Chlorimuron

Filed on regulations.gov — full text not in the inline record.

RE: EPA Public Comment on Sulfonylureas Herbicides. Thank you for the opportunity to comment on the twenty-two sulfonylurea (SU) herbicides currently undergoing registration review at EPA's Office of Pesticide Programs (OPP). Aerial Application Industry aircraft are tested to very specific configurations at professionally administered spray pattern testing events such as OPERATION S.A.F.E.*clinics, which are offered annually in Washington State via the Association of Washington Aerial Applicators (AWAA), to allow for maximum performance of the crop protection products being delivered while simultaneously providing the best possible pattern to prevent drift by controlling the droplet size, spectrum and swath width. By mandating a very course droplet with SU applications the label would be forcing the applicator into making an underperforming application, thereby increasing weed SU tolerance thus detrimentally and economically damaging an applicators good reputation. To reiterate, the modern Aerial Application Aircraft is already equipped with the very best scientifically engineered and tested Drift Reduction Technologies (DRT) in cooperation with USAD ARS** and pattern tested to each aircraft's specific configurations in cooperation with OPERATION S.A.F.E.*. Very course droplets would not yield better DRT results and would increase SU tolerance with mediocre to poor control of the target infestation. In Washington State Aerial Applicators are already regulated by law to a maximum boom length of 75% of the wing span. As for the swath and Nozzle selection, each aircraft is going to be configured in such a way as to minimize the drift potential. No two aircraft model types will have the similar DRT application configurations; nor should a label mandate the approach that an applicator utilizes to achieve the most efficacious and safe patent to apply crop protection products. Proposed- Tank mixes with different modes-of-action and herbicides such as glyphosate would be prohibited if the extremely course droplet size is required as these applications generally require small droplet size to be efficacious. There are many factors in determining when it is appropriate to tank mix several modes of action in one tank mix. There are situations that are perfectly acceptable to do so, thereby providing the most efficacious application in controlling the target infestation and simultaneously obtaining the best economic value to the applicator and grower. In fact, in some cases the best practice would be to tank mix multiple modes of action to ensure the products work at their highest possible performance standards preventing pesticide tolerance issues and achieving the intended control of the infestation. Often there are several weed types that are being targeted. If only one product is allowed per application the remaining weeds will likely be difficult to impossible to control with subsequent applications. The economic impact to the grower for not only having to pay for multiple applications but also only achieving moderate control by doing so is unrealistically financially burdensome. In Closing, The Aerial Application community strives to achieve the best industry practices while utilizing DRT and ensuring our nozzle selection and orientation is appropriate to each specific airframe and aircraft type. By adding blanket label language to mandate in regards to the droplet size and equipment type without accounting for the variations in our application fleet would be forcing the Aerial Applicator into sub medial control while gaining little to no drift mitigation beyond what each aircraft are already calibrated and tested to already accomplish. To compound the situation the economic burden of having to split SU applications out from other chemistries has far reaching implications for not only the grower but the solvency of many Aerial Application businesses nations wide. The "mandating" language proposed is far more harmful than helpfu…