Spudman November/December 2022 - 40

Sharing the complexities of production with EPA pesticide regulators
This summer, the
NATIONAL
POTATO
COUNCIL
Mike Wenkel
Chief Operating
Officer
National Potato Council
(NPC) in cooperation
with the Colorado
Potato Administrative
Committee (CPAC),
hosted a tour of potato
production for staff
of the EPA's Office of
Pesticide Programs
(OPP) in Colorado's
San Luis Valley. The
farm tour - hosted
annually in various
growing areas around the country - allows
federal regulators to better understand how
their decisions have real-world implications
on our farms.
This year EPA participants (many who
were new hires during COVID) were provided
information on pest management related to
growing seed and in the pre-plant, planting,
in-the-field, and postharvest stages. They
had the opportunity to spend time in the
fields and in the facilities where their
decisions will be implemented with all of
the potential consequences, both negative
and positive, that may result. Presenters
included growers, Extension educators, and
researchers from across the country on
weeds, pathogens, nematodes and insects.
It is imperative for our industry to
interact with EPA staff and share the
complexities of producing a high-quality,
high-cost potato crop for U.S. consumers and
customers around the globe. It is all of our
responsibilities to provide regulators with the
practical information to help them make the
best decisions. Though they may take that
information and still get a decision wrong,
our outreach is still important and improves
the chances for reasonable outcomes. In
that mission, the tour provided the industry
an opportunity to educate regulators on the
pest challenges faced by potato growers, and
the value we place on retaining the regulated
tools growers need to succeed.
This year's tour came at a time when
EPA and other federal regulators are under
increasingly vocal activist pressure to
consider eliminating valuable tools from
the grower toolbox to control pests and weeds.
Here are just a few examples of how NPC
is working to maintain access to important
chemistries.
40
Spudman.com
Participants from EPA's Office of Pesticide Programs pose with Mark Peterson of Peterson
Farms next to a self-propelled sprayer. Photo: National Potato Council
IMIDACLOPRID, CLOTHIANIDIN
AND THIAMETHOXAM
This summer, EPA released the final
biological evaluations (BE) for the neonicotinoid
insecticides clothianidin, imidacloprid and
thiamethoxam as part of an Endangered
Species Act (ESA) evaluation that identifies
potential impacts on endangered and
threatened species and their critical habitats.
During the open comment period, NPC
and the state potato organizations submitted
comments with examples of product
utilization and challenges of alternative
products across the nation. Unfortunately,
those real-word examples and usage data
were not incorporated into EPA's evaluation,
which could result in the loss of those tools.
The next stage is formal consultation
with the U.S. Fish and Wildlife Service and
National Marine Fisheries Service, where
we hope the evaluation can be refined to
present a more realistic assessment of the
impacts of these products on listed species
populations.
EPA PROPOSES
CANCELLATION OF PCNB
In September, EPA proposed the cancellation
of pentachloronitrobenzene (PNCB), the active
ingredient in AMVAC's Blocker, which would
result in the elimination of all registered uses
of PCNB in order to address human health and
ecological risk concerns.
PCNB is registered for use in-furrow
to control rhizoctonia, white mold, black
dot disease and common scab in potato
production. In the Proposed Final Decision, EPA
has identified multiple alternative products as
economical and effective alternatives to PCNB
in the control of these pests.
In response to the proposed decision,
AMVAC argued that " the loss of this product
would have economic consequences for
potato seed producers, where it is utilized
to preserve quality and integrity within
production of seed potatoes. For commercial
potato growers, the poorer aesthetics due
to presence of common scab decreases the
(grade and) value of their crop at market. "
NPC is currently working to evaluate
the Proposed Final Decision and provide
comments based on grower input on how they
control these pests.
CALLING ON EPA TO DENY
PETITION TO REVOKE
ORGANOPHOSPHATE
REGISTRATIONS
NPC and 10 state potato organizations
recently submitted formal comments to
EPA in response to a petition to revoke
tolerances and cancel registrations for certain
organophosphate uses, which was brought
before the agency by the group Earthjustice.
In the comments, NPC urged EPA to deny
See NPC, Page 41
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Spudman November/December 2022

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