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

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