Comment submitted by Isidro Hidalgo, Frutban S.A.

I write in favor of maintaining the exemption for the requirement of a tolerance for rotenone. I manage an organic banana farm in the province of Manabí, Ecuador (Frutban S.A.). Our farm is certified organic and can use only those products that are approved for organic agriculture by local and international agencies. Rotenone it is authorized by the Ministry of Agriculture in my country and is on the approved list of the US National Organic Program. We review the lists published by the Organic Materials Review Institute (OMRI) to decide on conformance with NOP. Rotenone is listed by OMRI. We use rotenone on our farm to control red rust thrips, a pest that can completely damage the peel of our bananas and make them not good for export. The attachment has pictures of the pest and the damage it causes. Rotenone is the only substance approved for organics that controls severe outbreaks of red rust thrips. These can cause losses of over 90% of our crop. Frutban S.A., exports about 70% of its organic bananas to the US market. If the rotenone tolerance exemption is eliminated, we could not use this substance at all and the next outbreak of thrips would destroy our export business. The farm employs about 315 people and is situated in a rural area where there are few economic activities. We planted this farm in this area far from conventional banana operations to be able to control pests and diseases better. Converting this farm to conventional agriculture is not feasible and we would have to close the farm. The nearby town, Angel Pedro Giler (La Estancilla), is very dependent on the incomes that our workers make and on the local taxes they receive from the operation of the organic farm. We fear that the impact of implementing this proposed rule will impact the livelihood of the entire community. I urge that the tolerance exemption for rotenone be maintained. Contact: isidrohidalgo10@yahoo.com. Isidro Hidalgo, Farm Manager, Frutban S.A., Ecuador.