Anonymous public comment

Document ID: EPA-HQ-OPP-2008-0695-0003
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: October 15 2008, at 10:36 AM Eastern Daylight Time
Date Posted: October 15 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: October 15 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: October 30 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 8075c8ac
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i think we need to reduce the need for this chemical to be used so widely on earth and ni this country. evidently practices that are used promote this disease and the people need to insist that some of the below practices need to be implemented immediately on anybody who asks to use this kasugamycin so that its use is used just once. Limited number of plant species planted at high densities. Most modern apple orchards are limited to two species: apples and grass ground cover. Fifty years ago apple orchards were routinely planted at densities of 100 trees per acre or less; now, we aim for tree populations of between 250 to 1,500 per acre. 2. Wide use of susceptible plants. While some apple cultivars demonstrate a moderate to high degree of resistance to fire blight, even that can be breeched by hail, wind or frost damage. Market demands over the last two decades have encouraged the production of new cultivars like Gala, Fuji, Braeburn, Empire, Ginger Gold and Granny Smith along with many traditional favorites like Rome, Jonathan, York and others that are moderately to highly susceptible to fire blight. 3. Wide use of genetically similar or identical cultivars and rootstocks. Apple and pear cultivars must be propagated vegetatively to maintain the characteristics of those varieties. In addition, to support the high tree densities that are now standard, clonal apple rootstocks such as M.26 and M.9 are widely used. Indeed, it is likely that 60% of U.S. apple production over the next decade will be on these two rootstocks which are both highly susceptible to fire blight. 4. Monoculture in time and space. Fruit crops are perennials and are planted with the full expectation that they will remain in place and productive for at least 15 to 20 years. This is monoculture in time. Monoculture in space occurs when a fruit industry develops in certain areas having climate and soil conditions most favorable for fruit production so that concentrations of several thousand acres or more provide an ideal base for maintaining important pathogen populations. 5. Uniform management practices throughout an orchard and across entire regions are required for both efficient production as well as for meeting specific market demands. As a result, large portions of the crop may be uniformly susceptible should conditions favorable for disease develop. All of these factors are necessary for the efficient production of high quality apple and pear production. Eliminating even one of these factors reduces the viability of the business of commercial fruit production. Understanding the risks these elements pose for disease development, however, is an important step in the design and implementation of effective disease management programs that do not decrease the overall efficiency of production. WE NEED TO STOP THE DISEASE NOT USE CHEMICALS OVER AND OVER AND OVER AGAIN.

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Total: 5
Anonymous public comment
Public Submission    Posted: 10/15/2008     ID: EPA-HQ-OPP-2008-0695-0003

Oct 30,2008 11:59 PM ET
Anonymous public comment
Public Submission    Posted: 10/27/2008     ID: EPA-HQ-OPP-2008-0695-0004

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Comment submitted by Dale T. Rowley, Cherry Hill Farms Inc.
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Comment submitted by Curtis Rowley, Cherry Hill Farms
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Oct 30,2008 11:59 PM ET
Comment submitted by Kent Evans, Ph.D., Utah State University, Extension Plant Pathology Program
Public Submission    Posted: 10/30/2008     ID: EPA-HQ-OPP-2008-0695-0007

Oct 30,2008 11:59 PM ET