# Dave Barnekow, John Busacca, Nick Poletika Dow AgroSciences Indianapolis, IN 

# 1,3 - Dichloropropene - Consultation Biological Opinion on Endangered Salmonids September 19, 2011

# Objectives

 

## Provide information relevant to assessing the biological impact of 1,3 -

dichloropropene to areas sensitive to salmonids in California, Washington, Oregon and Idaho  

## Provide information about the value and use of TeloneTM products in California, Idaho, Oregon and Washington  

## Demonstrate the commitment of Dow AgroSciences to develop and implement effective Product Stewardship programs to minimize risk to the environment TMRegistered Trademark of Dow AgroSciences LLC

# Expected Outcomes

 

## Demonstrate that Telone products represent a negligible risk to salmonids or habitat that may impact salmonids when used according to the label  

## Provide an overview of how Telone products are used under commercial conditions in these states  

## Show that DAS is committed to stewarding our fumigant products aggressively to help ensure they are used appropriately

# Agenda

 

# Importance of fumigants in the economic production of high value crops  

# Broad Overview of 1,3 - Dichloropropene  

# Product Use Information  

# Exposure potential in ESUs

# What is a fumigant?
 

## A fumigant is a formulation {liquid (e.g. 1,3 - D) or gas (methyl bromide)} that quickly begins to volatilize when it is applied in the soil.  

## It moves through the soil air space as a gas to provide very high levels of control to soil borne pests such as nematodes, pathogens or weeds.  

## Dow AgroSciences (DAS) is the sole manufacturer of 1,3 - D in the US and all 1,3 - D used in the US is manufactured by DAS

# Overview: Key Attributes – 1,3 - D

 

## Highly effective fumigant to control all species of nematodes that affect production of many high value fruits, vegetables, nursery crops and ornamentals  

## Supported by a strong product stewardship program that requires training before purchase or use of the product  

## Critical Role in Sustainable Agriculture – High Value Crops  

## Mixtures with chloropicrin are the key alternative to methyl bromide as it is phased out Globally  

## Supported by a dedicated sales staff that provides strong technical advice

# Overview: Importance

 

## Most effective fumigant for control of nematodes  

## Key mixing partner for alternatives to methyl bromide  

## Essential management tool for economic production of many high value crops such as fruits and vegetables  

## No crop residues from pre - plant use

# Overview: Spectrum of Activity

Nematodes Controlled Burrowing Citrus Cyst Dagger Lance Needle Pin Reniform Ring Root knot Root lesion Spiral Sting Stubby root Insects controlled Symphylans (garden centipedes) Wireworms Diseases suppressed Rhizomania disease Fusarium wilt of cotton Verticillium wilt of mint

# Overview: Registration History

 

# Telone ® 

# First registered in 1960  

# Telone II registered in 1975  

# Special Review in 1987  

# Registration Eligibility Decision in 1998  

# Fumigant Cluster Assessment in 2005

® TM Trademark of Dow AgroSciences LLC Telone is a federally Restricted Use Pesticide. Always read and follow label directions.

# Product Information: Use Profile

 

# Formulations (liquid only)  

## 1,3 - Dichloropropene by itself  

### Telone II  

### Telone EC  

### Curfew  

### Cordon 

###  

## 1,3 - Dichloropropene plus chloropicrin  

### Telone C - 17  

### Telone C - 35  

### InLine 

###  

## Telone II is the most frequently used formulation in CA, ID, OR and WA

# Why Use a Soil fumigant?

 

## Nematodes , pathogens and weeds are soil borne organisms that cause significant economic losses to high value crops  

## Soil fumigants control one or more types of soil borne organisms and their use results in significant increases in yield and quality of the crop

# Damage Potential of Nematodes

 

## Estimates of economic losses associated with nematode damage are $77.7 billion annually  

## Global losses for some crops such as bananas, coffee, sugarcane and tobacco can be as high as 15 - 20%

# Characteristics of the Soil Fumigation Business

 

## Pre - plant fumigants are used primarily in high value fresh fruit and vegetable markets.  

## Use of a fumigant is essential to produce a sustainable, economically viable crop in major production areas.  

## Fumigation represents a significant investment in time, money and equipment for the grower.

# Characteristics of Soil Fumigation

 

## Pre - plant application  

## High rates of use  

## Gas distributes through the soil  

## High rate of initial control  

## Rapid dissipation  

## No residual control  

## Crop is planted after the fumigant dissipates from the soil  

## No residues in the crop

# Benefits of Soil Fumigation

 

## Yield: enables sustainable yields of high value fresh fruits and vegetables  

## Quality: produce high grade fresh produce  

## Productivity: Crops, especially permanent crops, produce fruit earlier and become productive sooner  

## Economics: enable production at economically viable costs  

## Quarantine: prevent distribution of soil borne pests between areas

# Fumigant Application Types

Raised beds - row Injection ~12” deep Beds mulched w/plastic Broadcast Injection 12 - 18” deep Usually no mulch

Raised beds - row Drip irrigation Beds mulched w/plastic

# Product Information: Use Profile Shank

 

## Primary use is as a pre - plant application by shank injection

 

### Shanks inject 1,3 - D 12 - 18 inches below the soil surface  

### Injection ‘trace’ is disrupted and sealed to retain fumigant in the soil  

### Applications are restricted to specific soil moisture and temperature conditions

# Product Information: Use Profile - Drip
 

## Drip applications through surface tarped or deep, buried, non - tarp  

## Products are applied pre - plant

# Product Information: Use Rates – Telone - II

Broadcast Application Rate Gal/Acre Lbs ai/Ac Mineral 9 - 12 90.9 - 121.2 Muck or peat 25 252.5 Mineral 9 - 12 90.9 - 121.2 Muck or peat 18 181.8 272.7 - 353.5 424.2 - 555.5 27 - 35 42 - 55 

### Crop Soil Type or Texture Vegetable Crops Field Crops Fruit and Nut Crops Nursery Crops Mineral Mineral

# Product Information: Use Rates – Telone - II

Label Rate Use Rate 1 (Lbs ai/Ac) (Lbs ai/Ac) 90.9 - 121.2 Crop Soil Type or Texture

1 Data based on 2009 California PUR. Only crops with 5 or more applications were included in the assessment 55 - 118 Mineral 90.9 - 121.2 insufficient data 101 - 353 insufficient data Vegetable Crops: incl Tomato, Carrot, Sweet potato, Potato, Cabbage, Pepper and Watermelon Field Crops Fruit and Nut Crops : incl Cherry, Prune, Orange, Walnut, Peach, Grape, Almond, Blueberry, Plum, Strawberry and Raspberry Mineral 272.7 - 353.5 Nursery Crops Mineral 424.2 - 555.5 Mineral

# Key Markets - California

Source: 2009 California PUR Data Crop Number of Applications Total Acres Treated with 1,3-D Average lbs ai/Ac Percent of 1,3-D Acres Treated Cummulative Percent of 1,3-D

Treated Acres 1 Strawberry 325 10,336 109 27.3 27.3 2 Sweet potato 185 4,374 98 11.6 38.9 3 Carrot 70 3,424 115 9.1 48.0 4 Soil Fumigation/ preplant 171 3,004 252 7.9 55.9 5 Almond 139 1,948 306 5.2 61.0 6 Tomato, processing 27 1,862 118 4.9 66.0 7 Potato 30 1,855 95 4.9 70.9 8 Walnut 74 1,219 328 3.2 74.1 9 Grape, wine 50 1,136 262 3.0 77.1 10 Pepper 33 1,095 77 2.9 80.0

# Key Markets - Idaho

Crop Percent of DAS Sales in Idaho (approximate) Average use rate Application Method Crop Rotation Interval Potato 80 Telone II @ 17 gpa Telone C-17 @ 27 gpa Broadcast 14-18" deep 3 - 4 years Telone II @ 15 gpa Telone C-17 @ 24 gpa; Broadcast 16 - 18" deep; Telone C-17 @ 18 gpa Row 12" deep 17 Onions 3 - 5 years

# Key Markets - Oregon

Crop Percent of DAS Sales in Oregon

(approximate) Average use rate Application Method Crop Rotation Interval Potato >90 Telone II @ 17 gpa Telone C-17 @ 27 gpa Broadcast 14-18" deep 3 - 4 years Carrots <5 Telone II @ 15 gpa Broadcast 16 - 18" deep 3 - 4 years Onions <3 Telone II @ 15 gpa Telone C-17 @ 24 gpa Broadcast 16 - 18" deep 3 - 5 years

# Key Markets - Washington

Crop Percent of DAS Sales in Washington (approximate) Average use rate Application Method Crop Rotation Interval Potato 80 Telone II @ 17 gpa Telone C-17 @ 27 gpa Broadcast 14-18" deep 3 - 4 years Carrots 8 - 10 Telone II @ 15 gpa Broadcast 16 - 18" deep 3 - 4 years Onions 8 - 10 Telone II @ 15 gpa Telone C-17 @ 24 gpa Broadcast 16 - 18" deep 3 - 5 years Tree and Vine < 3 Telone II @ 30gpta Strip (~1/3 of acre) 14-18" deep 10-20 years

# Potential Routes of Exposure of Salmonids to Pesticides Typical potential transport processes  

# Drift – not applicable to fumigants  

# Volatility with re - deposition  

# Generally area - wide for fumigants, therefore should be detected in general ambient monitoring programs, if present  

# Surface runoff  

# Spills

# How does DAS Mitigate Risk? Effective Product Stewardship programs can significantly reduce potential risk:

 

# Label requirements  

# Dedicated technical and sales staff  

# Mandatory training programs

# Product Stewardship – Label Requirements

 

## Environmental Hazards and Groundwater Advisory:

 

## Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark  

## Do not contaminate water when disposing of equipment rinsate .  

## Do not apply within 100 feet of any well used for potable water.  

## Where groundwater aquifers exist at a depth of 50 feet or less from the surface, do not apply this product where soils are Hydrologic Group A.

# Product Stewardship – Label Requirements

 

# Application Directions  

# Soil Conditions  

# Soil temperature  

# Soil moisture  

# Soil preparation  

# Placement of fumigant  

# Soil sealing requirements

# Product Stewardship – Label Requirements Equipment requirements to prevent spillage

 

### End - Row Spillage Control: The dispensing system must shut off the feed stream when chisels are raised out of the ground.  

### With all bulk and mini - bulk containers, Telone II CA must be transferred through connecting hoses, pipes, and/or couplings sufficiently tight to prevent workers or other persons from coming in contact with liquid Telone II CA.  

### All hoses, piping, and tanks used in connection with Telone II CA shall be of type appropriate for use under the pressure and vacuum conditions to be encountered.  

### Shut -

off devices must be installed on the exit end of all hoses and at all disconnect points to prevent leakage of Telone II CA product when the transfer is stopped and hose is removed or disconnected.  

### A dry coupler that will minimize pesticide leakage must be installed at the disconnect point.  

### The pressure in hoses used to move Telone II CA beyond a pump must not exceed the manufacturer’s maximum pressure specification.

# Product Stewardship

 

## Product Stewardship is a critical element in mitigating potential off -

target exposure from 1,3 - D  

## Multiple elements contribute to effective Stewardship  

## Dedicated sales and technical staff to train and support stakeholders and enforce use of our products  

## Labels  

### The label is the law  

### Required practices and safeguards 

###  

## Required training  

### All stakeholders must be trained as a condition of purchase and use

# Dedicated Sales and Technical Support

 

## The sales organization in the US is unique in that they are all specialists that support only 1,3 - D products .  

## Additional support is provided by local field scientists and a dedicated Global Technical Expert

# Product Stewardship – Training and Certification

 

### DAS trains/certifies all Dealers (i.e. ‘Train the Trainer’) and also helps train applicators.  

### Training programs all contain basic use, safety and application components and are tailored to meet the needs of local agronomic and application considerations.  

### DAS maintains a list of Certified Dealers and also a list of who has completed the training within the Dealership.  

### State certification is required to purchase 1,3 - D or 1,3 - D/CP.  

### Retraining is required to maintain certification .

# Examples of Stewardship Brochures

9/26/2011

# Product Stewardship – Storage

Pictures – Top: Bulk storage with concrete containment area Bottom: Temporary field storage tank in PNW • 

### All bulk sites are surrounded by a concrete containment area that has a capacity of 125% of the volume of material stored • Bulk sites are inspected every three years • Typical bulk site. All tanks in containment

# Product Stewardship – Transportation

Pictures: Top: DOT 407 compliant transport truck. All product is transported in DOT approved vessels. Bottom: Top of DOT 407 tank showing rollover and dome to protect contents in the event of an accident 

### • Telone is transported from bulk sites in trucks that meet or exceed DOT 407 safety and security requirements • DOT compliant vehicles meet collision and roll - over specifications and have self closing internal valves to minimize the potential of leaks

# Product Stewardship – Product Transfer

Pictures: Top: custom applicator suited up making a product transfer using dry disconnects Bottom: close - up of a dry disconnect fitting. • 

### Telone is transferred from storage containers to the application equipment via a closed system that prevents leaks or drips • Dry disconnects are used in all transfers to prevent spills or leaks

# Product Stewardship – Application

• 

### Everyone who purchases or applies Telone must be certified and trained annually • All Telone is applied by licensed, custom applicators in California • 70% of Telone is applied by licensed custom applicators in PNW Pictures Top: Telone pigs Bottom: Telone application rig with pigs, nitrogen tanks, injection shanks and soil sealing equipment

# Product Stewardship – Application

• Telone is typically applied 12 to 18” deep depending on the crop. • Various implements are used to thoroughly cover the chisel trace and seal the soil • Typical ripper shank. Product is placed at 16 to 20” below the soil surface. • Typical applicator. Ripper, followed by a disc followed by a culti - packer.

# Product Stewardship – Application

• Telone can also be applied through existing drip irrigation lines • Drip application is common for strawberries in California but is rarely used in the PNW • Specific equipment is required to monitor injection into irrigation lines and prevent backflow into water supply Pictures Top: Drip irrigation setup for experimental trials Bottom: Bed prepared and treated via drip irrigation

# Zero Detects in Surface Water Monitoring Data for cis - 1,3 - D and trans - 1,3 - D

Chinook Lower Columbia River (Threatened) 14 14 Chinook Puget Sound (Threatened) 270 270 Chinook Sacramento River Winter-run (Endangered) / Central Valley Spring-run (Threatened) 55 55 Chinook Upper Columbia River Spring-run (Endangered) 1 1 Chinook Upper Willamette River (Threatened) 27 27

Chum Columbia River (Threatened) 14 14 Chum Hood Canal Summer-run (Threatened) 2 2 Coho Lower Columbia River (Threatened) 14 14 Steelhead California Central Valley (Threatened) 55 55 Steelhead Lower Columbia River (Threatened) 14 14 Steelhead Middle Columbia River (Threatened) 3 3 Steelhead Puget Sound (Threatened) 270 270 Steelhead Upper Columbia River (Threatened) 1 1 Steelhead Upper Willamette River (Threatened) 27 27 USGS: National Water Quality Assessment Program (NAWQA) Data Warehouse: National Marine Fisheries Service (NMFS): Evolutionary Significant Units (ESU) boundaries Species ESU Name (Status) Number of Observations Number of NonDetects

Data Sources: State of Washington, Department of Ecology; Environmental Information Management

# Use Intensity in CA is Low in Relation to Application Rate< 0.005< 0.005< 0.005< 0.005

ESU 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30USE INTENSITY (pounds ai/A)

0.0 0.1 0.2 0.3 0.4 0.50.001 The Use Intensity calculation is the quotient of the average annual use and the ESU area in pounds per acre.

Number Species ESU Name (Status) 9 Chinook California Coastal (Threatened) 10 Chinook Sacramento River Winter - run (Endangered) / Central Valley Spring - run (Threatened) 14 Coho Southern Oregon & Northern California Coast (Threatened) 15 Coho Central California Coast (Endangered) 25 Steelhead Northern California (Threatened) 26 Steelhead California Central Valley (Threatened) 27 Steelhead Central California Coast (Threatened) 28 Steelhead South - Central California Coast (Threatened) 29 Steelhead Southern California (Endangered)

# Improved Land Use Information in Cropland Data Layer  

## In the biop finalized on 30 Jun 2011, NMFS used land cover information from NLCD 2001 to evaluate each a.i . for decline in conservation value of designated critical habitat.  

## Note, however, that 1,3 - D is not found in monitoring data, so the land cover data is useful primarily for describing the extent of the action.  

## DAS suggests that for agricultural uses of 1,3, - D, a better land cover database to use for this purpose is the NASS Cropland Data Layer (CDL) a 

## .  

## CDL can be used as a surrogate for actual usage in OR, WA, and ID.  

## DPR PUR is best information for actual usage in CA.  

## When comparing CDL data to NLCD, DAS recommends using the more recent 2006 NLCD product.

a http://www.nass.usda.gov/research/Cropland/SARS1a.htm

# Improved Land Use Information in Cropland Data Layer for Typical Uses in WA, OR, and ID

Number Species ESU Name (Status) 1 Chinook Puget Sound (Threatened) 2 Chinook Upper Columbia River Spring - run (Endangered) 3 Chinook Snake River Fall - run (Threatened) 4 Chinook Snake River Fall - run (Threatened) / Snake River Spring/Summer - run (Threatened) 5 Chinook Lower Columbia River (Threatened) 6 Chinook Upper Willamette River (Threatened) 7 Chinook Snake River Spring/Summer - run (Threatened) 8 Chinook Lower Columbia River (Threatened) / Upper Willamette River (Threatened) 9 Chinook California Coastal (Threatened) 10 Chinook Sacramento River Winter - run (Endangered) / Central Valley Spring - run (Threatened) 11 Chum Hood Canal Summer - run (Threatened) 12 Chum Columbia River (Threatened) 13 Coho Oregon Coast (Threatened) 14 Coho Southern Oregon & Northern California Coast (Threatened) 15 Coho Central California Coast (Endangered) 16 Coho Lower Columbia River (Threatened) 17 Sockeye Ozette Lake (Threatened) 18 Sockeye Snake River (Endangered) 19 Steelhead Puget Sound (Threatened) 20 Steelhead Upper Columbia River (Threatened) 21 Steelhead Middle Columbia River (Threatened) 22 Steelhead Snake River (Threatened) 23 Steelhead Lower Columbia River (Threatened) 24 Steelhead Upper Willamette River (Threatened) 25 Steelhead Northern California (Threatened) 26 Steelhead California Central Valley (Threatened) 27 Steelhead Central California Coast (Threatened) 28 Steelhead South - Central California Coast (Threatened) 29 Steelhead Southern California (Endangered) ESU 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24LAND COVER (% ESU)

0 10 20 30 40 NLCD 81+82 CDL 2009-2010 Mean*

* Sum of potato, onion, carrot, tree/vine for ESUs in WA, OR, and ID

# Summary 1,3 - D has negligible potential to impact salmonids or their environment because: 1. Application methods
 

## Shank application methods place the product 12 - 18 inches below the surface of the soil and cover it up preventing the possibility of surface runoff...or  

## Drip applications place the product into the soil under plastic mulch tarps using existing irrigation lines protect the

# Summary 1,3 - D has negligible potential to impact salmonids or their environment because: 2. Product Stewardship commitment of DAS  

## Dedicated, experienced, responsive sales and technical staff  

## Required annual training  

## Extensive support literature 

## 3. The label is the law  

## Detailed specific label use instructions and requirements  

## Specific equipment requirements

# Summary 1,3 - D has negligible potential to impact salmonids or their environment because: 4. 

## As a Result of the Label Defined Use Pattern  

## Surface Water Monitoring - USGS: National Water Quality Assessment Program (NAWQA) Data Warehouse: Yields

 

## No Detections of 1,3 - D in surface water

# Thank you for your kind attention Questions?