Pesticides; Emergency Exemption Process Revisions Pilot and Request for Comment

The Northwest Horticultural Council (NHC) represents over 4,000 fruit growers, packers and shippers in the states of Idaho, Oregon and Washington. We support the changes proposed for the emergency exemption process and wish to offer comments regarding the proposed resistance management exemptions. We support the agency in its attempt to provide resistance management exemptions while recognizing that the criteria for documentation of resistance cannot be tightly codified for all crop/pest combinations. The questions posed in VI.B.4 of the Federal Register notice are important in assessing the degree of resistance to a given chemical/class of chemicals present in a population. The NHC hopes that the agency gains comments from a cross-section of resistance management researchers who can provide system-specific responses to those concerns. We wish to encourage the agency to consider creating a broader approach, particularly in those situations where significant resistance has already developed or in crop/pest situations with a history of resistance development. In those situations, the agency is encouraged to consider granting emergency exemptions to at least two alternatives that can be used in some rotational pattern to avoid the quick onset of resistance to a single effective product which becomes heavily used. This approach was once used for pear psylla control in pears in the Pacific Northwest, but only after each registrant agreed to restrict their product to a single application per season and two applications were needed for control. This single application restriction is not possible or desirable in most situations. Any new emergency exemption scheme, used as part of resistance management strategies, should address the possibility of granting the use of more than one active ingredient. Thank you, in advance, for your thoughtful consideration of our industry's views. Michael J. Willett Northwest Horticultural Council 509/453-319