Comment submitted by John Keeling, National Potato Council

NATIONAL POTATO COUNCIL 1300 L Street, NW, Suite 910 Washington, DC 20005 202.682.9456 ? 202.682.0333 fax www.nationalpotatocouncil.org spudinfo@nationalpotatocouncil.org February 14, 2008 Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P) Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460?0001. RE: Docket Identification (ID) number EPA?HQ?OPP?2002?0262 To Whom It May Concern: This letter is being provided to the U.S. Environmental Protection Agency?s (EPA) announcement on the availability of updated human health and ecological effects risk assessments and subsequent opening of the comment period for endosulfan, as outlined in the November 16, 2007 Federal Register Notice. The National Potato Council (NPC) is the only trade association representing commercial potato growers in 50 states. Our growers produce both seed potatoes and potatoes for consumption in a variety of forms. Annual production is estimated at 437,888,000 cwt. with a farm value of $3.2 billion. Total value is substantially increased through processing. The potato crop clearly has a positive impact on the U.S. economy. The NPC appreciates and welcomes the opportunity to supply the EPA with input on this important topic. Endosulfan has a long history of use in the U.S. potato industry. It is used against an unusually wide spectrum of pests including a number of problem insects not commonly thought of as pest management challenges in potatoes. It is one of only two products that are effective against the silverleaf whitefly in California and the Gemini virus transmitting whiteflies in Florida. It has an unusually important role in resistance management. It is specifically identified in resistance management programs in the Pacific Northwest, the South East, Texas and California. It is repeatedly recommended as a product that can control a mixture of pest species that other insecticides cannot control. The combination of its spectrum of control, resistance management role, short pre harvest interval, flexibility in methods of application and low relative toxicity to beneficial organisms make it an important tool for potato growers in all regions of the United States. In the Pacific Northwest, endosulfan is primarily used to control Colorado potato beetle (CPB). CPB has developed resistance to pyrethroid insecticides in Idaho and Oregon. The development of resistance has been documented by Dr. Juan Alvarez, entomologist, University of Idaho. Endosulfan has been proven to be effective against pyrethroid resistant CPB populations in this region. Endosulfan is also used to a lesser extent against beet leafhopper and the false chinch bug. In Michigan and Wisconsin, endosulfan is used to control potato leafhopper. It is most commonly applied once per season, usually in rotation with products belonging to other classes of chemistry. In Maine, endosulfan is applied by ground when growers have a mixed assemblage of pests that do not often occur and it is one of the products of choice against armyworms. Endosulfan is one of two products recommended for control of silverleaf whitefly in potatoes in California (http://www.ipm.ucdavis.edu/PMG/ selectnewpest.potatoes.html). More than one application is needed per season, and due to severe concerns with resistance, endosulfan should be rotated with dinotefuran. It is one of three products recommended for control of aphids in California potatoes. It is one of five products recommended for control of flea beetle. Endosulfan is an important product for potato production in the Mid-Atlantic states. Following is an excerpt from the Pennsylvania potato crop profile: ?During late June or Early July, aphids begin the destructive portion of their life cycle. At this time, endosulfan is rotated with the Organophosphates to manage Colorado potato beetle, potato leafhoppers and aphids. At this time of the season, the pyrethroid insecticides have normally become ineffective as a broad-spectrum compound. Applications that are rotated between endosulfan and the organophosphates continue until pre- harvest vine desiccation.? [see http://www.ipmcenters.org/cropprofiles/docs/ papotatoes.pdf] A small amount of endosulfan is used on Delaware potatoes for mixed assemblages of Colorado potato beetle and cutworms. Florida has one of the highest percentages of crops treated with endosulfan with approximately30 percent of the potato acreage an average of 1.0 time, at a rate of approximately 1.0 pounds of active ingredient per acre. Because endosulfan has such a short PHI, it is often the insecticide of choice to combat late season outbreaks of pests such as whiteflies and southern armyworms. The combination of imidacloprid and endosulfan also allows for season long control of whiteflies. This is important for adjacent producers of tomatoes for Gemini virus management on tomatoes. http://edis.ifas.ufl.edu/PI030 Endosulfan is used in Colorado for control of potato psyllids. In Ohio, it is used to control mixed assemblages of insect pests including flea beetles, Colorado potato beetle, leafhoppers, aphids, European corn borer, tarnished plant bug. The product is used on potatoes grown in Texas for control of leafhopper, potato psyllids, aphids and Colorado potato beetle. It is the only product recommended for use on potatoes that controls this spectrum of insects, other than neonicotinoid insecticides. One of the drivers in the use of this product in Texas is that the product is considered critical for preventing resistance development in the neonicotinoid class of insecticides. One of the primary alternatives to endosulfan are the pyrethroid insecticides, however these insecticides are well known to be disruptive to IPM programs. Endosulfan is lower in toxicity to beneficial organism than most organophosphate, carbamate and pyrethroid insecticides (http://www.ipm.ucdavis.edu/PMG/r607300711.html). Sincerely, John Keeling Executive Vice President and CEO