Comment submitted by C. Keyes, Utah Divison of Forestry, Fire and State Lands

Washington Toxics Petition to Cancel Carbaryl EPA-HQ-OPP-2006-0801 To Whom It May Concern, In Utah, the largest concern for private forest landowners is bark beetle induced mortality. Utah forests are currently under attack from several species of western bark beetles. I often suggest silvicultural treatments for long-term management of bark beetles. This type of treatment is frequently not acceptable for most private landowners. When silvicultural treatments do meet landowner objectives, it is exceptionally difficult for private landowners to contract with a logger or complete treatments in a timely manner. In addition, silvicultural management is generally not effective on a small scale or during outbreak situations. Chemical preventative treatment, in the short-term to protect high value trees, is often the only option for the private forest landowner. Chemical treatments for high value trees are expensive, and most private landowners consider all of the trees on their land as high value. Since it is cost prohibitive to treat all trees, it is with a heavy heart that they choose which trees to treat. The emotional attachment landowners have for their trees and the hope that they can be saved inevitably compel landowners to place a lot of confidence in chemical treatments, therefore, they must be highly effective. The application of a chemical is the largest cost for treatment. Some products containing pyrethroid--get adequate results and may be less expensive initially, but are effective for only one year. Carbaryl, applied at a 2% active ingredient solution provides very good protection for about two years. When you include application costs, Carbaryl is the only chemical that currently meets the high efficacy needs at the lowest overall cost. At this time, the loss of Carbaryl as a protective treatment would be a considerable disadvantage to the non-industrial private forest landowner. Sincerely, Colleen Keyes Forest Health Coordinator Utah Division of Forestry, Fire and State Lands 1594 W. North Temple, Suite 3520 Salt Lake City, UT 84114-5703 (801) 538-5211 colleenkeyes@utah.gov