# WYOM ING WEED AND PEST COUNCIL
(WWPC)
GOVERNOR, Matt Mead PRESIDENT, John Watson

__________________________________________________________________________________________ 6607 Campstool Road

- Cheyenne, WY 82002

- 0100

- (307) 777

- 6585 or 1195 South Guernsey R oad

– Wheatland, WY 82201

_____________________________________________________________________________________________________________________________ __________ Executive Directors
Slade Franklin State Coordinator, Cheyenne

Jim Cotterman Secretary

, Wh eatland Walt Hartung Area 1, Cody

Quade Schmelzle Area 2, Gillette Gail Mahnke Area 3, Lusk

Adrian Hunolt Area 4, Daniel Randy Laughter Area 5, Green River

Lindsay Wheat , Treasurer Area 6, Laramie



### January 27, 2014

Wyoming Department of Agriculture Attn: Polly Cross

– Tech. Services Asst. Manager 6607 Campstool Road Cheyenne, WY 82002

Mrs. Cross,

On behalf the Wyoming Weed and Pest Council, I would like to request the Wyoming Department of Agr iculture to seek an approval of a Section 18 label for the use of Dimilin to control grasshoppers in alfalfa. The twenty

- three Weed and Pest Control Districts in the state work diligently in assisting private, state and federal land managers in controllin g grasshoppers on their respective grounds. This Section 18 label for Dimilin has historically been an important tool for them in succeeding with their control

programs.

In Wyoming, grasshoppers have been a significant issue over the last three years. In 2010 and 2011, the state experienced higher than average hatches in most parts of the state. Unmanaged, they would have had a significant impact on the ecological health of rangeland and croplands both, not to mention a significant economical impact o n the agricultural community. Through the use of insecticides, mainly Dimilin, the Weed and Pest Control Districts were able to mitigate their impacts and save the agriculture community from losses estimated near $11 million dollars for 2010. A key to th at success was the Section 18 label for the use of Dimilin on alfalfa. Alfalfa proved to be a major hatching area for the grasshoppers, and Dimilin was the only insecticide available that would allow the Districts to mitigate the issue BEFORE the grasshop pers could significantly damage the alfalfa field.

Although we are not expecting grasshopper outbreaks even near the 2010 and 2011 levels, there are several areas where we expect higher than normal hatches to occur. Some of these areas will have
alfalf a fields within them. The approval of this Section 18 label will help the Weed and Pest Control Districts to prepare and implement management programs that will mitigate the impacts from any
outbreaks.

Sincerely,

John Watson
PresidentJOB/C 544 Chemtura Corporation
199 Benson Road Middlebury, CT 0 6749

203

- 573

- 2 454 tel



### February 14 , 201 4

Wyoming Dept. of Agriculture
Technical Services 2219 Carey Avenue Cheyenne, Wyoming 82002

- 0100

Att ention: Polly Cross, Assistant Manager

Subject: L et ter of Support for Emergency Exemption, Section 18
For Dimilin® 2L on Alfalf a in Wyoming

Dear Ms. Cross,

Chemtura Corporation supports the State of Wyoming Section 18 application for the use of Dimilin 2L, EPA Reg. No. 400

- 461, on alfalfa h ay and mixed grass/alfalfa hay for control of grasshoppers and Mormon crickets

. Chemtu ra agrees to supply commercially ready product via our normal channels of trade.

We would appreciate it if you would s e nd us a copy of all EPA correspondence
on this sub j ect to Caroline Maselli at the above address. Should you have any quest i ons, pleas e call Caroline at 203

- 573

- 24 49 or e

- mail c aroline.maselli@chemtura.com

.

Sincerely,

Chemtura Corporation

Allen R. Blem Product Registration Mgr., N orth A mericaDIMILIN® is a Registered Trademark of Chemtura Corporation, 199 Benson Road, Middlebury, CT 06749

All applicable directions, restrictions, and precautions on the registered product label for Dimilin 2L (400-461) are to be followed. These Use Directions must be in the possession of the user at the time of the pesticide application. 003 

### It is a violation of Federal law to use this product in a manner inconsistent with its labeling.



### FOR CONTROL OF GRASSHOPPERS AND MORMON CRICKETS IN ALFALFA AND MIXED GRASS/ALFALFA HAY

SITES AND ACREAGE TO BE TREATED:



## ALFALFA AND MIXED GRASS/ALFALFA HAY

GRASSHOPPERS AND MORMON CRICKETS: For optimum results, apply DIMILIN 2L when grasshoppers/Mormon crickets have reached the 2 nd to 3 rd instar stage of development. DIMILIN will not effectively control grasshoppers and Mormon crickets once they reach the adult st age.

Do not exceed 2 fl. oz. per cutting or 4 fl. oz per acre per year. Do not apply closer than 14 days prior to harvest. Do not apply DIMILIN directly to or allow to drift to water or wetlands. When disposing of equipment wash water or rinsate, do not contaminate water. Do not plant food or feed crops in DIMILIN treated soils within 1 month following last application, unless DIMILIN is authorize d for use on these crops. Do not enter or allow workers into treated area during the restricted entry interval (REI) of 12 hours. Do not apply within 25 feet by ground or within 150 feet by air of bodies of water such as lakes, reservoirs, rivers, permanent streams, natural ponds, marshes or estuaries. All applications must include a 25 foot buffer vegetative strip within the buffer zone to decrease runoff

. 

## SECTION 18 EMERGENCY EXEMPTION FOR ALFALFA AND MIXED GRASS/ALFALFA HAY
FOR USE ONLY WITHIN THE STATE OF WYOMING



# RESTRICTED USE PESTICIDE
Due to toxicity to aquatic invertebrate animals. For retail sale to and use only by Certified Applicators, or persons under their direct supervision, and only for those uses covered by the Certified Applicator's certification. 

# Dimilin ® 

# 2L

INSECT GROWTH REGULATOR SUSPENSION CONCENTRATE

Crops Pests Application Rate (fl oz/acre) Application Timing

Alfalfa and Mixed Grass/Alfalfa Hay Grasshopper 0.75 - 2 Use 1 application on early instar (majority in the 2nd through 4th instar nymphal stages). For best results use high rate on heavy infestations or dense foliage.

Mormon cricket May be used in a RAATs (Reduced Area and Agent Treatment) application on early instars. A RAATs application is an IPM strategy that takes advantage of grasshopper movement and conservation biological control to allow Dimilin 2L to be applied on a reduced treated area and at reduced rates, while sustaining acceptable control. The rate range to use per acre and amount of area treated will depend on grasshopper/ Mormon cricket age, plant canopy and topography. Skip up to 50% of the infested area (every other swath) and use the lower rate under uniform topography with early instar ages and sparse vegetation. If the majority of the population is late instars, vegetation is dense, terrain is considered rough, and conditions are hot during treatment, then the coverage and rate of DIMILIN 2L should be increased up to a blanket (100%) coverage with 1 fl oz per acre. Applications may be made after each cutting of alfalfa. Do not apply more than three applications per year.
DIMILIN will not effectively control grasshoppers and Mormon crickets once they reach the adult stage
Aerial application: For low/high volume application, apply in 2 to 10 gallons of water per acre. For ULV application, apply in a minimum of 12 fl. o zs. total volume per acre. Ground application: For low/high volume application, apply in 2 to 30 gallons of water per acre. For ULV application, apply in a minimum of 12 fl. o zs. total volume per acre. Regardless of application type, total spray volume used must ensure thorough coverage of the target crop. Aerial and ULV spray mixtures should include an evaporation/drift retardant product at use rates prescribed on the specific product label, particularly when conditio ns are favorable for water evaporation (e.g., high air temperature and/or low humidity). When using oil type evaporation/drift retardant products, b e sure to maintain a ratio of at least 2 parts water to 1 part oil. For low volume and ULV applications, make sure that the spray mixture in the boom contains the correct concentration of Dimilin 2L before application begins, and be sure that good agitation is maintained throughout mixing and application.Alexandre V. Latchininsky, Ph.D

. , Chair Clint Burfitt

, Vice Chair Paul E. Blom, Sec./Treas.

University of Wyoming Utah Dept. of Agriculture Oregon Department of Agriculture Department 3354

– Ecosystem Science and Management Box 146500 30588 Feedville Road 1000 E. University Avenue Salt Lake City, Utah 84114

- 6500 Hermiston OR 97838 Laramie, WY 82071

- 2000, USA Phone 801

- 538

- 7184 45.80570

- 119.29911
Phone 307

- 766

- 2298 Fax

- 801

- 538

- 7189 Work 503

- 508

- 1253

Fax 307

- 766

- 6403 cburfitt@utah.gov Fax 206

- 666

- 3981 latchini@uwyo.edu pblom@oda.state.or.us

, blom.paul.e@gmail.com 

# NATIONAL GRASSHOPPER MANAGEMENT BOARD

Judy Ball Chemtura Corporation
199 Benson Road Middlebury, CT 06749 USA
Tel 203

- 573

- 2449

, Fax 203

- 573

- 3394 judy.ball@chemtura.com ; www.chemtura.com
31 January 2014
Dear Dr. Ball

As Chemtura AgroSolutions is aware, grasshoppers and Mormon cricket outbreaks pose a significant threat to the agricultural and economic stability of many western states. To help combat these outbreaks personnel from USDA

APHIS

- PPQ, State Departments of Agricultur e and county officials conduct small to large

- scale spray programs to assist farmers, ranchers an d other land managers in protecting their agricultural resources as these outbreaks occur

. Currently

, the most widely accepted “ Best Management Practices” i n several states for these programs is applying Dimilin ® 25W (active ingredient: Diflubenzuron) with a Reduced Agent and A rea Treatments (RAATs) strategy . Dimilin ® 25W has proven itself as the insecticide of choice based on its mode of action, eff icacy and minimal impacts on non

- target beneficial insects such as the honeybee.

Unfortunately, the current Dimilin ® 25W label has its drawbacks. Although the typical state and federal grasshopper management program targets rangeland protection , large scale management blocks often have smaller areas of row crop s and other production agriculture included within the treatment boundaries . Under FIFRA, all pesticid es must successfully complete an assessment process with the Environmental Protection Agency for potential residues that might
enter in the food chain. Currently Dimilin ® 25W is limited by label in its applicability to many crops. For most cases this is immaterial as most row crops do n ot provide the proper conditions for Dimilin ® 25W use. However, alfalfa and mixed grass/alfalfa hay does provide suitable and susceptible habitat that can be protected through the use of Difluben zuron at the proper grasshopper growth stage . This is wh y many western states have annually requested a Section 18 Emergency Exemption for Diflubenzuron use on alfalfa or mixed grass/alfalfa production. The Section 18 label has allowed program managers to create large contiguous spray blocks that are complimen tary to the use of Dimilin ® 25W and to a success ful grasshopper management program.
The National Grasshopper Management Board membership, consisting of grasshopper management professionals from Federal, State and County programs, is respectfully requestin g an update to the current status of registration for alfalfa or alfalfa/mixed grass on the Dimilin ® 25W Section 3 label. In the past five years, various members of the Board have been advised that the full registration of this use is forthcoming, yet man y states are still required to issue Section 18 labels

. . The Board is also concerned that in the future the EPA may not continue issuing the Section 18 label based on the broad interpretation of what “Emergency Conditions” are under the Secti on 18 process.
We look forward to an update that we may share with our membership.

Sincerely,



### Alexandre V. Latchini nsky , NGMB Chair