Comment submitted by Brian A. Kunkel, Ph.D., Ornamentals IPM Extension Specialist, University of Delaware

Document ID: EPA-HQ-OPP-2005-0163-0171
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: January 12 2007, at 04:09 PM Eastern Standard Time
Date Posted: January 17 2007, at 12:00 AM Eastern Standard Time
Comment Start Date: January 17 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: January 16 2007, at 11:59 PM Eastern Standard Time
Tracking Number: 801f4348
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1. What pests do you feel aldicarb is critical in controlling on field grown ornamentals? I am unaware of aldicarb being used to control insect pests in DE on field grown ornamentals. 2. What alternatives, if any, do you believe are available to replace aldicarb use on field grown ornamentals? Newer chemistry such as dinotefuran for some armored scale, imidacloprid for other homopteran pests. These newer products rotated with oil, insecticidal soap, or pyrethroids where appropriate should provide adequate control when applied at the proper time. 3. What percentage of the use are the aldicarb post-emergence applications, and is aldicarb only applied post emergence as a side dress application? Do not think aldicarb is being used. 4. Against which pests and on which crops is the aldicarb post-emergence side dress application used, and how critical is this use? Same as 3. Issues could possibly arise if plant pathogenic nematodes become problematic. 5. What alternatives, if any, do you believe are available for the post-emergence side-dress use and how effective do you believe these alternatives to be? Unknown. 6. What percentage of the use, if at all, are the broadcast and/or banded applications? Unknown. 7. Against which pests and on which crops, if any, are broadcast and/or banded applications being used? Do not think it is being used. 8. Is positive displacement application equipment readily available and affordable for use on dry beans, field grown ornamentals, seed alfalfa, and soybeans? Unknown. 9. What percentage of aldicarb applications involves use of positive displacement equipment on dry beans, field grown ornamentals, seed alfalfa, and soybeans? Unknown. 10. What are the mitigation options that best address the risks of concern identified in the risk assessments? (Risk assessment is attached below.) Unknown. As far as I know, aldicarb is not being used in field grown ornamentals. Its use might be necessary if nematodes are a problem. We are planning to send out surveys this summer to businesses regarding pesticide and IPM use. Our goal with this survey is to get an updated grasp of the pesticides and other tactics used to control insect pests in ornamentals found in Delaware. Brian A. Kunkel, Ph.D. Ornamentals IPM Extension Specialist Dept. Entomology & Wildlife Ecology 248A Townsend Hall University of Delaware Newark, DE 19716 Phone: (302) 831-3641 FAX: (302) 831-8889 E-mail: bakunkel@udel.edu **************************************************************************** From Joanne Whalen, UD Agricultural IPM Coordinator: The only 3 agricultural crops that your request applies to in Delaware are dry beans ( we have a few acres of black eyed peas), soybeans, and sorghum. We do not have seed alfalfa. I spoke to Bob Mulrooney, our Extension Plant Pathologist, about alicarb since more of the need may apply to nematodes. At the present time, neither of us is aware of any aldicarb use on the above mentioned crops in Delaware. As far as insect pests listed on the label, there are foliar alternatives for those insect pests and I do not anticipate growers needing at an planting or side dress application option for those pests. However, as far as nematodes, Bob indicated that if we needed it we would have nothing else labeled on soybeans. His main concern would be if sting nematode ever spread -- so far it has only been documented in 2 fields.There are no other chemicals available -- only fumigation.

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