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### Aerial Pesticide Application Acre Estimates

The 2004 National Agricultural Aviation Association’s Pesticide Use Survey Report for Agricultural Aviation includes

charts, as shown on the pages below, that list the average and maximum number of acres treated per day by crop or

application target for the average aerial application business (see pages 23-25 of the report). This information shows that th e

average number of acres of an aerial mosquito application in a single day is 1,624 acres (see page 24 of the report). This is

250 percent greater than one threshold that was proposed for a pesticide applicator treating mosquitoes over land where a

water conveyance is present ( ≥ 640 acres) triggering an applicator to submit a notice of intent (NOI) to qualify for an NPDES

general permit.

NAAA has recommended to the EPA that decisi ons-makers be the entity responsible for NOI submission s, not for-hire

applicators, because of the differences in available resources and advanced knowledge. If EPA wants to set a realistic

threshold to alleviate overly burdensome NPDES compliance requirements for aerial application businesses it should take

into consideration that the majority of these businesses are small businesses and don’t have the manpower to devote a

significant amount of time to administrative work that will be required in obtaining water permits. The average aerial

application business has 2.2 aircraft (see page 7 of the report). It is safe to assume that approximately 29 percent of aerial

application businesses are single aircraft/single employee operations, based on the results from survey Question 5 “What

percent of all spray jobs does the pilot of the aircraft also mix & load pesticides?” (see page 11of the report). In 2006 EPA

conducted a survey of pesticide aerial applicators and determined that the average number of application flight time per

aircraft per year was 400 hours. The number of acres an agricultural aircraft is able to treat in an hour ranges depending on

your geographical location and the type of aircraft that is flown, but it is between approximately 96-260 acres per hour.

Multiplying this for a single plane aerial application operation flown in a single year (400 hours) gives an acre range of

between 38,400-104,000 acres. For single plane operations, again which approximate 29 percent of our industry, where the

pilot is also the mixer-loader and responsible for the billing, recordkeeping, etc. to add the burden of applying for NOIs to f all

under the general permit will be an unsustainable burden. EPA needs to significantly raise its thresholds to fairly take these

factors into account.

It is important the Agency do this because the aerial application industry is a vitally important method of applying crop

protection products, as it is the most expeditious and fuel-efficient means of application. It permits large areas to be covere d

rapidly, thus ensuring timely and effective applications. Timely applications of crop protection products results in

significantly reducing pesticide usage. When wet soil conditions or dense crop foliage prevent the use of other forms of

application, aerial application may be the only method of treating crops. Moreover, aerial application is conducive to higher

crop yields, as it is non-disruptive to the crop and causes no soil compaction. This lets farmers use less acreage to produce

more food, bio-fuel and fiber, and it allows land to be used for other purposes, including habitat preservation for endangered

and/or threatened plant, animal and aquatic species. Applying crop protection products by air is an essential component of

low or medium-tillage farming operations, which reduce soil erosion by as much as 90 percent. These farming methods,

through their preservation of top-soil, are beneficial to the environment because of their sequestration of carbon.

As outlined above, aerial applicators contribute to America’s safe, affordable, abundant, and sustainable supply of food, fiber

and bio-fuel. According to the USDA’s Economic Research Service, in a 2002 publication it issued titled “Major Uses of

Land in the United States” by Ruben N. Lubowski, Marlow Vesterby, Shawn Bucholtz, Alba Baez, and Michael J. Roberts,

there are a total of 442 million cropland acres in the U.S. Approximately 70 percent are commercially treated with crop

protection products, and an estimated 25 percent of commercial crop protection product applications are performed aerially.

Using these percentages with the ERS estimate of total U.S. cropland acres allows for us to estimate that 77 million acres of1005 E Street SE · Washington, DC 20003

Tel: 202-546-5722 · Fax: 202-546-5726 · www.agaviation.org cropland is treated via aerial application in the U.S. each year; this does not include aerially treated pasture and rangeland of

which there are 587 million total acres in the U.S. nor does it include the 651 million total forestry acres and 60 million tot al

urban acres in the U.S. that are treated by air. Data released by the USDA National Agricultural Statistics Service’s Census of

Agriculture shows that 947,279 total farms are treated in the U.S. each year. If the average number of pesticide applications

made per farm in a growing season is six—which we believe is a close approximation—then it can be estimated that aerial

applicators throughout the country make roughly 1,598,533 farm applications per year. The reason for presenting these

statistics is to show that aerially applied crop and public health protection products is a considerably important method of

application in the U.S. It is extremely imperative EPA is aware of this as it considers mandating label language that will

affect farmers’ and the public’s ability to protect crops and society from destructive weeds, fungi, insects and diseases.

Usual Acres Treated per Day Maximum Acres Treated per Day

Crop Treated Number of Percent of Usual Number of Percent of Maximum

(567 Operators responded) Responses Responders Acres Responses Responders Acres

Alfalfa 194 34% 322 197 35% 785

Corn, Sorgum 249 44% 541 248 44% 1281

Cotton 191 34% 1080 180 32% 2145

Forests 43 8% 587 43 8% 1481

Orchards (Fruit & Nut Trees) 54 10% 277 53 9% 598

Pastures & Rangeland 177 31% 549 173 31% 1238

Rice 139 25% 725 136 24% 1344

Small grains (Wheat, Barley) 348 61% 597 341 60% 1307

Soybeans 249 44% 591 237 42% 1282

Leafy vegetables 75 13% 389 72 13% 811

Roots & Tubers 102 18% 593 98 17% 1191

Small fruits (Grapes, Berries) 27 5% 339 24 4% 514

Other 42 7% 483 42 7% 13241005 E Street SE · Washington, DC 20003

Tel: 202-546-5722 · Fax: 202-546-5726 · www.agaviation.org Break down of Number of Percent of Usual Number of Percent of Maximum

"Other" Crops Responses Responders Acres Responses Responders Acres

Aquatic 1 0.2% 100 1 0.2% 200

Christmas trees 2 0.4% 165 2 0.4% 375

CRP (Gov't non

‐ crop land) 1 0.2% 350 1 0.2% 1500

Fallow (Idle

‐ out of production) 3 0.5% 220 3 0.5% 1500

Gladiolas 1 0.2% 50 1 0.2% 250

Misc. minor crops 1 0.2% 100 1 0.2% 300

Mosquito 2 0.4% 1624 2 0.4% 2724

Peppermint 1 0.2% 600 1 0.2% 900

Public Health 2 0.4% 1375 2 0.4% 3225

Pulp 1 0.2% 400 1 0.2% 2400

Right

‐ of

‐ way (powerlines, etc.) 3 0.5% 100 3 0.5% 300

Sugar cane 6 1.1% 633 6 1.1% 1700

Sod 2 0.4% 250 2 0.4% 1300

Sunflower 13 2.3% 476 14 2.5% 1229

Tobacco 2 0.4% 213 2 0.4% 413