Aldicarb Registration Review

June 27, 2016 Office of Pesticide Programs (OPP) Environmental Protection Agency Docket Center (EPA/DC) Mail Code: 28221T 1200 Pennsylvania Ave., NW Washington, DC 20460-0001 Submitted electronically via http://www.regulations.gov RE:Aldicarb; Re-Registration Docket (Docket ID EPA-HQ-OPP-20125-0161) On behalf of the National Potato Council (NPC) and U.S. potato growers, thank you for accepting these comments pertaining to EPA's consideration of re-registration of Aldicarb. The NPC represents more than ninety percent of the commercial potato growers in the United States. Potato growers, along with the U.S. potato industry, firmly believe in the responsible and judicious use of crop protection tools as a way to protect the environment while providing the nutritional needs of consumers around the world. As the Agency is well aware, since 2005 the National Potato Council has provided extensive comments on the value of Aldicarb to potato growers. Those comments included concerns over the assumptions in the 2005 EFED risk assessment and over the lack of science to support the risk characterizations related to dietary risk in the 2006 HED Risk Reduction Documents. We are pleased that the Agency in subsequent reviews of petitions for registered uses of Aldicarb by Ag Logic LLC has reached decisions that more realistically characterize both risks and benefits of the product. It is our strong belief that Aldicarb can be used safely and effectively on potatoes. We hope that the re-registration process for the currently registered uses will create the opportunity for consideration of registration for use on potatoes. While the current Re-Registration Docket for Aldicarb is not related to reestablishing a registration for potatoes, the value of the product to growers of the currently registered products are quite similar to those of potatoes. For many years Aldicarb was an essential tool to potato growers around the country. Since 2011 growers have been forced to adapt to the loss of access to this product. Over that time period the loss of Aldicarb has forced growers to rely more heavily on other chemistries than is desirable. This has disrupted Integrated Pest Management (IPM) programs and increased the application of foliar products. Expanded use of foliar products increases the number of sprays and leads to expanded pest resistance for those products. For potato growers lack of access to Aldicarb is particularly challenging due to the products singular ability to control nematodes for a long time period when used as a pre-plant treatment. The extensive data on Aldicarb as originally submitted by Bayer and as currently submitted by Ag Logic LLC supports the safety and the benefits of the product. We look forward to working with the Agency as this data is reviewed to support use on currently registered products and in consideration of the restoration of previous uses for potatoes. Sincerely, John Keeling Executive Vice President and CEO National Potato Council