Comments submitted by David Rennhack

Document ID: EPA-HQ-OPP-2005-0061-0053
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: January 18 2006, at 01:07 PM Eastern Standard Time
Date Posted: January 23 2006, at 12:00 AM Eastern Standard Time
Comment Start Date: January 23 2006, at 12:00 AM Eastern Standard Time
Comment Due Date: February 20 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 80115aa8
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I am a cherry grower and farm market operator located in Hart, Michigan. I raise both sweet and tart cherries for both the processing and fresh markets. I have used azinphosmethyl (AZM) for my entire adult life in my farming operation. I have found it an essential product in our constant battle against many worm type insects such as Plum Curculio and Cherry Fruit Fly. It has been a reliable insecticide against these pests and is consistent and predictable in its results. By using this product we have been able to produce worm free fruit to our processor and retail and wholesale customers. I would be very concerned if AZM was removed from our limited arsenal of compounds. We have a zero tolerance for worms in fruit at the processor level and at the fresh marketing level worms in cherries would be devestating to sales the year it happened and would severly harm our good reputation for years to come. A reputation takes years to build and one instance to lose. Consumers who found worms in cherries would be more likely to avoid this fruit in the future if they have had a bad experience with it. Given the health benefits of fruit in general and cherries specifically this reduced consumption would harm their long term overall health. Several of the benefits of AZM unmatched by other chemicals are its relatively long effectiveness and dependability under different weather conditions. We try not to have to spray close to harvest to avoid damage to the fruit or loss of the fruit from being knocked off the trees as the tractor and sprayer travel down the rows. We have had experience in tart cherries of having to spray repeatedly close to harvest with Carbarly and have actually blown cherries out of the trees. We also try to avoid putting pesticides on the last few days prior to hand harvesting to keep fruit cleaner and nicer for our hand harvesters. There are other chemicals which will control AZM but many of these need to be applied closer to harvest because of their short term control. Another concern with the loss of AZM in sweet cherries is that we cannot use Phosmet on sweet cherries. This would take away a type of chemistry which has had good efficacy as well as been cost effective. Thank you for considering my comments. I am a small family farmer in a small rural community who would like to see another generation have the opportunity to continue our production of cherries for our citizens. I value the land and its entire ecosystem. I feel that AZM is used appropriately and responsibly on our farm and by our fellow growers. I hope you will allow us to continue to have the tools to produce a great product at a price that can compete in the ever growing world economy. No one else cares about the food eaten in America more than American family farmers. Sincerely, David Rennhack

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