Comment submitted by Lewis Orchards Inc.

Document ID: EPA-HQ-OPP-2005-0061-0056
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: January 28 2006, at 12:14 PM Eastern Standard Time
Date Posted: January 30 2006, at 12:00 AM Eastern Standard Time
Comment Start Date: January 30 2006, at 12:00 AM Eastern Standard Time
Comment Due Date: February 20 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 8011ff37
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I'm a fourth generation family farmer in Michigan. I'm writing about the proposed removal of Guthion (Azinphos-Methyl) from the marketplace specifically apples. Farming is a tough occupation to go into, the mean age of farmers os about 65. I enjoy farming but their are very few farmers continuing that line of work. If you eliminate the use of Guthion it will take what little profit there is in apple production in the Great Lakes and potentially eliminate the family apple farm. This may not be important to you, but I see the day when there are ships of food coming from overseas not oil that the United States will have to depend on. Yes I'm sure you find this a little dramatic and yes there are other chemicals in your opinion may be used such as neonicotinoids. The problem is these cost 4 times more then Guthion and they are precise as to timing and what they kill. It will require more sprays which means more fuel cost and more pesticide cost. Plus Michigan State University data shows these chemicals penetrate the fruit which may have residule problems we do not know about. So please take into account the economic impact this will have on the family farms future survival. Sincerely, Scott Lewis

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