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flumetsulam (Broadstrike) NYSDEC Approval of Addendum to EUP 5/94

MAY 31, 1994
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Steve A. McMaster
Manager, State Regulatory Affairs
DowElanco
308, 3E
9330 Zionsville Road
Indianapolis, IN  46268-1054
Dear Mr. McMaster:
Re:  Addendum to Experimental Use Permits Containing
     Flumetsulam (Broadstrike);
     Broadstrike + Treflan (soybeans)  (EPA Reg. No. 62719-EUP-17)
     Broadstrike + Dual (soybeans)  (EPA Reg. No. 62719-EUP-22)
     Broadstrike + Dual (corn)  (EPA Reg. No. 62719-EUP-23)
     The New York State Department of Environmental Conservation received a
request April 19, 1994 from DowElanco to increase the number of acres from
a total of 180 acres in 1993 to a total of 300 acres in 1994 for the above
referenced New York State experimental use permits.
     The April 19, 1994 request contained no technical justification or 
explanation of intended research goals. Conversations with Joanne Miller of
EPA provided no additional insight into the technical justification to 
increase the acreage.
     Therefore, my letter dated May 26, 1994 resulted in the denial of your
request.
     A technical justification and further explanation to increase the size
of your experimental program was forwarded to this Department May 27, 1994.
     Upon review of the justification and usage areas (Chenango, Clinton, 
Columbia, Cortland, Erie, Genesee, Oneida, Orange, Otsego, St. Lawrence, 
Washington, Wayne and Wyoming Counties) it appears there is a necessity to
evaluate application rates, climatological changes and stunting effects of
Broadstrike on a commercial application as opposed to small plot research 
testing in New York State.
     In review of our files and information submitted it has been noted 
that applications of Broadstrike were made on May 5, 1993 prior to the 
Experimental Use Permit approval issued on June 2, 1993.
     As a condition of this addendum to the above mentioned experimental 
use permits, you must contact our appropriate regional pesticide inspectors
or this office 7 days prior to field application.
       The revised experimental use permits specify:
       Broadstrike + Treflan (soybeans) (EPA Reg. No 62719-EUP-17) to be
          used on 50 acres in 1994, expires 9/4/94
       Broadstrike + Dual (soybeans) (EPA Reg. No 62719-EUP-22) to be used
          on 50 acres in 1994, expires 9/4/94
       Broadstrike + Dual (corn) (EPA Reg. No. 62719-EUP-23) to be used on
          200 acres in 1994, expires 2/25/95
     If you have any questions, contact Ms. Maureen Serafini, of my staff, 
at (518) 457-7446.
                                   Sincerely,
                                   Robert J. Haggerty, Jr.
                                   Chief
                                   Bureau of Technical Support
                                   Division of Hazardous Substances
                                   Regulation
cc:  J. Miller (EPA)
     R. Hahn (Cornell)
     D. Rutz (Cornell)