Grasshopper Suppression Program Comments

March 15, 2019

Docket No. APHIS-2016-0045-0001

Regulatory Analysis and Development, PPD, APHIS Station 3A-03.8

Care of Jim E. Warren PhD

4700 River Road Unit 118

Riverdale, MD 20737-1238

RE: Rangeland Grasshopper and Mormon Cricket Suppression Program Draft Environmental Impact Statement (DEIS) To: Mr. Warren Thank you for the opportunity to comment on the Rangeland Grasshopper and Mormon Cricket Suppression Program Draft Environmental Impact Statement. The South Dakota Stockgrowers Association (SDSGA) is a producer/member organization that represents livestock producers across South Dakota and beyond. Our members recognize the need for flexibility in management practices and appreciate USDA APHIS’ ability and need to respond to requests in a timely and effective manner. Therefor we would encourage APHIS to implement Alternative #3, Insecticide applications at conventional rates or reduced agent area treatments, the preferred alternative. We understand the need for use of each carbaryl, diflubenzuron, chlorantraniliprole, and malthion. We encourage the responsible use of these chemicals for control of outbreaks of grasshoppers and mormon crickets. We appreciate APHIS wanting to address “site specific issues” (pg 5 DEIS). The need for availability and application of Environmental Protection Agency (USEPA) approved insecticides is historically documented and has not diminished. The United States Congress has repeatedly echoed this priority in 1934, 1937, 1944, 1962, 1985, and 2000 with various statutes that encouraged grasshopper control. Obviously, this is a pest that has historically needed control and will continue to in the future in order to prevent catastrophic outbreaks. “Outbreaks produce…intense competition for the available food supply, which may cause damage to rangeland, and nearby crops…compete for food with livestock…and destroy wildlife habitat” (pg 6 DEIS). Furthermore, the stated objectives of the APHIS Rangeland Grasshopper and Mormon Cricket Suppression Program 3) “suppress…damaging…outbreaks”. In order to effectively complete this objective, each of these insecticides should be available. Producers have used carbaryl very effectively across South Dakota for a long time. “Sevin Bait (carbaryl) is an extremely useful tool” commented Mark Tubbs, South Dakota Rancher and member of the National Grasshopper Management Board. “Sevin is used by large producers and hobby gardeners alike. This is an effective tool that must remain in the toolbox for APHIS and anyone else who needs to control insects.” Added Tubbs. The SDSGA encourages the availability of each of these agents to control “Large scale outbreaks that can inflict serious economic damage to western rangelands (Lockwood et al., 1996)(pg 11, 12 DEIS). These large-scale damages also have an equally damaging ecological impact as well. With the USEPA removal of the insecticide acephate as a grasshopper suppression tool, we see the importance of adding a new tool, chlorantraniliprole. Additionally, the Code of Federal Regulations repeatedly calls for coordination of federal agencies with local governments. We support this coordination and believe it is the best way to ensure success of management plans. Implementing alternative 3) will allow for the greatest collaboration with state, county, and local governments as well as local weed and pest boards. The calculated use of each of these management tools must be available for continued control of grasshoppers and mormon crickets. The SDSGA encourages alternative 3) to provide APHIS and landowners the most flexible, site-specific control methods. Any land manager knows the most effective decisions must be made at the ground level and not at the landscape, regional or larger scale areas. This plan allows for that flexibility and should be implemented without delay. Thank you for our continued efforts in this manner and feel free to contact our office anytime for additional comments or information. Sincerely, James L. Halverson Executive Director South Dakota Stockgrowers Association