PMEP Home Page Pesticide Regulations 2005 Section 18 Emergency Exemptions NYS Quarantine Exemptions for Soybean Rust

NYS Soybean Rust Quarantine Exemption Request (without appendices) 5/04

1. Type of exemption
Quarantine Emergency Exemption (FIFRA Section 18) request for the use of the following materials to control Australasian Soybean Rust (Phakopsora pachyrhizi) in New York State during 2004:
     Propiconazole (Tilt, Propimax EC, Bumper)
     Tebuconazole, (Folicur)
     Myclobutanil (Laredo EC, Laredo EW)
     Propiconazole + Trifloxystrobin (Stratego)
     Tetraconazole (Domark),
     Pyraclostrobin (Headline),
     Pyraclostrobin + Boscalid (Pristine)

2. Identity of contact persons

3. Description of pesticide

Pesticides requested: Several products have emerged as potentially efficacious against Australasian soybean rust in international trials. No registrant has indicated the ability to meet the needs of the soybean industry should an Australasian soybean rust epidemic occur in the US in 2003. As such, we request that several products be considered for approval. Biological and economic considerations will be presented to support the use of additional products beyond those already labeled.

Limited efficacy data is currently available for any product against soybean rust. Pending the outcome of continuing comparative fungicide efficacy trials being conducted in Africa and South America under USDA, ARS direction, the following products are listed as candidates. While each state may make its own product decisions, depending on local conditions, it is suggested that several rather than one or two fungicides should be requested. This is considered important from several perspectives (biological and economic justifications).

Due to the large acreage potentially impacted, registrants have informed the states that no single product will be available in sufficient quantity to treat the potential land area impacted by soybean rust. See letters of support that were submitted in the Minnesota/South Dakota request.

A revised Section 18 petition may be submitted at a later date as more current data becomes available or as need for more products becomes apparent due to short product supplies and severe disease or disease potential.

Products are listed in order of greatest potential for availability and preference for use.

Common Chemical Name (Active Ingredient): propiconazole
Trade Names(s)And EPA Reg. No.: Tilt®, EPA Reg. Number 100-617
Formulation: 3.6EC
% Active Ingredient: 41.8% (3.6 lb/gal)
Manufacturer: Syngenta Crop Protection, Inc.; Greensboro, NC 27409

Common Chemical Name (Active Ingredient): propiconazole
Trade Names(s)And EPA Reg. No.: PropiMax™ EC, EPA Reg. Number 62719-346
Formulation: 3.6EC
% Active Ingredient: 41.8% (3.6 lb/gal)
Manufacturer: Dow Agrosciences, LLC; Indianapolis, IN 46268

Common Chemical Name (Active Ingredient): propiconazole
Trade Names(s)And EPA Reg. No.: Bumper®, EPA Reg. Number 66222-42
Formulation: 41.8EC
% Active Ingredient: 41.8% ai by weight (3.6 lb/gal)
Manufacturer: Makhteshim-Agan; New York, NY 10176

Common Chemical Name (Active Ingredient): tebuconazole
Trade Names(s)And EPA Reg. No.: Folicur®, EPA Reg. Number 3125-394
Formulation: 3.6F
% Active Ingredient: 38.7% (3.6 lb/gal)
Manufacturer: Bayer Corporation; Kansas City, MO 64120-0013

Common Chemical Name (Active Ingredient): myclobutanil
Trade Names(s)And EPA Reg. No.: Laredo™ EC, EPA Reg. Number 62719-412
Formulation: 25EC
% Active Ingredient: 25% (2 lb/gal)
Manufacturer: Dow AgroSciences LLC; Indianapolis, IN 46268

Common Chemical Name (Active Ingredient): myclobutanil
Trade Names(s)And EPA Reg. No.: Laredo™ EW, EPA Reg. Number 62719-493
Formulation: 25EW
% Active Ingredient: 25% (2 lb/gal)
Manufacturer: Dow AgroSciences LLC; Indianapolis, IN 46268

Common Chemical Name (Active Ingredient): propiconazole + trifloxystrobin
Trade Names(s)And EPA Reg. No.: Stratego®, EPA Reg. Number 264-779
Formulation: 2.08F
% Active Ingredient: 11.4% propiconazole (1.04 lb/gal), 11.4% trifloxystrobin (1.04 lb/gal)
Manufacturer: Bayer Corporation; Kansas City, MO 64120-0013

Common Chemical Name (Active Ingredient): tetraconazole
Trade Names(s)And EPA Reg. No.: Domark™, EPA File Symbol 60063-RE
Formulation: 125SL
% Active Ingredient: 11.6% (125g/l ai - 1 lb ai/gal)
Manufacturer: Sipcam Agro USA, Inc.; Roswell, GA 30076

Common Chemical Name (Active Ingredient): pyraclostrobin + boscalid
Trade Names(s)And EPA Reg. No.: Pristine®, EPA Reg. Number 7969-199
Formulation: 38% WDG
% Active Ingredient: 25.2% boscalid, 12.8% pyraclostrobin (38% total ai)
Manufacturer: BASF Corporation; Research Triangle Park, NC, 27709

Common Chemical Name (Active Ingredient): pyraclostrobin
Trade Names(s)And EPA Reg. No.: Headline®, EPA Reg. Number 7969-186
Formulation: 2.09EC
% Active Ingredient: 23.6% (2.09 lb ai/gal)
Manufacturer: BASF Corporation; Research Triangle Park, NC, 27709

4. Description of proposed use

Sites to be Treated: Soybeans

Method of Application: Ground or Aerial

Rate of Application (propiconazole): 1.8-3.6 oz a.i./A, 4-8 fluid ounces product per acre

Rate of Application (tebuconazole): 1.3-1.8 oz a.i./A, 3-4 fluid ounces product per acre

Rate of Application (myclobutanil): 1.0-2.0 oz a.i./A, 4-8 (4.8-9.6 fl oz per acre for the EW formulation) fluid ounces (EC formulated) product per acre

Rate of Application (propiconazole + trifloxystrobin): 1.4-2.6 oz a.i./A, 5.5-10 fluid ounces product per acre

Rate of Application (tetraconazole): 1.2-1.6 oz a.i./A, 10-13 fluid ounces product per acre

Rate of Application (pyraclostrobin + boscalid): 3.0-6.1 oz a.i./A, 8-16 ounces product per acre

Rate of Application (pyraclostrobin): 1.6-3.1 oz a.i./A, 6-12 fluid ounces product per acre

Maximum Number of Applications: Maximum of two applications of Section 18 products. In many cases three to four total fungicide applications will be made.

Total Acreage to be Treated: Based on the most recent soybean statistics (2002) reported by the New York State Department of Agriculture and Markets, 140,000 acres will need to be treated in New York State.

Australasian soybean rust models (Appendix C of the Minnesota/South Dakota request) suggest that most of the soybean acres in the United States could be compromised by soybean rust at the point that the disease becomes established in the country. Unfortunately, at the current level of knowledge of this disease, there is no way of knowing with any degree of scientific certainty, what the risk of this disease will be in any specific location in advance of the epidemic. States where the epidemic originates may have a much higher percentage of their acreage impacted by the disease or treated to prevent infection.

In another scenario, the pathogen could be accidentally or purposely introduced into the major soybean production belt in the United States. In that scenario, the epidemiological dynamics of the pathogen's spread may be very different, depending on the site of the initial introduction. In accordance with the 2002 Agricultural Bioterrorism Protection Act, Phakopsora pachyrhizi has been identified as a biological agent with potential to pose a severe threat to plant health or plant products (Federal Register December 13, 2002 - 67:76908-76938 - http://www.aphis.usda.gov/vs/ncie/pdf/btarule.pdf) (Appendix D of the Minnesota/South Dakota request).

Total Amount of Pesticide to be Used: Assuming 140,000 acres of soybeans in New York State need to be treated, the following scenario applies: (assumes that only one of the products used over the treated acreage - actual use may reflect a combination of products).

New York (140,000 acres treated with a maximum of two applications per product)

Propiconazole: 14,175-28,026 lbs. active ingredient or 8,750----17,500 gal of product, or

Tebuconazole: 10,237.5-14,175 lbs. active ingredient or 6,562.5-8,750 gal of product, or

Myclobutanil: 4,375-8,750 lbs. active ingredient or 8,750-17,500 gal of product, or

Propiconazole + trifloxystrobin:

tetraconazole:

pyraclostrobin + boscalid:

pyraclostrobin:

Among the requested products, propiconazole (Tilt, PropiMax EC, and Bumper) is a systemic, triazole fungicide with curative and protectant activity. It has post-infection activity that can stop pathogen establishment in the early phases of disease development. Propiconazole can also exhibit anti-sporulant activity, reducing inoculum production and slowing disease progress. This exemption request is for the use of one to two applications of propiconazole (Tilt, PropiMax, or Bumper) for control of Australasian soybean rust. This disease organism is expected to attack the crop after canopy development and response to fungicides have required multiple applications for optimum disease management.

Tebuconazole (Folicur) is also a systemic, triazole fungicide that can be used as curative systemic eradicant and a protectant. It has post-infection activity that can stop pathogen establishment in the early phases of disease development. Tebuconazole has also shown anti-sporulant activity, reducing inoculum production, thereby slowing disease progress. Tebuconazole is a broad-spectrum product and has shown excellent activity against other rust diseases, such as wheat leaf rust and sunflower rust. This exemption request is for the use of one to two applications of tebuconazole (Folicur) for control of Australasian soybean rust. This disease organism is expected to attack the crop after canopy development and response to fungicides have required multiple applications for optimum disease management.

Myclobutanil (Laredo) is a similar systemic, triazole fungicide that can be used as systemic eradicant and a protectant. It has post-infection activity that can stop pathogen establishment in the early phases of disease development. Myclobutanil is an anti-sporulant, reducing inoculum production, thereby slowing disease progress. This exemption request is for the use of one to two applications of myclobutanil (Laredo) for control of Australasian soybean rust. This disease organism is expected to attack the crop after canopy development and response to fungicides have required multiple applications for optimum disease management in other parts of the world.

Tetraconazole (Domark) is a systemic, triazole fungicide similar to propiconazole, tebuconazole, and myclobutanil that can be used as systemic eradicant and a protectant. It has post-infection activity that can stop pathogen establishment in the early phases of disease development. This exemption request is for the use of one to two applications of tetraconazole (Domark) for control of Australasian soybean rust. This disease organism is expected to attack the crop after canopy development and response to fungicides have required multiple applications for optimum disease management in other parts of the world.

Propiconazole + trifloxystrobin premix (Stratego) is a premixed combination of two systemic products, a triazole fungicide (propiconazole) that can be used as systemic eradicant and a protectant, and a strobilurin (trifloxystrobin). While propiconazole has post-infection activity that can stop pathogen establishment in the early phases of disease development and anti-sporulant activity, reducing inoculum production, this product premix should not be used as a curative. This exemption request is for the use of one application of propiconazole + trifloxystrobin (Stratego) for control of Australasian soybean rust. This disease organism is expected to attack the crop after canopy development and response to fungicides have required multiple applications for optimum disease management in other parts of the world.

Pyraclostrobin + boscalid (Pristine) is a premixed combination of these two fungicides. Pyraclostrobin is a systemic, strobilurin fungicide similar to azoxystrobin and trifloxystrobin that is a strong penetrant that can be used as systemic and protectant with curative activity. Nonetheless, strobilurins are not recommended for use as curatives. Boscalid has been shown to have mild activity against soybean rust and is included in this premix as a resistance management tool. This exemption request is for the use of one to two applications of pyraclostrobin + boscalid (Pristine) for control of Australasian soybean rust. This disease organism is expected to attack the crop after canopy development and response to fungicides have required multiple applications for optimum disease management in other parts of the world.

Pyraclostrobin (Headline) is a systemic, strobilurin fungicide similar to azoxystrobin and trifloxystrobin that is a strong penetrant that can be used as systemic and protectant with curative activity. Nonetheless, this and other strobilurins are not recommended for use as curatives. This exemption request is for the use of one to two applications of pyraclostrobin (Headline) for control of Australasian soybean rust. This disease organism is expected to attack the crop after canopy development and response to fungicides have required multiple applications for optimum disease management in other parts of the world.

Under this exemption, only one of the listed products could be used for one or two applications in a given season. In combination with products that are already registered, control should be achieved where the following guidelines are followed:

Stage of Crop Growth When Treatment Will Be Made: R-3 to R-5 (full flowering to early pod formation).

Use Season: Immediately upon the introduction of Australasian soybean rust into the United States until September 15 of the final production year approved in this action.

Additional Restrictions, User Precautions & Requirements of Applicators: Apply products in a sufficient volume of water to ensure adequate coverage, consistent with product labeling, as follows:

ALTERNATIVE METHODS OF CONTROL (166.20(a)(4))

Registered Alternative Pesticides: azoxystrobin, chlorothalonil, thiophanate-methyl

azoxystrobin (Quadris®) is a systemic strobilurin registered for soybean and shown to have broad spectrum activity against diseases caused by fungal pathogens.

• Locally systemic with broad spectrum of activity.
  
• Registered for application at many crop stages and can be applied late in crop development.
  
• Shown to provide control of soybean rust in international industry regulated trials.

• No independent efficacy trial data available as yet.
  
• Moderately high risk of fungicide resistance in the interaction with the pathogen.
  
• At the lowest labeled rate of the product, azoxystrobin is still the highest cost of treatment.
  
• Current Fungicide Resistance Action Committee (FRAC) guidelines recommend a 1:>1 rotation of QoI chemistry with other modes of action - as such, with two or three applications, only one treatment could be made with Quadris (Appendix A).
  
• Current FRAC guidelines recommend that QoI chemistry represent no more than 1/3 of the total number of fungicide applications - as such, with two or three applications, only one treatment could be made with Quadris.
  
• Current FRAC guidelines recommend that QoI chemistry only be used preventatively, not curatively. As such, this product should only be applied before disease is present.
  
• The states have been informed that the registrant does not have adequate supplies to meet grower needs should a soybean rust epidemic occur and they are not willing to absorb the cost of over-production of the product and maintaining large stockpiles for the possibility of an epidemic.
  
• Due to higher product cost for azoxystrobin (Table 10) producers will be tempted to reduce application rates. This practice increases the selection risk for resistance emerging from the pathogen population (see below).

There are several significant drawbacks to the use of strobilurin fungicides with fungal pathogens. Pathogen resistance to the fungicide is a risk that cannot be overlooked. Resistance to azoxystrobin has already been reported in the US from three powdery mildew isolates. FRAC classifies the strobilurins among the most likely fungicides to lead to resistant strains, among the fungicides commonly used in agriculture today. Soybean rust has the ability for prolific production of urediniospores. While theses spores are asexual, in less than two field seasons in South America, a mixed population with complex virulence diversity has developed, indicating that environmentally and genetically fit mutations can arise in a short time frame.

The cost of treatment with azoxystrobin is higher than any of the requested Section 18 products, even when applied at its lowest rate. The high cost of the product could encourage application of reduced rates which will exert a selection pressure for QoI-resistant off-types.

There will likely only be one or two applications of a Section 18 product each year to soybeans. Hopefully only one application is needed, but if additional applications are needed they can be combined with currently labeled products, used within FRAC guidelines for fungicide resistance management. Strictly interpreted, rusts are not generally considered high risks for fungicide resistance, but azoxystrobin is considered to carry a high risk for resistance and there remain unanswered questions about the biology of this organism in the New World.

Group 11 fungicides, fungicides with QoI mode of action, are fungicides that act on the Quinone 'outside' binding site of the cytochrome bc1 complex. Resistance to this mode of action has been widely documented in Europe where strobilurins have a longer use history. The most common resistance is a mutation at the G143A site of action and has been documented with Alternaria solani in the US; Sphaerotheca fulginea in Japan, Taiwan, and Spain; Septoria tritici in Ireland, UK, Germany, and France; Venturia inaequalis in Germany, Italy, and Poland; Erysiphe tritici f. sp. tritici in UK, Germany, France, Belgium, Denmark, and Sweden; Erysiphe tritici f. sp. hordei in UK Scotland, Germany, Belgium and France, and; Plasmopara viticola in Japan and Taiwan. Recently a second mutation at L129L was identified in Plasmopara viticola. Additionally, metabolic resistance, sometimes called tolerance has been identified in Venturia inaequalis. To date, no cases of resistance have been identified in the wheat leaf rust pathogen (Puccinia recondita), perhaps the closest relative to Phakopsora that has been monitored. Phakopsora pachyrhizi exists in an asexual population, the sexual hosts of the fungus are not known to exist. However, in South America it is present in a mixed population of many strains, even though it was only introduced to the continent in 1999. This issue begs that question of whether there have been multiple cross-Atlantic introductions or if there are frequent mutations of parasexuality that could be leading to the development of variants. Until those questions are answered, resistance management should be among our utmost concerns.

chlorothalonil (Bravo®, Echo®, Equus®, and others. Bravo® WeatherStik®, and; Echo® 720, DF and Zn are currently labeled for soybean rust) is a protectant registered for soybean.

• Widely available
  
• Relatively low cost
  
• Provides fair to good rust control in dry beans (Phaseolus spp.) when applied before infection
  
• Broad spectrum of protectant activity
  
• Resistance management tool for strobilurin chemistry
  

• Only Bravo® WeatherStik® and Echo® 720, DF and Zn are specifically labeled for soybean rust (supplemental labels)
  
• No efficacy data is available from independent trials, as yet
  
• As a protectant, this product must be applied with thorough coverage to the upper and lower leaf surfaces
  
• As a protectant, this product may weather from the leaf surface and must be reapplied more frequently. Fourteen days is stated as the minimum retreatment interval for Bravo Weather Stik.
  
• Industry concerns as to reliability of efficacy
  
• Excessively long preharvest interval (six weeks)
  
• Once disease is well established and rust populations are high, it is difficult to protect new foliage before infection occurs, resulting in only moderate control
  

Chlorothalonil is a protectant fungicide with a mixed track record in controlling rust diseases. Performance has been somewhat acceptable with bean rust (Uromyces appendiculatus), but unacceptable when tested for wheat leaf rust control (Puccinia recondita). While it offers a tool for fungicide resistance management and an alternate mode of action, it does not appear to offer the greatest promise for disease control. Additionally, a six week (42 day) preharvest interval with only 14 days of protection is unacceptable and limits the products use to early season application.

thiophanate-methyl (Topsin®, Topsin® M, T-methyl) is a systemic benzimidazole fungicide registered for soybean with activity against Sclerotinia and some other leaf diseases.

• Locally systemic with broad spectrum of activity.
  
• Labeled for soybean.

• Not labeled for rust and research data indicate the product is ineffective against Uromyces and Phakopsora rusts (Table 1, 2).
  
• Moderate risk of fungicide resistance in the interaction with the pathogen.
  

While labeled for use on soybeans, thiophanate-methyl is a systemic fungicide that is not labeled for rust control and experimental data has shown a poor track record in controlling rust diseases, including Australasian soybean rust (Table 1, 2).

Large economic losses due to Australasian soybean rust loom if the disease is allowed to progress unchecked. Losses in Brazil in 2002 exceeded 60% in some fields (Appendix F of the Minnesota/South Dakota request). Under conditions of severe disease pressure, soybean producers need systemic products that are in good supply. Use of any fungicide product on soybeans has been very limited, because of lack of availability of suitable efficacious registered products to address real disease needs and infrequency of severe disease, and lack of serious disease that would be effectively controlled by fungicides.

Recent data generated in Brazil, indicates that triazole fungicides are quite effective against this pathogen. Triazole fungicides, have proven most consistent in providing curative control with the minimum acceptable risk of fungicide resistance and with superior economics to registered products (see efficacy and economics sections). As a means of comparison, a one million acre figure will be used to consider use rates of each of the products requested. Use in specific states can be easily calculated from that figure.

Suggested product use regimen:

If disease is established on site (curative treatment):
¨ Treat with a Section 18 triazole product (propiconazole, tebuconazole, myclobutanil, or tetraconazole).
¨ If a second application is needed, treat with azoxystrobin if disease is at a minimal level, otherwise retreat with a Section 18 product.
¨ If a third application is needed, treat with chlorothalonil.

If disease is expected, but not yet present (preventative):
¨ Treat with azoxystrobin or pyraclostrobin.
¨ If a second application is needed, treat with a Section 18 triazole product (propiconazole, tebuconazole, myclobutanil, or tetraconazole).
¨ If a third application is needed, treat with chlorothalonil or a Section 18 product.

If disease is expected, but not yet present (preventative), and develops after initial treatment:
¨ Treat with azoxystrobin or pyraclostrobin.
¨ If a second application is needed, treat with a Section 18 triazole product (propiconazole, tebuconazole, myclobutanil, or tetraconazole).
¨ If a third application is needed, treat with chlorothalonil or a Section 18 product.

If disease is expected, but not yet present (preventative):
¨ Treat with propiconazole + trifloxystrobin (Stratego) or pyraclostrobin + boscalid (Pristine).
¨ If a second application is needed, treat with chlorothalonil or a Section 18 triazole product (propiconazole, tebuconazole, myclobutanil, or tetraconazole).
- or -
¨ Treat with azoxystrobin or pyraclostrobin.
¨ If a second application is needed, treat with a Section 18 triazole product (propiconazole, tebuconazole, myclobutanil, or tetraconazole).

Alternative Control Practices: Crop rotation, tillage, early planting and use of more tolerant varieties are ineffective management strategies for this disease. Crop rotation is a tactic commonly used to avoid exposure to residue-borne diseases. However, Australasian soybean rust will survive on alternative hosts and be air-borne throughout the soybean producing areas of the United States, blowing northward on winds from the south, commonly called the Puccinia pathway for their importance in moving urediniospores of wheat leaf rust and wheat stem rust into northern states. Thus, crop rotation is not a workable option. Areas where soybeans are grown tend to be intensively cropped with soybeans. As such, once inoculum reaches an area, exposure from nearby fields will always be a concern. Further, crop rotations are inadequate as the primary management strategy when environmental conditions are optimal for an epidemic.

Primary tillage reduces infested residue that harbors sources of inoculum. However, Australasian soybean rust is caused by an obligate parasite that will survive on alternative hosts in areas surrounding fields in the southern United States, rather than directly in cultivated fields. As such, tillage will be ineffective in significantly reducing the spread or inoculum sources of Australasian soybean rust.

Early planting may help escape the most serious disease buildup. This method will only be practical in southern states where weather is less of a factor limiting planting decisions. Planting dates cannot be adjusted very dramatically in northern production areas as producers are already planting as early as weather allows.

Host resistance is not yet a viable option for soybean producers. While resistance genes have been identified, no commercially acceptable varieties have become available. Mixed populations of rust races have limited the efficacy of deploying a single resistance gene in South America. Since it is not yet known which race will first appear in the US, efforts to screen introgressions into North American germplasm for resistance to isolates of the soybean rust pathogen is premature.

Alternative unlabeled fungicides, include oxycarboxin (Plantvax) and mancozeb (Dithane, Penncozeb, Manzate, and others) have also been shown to have measures of efficacy against soybean rust in other parts of the world. However, several problems have been identified in examining these products. Mancozeb, while quite effective against rusts, has a very full risk cup under and FQPA requirements, and has a fairly short period of effective protection before weathering reduces effective residues, requiring reapplication as frequently as every five days. Oxycarboxin, has also been used in Taiwan for control of soybean rust (Phakopsora) and bean rust (Uromyces) in Asia. In published data, effective control appears to require short reapplication intervals. Additionally, the applicants have not been made aware of any food crop tolerances for the active ingredient by the registrant.

In summary, alternative control practices are ineffective or insufficient for the management of this disease. Most cultural control methods will have little effect on a pathogen that will blow into northern states and may survive on alternative hosts in southern states. A severe soybean rust epidemic will cause considerable economic damage to an already weakened agricultural community in most soybean producing states.

A USDA soybean rust action plan discusses action to be taken to combat soybean rust (Appendix B).

EFFICACY OF USE PROPOSED UNDER SECTION 18 (166.20(a)(5))

Propiconazole, tebuconazole, myclobutanil and tetraconazole have post-infection activity which can stop pathogen establishment in the early stages of disease development. Eradicant activity is apparently greatest with tebuconazole and tetraconazole, but all four have curative activity. These triazole fungicides prevent the completion of the infection process by direct inhibition of sterol biosynthesis in the fungus. This mode of action (MOA) is known as FRAC group 3 or SBI (sterol biosynthesis inhibition) activity. These attributes allow an integrated pest management approach, using scouting, weather data, and application of only when conditions indicate it is warranted and disease risk is high.

Efficacy of possible products against Australasian soybean rust on Soybeans
(Conducted by USDA in Brazil and Paraguay, 2003)
No studies have been conducted in the United States because the pathogen is not yet present. However, industry and USDA studies have been conducted in Brazil and Paraguay (Appendix H of the Minnesota/South Dakota request), and data is available from Dr. Clive Levy in Zimbabwe, where the disease has been present since 2000. Following are summary data tables from the 2003 USDA studies in South America. Table 1 shows suppression of disease while Table 2 compares yield, expressed as 1000 seed weight, while Table 3 compare treatments for total plot yield and defoliation.

Table 1. Mean rust severity (%) at growth stage R6 in each fungicide treatment from the three locations of the fungicide efficacy trial located in Paraguay during the 2002-2003 growing season (USDA data).

¹ All fungicide treatments significantly different from control (P=0.05).
² Differences between locations significant at (p=0.001), means with different letter were significantly different. There was a significant location by treatment interaction (p=0.0001) seen as differences in ranking within each location.
³ Significant (p=0.05) location by number of applications interaction.

Table 2. Mean 1000 seed weights of each fungicide treatment from the three locations of the fungicide efficacy trial done in Paraguay during the 2002-2003 season (USDA data).

¹Significant differences among treatments within each location, ( ) indicates treatments not significantly different from the control within the location. There was a significant treatment by location interaction (p=0.1).
²Differences among means were significant (p=0.05), means with different letters differed significantly.

Table 3. Mean yield and percent defoliation of soybean plots treated with twenty fungicide treatments at three locations in Paraguay during the 2002-2003 growing season (USDA data).

¹Mean of two application schedules at three locations, four replications per location. No significant location or application interactions.
²Mean of four replications from the Sato location. Significant treatment by application schedule interaction seen.
³Means separated using LSD, means with same letter are statistically the same.

Efficacy of tebuconazole and trifloxystrobin + propiconazole on Soybeans
(Conducted by Bayer CropScience)

No studies have been conducted in the United States because the pathogen is not yet present. However, industry and USDA studies have been conducted in Brazil and Paraguay, and data is available from Dr. Clive Levy in Zimbabwe, where the disease has been present since 2000. Based on Bayer studies in South America, during the winter of 2001-02, two applications of Stratego (trifloxystrobin + propiconazole) significantly reduced disease and increased yield (Table 4, 5) over thiophanate-methyl and the untreated control. At another Brazilian location, two applications of Stratego (trifloxystrobin + propiconazole) and tebuconazole performed similarly with significant reduction in disease and increase in yield (Table 6). Similarly, a study conducted for Dow AgroSciences showed tebuconazole to be among the most efficacious fungicides tested in this study (Table 7) against Australasian soybean rust.

2003 Trial - Syngenta Crop Protection at Embrapa (Brazil)
The following greenhouse data shows excellent control of soybean rust up to 8 days prior to inoculation. Control success is limited as timing from treatment to inoculation reaches 14 days. Curative control was good up to 4 days after infection. While azoxystrobin provided the best curative control, this method of application is contrary to the product label and increases risk of selecting for fungicide resistance in the pathogen population.

Table 4. 2003 control (%) data from Embrapa (Brazil) commissioned by Syngenta Crop Protection

¹ - Treated with fungicide and inoculated 4, 8, 14 days after treatment (DAT).
² - Inoculated with pathogen and treated 2, 4, 8 days after inoculation (DAI).
³ - Opera is a premix of pyraclostrobin + epoxiconazole.

• 2002 Trial - Bayer CropScience

One trial was commissioned by Bayer at Chapadao do Sul, MS. TAGRO, Safra. Fungicide was applied at R 5.1(beans beginning to form in pod) and R 5.2 (beans forming in pod). Stratego and a tebuconazole premix provided significant reduction in disease and increase in yield (Table 5).

Table 5. Control of Phakopsora pachyrhizi in Soybeans at Chapadao do Sul, MS. TAGRO, Safra 2001/02

¹ Evaluations recorded at 125-138 days after planting.
² Yield from 5m² plots.
³ Infestation in untreated plot was 93.75 %.
* Duncan's Multiple Range Test @ 5% significance level.

• 2002 Trial - Bayer CropScience

A second trial was also commissioned by Bayer at Chapadao do Sul, MS. TAGRO, Safra. Fungicide was applied at soybean growth stage R 5.1(beans beginning to form in pod) and R 5.2 (beans forming in pod). In this study, trifloxystrobin + propiconazole (Stratego) and tebuconazole both provided excellent disease control, significantly better than thiophanate-methyl (Topsin-M), a product labeled for soybeans (not rust) in the US (Table 6). Similarly, both products also significantly increased yield over the untreated control and thiophanate treatment.

Table 6. Treatments to Control Phakopsora pachyrhizi in Soybeans, Chapadao do Sul, MS. TAGRO, Safra 2001/02

¹ Evaluations recorded at 126-139 days after planting.³ Infestation in untreated plot was 83.7%.
² Yield from 5m² plots.* Duncan's Multiple Range Test @ 5% significance level.

• Efficacy of myclobutanil on Australasian soybean rust
(Conducted in Brazil by the FT Foundation, an independent contractor for Dow AgroSciences).

Myclobutanil showed good curative and eradicative activity against this disease following a single application of fungicide, similar to tebuconazole and Impact, and superior to the strobilurins alone or premixed (Stratego) and difenoconazole in control of Australasian soybean rust (Table 7). In another study, still underway (May 2003) myclobutanil proved effective and comparable to other products requested in this Section 18, propiconazole, tebuconazole, and trifloxystrobin + propiconazole (Table 8).

Table 7. Greenhouse infection of soybean by Phakopsora pachyrhizi (study done in Brazil). A single application of fungicide for rust control was applied when the inoculated soybeans showed around 5 - 10 % of infection level. This study focused on curative and eradicant features rather than protectant activity.

¹ - Disease Scale: 1= No symptoms; 2= 1 - 10 % of infection level; 3= 11 - 25 % of infection level; 4= 26 - 50 % of infection level; 5= 50 - 100 % of infection level.
² - DAT = Days after treatment for evaluation.

Table 8. Field infection of soybean by Phakopsora pachyrhizi (study done in Brazil by the FT Foundation, an independent contractor for Dow AgroSciences). A single application of fungicide for rust control was applied on March 10 (GS R 5.4) when the soybeans showed 0.9% disease incidence. This study focused on application during curative conditions, similar to what many US producers will deal with.

¹ Systhane EC = Laredo EC (myclobutanil)
² DAT = Days after treatment for evaluation.

• Control of rust by propiconazole (independent study)

In an older study (1998), another triazole, triadimefon, provided the best control of soybean rust, but propiconazole, hexaconazole, and difenoconazole all provided significant reduction in disease over the untreated control. However, while yield increases were greater on a percentage basis, no significant yield increases were realized from any fungicide treatment in this relatively low yielding trial (Table 9). Above, (Table 8) propiconazole was shown to significantly reduce rust incidence by 24 days after treatment with a single application.

Table 9. Control of soybean rust by several fungicides including propiconazole. Two applications made at 50 and 65 days after planting (Patil, R.V. and Anahofur, K.H. 1998. Control of soybean rust with fungicides. Indian Phytopathology 51: 265-268).

• Control of rust by tetraconazole (Conducted in Sao Joao da Alianca, Brazil by Sipcam Agro SA)
Tetraconazole displayed excellent control of soybean rust as measured by nearly 50% to greater than 70% reduction in infection and about 40-65% reduction in defoliation when applied late in crop development (R5.2) (Table 10). Similar responses were achieved under heavier disease pressure (Table 11).

Table 10. Treatments to Control Phakopsora pachyrhizi in Soybeans in Brazil - Sao Joao da Alianca¹.

Table 11. Treatments to Control Phakopsora pachyrhizi in Soybeans in Brazil - Agua Fria¹.

• Control of rust by pyraclostrobin + boscalid and pyraclostrobin alone
(Conducted in Paraguay and Brazil by BASF).

Pyraclostrobin displayed excellent control of soybean rust in several South American trials. Pyraclostrobin was consistently among the best yielding treatments and the lowest defoliation values (Table 12, 13, 14, 15, 16, and 17). Only epoxiconazole performed better and that product is not being pursued in this application at the option of the manufacturer. When combined with boscalid in USDA trials in South America during the 2002-2003 crop production season, efficacy of control was diminished some, but it still remained among the better treatments and similar to other products in this submission (Table 1, 2, 3).

Table 12. Treatments to Control Phakopsora pachyrhizi in Soybeans in Paraguay - Pirapo¹.

Table 13. Treatments to Control Phakopsora pachyrhizi in Soybeans in Paraguay - Pirapo (Trial 2)¹.

Table 14. Treatments to Control Phakopsora pachyrhizi in Soybeans in Paraguay - Jesus¹.

Table 15. Treatments to Control Phakopsora pachyrhizi in Soybeans in Paraguay - Jesus (Trial2)¹.

Table 16. Treatments to Control Phakopsora pachyrhizi in Soybeans in Brazil - Centro Oeste¹.

Table 17. Treatments to Control Phakopsora pachyrhizi in Soybeans in Brazil - Sorriso¹.

EXPECTED RESIDUE LEVELS IN FOOD (166.20(a)(6))

See letters of support (Appendix B - i through B - vi of the Minnesota/South Dakota request) for details on the following information:

Propiconazole - Residue data has been collected for soybean and is included in petition no. 2F6371, MRID 43386502 and 44549101.

Tebuconazole - Bayer is conducting soybean residue trials in the U.S. in 2003 with the intent of developing data on potential residues of tebuconazole in the various soybean commodities. Tebuconazole residue data is on file with EPA proposing tolerances on bean seed, wheat forage, hay and straw (Federal Register March 19, 2001, 66(53):15437-15443) (Appendix B - ii of the Minnesota/South Dakota request).

Trifloxystrobin - Bayer is conducting soybean residue trials in the U.S. in 2003 with the intent of developing data on potential residues of trifloxystrobin in the various soybean commodities. Permanent tolerances are established for residues of trifloxystrobin on wheat grain, forage, hay and straw.

Myclobutanil - Indirect or inadvertent residue of myclobutanil of 0.03 ppm for legume vegetables has been established (Federal Register May 10, 2000). Direct residue studies have been conducted in Brazil on soybeans. These studies indicate a residue of 0.03 ppm in soybeans. Additional studies are planned to be conducted in the U.S. in 2004.

Tetraconazole - Sipcam is currently conducting soybean residue trials and data is expected by early December, 2003. Brazil has recently registered tetraconazole for use on soybeans with a Maximum Residue Limit (MRL) for tetraconazole at 0.1 ppm on harvested soybeans. The Brazilian MRL is based on three applications of tetraconazole on soybeans with a seven day pre-harvest interval. Based on the proposed use pattern in the U.S., residues of tetraconazole on soybeans would not be expected to exceed the Brazilian MRL (Appendix B - iv of the Minnesota/South Dakota request).

Boscalid - The following tolerances for indirect or inadvertent residues of boscalid in soybeans have been established (Federal Register, July 30, 2003): soybean hulls 0.20 ppm, soybean seed 0.10.

Pyraclostrobin - The proposed tolerances for pyraclostrobin on soybeans are: soybeans 0.4 ppm, soybean forage 5.0 ppm, soybean hay 7.0 ppm, and soybean aspirated grain fraction 0.25 ppm (MRID 45903602). Existing tolerances for pyraclostrobin have been published in the Federal Register 67:60886-60901, September 27, 2002.

DISCUSSION OF RISK INFORMATION (166.20(a)(7))

See letters of support (Appendix B - i through B - vi of the Minnesota/South Dakota request) for details on the following information:

Propiconazole - Risk information has previously been submitted and assessed to support the Section 3 registration of propiconazole on numerous crops including wheat, oats, barley, rye, rice, wild rice, corn and peanuts. A petition (2F6371), including risk assessment, for the use of propiconazole on soybeans has been submitted to EPA. The RED for propiconazole is still underway.

Tebuconazole - Risk information has previously been submitted and assessed to support the Section 3 registration of tebuconazole on peanuts. A toxicological profile was published in the Federal Register March 19, 2001 (Appendix B - ii of the Minnesota/South Dakota request).

Trifloxystrobin - Risk information has previously been submitted and assessed to support the Section 3 registration of trifloxystrobin on numerous crops including cucurbit vegetables, fruiting vegetables, grapes, hops, pome fruits, stone fruits, tree nuts, citrus, potatoes, rice and sugar beets.

Tetraconazole - A risk assessment for tetraconazole has been submitted to EPA (MRID no. 45155007). A risk assessment for tetraconazole was published in the Federal Register December 6, 1999, in response to EPA's authorizing the use of tetraconazole on sugar beets pursuant to section 18 of FIFRA (Appendix B - iv of the Minnesota/South Dakota request).

Pyraclostrobin - Risk information has previously been submitted and assessed to support the Section 3 registration of pyraclostrobin on numerous crops including dry beans, peanuts, sugar beets, wheat, barley, rye, citrus, berries, bulb vegetables, cherry, cucurbit vegetables, fruiting vegetables, root vegetables and strawberries.

Myclobutanil - Risk information has previously been submitted and assessed to support the Section 3 registration of myclobutanil on numerous crops including grapes, herbs and spices, apples, small fruits, stone fruits, cucurbits, snap beans, tomatoes, and ornamentals. Myclobutanil has not been shown to degrade to 1,2,4-Triazole, a triazole fungicide metabolite of concern to EPA (see below).

Boscalid - Risk information has previously been submitted and assessed to support the Section 3 registration of boscalid on numerous crops including dry and succulent beans, bulb vegetables, canola, carrots, fruiting vegetables, grapes, lettuce, peanuts, and potatoes.

Propiconazole, tebuconazole, tetraconazole, and myclobutanil are triazole fungicides. EPA is evaluating the toxicological significance of triazole metabolites 1,2,4-triazole, triazolylalanine (TA) and triazolylacetic acid (TAA). Of the three metabolites, only 1,2,4-triazole can be considered toxicologically significant and EPA has identified developmental toxicity as the endpoint of concern. An industry Triazole Task Force has submitted worst-case studies (Appendix J of the Minnesota/South Dakota request) to EPA demonstrating a reasonable certainty of no harm for 1,2,4-triazole stemming from triazole-derivative fungicides for food only, as well as for food and water.

COORDINATION WITH OTHER AFFECTED FEDERAL, STATE, AND LOCAL AGENCIES (166.20(a)(8))
This request is being formally submitted to the U.S. Environmental Protection Agency (EPA) by the New York State Department of Environmental Conservation - the state lead agency responsible for pesticide enforcement in New York State. A copy is also being submitted to the New York State Department of Agriculture and Markets.
Also, please find a list of endangered and threatened species known to occur in New York State (Appendix C). It is expected that applications by ground equipment directly to soybean fields should not pose a problem to endangered species, especially when spray drift is kept under control. Aerial applicators will need to be familiar with those areas adjacent to sprayed fields and should check with local and regional NYSDEC biologists for endangered species residing near the spray area. Scouting of adjacent areas near soybean fields is encouraged prior to aerial applications.

NOTIFICATON OF REGISTRANT(166.20(a)(9))

The manufacturers of tebuconazole (Folicur 3.6F - Bayer CropScience), propiconazole + trifloxystrobin (Stratego - Bayer CropScience), propiconazole (Tilt - Syngenta Crop Protection, Inc.; PropiMax EC - Dow AgroSciences, Inc, and; Bumper - Makhteshim Agan of North America, Inc.), myclobutanil (Laredo EC - Dow AgroSciences, Inc.), tetraconazole (Domark - Sipcam Agro USA, Inc.), and pyraclostrobin + boscalid (Pristine - BASF Corporation) and pyraclostrobin (Headline - BASF Corporation) are aware of and supportive of this request. Letters of support and draft labels for soybeans have been received (Appendix B - i through B - vi of the Minnesota/South Dakota request).

ENFORCEMENT PROGRAM (166.20(a)(10))

The New York State Department of Environmental Conservation is responsible for pesticide enforcement and will take appropriate steps to ensure that the conditions of this exemption are met. The Pesticide Management Education Program (PMEP) at Cornell University and Cornell Cooperative Extension will provide use information to the field to ensure that all applicable directions and restrictions are available to growers/producers if our request is approved by the EPA.

REPEAT USES(166.20(a)(11))

This request is the first request for the use of each of the requested products; Tilt, PropiMax EC, Bumper, Folicur 3.6F, Stratego, Laredo EC, Domark, Pristine, and Headline on soybean by New York State.

PROGRESS TOWARD REGISTRATION (166.25(b)(2)(ii))

Please refer to the quarantine exemption request submitted by the states of North Dakota and Minnesota for 2004

See letters of support (Appendix B - i through B - vi of the Minnesota/South Dakota request) for details on the following information:

Propiconazole - Syngenta submitted a petition for the use of propiconazole on soybeans to EPA on September 21, 1994 (PP 5F04424) and submitted a new petition on November 14, 2001 (PP2F6371).

Tebuconazole - Bayer will be pursuing Section 3 registration of tebuconazole on soybeans following the development and collection of data from residue trials which are underway.

Myclobutanil - The registration of myclobutanil on soybeans is not expected to occur until the completion of the triazole metabolite review by the EPA and the completion of soybean trials in the U.S. Estimated registration date would be 2006.

Trifloxystrobin - Bayer will be pursuing Section 3 registration of trifloxystrobin on soybeans following the development and collection of data from residue trials which are underway.

Tetraconazole - Sipcam's pursuit of registration for potential uses, including soybeans, of tetraconazole is suspended until the triazole metabolite issue is resolved. Once the triazole metabolite issue is resolved, Sipcam will move forward on new registrations for tetraconazole.

Pyraclostrobin - Data supporting pyraclostrobin use in soybeans were submitted to EPA in March 2003 (PP 3F6581). The review of pyraclostrobin on soybeans is expected to be included in EPA's 2004 work plan.

Boscalid - Is a component of the combination product Pristine (pyraclostrobin plus boscalid).

name OF PEST (166.20(c)(1))

Scientific Name: Phakopsora pachyrhizi H. Sydow and Sydow
Phakopsora meibomiae
Common Name: Australasian soybean rust

ORIGIN OF INTRODUCED PEST (166.20(c)(2))

Australasian soybean rust, when introduced to the United States, has the potential of being a widespread, damaging disease, capable of causing losses in all soybean production areas on the United States soybean acreage. With more than 73 million acres of soybeans in the United States, industry sources have communicated that a supply of one or two fungicides, including the currently registered products, will likely be insufficient for the vast acreage of soybeans potentially affected. The joint supplies of several fungicides representing several different products will more than likely be required to combat an outbreak. We do not envision registrants, dealers, or producers stockpiling fungicide to combat a potential outbreak due to the tremendous potential inventory cost for the unused product.

Local conditions demand the ability to choose between several fungicides - one or two products may be found ineffective in the early days of an epidemic, despite Africa and South America efficacy trials. Efficacy is really a local issue. Unfortunately, the nature of this threat precludes local testing which normally serves us so well.

Resistance management demands an alternation of chemistries applied, especially for a pathogen that reproduces so rapidly and is spread aerially over great distances. FRAC guidelines direct producers and applicators to alternate chemistries or modes of action, not only locally but also regionally, to effectively blockade any resistance that does develop. Also, combination products may prove an effective tool in limiting resistance development, especially the combination of an older multi-site inhibitor, such as chlorothalonil or mancozeb, with one of the newer, systemic compounds, such as the triazoles or strobilurins.

Australasian soybean rust is known to occur and cause serious crop losses in Asia (China, Korea, India, Japan, Nepal, Russia, Taiwan, Thailand, the Philippines), Australia, Africa (Mozambique, Nigeria, Rwanda, South Africa, Uganda, Zambia, and Zimbabwe), and since 2000, in South America (Argentina, Brazil, and Paraguay). As of April 2003, Australasian soybean rust has not yet been detected in the continental United States. It has been present in Hawaii since 1994 (anonymous, 2002). However, the pathogen is spread by wind-borne spores, suggesting that it may reach major soybean production areas in the United States. Presumably, the pathogen entered South America as wind-borne urediniospores blown across the Atlantic Ocean, very similar to the path presumptively taken by the sorghum ergot pathogen (Appendix C- Figure 1 of the Minnesota/South Dakota request). Once introduced, The pathogen is airborne and may follow a pathway similar to the wheat stem rust and leaf rust pathway, northward through the central US (Appendix C- Figure 2 of the Minnesota/South Dakota request) or the dispersal pattern like the Southern corn leaf blight pathogen during the US epidemic of 1970 (Appendix C- Figure 1 of the Minnesota/South Dakota request).

Soybean rust is caused by two morphologically similar fungal species, Phakopsora pachyrhizi and Phakopsora meibomiae. P. meibomiae was reported in Puerto Rico in 1976, but this species has proven to be a weak pathogen. The much more aggressive Phakopsora pachyrhizi was reported in Hawaii in 1995. Introductions of P. pachyrhizi in other parts of the world more recently have shown rapid spread and severe crop damage in Zimbabwe, South Africa, Paraguay, and Brazil. Yield losses have been reported from 10-80%.

One of the primary issues complicating the detection and control of this insidious pest are the large number of legume hosts that can serve as alternative hosts for soybean rust. In addition to soybean, there are 30 species of legumes across 17 genera that have been reported to be hosts for soybean rust in nature. Additionally, 60 species in 26 genera have been successfully inoculated in the laboratory. There is a great threat for inoculum production on a widespread weed host in the United States, Pueraria montana var. lobata commonly known as kudzu. Many other leguminous crops and weeds have also shown varying degrees of susceptibility to both species of Soybean rust. Some common hosts include yellow sweet clover (Melilotus officinalis), vetch (Vicia dasycarpa), medic (Medicago arborea), lupine (Lupinus hirsutus), green and kidney bean (Phaseolus vulgaris), lima and butter bean (Phaseolus lunatus), and cowpea or black-eyed pea (Vigna unguiculata) (anonymous, 2002). See Appendix F of the Minnesota/South Dakota request for ASA Soybean Rust Alert, Plant Health Initiative, APHIS Data Sheet, USB Soybean Rust Alert Publication.

Nearly 74,000,000 acres of soybeans are grown in the United States. Nationally, soybeans account for 73.8 million planted acres, 2.75 billion bushels produced, and over $13 billion value of production. Even a modest 4% minimal loss of production would reduce domestic soybean production to its lowest point in the preceding five years. Depending on the crop stage when disease onset occurs, losses could vary dramatically from field to field. South Dakota grows approximately 4 million acres of soybeans, the most widely planted crop in the state in 2001 and 2002. Counties in the Southeast and East Central crop reporting districts are at the greatest risk of soybean rust due to more common high relative humidity and common use of windbreaks that increase relative humidity and prolong dew periods. Minnesota grows more than 7 million acres of soybeans, also the most widely planted crop in the state in 2002. Counties in the South Central, Southwest, West Central, and Central crop reporting districts are at the greatest risk of soybean rust due to more common high relative humidity and common use of windbreaks that increase relative humidity and prolong dew periods and the influence of the Minnesota River Valley over a large portion of the central and west central parts of the state. Additionally, extensive expansion of soybeans in the Northwestern crop reporting district also leaves that area at risk.

IMPACT OF THE PEST (166.20(c)(3))

Product cost must be considered in selecting efficacious products. Several commodity representatives have told us that three applications of a fungicide could cost about $45/acre. These are new costs to production. Fungicides are not commonly applied on soybeans in the US. Soybean producer representatives have indicated that such costs would exceed profits for many producers under current conditions. Depending on the area of the country and environment in the year, profitability on the farm is tenuous. A selection of products should be made available to allow for reasonable soybean rust management under various economic management situations. Also, a variety of fungicides are needed to provide adequate supplies of efficacious fungicides at reasonable prices thereby avoiding market-induced high prices.

Soybean rust is a potentially devastating disease. A variety of published reports have indicated that soybean rust is capable of causing yield reductions area-wide on soybeans from 10 to 50% and in selected fields over 90%. We do not know of any published reports on yield reductions on other leguminous crops that are known to be susceptible to the soybean rust pathogen, but similar impacts are possible. Two USDA Economic Research Service reports that were published in 1984 estimated that total U.S. losses from soybean rust five years following its introduction could range from $592 million/year to as high as $19.9 billion/year in 1986 dollars (Kuchler et al. 1984; Kuchler and Duffy. 1984) (Appendix L of the Minnesota/South Dakota request). Assumed yield losses in these scenarios ranged from 4% to 25%, with and without grower response to soybean rust. Total losses would not only be due to soybean yield losses but also to the disruptive effect on the soybean feed and food industries. However, producers would realize higher prices for harvested soybeans and corn following a soybean rust epidemic, reducing the negative effect of soybean rust. The net effect to the U.S. economy was estimated to range from $235 million/year to $4.5 billion/year.

If losses comparable to the 60% figures experienced in Brazil were to occur the already fragile farm economy would be tragically impacted.

Projected losses: If soybean rust is introduced to the US late in any given season, losses may be small. However, introduction of the diseases early could be very serious. It is currently not known how the disease would impact markets. The Economic Research Service of USDA is in the process of completing a rewrite of the potential effects of soybean rust entering the US but is not available at this time. However, a brief analysis was compiled and is included in draft form (Appendix L of the Minnesota/South Dakota request).

Economic Data From The Past Five Years

The past several years in New York State, much like that of South Dakota and Minnesota, have been full of environmental change. Nonetheless, conditions are very favorable for the development of soybean rust over the entire state of New York. New York's soybean production for 2002 was valued at $24.5 million (Appendix D).

Cost of production data for 16 soybean producing states is available through the National Ag Risk Education Library Budget Section (http://www.agrisk.umn.edu/Default.aspx?Lib=Budget&P=CustomSearch). Table 18 reflects an estimate of soybean production in New York State over the last five years (1998-2002). Profitability of the crop has been variable over that time and producers in New York may have been operating at a loss in some of those years (Table 18).

Soybean Production.

Table 18: New York State statewide soybean production.

* USDA, New York State Agr. & Mkts Statistics
**Source: SDSU Economics Department estimate.

http://www.finbin.umn.edu/CropEnterpriseAnalysis/Default.aspx)

Available data from the Minnesota/South Dakota request (Appendix E) indicate that the triazole fungicides and propiconazole + trifloxystrobin will perform similarly, that azoxystrobin may provide slightly better control when used preventatively and no data is available for chlorothalonil. The proposed Section 18 products appear to offer the potential of preventing a 60-80 % yield loss of soybean production. Per the Minnesota/South Dakota request and their economic analyses (Appendix E), we will use 50% as a conservative estimate for the requested products and azoxystrobin. No estimate can be made for chlorothalonil. Without the use of one or more of the requested products, New York Soybean producers could lose at least 50% of their crop or an estimated value of $12.25 million.

wgs/
5/04

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