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EPANonrulemakingEPA-HQ-OPP-2008-0844

Imidacloprid Registration Review

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Jul 7, 2025
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closed 642d ago
National Potato Council filings
4

Activity

National Potato Council filed 4 comments on this docket between Mar 19, 2009 and Aug 24, 2017. 132 other organizations filed here. The comment window closed 642d ago.

What National Potato Council filed (4)

Aug 24, 2017· Comment submitted by John Keeling, Executive Vice President and Chief Executive Officer, National Potato Council (NPC)· EPA-HQ-OPP-2008-0844-1231

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

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Apr 26, 2016· Comment submitted by John Keeling, Executive Vice President and Chief Executive Officer (CEO), National Potato Council· EPA-HQ-OPP-2008-0844-0861

April 14, 2016 U.S. Environmental Protection Agency Docket ID number: EPA-HQ-OOP-2008-0844 Re: Preliminary Risk Assessment to Support Registration Review of Imidacloprid The following comments are submitted by the National Potato Council on behalf of potato growers who produce more than ninety percent of the U.S. potato crop. U.S. commercial potato production occurs in 34 states and has a farm gate value in excess of $3.5 billion annually. Although potato growers do not require bees to pollinate their crops, many potato growers have relationships with beekeepers that include having managed hives on their farms in close proximity to potatoes and other rotational crops. That experience informs our industry's understanding that the use of Imidacloprid and other neonicotinoids can occur while the health of bees is being sustained. It is clear from scientific literature and from the recent reviews by U.S. Department of Agriculture (USDA) and the Environmental Protection Agency (EPA) that there is no single cause for over wintering losses. The 2013 report by USDA and EPA reviewing the science related to bee health concluded that a number of factors including Varroa Mite, habitat quality, poor nutrition and exposure to pesticides affect bee health. While there is disagreement among various groups on how they would rank the importance of these factors, it seems clear that the impact of the Varroa Mite would rank near or at the top for most stakeholder groups. The fundamental premise of the discussion on bee health is the losses due to over wintering, Colony Collapse Disorder, pest and disease and impacts from pesticide exposure are reducing bee and hive numbers in dramatic ways. In fact, according to National Agricultural Statistical Service (NASS) data published in the annual Honey Report, there has been a low rate of variability in the number of colonies over the last 20 years. During that time period the variation between the largest and the smallest number of colonies has been no more than 18 percent. During that time period colony numbers have hovered around 2.5 million and did not exceed that number by more than 240,000 hives nor been more than 200,000 hives below that number. Importantly in every year since 2012, colony numbers have exceeded 2.5 million. Given the importance of pollinators to agriculture these stable colony numbers do not suggest we should ignore or not study bee health issues. But it should allow for a thoughtful approach to these issues that is holistic and focused on cooperation with agriculture - not a rush to judgment on important crop protection products that have a history of safe use. Potato growers do not depend on the services of pollinators to produce a potato crop but they understand and appreciate the importance of healthy bee populations to agriculture, to bee keepers and to society. Potatoes are not forage favored by bees and other pollinators. The use of Imidacloprid and other neonicotinoids on potatoes at any stage of the growing season is unlikely to expose pollinators to this or other classes of chemistry. In spite of this fact EPA has proposed changes in the Federal Register to the label requirements for applications to potatoes and other crops to "Mitigate Exposure to Bees from Acutely Toxic Pesticides." The final Risk Assessment used in the Registration Review of Imidacloprid should fully acknowledge the unique relationship of potatoes and pollinators. Potato growers utilize Imidacloprid as an integral part of their Integrated Pest Management Plans for their potato crop and for their rotational crops. This product provides the opportunity to target specific pests and reduce any impacts on beneficial insects. The loss of Imidacloprid and other neonicotinoids would reduce the effectiveness of IPM programs ad would increase the use of other broad spectrum crop protection products. Growers have collaborated on state-level Managed Pollinator Protection Plans that use best managemen…

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Mar 15, 2016· Comment submitted by Edward M. Ruckert, Counsel, McDermott Will & Emery on behalf of the National Potato Council (NPC)· EPA-HQ-OPP-2008-0844-0172

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

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Mar 19, 2009· Comment submitted by John Keeling, National Potato Council· EPA-HQ-OPP-2008-0844-0103

March 17, 2009 Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P) Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460-0001 Re:EPA–HQ–OPP–2008-0844 Dear Sir or Madam: The National Potato Council (NPC) welcomes the opportunity to comment on the registration review process for Imidacloprid. We are responding to your request for comments published in the Federal Register (Vol. 73, No. 243), dated December 17, 2008 [EPA–HQ–OPP–2008-0662; FRL–8391–7]. The NPC is the only trade association representing commercial growers in 50 states. Our growers produce both seed potatoes and potatoes for consumption in a variety of forms. Annual production is estimated at 437,888,000 cwt with a farm value of $3.2 billion and total value is substantially increased through processing. The potato crop clearly has a positive impact on the U.S. economy. Imidacloprid has been used on potatoes for 14 years in the United States. During that period it has become the most widely used insecticide on potatoes. The primary insect pest targets for imidacloprid are Colorado potato beetle and green peach aphid. This product is also used against less widely occurring pests such as beet leafhopper and potato leafhopper. In some regions of the United States, the majority of potato acres receive an application of imidacloprid during the growing season. Growers use the products at planting as a seed treatment or as an in furrow treatment or the product is applied during the growing season. Imidacloprid is highly effective, consistent in its efficacy and has a relatively long period of residual control (80 to 100 days). No other insecticide which can be applied at planting has a longer period of residual control. The product is selective and while it is effective against important insect pests it has a relatively low impact on beneficial organisms. This trait has made the product a cornerstone of Integrated Pest Management (IPM) programs. Imidacloprid is a relatively low cost product. The lower cost of the product has provided additional economic benefits to the grower. While the availability of other products in the same class of chemistry and the development of some resistance in Colorado potato beetle in some states has reduced the overall value of the insecticide to the potato industry, it is still the most widely used product on potatoes for insects and is considered the most economically important insecticide on potatoes. NPC looks forward to the opportunity to provide additional comments to the Agency as the process of registration review for Imidacloprid continues. Imidacloprid is a product that provides significant benefits to potato growers. Therefore, NPC is willing to attempt to obtain any additional information needed by the Agency on use of Imidacloprid on potatoes. Sincerely, John Keeling Executive Vice President and CEO

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Abstract

For further information contact: Matthew Khan at khan.matthew@epa.gov or neonicotinoidinquiries@epa.gov

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Co-filers (132)

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