As usual, there is more than one side to this. Many growers have written to the EPA asking them to keep imidacloprid available I represent Brussels sprout growers on the Central Coast of California who farm the majority of the acreage of our product in the United States. Since the development of "Admire" brand insecticide containing Imidacloprid, the use of organophosphate products has been reduced tremendously in our industry. Cabbage aphid is a major pest of our product, and the effectiveness of Imidacloprid has been an excellent tool to combat the pest. We currently apply less than 8oz per acre, injected into the soil, and it provides over 100 days of protection from the aphid. This replaced 4-6 uses of traditional organophosphates used previously. This is a most valuable tool, and it's low rate and long term effectiveness are wonderful benefits, not to mention the reduction of the much more dangerous mevinphos. The loss of this would definitely have a detrimental effect upon the position of reducing the use of the more dangerous types of chemicals used in the past. Please keep this tool available to us Comment submitted by Steve Bontadelli, Phyffer Associates * * * Imidacloprid is an important insecticide to control wire worm (various species), palestriped flea beetle (Systena blanda) and the sunflower beetle (Aygogramma exclamationis) in the early seedling stage. Seed treatments are well recognized as the most efficient way to control early season insects with a minimal amount of insecticide. The product is applied to the seed by the seed manufacturer. The farmer never handles the insecticide adding a significant safety feature. Prior to insecticide seed treatments, sunflower farmers had to rely on a long residual liquid insecticide spray over the entire field. Timing was a critical issue and reapplication was often required as was replanting to achieve a desirable plant stand. Most farmers use a no-till or minimal till planting system which greatly reduces moisture loss and soil erosion. One of the draw backs of this tillage system is an increase is soil type insects. This increases the need for an insecticide seed treament which our growers recognize as safe to the environment and themselves. Comment submitted by Larry Kleingartner, National Sunflower Association * * * This letter is to offer our support for the continued registration of imidacloprid. I work for the State Plant Regulatory Official for Kentucky and I have been in my position for 15 years. The use of imidacloprid insecticide is vital to many ongoing projects in Kentucky. We are on the leading edge of hemlock woolly adelgid infestations as the insect was first found in KY in 2006. Hemlocks are an extremely important forest tree as they provide habitat for wildlife and also cool streams and slow stream bank erosion. Imidacloprid is an outstanding tool for management of hemlock woolly adelgid as its application is simple, safe and gives several years of control with just a single application. Research has shown that a single application of imidacloprid applied via soil injection can provide protection for up to 6-7 years. The nursery industry of Kentucky also considers imidacloprid vital. Kentucky is quarantined because of Japanese beetle. For nurseries in Kentucky to ship nursery stock to the midwest, treatments must first be made to the soil to kill any Japanese beetle larvae. The guidelines for treating the nursery stock are given in the Domestic Japanese Harmonization Plan. Only after treatment are the plants allowed to be shipped. The use of imidacloprid has greatly reduced the risk of Japanese beetle becoming established in new locations. Imidacloprid also homeowners with an option against emerald ash borer, a pest that has not yet been found in Kentucky but one that most certainly will be soon. Homeowners can mix up a simple drench solution of imidacloprid and pour it around the trunk flare (area where trunk and roots meet). This simple treatment will provide season long control of emerald ash borer. Imidacloprid is a very important tool in regulatory entomology. To lose imidacloprid registration would cause numerous problems; both in the immediate and long term future of Kentucky. Comment submitted by Joe Collins, University of Kentucky, Dept. of Entomology *********************************************** The BEE-L mailing list is powered by L-Soft's renowned LISTSERV(R) list management software. For more information, go to: http://www.lsoft.com/LISTSERV-powered.html