Comment submitted by D. E. Schultz, USDA-Forest Service

I have worked for the USDA-Forest Service as a Forest Entomologist in California since 1977. On rare occasions it has been necessary to protect individual, high value trees from bark beetles. Examples include genetically superior trees and campground trees stressed by drought, fire or construction injury. The number of insecticides available for this purpose is dwindling. In California, the only materials available that are proven to give a high degree of protection for standing conifers are carbaryl and permethrin. Carbaryl has a proven track record and it will provide protection for up to two years. We commonly use mitigating measures to protect non-target organisms such as: spray early in the day before pollinators are active, suspend spraying if windy, avoid spraying water, and tarp sensitive areas. Spraying is only done after compliance with the National Environmental Policy Act. Our applicators are all certified by the State of California. David E. Schultz, PhD. Entomologist USDA-Forest Service 3644 Avtech Parkway Redding, CA 96002 dschultz01@fs.fed.us