Document a1JGjo5yLGZObJKrQamZrgGYe

Message From: Sent: To: Subject: Bennett, Tate [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECI PI ENTS/CN=1FA92542F7CA4D01973B18B2F11B9141-BEN NETT, EL] 8/15/2018 7:29:52 PM Paul Schlegel [pauls@fb.org] Re: Chlorpyrifos Received. Thank you, Paul. On Aug 15, 2018, at 3:24 PM, Paul Schlegel <pauis@fb.org> wrote: T a te .. assess the potential impact of the loss of this product for farmers. Frn setting out below a few of the responses we have already received. I expect we will be receiving more in coming days and weeks. To put it bluntly, most of our members who rely on this product are extremely concerned about the ramifications ol: the court: decision: Florida is greatly concerned about the potential impact of its loss, particularly as It is one ol: the critical tools available to the citrus industry in combating citrus greening. 'That disease alone has devastated the Florida citrus industry and losing chlorpyrifos would greatly hamper their efforts to combat the disease. Michigan Farm Bureau has indicated that losing chlorpyrifos would be devastating to specialty crop growers in that state. Currently, the pesticide is used on approximately: o 32,000 acre of cherries o 32,000 acres of apples o 9,000 acres of peaches it: is primarily used as a trunk application tor the protection against borers (normally one application per season). As ol: today, there are no affordable alternatives to the product. Maryland orchardists currently rely on chlorpyrifos as a defense against peach tree borer. Because of its ability to kills egg masses on woody surfaces, they are hopeful it can be a major player in controlling the Spotted Lanternfly that: has invaded Southeast PA and could move into Northeast Maryland in the near future. If it does kill the over-wintering egg masses, it could be one ol: the only pesticides out: there to control the pest: outside ol: the growing season. Maryland Department: of Agriculture indicates that: only about 3,000 lbs. of the pesticide was used annually in the state:..a reduction attributed primarily to the expanded use of Bt corn, Texas producers employ chlorpyrifos as one: tool to help combat: insect intestations; by offering a different mode of action, it helps producers in protecting their crops. The mam crops that it is used on in Texas are winter wheat: and pecans due to its effectiveness of controlling certain insect populations. Other crops for which it is used include: o C o rn ..not used as widely due to Bt traits in corn. o C otton..used in cotton, but use varies. Not the number one insecticide used, but used for resistance management, o Citrus --use has declined in citrus, but still used. o Sorghum ..again, not the number one insecticide used, but: is one more `tool in the tool box' o Peanuts..used to control corn rootworm on peanuts in Texas. o Pecans --widely used in pecans. o W heat..Widely used in wheat during the winter months. Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00074214-00001  CaFfomia estimates that: the loss ot chlorpyritos would lead to higher uses ol: pyrethroid: and neonicotinoids, which are already under scrutiny. As dependence on those products goes up, so does the risk tor resistance and damage from pests and diseases. 1 am also attaching a couple of documents I hope will be helpful, One is comments from Calitomia Farm Bureau outlining in greater detail usage ot chlorpyntos in that state. The other is comments filed by American Farm Bureau which gives a broader overview, from a national perspective, on the importance of the product to a wide range of crops and why it is important to maintain its availability. 'Thanks for your attention to this matter. Please let me know if I can provide any further information. Paul Paul Schlegel .Managing Director, Public Policy and Economics American Farm Bureau Federation p aiilsitgfb.org <Comment.pdf> <pesticides-AFBFCommentsl6a.0104.docx> Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00074214-00002