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Imidacloprid - Section 18 Request for Provado for Stone Fruits/Aphids as Vectors of Plum Pox 3/02

New York State Department of Environmental Conservation
Division of Solid and Hazardous Materials
Bureau of Pesticides Management, 9th Floor
625 Broadway, Albany, New York 12233-7254
Phone: (518) 402-8788 • FAX: (518) 402-9024
Website: www.dec.state.ny.us

March 8, 2002

Ms. Meredith Laws
Team Leader

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 Ms. Laws:

Re: Specific Exemption Request for Use of imidacloprid (Provado 1.6F EPA Reg. No. 3125-457) on stone fruits in New York in 2002 for the control of aphids as vectors of Plum Pox Virus (PPV)

  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). Also, enclosed is the use report from the 2001 Section 18 use.

  This is the third year that we are requesting imidacloprid (Provado 1.6F) for emergency use to control aphids, particularly green peach aphid (GPA) and other aphid vectors of the Plum Pox Virus (PPV) in the major stone fruit production areas of New York State. Methomyl, the mainstay insecticide for aphid control, is no longer effective. Aphids have developed tolerance or resistance to the chemical, and the increased use rates in 1997 and 1998 still failed to suppress field populations. These aphid populations are cross-resistant to the OP insecticides that are in use on stone fruit. Nonchemical aphid suppression (i.e., the use of natural predators such as lacewings, lady bird beetles and syrphid fly larvae) cannot provide the satisfactory control that is required to prevent the spread of Plum Pox Virus.

 Imidacloprid is currently used worldwide for managing aphids on major food crops. It is a chloronicotinyl insecticide not currently in review under the FQPA provisions. Imidacloprid (Provado 1.6F) has been evaluated on peaches as foliar sprays for the management of green peach and other aphids at one- to 16-fl. oz per acre in New Jersey, Pennsylvania, West Virginia and California (Appendix C). At these rates, imidacloprid has been outstanding in suppressing aphid populations.

Ms. Meredith Laws 2.

  New York is requesting a maximum of four applications of Provado 1.6F (EPA Reg. No. 3125-457). Provado application should, in general, be made at the first appearance of aphids at a rate of five- to six-fl. oz. of formulated product per acre (0.0625-0.075 lbs a.i./acre) to be applied as a ground application by certified applicators. A second application at a seven- to ten-day interval may be needed under heavy pest pressure. Total acreage to be treated will not exceed 3200 acres Statewide. The anticipated use season for imidacloprid on stone fruits in New York State starts May 1, 2001, and can extend up to the day of harvest.

  Bayer Ag. Division, the manufacturer of Provado 1.6F, fully supports our efforts to obtain an emergency exemption for the use of imidacloprid (Provado 1.6F) on stone fruit in New York State for the 2002 growing season (Appendix F). Bayer is actively pursuing the Section 3 registration for this product on stone fruits. IR-4 is preparing the stone fruit crop group tolerance petition for submission to USEPA. The review has been scheduled for fourth quarter on the 2002 work plan.

Please contact Robin Hackett, of our Pesticide Product Registration Section, at (518) 402-8768, if you require further assistance on this request.


Sincerely,


Maureen P. Serafini
Director, Bureau of Pesticides Management
Division of Solid & Hazardous Materials
Enclosure
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.