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Imidacloprid - 2ee Recommendation for Merit 2 Insecticide 4/04

New York State Department of Environmental Conservation
Division of Solid & Hazardous Materials
Bureau of Pesticides Management
Pesticide Product Registration Section
625 Broadway, Albany, New York 12233-7257
Phone 518-402-8768 FAX 518-402-9024

May 3, 2004


Mr. Richard M. Gorrell
Manager, Registrations
Bayer Environmental Science
95 Chestnut Ridge Road
Montvale, New Jersey 07645

Dear Mr. Gorrell:
Re: FIFRA 2(ee) Recommendation for Merit 2 Insecticide (EPA Reg. No. 3125-418) to Add a Pest Not on The Label - Asian Longhorned Beetle

The Department of Environmental Conservation (Department) has approved your FIFRA 2(ee)
request to add the target pest Asian Longhorned Beetle (Anoplophora glabripennis) for the
above listed product on trees, using the application techniques of soil injection and soil
drench. The registered New York State label for Merit 2 Insecticide does not include Asian
Longhorned Beetle.

The Asian Longhorned Beetle (a non-native pest) bores into and kills a variety of tree
species including species of maple, elm, chestnut, birch, poplar and willow. Anyone
treating trees for control of Asian Longhorned Beetle with Merit 2 Insecticide, under this
recommendation, must have the recommendation in their possession at the time of application.
Conditions of this FIFRA 2(ee) are the following:

 the recommendation is only for use under the direction of the USDA;
 the application methods are soil drench and soil injection; and
 no soil injection applications are allowed in Nassau and Suffolk Counties of New
York State.

Enclosed is the stamped "accepted" copy of the recommendation as it is to appear in
the Cornell Recommends.

If you have any questions regarding this letter please contact Jeanine Broughel, of
my staff, at (518) 402-8768.


Samuel J. Jackling
Pesticide Product Registration Section


cc: w/enc. - R. Zimmerman/ R. Mungari - NYS Dept. of Ag. & Markets
G. Good/W. Smith - Cornell University, PMEP