Mr. Dan Rosenblatt
USEPA/Office of Pesticide Programs
Emergency Response Team (7505C)
Document Processing Desk
Crystal Mall 2--2nd Floor
1921 Jefferson Davis Hwy.
Arlington, Virginia 22202
Dear Mr. Rosenblatt:
Re: Specific Exemption Request for Use of Lambda-Cyhalothrin (Warrior with Zeon Technology, EPA Reg. No. 10182-434) to control potato leafhopper on alfalfa/clover/grass mixed stands in New York in 2004
The New York State Department of Environmental Conservation, as the State lead agency for pesticide matters, hereby requests approval of the referenced application (see enclosure) under Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act, as amended. The enclosed application includes the information required in 40 CFR, Part 166, Subpart B (166.20). A copy of the 2003 use report for the Section 18 use of Warrior with Zeon Technology is also enclosed (Appendix 7).
This is the third year we are requesting the use of lambda-cyhalothrin (Warrior with Zeon Technology) to control potato leafhopper on alfalfa/clover/grass mixed stands. The potato leafhopper is a sucking insect, migrating from the south each spring and infesting newly established alfalfa stands, feeding on new plants and stunting regrowth after the first cutting. It can arrive in New York anytime from mid-May to late June. By feeding on the vascular system of the plant, the leafhopper reduces photosynthesis, decreases productivity, stunts the plant, and sometimes kills young seedlings. The adults are very long-lived and the generations continue to overlap and increase through mid-August.
In response to the 2001 SFIREG issue paper regarding treatments of mixed stands, the United States Environmental Protection Agency (USEPA) identified alternative chemicals with existing group tolerances on alfalfa/clover/grass (Appendix 2). Of these alternatives, only carbaryl and malathion are readily available in New York. However, these chemicals are "very weak" materials for the control of the potato leafhopper (Appendix 3).
Lambda-cyhalothrin (Warrior with Zeon Technology) has shown excellent control of potato leafhopper (Appendix 3). In the 1991 Ithaca field trial, only cyfluthrin (Baythroid) showed better control of potato leafhopper. However, there is no established tolerance for cyfluthrin except for use on "clear seeded" fields of alfalfa.
Lambda-cyhalothrin (Warrior with Zeon Technology) is applied at a rate of 1.92 to 3.2 fl oz (0.015 to 0.025 lbs ai) per acre to control potato leafhopper. A maximum of 0.96 pints (0.121b ai) may be applied per acre per season. The PHI is one day for forage and seven days for hay. A 24-hour REI is in effect for treated areas.
A total of 570,000 acres of alfalfa/clover/grass mixed stands may be treated in New York State. The anticipated use season in New York State is June through August. A bee restriction and buffer strip for aquatic sites are also required. Warrior with Zeon Technology is classified as a "Restricted Use Pesticide" by the USEPA for toxicity to fish and aquatic organisms.
Syngenta Crop Protection (formerly Zeneca Ag. Products, Inc.) fully supports the section 18 application to use Warrior with Zeon Technology for the control of potato leafhopper on alfalfa/clover/grass mixed stands (Appendix 6). A time limited tolerance of six ppm. for grass hay and five ppm for grass forage was approved and published in the Federal Register on January 3, 2003. The residue trials to support the establishment of a permanent tolerance have been initiated.
Please contact Robin Hackett, of our Pesticide Product Registration Section, at (518) 402-8768, if you require further assistance on this request.
Maureen P. Serafini
Bureau of Pesticides Management
cc: w/enc. - A. Enache, USEPA Region II
cc: w/o enc. - G. Good\W. Smith, Cornell University, PMEP
R. Zimmerman\R. Mungari, New York State Dept. Of Ag. & Mkts.