Comment submitted by L. Kleingartner, National Sunflower Association

September 22, 2006 RE: Furadan on Sunflower Sunflower is a commercial crop that has been grown in the U.S. since 1970. Sunflower is a native species plant resulting in a host of native diseases and insects that are unique to other growing regions of the world. Over the years sunflower has been grown on 1.5 to 5.0 million acres in the semi arid regions ranging from the Canadian border to the southern part of Texas. Sunflower is considered a high value crop in this region averaging a gross value of $200/acre. Sunflower works very well under limited irrigation (one to three supplemental irrigations) in the High Plains from Nebraska to Texas. Under that scenario sunflower can generate well over $400/acre. Sunflower works very well in rotation with grain crops such as corn and wheat. Sunflower has a deep tap root that can utilize stored soil moisture and leeched nitrogen. One of the most serious insects, especially in the High Plains, is the sunflower stem weevil Cylindrocopturus adspersus. This insect is very difficult to scout since it falls to the soil and blends with the soil environment. Growers have described silently sitting in a sunflower field for up to two hours trying to get an insect count. The insect can be controlled by topical insecticides but timing is crucial and repeat applications may be necessary because of emerging populations. That problem is eliminated with Furadan due to its translocation properties. Lack of stem weevil control often results in severe lodging prior to harvest. According to the manufacturer, approximately 27,000 acres of sunflower were treated this year with Furadan. Furadan is costly which limits its use. Losses to the stem weevil can approach 100 percent or $200 per acre with no control. Using a non-Furadan product to control the insect can result in a yield loss approaching 25 percent. Most lodged sunflower is permanently lost. Example: Non-Furadan control loss = 25% x $200/A = $50/A. $50/A loss x 27,000 acres = $1,3050,000 loss annually from using alternative products. One integrated pest management technique farmers have been using to minimize stem weevil damage is delayed planting. However, this can also result in a yield loss since early season rainfall is no longer available to the crop. A 10 percent yield loss is possible. Furadan is best suited for irrigated sunflower where timely planting is required, inputs are high and potential yield and net returns are also high. This production is immensely important to the industry. Much of the irrigated production is the edible or confection sunflower which can gross up to $700 per acre. Quality is of utmost necessity. The confection hybrids are taller and more prone to lodging thus stem weevil control is mandatory. This production is of significant economic importance to these producers, and the processors and the confection sunflower snack industry. Example: 10% loss from later planting x $700/A = $70/A loss. $70/A loss x 27,000 A. = $1,890,000 annual loss from late planting. Furadan is an important tool for sunflower producers. This is a crop with only limited pest product availability. Further erosion of control products would negatively impact the overall industry. It is also important to point out that the U.S. and world vegetable oil market is under a great deal of change. Sunflower oil is highly sought after by domestic snack food manufacturers due to its excellent frying stability, low saturated fats and no requirement for hydrogenation. It is this latter process which produces the negative trans fats. It is very likely that the U.S. will need to import sunflower oil from Argentina this year to maintain a sufficient supply. This provides additional cost to the snack food manufacturer. The second aspect of this dynamic vegetable oil market is the aggressive development of bio-diesel made. Again, there is strong interest in utilizing sunflower oil for this purpose because of the seed?s high oil content of 40 percent and higher. Best Regards, Larry Kleingartner Executive Director