US IPM Standard: Pro-Poison, Pro- Big Business

[treeseer]

After Monday August 25, Public Comments on the Integrated Pest Management Part 10 Draft will not be accepted. This is your last chance to advocate for a balanced IPM Standard that gives equal attention to cultural and biological means of managing pests. If you are happy having our industry dominated by big corporations, and seeing piles of dead bees as the face of IPM in the US, read no more.

The current draft focuses on chemical applications by large companies, like the company responsible for the big bee kill in Oregon. That’s who wrote it, so that’s who benefits. This draft includes not only IPM but also A Guide for Big Companies to Set up and Operate an IPM Program. This does not apply to many users: agencies, smaller-scale operations, or individuals. If it’s in the standard, bigger companies with a more formal program would enjoy an even greater competitive advantage.

Less damaging methods are thrown aside with the weakest language possible: ‘Consideration should be given to…’ This document needs better balance, to include users who prefer cultural and biological approaches. Other suggestions in the copy below are to follow chronological order, simplify wording, and streamline the process.
IF you are an individual practicing less toxic pest management, the only way to avoid having the rules rigged against you is to review this draft and comment to [email protected]. If you are associated with any of the below committee members, please comment to them as well.

Bartlett Tree Experts [email protected]
Asplundh Tree Expert Co. [email protected]
Davey Tree Expert Company [email protected]
Tree Care Industry Assn. [email protected]
PLANET Alice Carter [email protected]
Society of Municipal Arborists Nolan Rundquist [email protected]
International Society of Arboriculture Richard Hauer, PhD [email protected]
American Society of Consulting Arborists: Torrey Young [email protected]
Professional Grounds Management Society: Gene Pouly [email protected]
Utility Arborists Association: William Rees (410) 291-3633
USDA/US Forest Service: Ed Macie (404) 347-1647
Alliance for Community Trees [email protected]

A300Part10-IPM-Drft1-V1 140821

 

[sac-climber]

Thanks for posting this treeseer...I'm sure my letter won't make a bit of difference but I'm gonna try!

Our company actually practices IPM as intended, standards like this water down and negate a true integrated and sustainable approach. There are some very qualified people sitting as board members, although none of which I personally recognize as being outspoken champions of IPM. Show me a Mary Louise Flint or Pam Marrone on that board and then I'll feel better.

 

[treeseer]

Thanks for posting this treeseer...I'm sure my letter won't make a bit of difference but I'm gonna try!

Our company actually practices IPM as intended, standards like this water down and negate a true integrated and sustainable approach. There are some very qualified people sitting as board members, although none of which I personally recognize as being outspoken champions of IPM. Show me a Mary Louise Flint or Pam Marrone on that board and then I'll feel better.

sac, thanks for speaking up, and you're right: What the committee calls the 'environmental' vote on the committee is....(drum roll...)...The US Forest Service! And the majority of the time their rep hasn't even been present at the meetings. One community member, one small biz, the rest is a corporate bloc. I don't know Mary or Pam but there sure could be some more diverse input from non-nozzleheads! Any other pest (i.e. weed, fungus, anything biotic that might harm a tree) managers here are encouraged to at least skim it and speak up for balanced IPM, before the rules are rigged against you!

 

[sac-climber]

Well we know the Forest Service has such a sparkling past of low impact chemical use. I recall a book about it...Silent Spring?

 

[treeseer]

Yeah it's amazing to see them keep a straight face while listing the USFS as environmentalists...not to disparage many fine professionals there, but cmon...

An example: instead of just hinting at this stuff and burying it on page 12, it should be way back up with the resource assessment:

“Consideration should be given to the conservation, introduction,and /or augmentation of natural predators and parasites of pests on the site

Consideration should be given to installing plant species that promote predators and parasites of pests.

Consideration should be given to cultural approaches to maintaining plant health such as, but not limited to, pruning, improving soil conditions, mulching, and irrigation.”

This should be at the top of page 10:

“The site shall be assessed for conditions that benefit pests, such as water drainage, light and air movement, … and all reasonable options reviewed for cultural approaches to maintaining plant health such as, but not limited to, pruning, improving soil conditions, mulching, and irrigation.

The site shall be inventoried for natural predators and parasites of pests, and options reviewed for their conservation, introduction, and /or augmentation.

The site shall be inventoried for plant species that promote predators and parasites of pests and/or contribute to plant health, and options reviewed for their conservation, installation, and /or augmentation.”

See the difference? "Shall" is a requirement. Without changes like this, anyone offering less-toxic tree care is at a competitive disadvantage. A300 says they set the parameters of what is acceptable practice in the USA, so if your work is not recognized, you will be outmarketed and outbid unless you act to change this!

 

[sac-climber]

I'll post my letter on here once I get it all typed up.

 

[pdqdl]

I don't see the introduction of "shall" to the dialogue as beneficial to the large chemical application companies. In fact, requiring such documentation would have the effect of eliminating the prudent application of pesticides by all applicators anywhere, except by those companies large enough to support their applicators with a phalanx of support staff and lawyers.

That's all I need is some bureaucrat looking into all my files for my proven efforts to establish some parasitic wasps next time I come across a customer with some pine sawflies defoliating their trees. I'm sure that you have some ecologically friendly way to kill off bagworms, but I don't know of it, so I don't see any "shall" alternatives in my future. Don't even think about telling me to plant any asters, or spray some bacillus when some rich customer calls me out to keep his junipers from dying. "Picking" isn't an option, either; not for most customers.

I generally don't care for any proposed regulation that includes "shall" as part of it's creed for implementing change.

 

[treeseer]

If you don't like 'shall', then 'should' would work, but I don't know what documentation you're talking about. btw if you read the draft you will see lots of 'shall's in there.

Bagworms are typically sheared off or hand-picked here. And what do you have against asters?

 

[pdqdl]

When it is July and the bushes are turning brown, shearing and planting asters ain't gonna cut it.

Hand picking is a nice plan, but it practically guarantees continuity of the problem. Unless you are exceptional at picking the bags, at least one female will go undetected, and then you have another infestation next year. Furthermore, hand picking just isn't cost effective. Spraying is a far more cost-effective treatment, with a much higher assurance of customer satisfaction...unless your customer has a media induced fear of all things chemical.

 

[treeseer]

Some clients have that fear, but most simply prefer that chemicals be a last resort. Without more information about diagnosis, and equal (or greater) guidance on cultural alternatives, the standard would work against IPM practitioners who honestly integrate all reasonable management options.