Comment submitted by Larry Kleingartner, National Sunflower Association

Ripening sunflower is an attractive source of food for approximately 70 million nesting and migrating blackbirds in the prairie pothole region. Damage has been and continues to be significant to individual farmers. Many farmers in this region have stopped producing the crop for fear of losses to this pest. There are very limited resources available to farmers or government officials attempting to minimize damage. Although 4-AP has limitations as a tool, (largely due to possible manufacturing/handling adherence issues to the carrier) it has potential within an integrated management system. However, the proposed changes relating to pre-baiting prior to use and restrictions for use in standing crops would make this product useless to sunflower growers. Sunflower oil is one of the few alternatives to hydrogenated oils for food manufacturers. FDA labeling requirement of trans has placed a great demand on this oil. The single most significant production problem which greatly limits acres and production is the blackbird.