Anonymous Public Comment

Regarding the petition from the Washington Toxics Coalition for EPA to revoke all tolerances for carbaryl, I believe it is important to weigh both the benefits and costs of such an action. My training is in entomology and pest management and I am currently Associate Professor of Entomology at Cornell University with research and extension responsibilities for grapes and small fruit crops in the state. I would like to take this opportunity to elaborate on the benefits of maintaining tolerances for carbaryl for grapes and small fruit crops for NY growers. Over the past 20 years the average number of insecticide applications made to grapes has declined from 3 to slightly over 1. Thus, the amount of insecticide used on grapes in NY is fairly low. Even so, there are several very important insect pests that can cause considerable damage to grapes and therefore need to be managed in some sites in some years. Carbarly is an important option for grape growers because it includes many ?minor? insect pests on the label. In NY, the pest must be included on the label to be used. Some of these ?minor? pests can cause large economic damage in some years. For example, the banded grape bug is sporadic pest of grapes but when present can cause major yield reductions at fairly low densities. Provisionally, we have estimated that one nymph per 10 shoots can cause economic damage. Carbaryl is one of three insecticides legally available for NY grape growers to use against banded grape bug. The other two are fenpropathrin [Danitol 2.4 EC] and phosmet (Imidan 75W). Recently the REI for Imidan on grapes has been increased from 24 hours to 14 days, which makes it almost useless for most situations. Although Danitol is available, it is very hard on predatory mites. Although it also currently controls spider mites, I have concerns that spider mites will develop resistance, as they have to other pyrethroid insecticides. My concern is enhanced by the fact that the use of Danitol on NY grapes has increased in the last five years. Thus, it would be helpful to have several alternatives for controlling insect pests in grapes. Similar arguments can be made for other small fruit crops grown in NY such as raspberries and strawberries. For raspberries we have even fewer registered insecticides than in grapes and in many cases carbaryl is the only material labeled. Because acreage of small fruit crops in NY is low, there is not a large incentive for chemical companies to invest resources to get their insecticides approved for use on these crops. For these reasons it would be beneficial to maintain tolerances of carbaryl for grapes, raspberries, strawberries, and blueberries. Thank you.