I submit that a lot of beekeepers are being extremely mypoic on this
issue. Even if bees are needed to pollinate the bulk of the world's
fruit and nut crops, the crops have to be protected from pests or
there are no be flowers to pollinated, and no fruit to sell. No
flowers, no fruit, who needs bees? Furthermore, fruit growers are just
as interested in the survival of their industry as beekeepers are in
theirs! Why has this devolved into them against us?

QUOTED MATERIAL:

> Ninety-seven percent of table grapes grown commercially in the US are produced in California, and account for approximately 11 % of world production. An average of 730,000 tons is produced annually on 88,000 acres. The table grape industry reserves materials, such as Imidacloprid, for prescriptive use by pest control advisors when ranking risk to treat severe pest damage or disease.

> A considerable risk to California table grape growers is the threat of Pierce's Disease, vectored through sharpshooters feeding in vineyards. Pierce's Disease control is based entirely on preventing infection. Once infection occurs, vine death is inevitable as there is Imidacloprid Registration Review no cure. Vineyards at greatest risk are those adjacent to citrus, where the vectors of the disease, the Glassy-winged Sharpshooter, can over-winter, as well as a large number of other perennial, ornamental and weedy plant species. Citrus plantings are commonly found adjacent to vineyards in Temecula and Kern and Tulare Counties. Kern County, California table grape producers have seen a significant increase in Glassy-winged Sharpshooter populations, a new invasive species, prompting a multiyear program to map the progression of Pierce's Disease within approximately 6,000 producing acres; at considerable cost to the industry. This program included monitoring, treatment and complete removal of affected grapevines in an effort to prevent the devastating losses that occurred within the Temecula, California grape growing region. In the 1880's, Pierce's Disease, then known as Anaheim Disease, broke out in southern California, destroying 35,000 acres of grapes. This was before the arrival of the more efficient vector, the Glassy-winged Sharpshooter.

> The University of California, Agriculture and Natural Resources, Integrated Pest Management Program (IPM) guidelines, identify Imidacloprid as the most efficacious material to treat grape sharpshooters. Treatment(s) aimed at controlling the vector in areas adjacent to a vineyard, such as citrus groves, have reduced the incidence of Pierce's Disease by reducing the numbers of sharpshooters migrating into nearby vineyards.

> We understand the Agency has yet to complete a more through review of an ecological risk assessment, and we appreciate the acknowledgment that there is more data needed to complete this review. Most often, table grape growers apply Imidicloprid thorough low volume irrigation such as drip, which is in a controlled volume directly applied to the target plant. Foliar applications fertilizing spray rig are also used to apply the material. Maximum label application rates are 1 ounce of dry material or 4 ounces of liquid Imidacloprid, typically applied in a spray volume of 40 to 100 gallons of water. These application methods eliminate the potential for run off.

> California table grape producers have had a succession of exotic pest introductions which have made it more difficult and expensive to produce grapes and the economic future of the industry will continue to depend upon excluding exotic pests. It is critically important that all of agriculture continue to have available those materials that allow the immediate and appropriate response to protect production.

-- 
Marcy L. Martin
California Grape & Tree Fruit League

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