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| ![](m     | ## State of Utah                                         |
| edia/imag |                                                          |
| e1.png){w | DEPARTMENT OF NATURAL RESOURCES                          |
| idth="0.7 |                                                          |
| 083333333 | DIVISION OF FORESTRY, FIRE AND STATE LANDS               |
| 333334in" |                                                          |
| h         | 1594 West North Temple, Suite 3520                       |
| eight="0. |                                                          |
| 65625in"} | PO Box 145703                                            |
|           |                                                          |
| #         | Salt Lake City, Utah 84114-5703                          |
| ## Olene  |                                                          |
| S. Walker | 801-538-5555                                             |
|           |                                                          |
| Governor  | 801-533-4111 (Fax)                                       |
|           |                                                          |
| ##        |                                                          |
| # Robert  |                                                          |
| L. Morgan |                                                          |
|           |                                                          |
| Executive |                                                          |
| Director  |                                                          |
|           |                                                          |
| ##        |                                                          |
| # A. Joel |                                                          |
|  Frandsen |                                                          |
|           |                                                          |
| State     |                                                          |
| Forester  |                                                          |
| /Director |                                                          |
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November 13, 2023

In Utah, the largest concern for private forest landowners is bark
beetle induced mortality. Utah forests are currently under attack from
several species of western bark beetles.

I often suggest silvicultural treatments for long-term management of
bark beetles. This type of treatment is frequently not acceptable for
most private landowners. When silvicultural treatments do meet landowner
objectives, it is exceptionally difficult for private landowners to
contract with a logger or complete treatments in a timely manner. In
addition, silvicultural management is generally not effective on a small
scale or during outbreak situations. Chemical preventative treatment, in
the short-term to protect high value trees, is repeatedly the only
option for the private forest landowner.

Chemical treatments for high value trees are expensive, and most private
landowners consider all of the trees on their land as high value. Since
it is cost prohibitive to treat all trees, it is with a heavy heart that
they choose which trees to treat. The emotional attachment landowners
have for their trees and the hope that they can be saved inevitably
compel landowners to place a lot of confidence in chemical treatments,
therefore, they must be highly effective.

The application of a chemical is the largest cost for treatment. Some
chemicals such as pyrethroids\--get adequate results and may be less
expensive initially, but are effective for only one year. Carbaryl,
applied at a 2% active ingredient solution provides very good protection
for about two years. When you include application costs, carbaryl is the
only chemical that currently meets the high efficacy needs at the lowest
overall cost.

It is my understanding that the broad "bee" statement for the
re-registration of carbaryl would eliminate the use of this product in a
forest setting. At this time, the loss of carbaryl as a protective
treatment would be a considerable disadvantage to the non-industrial
private forest landowner.

Colleen Keyes

Forest Health Coordinator

Utah Division of Forestry, Fire and State Lands

1594 W. North Temple, Suite 3520

Salt Lake City, UT 84114-5703

\(801\) 538-5211

colleenkeyes@utah.gov