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> Number range CHAPTER**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY**
>
> ­­­WASHINGTON D.C., 20460
>
> ­­
>
> May 15, 2006
>
> Number range CHAPTEROFFICE OF
>
> PREVENTION, PESTICIDES AND TOXIC SUBSTANCES

**[MEMORANDUM]{.underline}**

**SUBJECT:** Preliminary Alternatives Analysis for Aldicarb on Cotton
(DP 299886)

**FROM:** Angel Chiri, Entomologist

> William L. Gross, Jr., Entomologist

Biological Analysis Branch

Biological and Economic Analysis Division (7503C)

> Derek Berwald, Economist

Economic Analysis Branch

Biological and Economic Analysis Division (7503C)

**THRU:** Arnet Jones, Chief

Biological Analysis Branch

> Timothy Kiely, Acting Chief

Economic Analysis Branch

Biological and Economic Analysis Division (7503C)

**TO:** Sherrie Kinard, Chemical Review Manager

Robert McNally, Chief

Special Review Branch

Special Review and Reregistration Division

**Peer Review Panel: April 26, 2006**

**[Summary]{.smallcaps}**

Aldicarb is a systemic carbamate pesticide used on cotton primarily for
control of thrips. As part of the risk-benefit analysis for
reregistration, BEAD conducted an analysis of possible alternatives to
aldicarb used on cotton in the major cotton growing areas. There appear
to be several alternatives to aldicarb for control of thrips. We
estimate the costs of alternative chemicals for thrip control to be from
\$2 -- 10 per acre per year, which is less than the cost of aldicarb, at
about \$14 per acre. However, aldicarb also provides control of several
other cotton pests, and it provides protection for a longer time than
any of the alternatives. Because of its long residual activity, in many
cases growers can apply one treatment of aldicarb, rather than multiple
treatments of other chemicals for equivalent control. As a result, the
cost of controlling thrips will be higher if alternatives must be used.

**[Background]{.smallcaps}**

As part of the Reregistration Eligibility Decision (RED) process, BEAD
conducted an analysis of potential alternatives for aldicarb. Aldicarb
(Temik® 15G) is a systemic carbamate pesticide used to manage several
insects, mites, and nematodes, but its primary use on cotton is to
control thrips. Agency risk assessments have raised concerns about acute
and chronic exposure for terrestrial and aquatic organisms.

**[Analysis]{.smallcaps}**

**Crop Production**

Cotton is a major crop in the United States, with a total value of
production averaging over \$4.5 billion per year (see Table 1). The
primary growing region for upland cotton (*Gossypium hirsutum*) is from
Texas in the west, throughout the southeast to the Atlantic Coast,
extending as far north as Kansas and Missouri, although it is also grown
in California and Arizona. Pima cotton is a more valuable cotton, with
longer fibers. Pima cotton requires a longer growing season than upland
cotton; it is grown in California, Texas, Arizona, and New Mexico.
Depending on geography, climate, and cultural practices, cotton may be
planted as early as February through June and is generally harvested
September through December.

Table 1 shows the area harvested, production, and the value of
production for both types of cotton, averaged over the years 2001 --
2005. Texas is the largest producer of cotton, both in terms of acreage
and value. California has the second largest value of production,
although the acreage is much lower than 4 other states. The high value
of production in California reflects higher yields than other states, as
well as higher value cotton grown.

+-----------------+-----------------+--------------+------------------+
| Table 1. All    |                 |              |                  |
| Cotton Area     |                 |              |                  |
| Harvested,      |                 |              |                  |
| Production, and |                 |              |                  |
| Value: 2001 -   |                 |              |                  |
| 2005 Average    |                 |              |                  |
+-----------------+-----------------+--------------+------------------+
|                 | Area Harvested  | Production   | Value of         |
|                 |                 |              | Production       |
+-----------------+-----------------+--------------+------------------+
|                 | (1,000 Acres)   | (1,000       | (1,000 Dollars)  |
|                 |                 | Bales^1^)    |                  |
+-----------------+-----------------+--------------+------------------+
| Texas           | 4,810           | 5,955        | 1,221,090        |
+-----------------+-----------------+--------------+------------------+
| Georgia         | 1,324           | 1,971        | 431,468          |
+-----------------+-----------------+--------------+------------------+
| Mississippi     | 1,228           | 2,191        | 451,680          |
+-----------------+-----------------+--------------+------------------+
| Arkansas        | 974             | 1,917        | 410,207          |
+-----------------+-----------------+--------------+------------------+
| North Carolina  | 838             | 1,261        | 267,356          |
+-----------------+-----------------+--------------+------------------+
| California      | 734             | 2,088        | 677,228          |
+-----------------+-----------------+--------------+------------------+
| Louisiana       | 590             | 961          | 204,751          |
+-----------------+-----------------+--------------+------------------+
| Tennessee       | 567             | 958          | 201,810          |
+-----------------+-----------------+--------------+------------------+
| Alabama         | 548             | 795          | 167,303          |
+-----------------+-----------------+--------------+------------------+
| Missouri        | 395             | 744          | 156,329          |
+-----------------+-----------------+--------------+------------------+
| Arizona         | 242             | 649          | 148,033          |
+-----------------+-----------------+--------------+------------------+
| South Carolina  | 239             | 338          | 73,504           |
+-----------------+-----------------+--------------+------------------+
| Oklahoma        | 195             | 258          | 54,325           |
+-----------------+-----------------+--------------+------------------+
| Florida         | 101             | 122          | 27,058           |
+-----------------+-----------------+--------------+------------------+
| Virginia        | 92              | 152          | 30,906           |
+-----------------+-----------------+--------------+------------------+
| Kansas          | 66              | 71           | 15,841           |
+-----------------+-----------------+--------------+------------------+
| New Mexico      | 62              | 114          | 29,828           |
+-----------------+-----------------+--------------+------------------+
|                 |                 |              |                  |
+-----------------+-----------------+--------------+------------------+
| United States   | 13,003          | 20,547       | 4,568,718        |
+-----------------+-----------------+--------------+------------------+
| Source: United  |                 |              |                  |
| States          |                 |              |                  |
| Department of   |                 |              |                  |
| Agriculture,    |                 |              |                  |
| National        |                 |              |                  |
| Agricultural    |                 |              |                  |
| Statistics      |                 |              |                  |
| Service: *Crop  |                 |              |                  |
| Production 2003 |                 |              |                  |
| Summary, Crop   |                 |              |                  |
| Production 2005 |                 |              |                  |
| Summary, Crop   |                 |              |                  |
| Values 2003     |                 |              |                  |
| Summary, Crop   |                 |              |                  |
| Values 2005     |                 |              |                  |
| Summary.*       |                 |              |                  |
|                 |                 |              |                  |
| ^1^ A standard  |                 |              |                  |
| bale weighs 480 |                 |              |                  |
| pounds.         |                 |              |                  |
+-----------------+-----------------+--------------+------------------+

**Use and Usage of Aldicarb on Cotton**

Aldicarb is a systemic and contact carbamate insecticide and nematicide.
TEMIK^®^ brand 15G aldicarb is a restricted use pesticide which is used
on cotton primarily for control of thrips, although it also controls
other insect pests, such as as mites. Aldicarb is applied at planting,
in the furrow with the cotton seed, or it can be side-dressed to planted
cotton, 8 inches from the plants, two or three inches deep. Although
Texas is the largest producer of cotton, it uses less aldicarb, both in
terms of active ingredient applied per acre, and the percent of the crop
treated than most other states. Most of the Texas cotton acres are
located in the High Plains and Rolling Plains areas of the state that do
not experience a lot of thrips activity in seedling cotton.

Table 2 shows the average use of aldicarb on cotton for each state for
which NASS reports data, from 1991 -- 2003. The information in Table 2
should be viewed with caution, because not every state is sampled every
year, and if the data quality is low, results are not reported for a
state in a given year. For example, data on aldicarb use for Texas are
reported 12 times over the period 1999 -- 2003, while data for South
Carolina were reported only for 2003 and 2001. Despite these issues, the
data from USDA NASS are the best publicly available data. The table
shows that aldicarb is widely applied to cotton, and it is used in all
of the large cotton growing states. Use of aldicarb on cotton has been
increasing over time as shown in Figure 1. Most of the increase occurred
in the early 1990s; since the mid-90s, use has been highly variable,
without a clear trend.

  -------------------------------------- ---------------- -------------- ----------------
  Table 2: Aldicarb Use on Cotton,                                       
  1991 - 2003 Average                                                    

  State/Area                             Active           Percent        Application Rate
                                         Ingredient       Acreage        (pounds per
                                         Applied          Treated        acre)
                                         (thousand pounds                
                                         per year)                       

  Georgia                                394              46             0.61

  Texas                                  278              11             0.46

  North Carolina                         268              47             0.69

  California                             261              24             1.27

  Mississippi                            200              27             0.61

  Alabama                                151              42             0.64

  Arkansas                               147              25             0.61

  South Carolina                         142              68             0.83

  Missouri                               121              48             0.65

  Louisiana                              101              26             0.50

  Tennessee                              54               18             0.58

  Arizona                                42               10             1.29

  Source: Calculated from USDA NASS                                      
  database, which can be queried here:                                   
  http://www.pestmanagement.info/nass/                                   

  Note: USDA NASS does not report data                                   
  for every state for every year. The                                    
  number of observations is the number                                   
  of years for which USDA NASS reports                                   
  use in a state.                                                        
  -------------------------------------- ---------------- -------------- ----------------

![](media/image2.wmf){width="6.493055555555555in"
height="4.440972222222222in"}

**Important Cotton Pests Controlled by Aldicarb**

Thrips are the primary target pest for aldicarb on cotton. Aldicarb has
historically been used to control thrips on very young or seedling
cotton. Thrips are very small insects with rasping and sucking mouth
parts that rasp the tissue of young cotton plants and feed on the
exudates. This damage causes silvering and stunting of the leaves in
young cotton, delayed maturity, and ultimately yield loss. Usually
thrips infestations occur during cool and wet springs. Aldicarb is
applied in granular form, usually at the same time as planting, and it
can also provide protection against nematodes. A systemic pesticide,
aldicarb is taken up by the plant, where it provides long term
protection against thrips, nematodes, and other early season pests.

**Alternatives for Aldicarb Use on Cotton to Control Thrips and
Nematodes**

If aldicarb were not available, growers would likely use a combination
of acephate, chlorpyrifos, dicrotophos or imidacloprid to control
thrips. Acephate, dicrotophos and imidacloprid are excellent
alternatives for thrips control. Acephate is probably the most feasible
and flexible. It can be applied at planting as a seed treatment and as a
planter box treatment. Phorate, methamidophos, disulfoton, chlorpyrifos
and esfenvalerate can also be used for thrips control. Like aldicarb,
many of the alternatives give incidental control of spider mites,
aphids, and lygus bugs. The determination of aldicarb alternatives and
related information is based on analyzing the information in the crop
profiles and pest management strategic plans from the cotton growing
states. These documents are listed in the references.

Table 3 shows the alternatives to aldicarb that have been identified for
insect control. The table also shows the current use on cotton, as well
as the average cost of the alternatives. As shown in Table 3, aldicarb
is more widely used than the proposed alternatives, both in terms of
pounds applied, and the percent of the cotton crop treated. The
alternatives to aldicarb are less expensive, ranging in cost from two to
ten dollars per acre. Because cotton growers have access to these
chemicals now, but choose not to replace aldicarb with a cheaper
alternative, we infer that there are agronomic benefits to using
aldicarb instead of the one of the alternatives. In particular,
advantages of aldicarb are a long period of effectiveness, and control
over multiple pests, including nematodes as well as insects. To get
equivalent control to aldicarb, a grower would likely have to combine
one or more of the alternatives listed for thrips control, possibly with
other chemicals to control secondary pests. The costs in Table 3 include
only chemical costs. Application costs are not included in the costs
shown in the table.

The costs of individual alternative chemicals for thrip control to be
from \$2 -- 10 per acre per year, which is less than the cost of
aldicarb, at about \$14 per acre. However, recall that growers will
likely have to use multiple chemicals to get the same level of control.
For comparison, average revenues for cotton are about \$350 per acre,
nationwide[^1]. Cotton, however, is also a high cost crop to grow, and
for many farmers cash returns from selling cotton do not cover the
direct cash outlays, although growers also receive government payments.

+-----------------------+-------------------+-------------+----------+
| Table 3: Alternatives |                   |             |          |
| to Aldicarb: Use on   |                   |             |          |
| Cotton (Nationwide),  |                   |             |          |
| 1999 - 2003 Average   |                   |             |          |
+-----------------------+-------------------+-------------+----------+
|                       | Use on Cotton     |             |          |
+-----------------------+-------------------+-------------+----------+
| Active Ingredient     | Active Ingredient | Percent     | Cost     |
|                       | Applied (thousand | Acreage     | (        |
|                       | pounds per year)  | Treated     | \$/Acre) |
+-----------------------+-------------------+-------------+----------+
| > Aldicarb            | 2,112             | 25          | 14       |
+-----------------------+-------------------+-------------+----------+
|                       |                   |             |          |
+-----------------------+-------------------+-------------+----------+
| Alternatives          |                   |             |          |
+-----------------------+-------------------+-------------+----------+
| > Acephate            | 1,679             | 16          | 5        |
+-----------------------+-------------------+-------------+----------+
| > Dicrotophos         | 618               | 12          | 2        |
+-----------------------+-------------------+-------------+----------+
| > Imidacloprid        | 17                | 3           | 10       |
+-----------------------+-------------------+-------------+----------+
| > Phorate             | 341               | 4           | 10       |
+-----------------------+-------------------+-------------+----------+
| > Methamidophos       | 35                | 1           | 4        |
+-----------------------+-------------------+-------------+----------+
| > Disulfoton          | 176               | 2           | 5        |
+-----------------------+-------------------+-------------+----------+
| > Chlorpyrifos        | 306               | 2           | 6        |
+-----------------------+-------------------+-------------+----------+
| > Esfenvalerate       | 6                 | 1           | 4        |
+-----------------------+-------------------+-------------+----------+
| Source: Calculated    |                   |             |          |
| from USDA NASS        |                   |             |          |
| database, which can   |                   |             |          |
| be queried here:      |                   |             |          |
| http://www.pestm      |                   |             |          |
| anagement.info/nass/, |                   |             |          |
| and EPA Proprietary   |                   |             |          |
| Data.                 |                   |             |          |
+-----------------------+-------------------+-------------+----------+

The conditions faced by individual growers are quite variable and
available data are limited, and therefore it is currently impossible to
provide a reasonable estimate of the cost of aldicarb alternatives that
is appropriate for all growers. Instead, we provide here two
illustrative scenarios for different production regions. These provide
examples of the combinations of chemicals growers in different regions
might need to replace aldicarb, along with estimates of the cost
impacts. In addition, the prices and yields vary widely across different
regions of the country, so a single scenario can be misleading.

The scenarios are shown in Table 4, with estimates provided for cotton
production in California, and the production area around the Mississippi
River. For each area, a baseline scenario is provided, to represent
current conditions, in which aldicarb is used. The cost of production
and price data used are from the USDA Economic Research Service
commodity cost and returns data sets (USDA-ERS(a)), which provide
regional estimates of revenues and costs. For Table 4, the cost of
production, prices, and yields, are averages for 2000 -- 2004. The cost
and return estimates available from the USDA are based on farm resource
regions[^2], rather than states. We use the cost and returns estimates
from the "Mississippi Portal" for the Mississippi River region and the
"Fruitful Rim" for California.

The costs for the individual chemicals, both for aldicarb and its
replacements, are from EPA proprietary data[^3]. For the Mississippi
River region, the pesticide costs are the averages of three states
(Mississippi, Louisiana, and Arkansas) for the same time period. Note
that the cost of chemicals can vary by region, even for the same
chemical. This is a result of different use patterns, such as the amount
of active ingredient applied, and different costs in different regions.

For the Mississippi River region, we assume that as an alternative to
aldicarb, growers will use an application of imidacloprid at planting,
followed by an application of acephate, and a later application of
dicrotophos. For California, the use of aldicarb is for control of a
complex of target pests, which include thrips, aphids, and mites. The
alternative regime is assumed to be an application of acephate at
planting, a treatment of chlorpyrifos, and a treatment of abamectin. In
both cases, we assume that the alternatives provide the same level of
control as aldicarb, and so we assume that there are no yield or quality
losses. The inclusion of abamectin in the alternative scenario may cause
this to be an upper bound estimate, because it is a very expensive
chemical, with a cost of about \$28 per acre in California cotton.

As shown in Table 4, we estimate that using alternatives to aldicarb
will cost cotton growers about \$2 per acre more in the Mississippi
River region. In California, we estimate the alternatives to aldicarb to
be about \$44 per acre. This high per acre cost is a result of including
abamectin for mite control, which costs about \$28 per acre. However,
even this high cost is only about twice the cost of aldicarb in
California, because the amount of aldicarb active ingredient applied is
higher in California than other areas, as shown in Table 2.

Also included in Table 4, but not the USDA cost and returns estimates,
are estimated government payments to cotton growers. To estimate the
government payments, we use information available from the United States
Department of Agriculture Economic Research Service (USDA ERS (b)).
Growers receive payments based on historical yields and acreage grown.
The base yield for the program is 93.5% of the 1998 -- 2001 average
yield. Because our estimates of the impacts are on a per acre basis, we
approximate that by multiplying the assumed yield in the table (which
varies by region) by 0.935. Growers receive payments on a maximum of 85%
of their base acreage. We approximate that by multiplying again by 0.85,
which gives us an approximate of the base acreage on a per acre basis.
The target price for upland cotton is \$0.724 per pound, and growers
also receive \$0.0667 per pound direct payments. To approximate these
payments, we multiply the cotton eligible for government payments by
\$0.0667 (to represent the direct payment) plus the difference between
\$0.724 and the average cotton price for the region (to represent the
difference between the target price and the market price). For example,
in California the government payments are estimated to be about
0.935\*0.85\*((0.724 -- 0.54) +0.0667)\*1,118 = \$223 per acre. We did
not estimate the revenue from the marketing loan program, because cotton
prices are close to the loan price.

+---------------------------+---+------+----------+---+---------+--------+
| Table 4. Gross Returns,   |   |      |          |   |         |        |
| Production Costs and Net  |   |      |          |   |         |        |
| Cash Returns for Aldicarb |   |      |          |   |         |        |
| Alternatives in Cotton.   |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
|                           |   | Mis  |          |   | Cal     |        |
|                           |   | siss |          |   | ifornia |        |
|                           |   | ippi |          |   |         |        |
|                           |   | R    |          |   |         |        |
|                           |   | iver |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
|                           |   | Base | Alt      |   | B       | Alter  |
|                           |   | line | ernative |   | aseline | native |
|                           |   |      | Scenario |   |         | Sc     |
|                           |   |      |          |   |         | enario |
+---------------------------+---+------+----------+---+---------+--------+
| Cotton Production         |   | 828  | 828      |   | 1,118   | 1,118  |
| (pounds/acre)             |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Cotton Price (\$/pound)   |   | \$   | \$0.50   |   | \$0.54  | \$0.54 |
|                           |   | 0.50 |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Cottonseed Production     |   | 1478 | 1,478    |   | 1,671   | 1,671  |
| (pounds/acre)             |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Cottonseed Price          |   | \$   | \$0.05   |   | \$0.07  | \$0.07 |
| (\$/pound)                |   | 0.05 |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Gross Returns (\$/acre)   |   | \    | \$486    |   | \$717   | \$717  |
|                           |   | $486 |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
|                           |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Pesticides                |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Aldicarb (\$/acre)        |   | \$12 |          |   | \$22    |        |
+---------------------------+---+------+----------+---+---------+--------+
| Alternative Chemicals\*   |   |      | \$14     |   |         | \$44   |
| (\$/acre)                 |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Percent Change            |   |      | 19.7%    |   |         | 100.7% |
+---------------------------+---+------+----------+---+---------+--------+
|                           |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Other Pesticide Costs     |   | \$81 | \$81     |   | \$66    | \$66   |
| (\$/acre)                 |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
|                           |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Other Direct Costs        |   | \    | \$265    |   | \$384   | \$384  |
| (\$/acre)                 |   | $265 |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
|                           |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Total Operating Costs     |   | \    | \$361    |   | \$472   | \$494  |
| (\$/acre)                 |   | $358 |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Estimated Government      |   | \    | \$190    |   | \$223   | \$223  |
| Payments\*\* (\$/acre)    |   | $190 |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Net Cash Returns          |   | \    | \$316    |   | \$468   | \$446  |
| (\$/acre)                 |   | $318 |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+
| Percent Change            |   |      | -0.7%    |   |         | -4.7%  |
+---------------------------+---+------+----------+---+---------+--------+
| Source: Crop cost and     |   |      |          |   |         |        |
| returns estimates from    |   |      |          |   |         |        |
| USDA ERS(a), EPA          |   |      |          |   |         |        |
| Proprietary Data.         |   |      |          |   |         |        |
|                           |   |      |          |   |         |        |
| Totals may differ from    |   |      |          |   |         |        |
| sum of components due to  |   |      |          |   |         |        |
| rounding.                 |   |      |          |   |         |        |
|                           |   |      |          |   |         |        |
| \*For the Mississippi     |   |      |          |   |         |        |
| River region, the         |   |      |          |   |         |        |
| alternative chemicals are |   |      |          |   |         |        |
| imidachloprid, acephate,  |   |      |          |   |         |        |
| and dicrotophos. For      |   |      |          |   |         |        |
| California, the           |   |      |          |   |         |        |
| alternatives chemicals    |   |      |          |   |         |        |
| are acephate,             |   |      |          |   |         |        |
| chlorpyrifos, and         |   |      |          |   |         |        |
| abamectin.                |   |      |          |   |         |        |
|                           |   |      |          |   |         |        |
| \*\*Government payments   |   |      |          |   |         |        |
| are estimated as          |   |      |          |   |         |        |
| 0.935\*0.85\*((0.724 --   |   |      |          |   |         |        |
| 0.50) +0.0667)\*828 =     |   |      |          |   |         |        |
| \$190 per acre for the    |   |      |          |   |         |        |
| Mississippi River region, |   |      |          |   |         |        |
| and 0.935\*0.85\*((0.724  |   |      |          |   |         |        |
| -- 0.54) +0.0667)\*1,118  |   |      |          |   |         |        |
| = \$223 per acre for      |   |      |          |   |         |        |
| California. See the text  |   |      |          |   |         |        |
| for an explanation.       |   |      |          |   |         |        |
+---------------------------+---+------+----------+---+---------+--------+

In our baseline scenarios, where aldicarb is used, returns to the grower
are estimated to be about \$318 per acre in the Mississippi River region
and \$468 per acre in California. Using the alternatives in place of
aldicarb results in an increase in total pesticide costs of about 3% in
the Mississippi River region, and almost 25% in California. The
additional costs will decrease net cash returns to growers, as well.
Because pesticide costs are only one part of the total costs, the change
in net cash returns will be smaller. Net cash returns decrease by about
1% in the Mississippi River region, and about 5% in California. These
figures include government payments to growers, and these payments are
independent of current cotton production. If we consider only the
revenue from cotton production and sales, the decrease in net cash
returns is roughly doubled, to about 2% for the Mississippi River
region, and about 9% for California.

**Uncertainties in the Analysis**

Assumptions about the lack of yield and quality changes with alternative
controls are based on the best professional judgment of BEAD analysts;
in-field experience may differ. The analysis also assumes that currently
available chemicals will be available in the future, and that market
conditions will not change dramatically.

Aldicarb has other advantages to the grower for which we do not estimate
dollar values, such as simplicity of management, and confidence in the
level of control in the face of unexpected infestation, and
cost-effectiveness when considering the full range of pests and duration
of control. Finally, BEAD's economic calculations focus on net cash
returns, which overstate grower income. This is an uncertainty inherent
in all of BEAD's economic assessments and is a result of the fact that
there is no way for BEAD to know with certainty all the fixed costs
growers face.

**References**

Pest Management Strategic Plan in California Cotton Production. 2002.

[http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site](http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National Site)

Pest Management Strategic Plan for Cotton in the Midsouth. 2003.

[http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site](http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National Site)

Stevenson, D.E. and M.A. Matocha. 2005. A Pest Management Strategic Plan
for Cotton

Production in Texas.

[http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National%20Site](http://www.ipmcenters.org/pmsp/pmsp_form.cfm?usdaregion=National Site)

United States Departmetent of Agriculture, Economic Research Service
(USDA ERS(a)). U.S. and Regional Cost and Return datasets. Available
here: <http://www.ers.usda.gov/Data/CostsAndReturns/testpick.htm>

United States Departmetent of Agriculture, Economic Research Service
(USDA ERS(b)). *The 2002 Farm Bill: Provisions and Economic
Implications*. Available here:
<http://www.ers.usda.gov/Features/FarmBill/>

# United States Department of Agriculture. *Crop Profile for Cotton in Alabama*. September, 2001. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/alcotton.html**](http://www.ipmcenters.org/cropprofiles/docs/alcotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton in Arizona*. August, 1999. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/Azcotton.html**](http://www.ipmcenters.org/cropprofiles/docs/Azcotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton in Arkansas*. August, 2000. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/Arcotton.html**](http://www.ipmcenters.org/cropprofiles/docs/Arcotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton in California*. January, 2002. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/CAcotton.html**](http://www.ipmcenters.org/cropprofiles/docs/CAcotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton in Louisiana*. August 2002. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/LAcotton.html**](http://www.ipmcenters.org/cropprofiles/docs/LAcotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton in Mississippi*. March, 2002. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/MScotton.html**](http://www.ipmcenters.org/cropprofiles/docs/MScotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton in Missouri*. August, 2000. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/mocotton.html**](http://www.ipmcenters.org/cropprofiles/docs/mocotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton in North Carolina*. June, 2005. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/nccotton.html**](http://www.ipmcenters.org/cropprofiles/docs/nccotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton (Gossypium hirsutum) in Tennessee*. January, 2005. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/tncotton.html**](http://www.ipmcenters.org/cropprofiles/docs/tncotton.html)

# United States Department of Agriculture. *Crop Profile for Cotton in Texas*. September, 1999. Available here: [**http://www.ipmcenters.org/cropprofiles/docs/txcotton.html**](http://www.ipmcenters.org/cropprofiles/docs/txcotton.html) 

# United States Department of Agriculture, National Agricultural Statistics Service (USDA NASS). Pest Management Database. The database can be queried here: http://www.pestmanagement.info/nass/app_usage.cfm

United States Department of Agriculture, National Agricultural
Statistics Service (USDA NASS). 2006a. Crop *Production 2005 Summary*,
available here:
[http://usda.mannlib.cornell.edu/reports/nassr/field/pcp-bban/cropan06.pdf](http://usda.mannlib.cornell.edu/reports/nassr/field/pcp-bban/cropan04.pdf)

United States Department of Agriculture, National Agricultural
Statistics Service (USDA NASS). 2005. *Crop Production -- Acreage --
Supplement*, available here:
http://usda.mannlib.cornell.edu/reports/nassr/field/pcp-bba/acrg0605.pdf

United States Department of Agriculture, National Agricultural
Statistics Service (USDA NASS). 2004a. Crop *Production 2003 Summary*,
available here:
<http://usda.mannlib.cornell.edu/reports/nassr/field/pcp-bban/cropan04.pdf>

United States Department of Agriculture, Agricultural Statistics Service
(USDA NASS). 2004b. Crop *Values 2003 Summary*, available here:
<http://usda.mannlib.cornell.edu/reports/nassr/price/zcv-bb/cpvl0206.pdf>

United States Department of Agriculture, Agricultural Statistics Service
(USDA NASS). 2006b. Crop *Values 2005 Summary*, available here:
http://usda.mannlib.cornell.edu/reports/nassr/price/zcv-bb/cpvl0204.pdf

# Texas Cooperative Extension Service (2004). Suggested Insecticides for Managing Cotton Insects in the High Plains, Rolling Plains and Trans Pecos Areas of Texas.

# 

[^1]: This figure was calculated from Table 1. The numbers vary by
    state, with high revenues in California of over \$900 per acre), to
    low revenues in Kansas of under \$250 per acre.

[^2]: A description of the farm resource regions can be found here:
    <http://www.ers.usda.gov/Briefing/ARMS/resourceregions/resourceregions.htm>

[^3]: EPA proprietary data are data on pesticide use purchased from
    private sector firms