldicarb instead of the one of the alternatives.  In particular,
advantages of aldicarb are a long period of effectiveness, and control
over multiple pests, including nematodes as well as insects.   To get
equivalent control to aldicarb, a grower would likely have to combine
one or more of the alternatives listed for thrips control, possibly with
other chemicals to control secondary pests.  The costs in Table 3
include only chemical costs.  Application costs are not included in the
costs shown in the table.    

The costs of individual alternative chemicals for thrip control to be
from $2 – 10 per acre per year, which is less than the cost of
aldicarb, at about $14 per acre.  However, recall that growers will
likely have to use multiple chemicals to get the same level of control. 
 For comparison, average revenues for cotton are about $350 per acre,
nationwide.  Cotton, however, is also a high cost crop to grow, and for
many farmers cash returns from selling cotton do not cover the direct
cash outlays, although growers also receive government payments.  

Table 3:  Alternatives to Aldicarb: Use on Cotton (Nationwide), 1999 -
2003 Average

	Use on Cotton

	Active Ingredient	Active Ingredient Applied (thousand pounds per year)
Percent Acreage Treated	Cost ($/Acre)

Aldicarb	2,112	25	14





	Alternatives



	Acephate	1,679	16	5

Dicrotophos	618	12	2

Imidacloprid	17	3	10

Phorate	341	4	10

Methamidophos	35	1	4

Disulfoton	176	2	5

Chlorpyrifos	306	2	6

Esfenvalerate	6	1	4

Source:  Calculated from USDA NASS database, which can be queried here:
http://www.pestmanagement.info/nass/, and EPA Proprietary Data.



The conditions faced by individual growers are quite variable and
available data are limited, and therefore it is currently impossible to
provide a reasonable estimate of the cost of aldicarb alternatives that
is appropriate for all growers.  Instead, we provide here two
illustrative scenarios for different production regions.  These provide
examples of the combinations of chemicals growers in different regions
might need to replace aldicarb, along with estimates of the cost
impacts.  In addition, the prices and yields vary widely across
different regions of the country, so a single scenario can be
misleading.  

The scenarios are shown in Table 4, with estimates provided for cotton
production in California,  and the production area around the
Mississippi River.  For each area, a baseline scenario is provided, to
represent current conditions, in which aldicarb is used.  The cost of
production and price data used are from the USDA Economic Research
Service commodity cost and returns data sets (USDA-ERS(a)), which
provide regional estimates of revenues and costs.  For Table 4, the cost
of production, prices, and yields, are averages for 2000 – 2004.  The
cost and return estimates available from the USDA are based on farm
resource regions, rather than states.  We use the cost and returns
estimates from the “Mississippi Portal” for the Mississippi River
region and the “Fruitful Rim” for California.

The costs for the individual chemicals, both for aldicarb and its
replacements, are from EPA proprietary data.  For the Mississippi River
region, the pesticide costs are the averages of three states
(Mississippi, Louisiana, and Arkansas) for the same time period.  Note
that the cost of chemicals can vary by region, even for the same
chemical.  This is a result of different use patterns, such as the
amount of active ingredient applied, and different costs in different
regions.

For the Mississippi River region, we assume that as an alternative to
aldicarb, growers will use an application of imidacloprid at planting,
followed by an application of acephate, and a later application of
dicrotophos.  For California, the use of aldicarb is for control of a
complex of target pests, which include thrips, aphids, and mites.  The
alternative regime is assumed to be an application of acephate at
planting, a treatment of chlorpyrifos, and a treatment of abamectin. In
both cases, we assume that the alternatives provide the same level of
control as aldicarb, and so we assume that there are no yield or quality
losses.  The inclusion of abamectin in the alternative scenario may
cause this to be an upper bound estimate, because it is a very expensive
chemical, with a cost of about $28 per acre in California cotton. 

As shown in Table 4, we estimate that using alternatives to aldicarb
will cost cotton growers about $2 per acre more in the Mississippi River
region.  In California, we estimate the alternatives to aldicarb to be
about $44 per acre.  This high per acre cost is a result of including
abamectin for mite control, which costs about $28 per acre.  However,
even this high cost is only about twice the cost of aldicarb in
California, because the amount of aldicarb active ingredient applied is
higher in California than other areas, as shown in Table 2.  

Also included in Table 4, but not the USDA cost and returns estimates,
are estimated government payments to cotton growers.  To estimate the
government payments, we use information available from the United States
Department of Agriculture Economic Research Service (USDA ERS (b)). 
Growers receive payments based on historical yields and acreage grown. 
The base yield for the program is 93.5% of the 1998 – 2001 average
yield.  Because our estimates of the impacts are on a per acre basis, we
approximate that by multiplying the assumed yield in the table (which
varies by region) by 0.935.  Growers receive payments on a maximum of
85% of their base acreage.  We approximate that by multiplying again by
0.85, which gives us an approximate of the base acreage on a per acre
basis.  The target price for upland cotton is $0.724 per pound, and
growers also receive $0.0667 per pound direct payments.  To approximate
these payments, we multiply the cotton eligible for government payments
by $0.0667 (to represent the direct payment) plus the difference between
$0.724 and the average cotton price for the region (to represent the
difference between the target price and the market price).  For example,
in California the government payments are estimated to be about
0.935*0.85*((0.724 – 0.54) +0.0667)*1,118 = $223 per acre.  We did not
estimate the revenue from the marketing loan program, because cotton
prices are close to the loan price.  

Table 4.  Gross Returns, Production Costs and Net Cash Returns for
Aldicarb Alternatives in Cotton. 



Mississippi River

California



Baseline	Alternative Scenario

Baseline	Alternative Scenario

Cotton Production  (pounds/acre)

828	828

1,118	1,118

Cotton Price  ($/pound)

$0.50 	$0.50 

$0.54 	$0.54 

Cottonseed Production  (pounds/acre)

1478	1,478

1,671	1,671

Cottonseed Price  ($/pound)

$0.05 	$0.05 

$0.07 	$0.07 

Gross Returns  ($/acre)

$486 	$486 

$717 	$717 









Pesticides







Aldicarb ($/acre)

$12

	$22

	Alternative Chemicals* ($/acre)

	$14

	$44

Percent Change

	19.7%

	100.7%









Other Pesticide Costs  ($/acre)

$81	$81

$66	$66









Other Direct Costs  ($/acre)

$265	$265

$384	$384









Total Operating Costs  ($/acre)

$358	$361

$472	$494

Estimated Government Payments**  ($/acre)

$190 	$190 

$223 	$223 

Net Cash Returns  ($/acre)

$318 	$316 

$468 	$446 

Percent Change	 	 	-0.7%	 	 	-4.7%

Source:  Crop cost and returns estimates from USDA ERS(a), EPA
Proprietary Data.

Totals may differ from sum of components due to rounding.

*For the Mississippi River region, the alternative chemicals are
imidachloprid, acephate, and dicrotophos.  For California, the
alternatives chemicals are acephate, chlorpyrifos, and abamectin.  

**Government payments are estimated as 0.935*0.85*((0.724 – 0.50)
+0.0667)*828 = $190 per acre for the Mississippi River region, and
0.935*0.85*((0.724 – 0.54) +0.0667)*1,118 = $223 per acre for
California.  See the text for an explanation. 



In our baseline scenarios, where aldicarb is used, returns to the grower
are estimated to be about $318 per acre in the Mississippi River region
and $468 per acre in California.  Using the alternatives in place of
aldicarb results in an increase in total pesticide costs of about 3% in
the Mississippi River region, and almost 25% in California.  The
additional costs will decrease net cash returns to growers, as well. 
Because pesticide costs are only one part of the total costs, the change
in net cash returns will be smaller.  Net cash returns decrease by about
1% in the Mississippi River region, and about 5% in California.  These
figures include government payments to growers, and these payments are
independent of current cotton production.  If we consider only the
revenue from cotton production and sales, the decrease in net cash
returns is roughly doubled, to about 2% for the Mississippi River
region, and about 9% for California.  

Uncertainties in the Analysis

Assumptions about the lack of yield and quality changes with alternative
controls are based on the best professional judgment of BEAD analysts;
in-field experience may differ.  The analysis also assumes that
currently available chemicals will be available in the future, and that
market conditions will not change dramatically.  

Aldicarb has other advantages to the grower for which we do not estimate
dollar values, such as simplicity of management, and confidence in the
level of control in the face of unexpected infestation, and
cost-effectiveness when considering the full range of pests and duration
of control.  Finally, BEAD’s economic calculations focus on net cash
returns, which overstate grower income.  This is an uncertainty inherent
in all of BEAD’s economic assessments and is a result of the fact that
there is no way for BEAD to know with certainty all the fixed costs
growers face.  

References

Pest Management Strategic Plan in California Cotton Production.  2002.

	  HYPERLINK
"http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site
" 
http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site 

Pest Management Strategic Plan for Cotton in the Midsouth.  2003.

  HYPERLINK
"http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site
" 
http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site 

Stevenson, D.E. and M.A. Matocha.  2005.  A Pest Management Strategic
Plan for Cotton

Production in Texas.

  HYPERLINK
"http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site
" 
http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site 

 

United States Departmetent of Agriculture, Economic Research Service
(USDA ERS(a)).  U.S. and Regional Cost and Return datasets.  Available
here:   HYPERLINK
"http://www.ers.usda.gov/Data/CostsAndReturns/testpick.htm" 
http://www.ers.usda.gov/Data/CostsAndReturns/testpick.htm 

United States Departmetent of Agriculture, Economic Research Service
(USDA ERS(b)).  The 2002 Farm Bill: Provisions and Economic
Implications.   Available here:   HYPERLINK
"http://www.ers.usda.gov/Features/FarmBill/" 
http://www.ers.usda.gov/Features/FarmBill/ 

United States Department of Agriculture. Crop Profile for Cotton in
Alabama.  September, 2001. Available here:   HYPERLINK
"http://www.ipmcenters.org/cropprofiles/docs/alcotton.html" 
http://www.ipmcenters.org/cropprofiles/docs/alcotton.html 

United States Department of Agriculture. Crop Profile for Cotton in
Arizona.  August, 1999.  Available here:   HYPERLINK
"http://www.ipmcenters.org/cropprofiles/docs/Azcotton.html" 
http://www.ipmcenters.org/cropprofiles/docs/Azcotton.html 

United States Department of Agriculture. Crop Profile for Cotton in
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http://www.ipmcenters.org/cropprofiles/docs/Arcotton.html 

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"http://www.ipmcenters.org/cropprofiles/docs/CAcotton.html" 
http://www.ipmcenters.org/cropprofiles/docs/CAcotton.html 

United States Department of Agriculture. Crop Profile for Cotton in
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http://www.ipmcenters.org/cropprofiles/docs/LAcotton.html 

United States Department of Agriculture. Crop Profile for Cotton in
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"http://www.ipmcenters.org/cropprofiles/docs/MScotton.html" 
http://www.ipmcenters.org/cropprofiles/docs/MScotton.html 

United States Department of Agriculture. Crop Profile for Cotton in
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United States Department of Agriculture. Crop Profile for Cotton in
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United States Department of Agriculture. Crop Profile for Cotton
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HYPERLINK "http://www.ipmcenters.org/cropprofiles/docs/tncotton.html" 
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United States Department of Agriculture. Crop Profile for Cotton in
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"http://www.ipmcenters.org/cropprofiles/docs/txcotton.html" 
http://www.ipmcenters.org/cropprofiles/docs/txcotton.html  

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"http://usda.mannlib.cornell.edu/reports/nassr/field/pcp-bban/cropan04.p
df" 
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f  

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df" 
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f  

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" 
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Texas Cooperative Extension Service (2004).  Suggested Insecticides for
Managing Cotton Insects in the High Plains, Rolling Plains and Trans
Pecos Areas of Texas.

 This figure was calculated from Table 1.  The numbers vary by state,
with high revenues in California of over $900 per acre), to low revenues
in Kansas of under $250 per acre.  

 A description of the farm resource regions can be found here:  
HYPERLINK
"http://www.ers.usda.gov/Briefing/ARMS/resourceregions/resourceregions.h
tm" 
http://www.ers.usda.gov/Briefing/ARMS/resourceregions/resourceregions.ht
m 

 EPA proprietary data are data on pesticide use purchased from private
sector firms

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