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EXHIBIT K
REVIEW OF USDA STUDIES ON IMPACTS OF CANCELLATION/SUSPENSION
OF CHLORDANE/HEPTACHLOR USE ON CORN
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September 1975
-210-
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Review of USDA Studies on Impacts of Cancellation/
Suspension of Chlordane/Heptachlor Use on Corn
This exhibit summarizes results of earlier economic studies conducted
on the impact of cancelling chlordane and heptachlor, including one study
done on the impact of cancelling aldrin which relates also to the C/H can-
cellation. These earlier studies include estimates of impact on the year
1971.
Staff.members of the U.S. Department of Agriculture have prepared
brief economic impact analyses of the effects of discontinuing farm use of
chlordane (1) and heptachlor (2). The USDA report on chlordane indicates
there would be no yield impact, from the withdrawal of chlordane, on 210,000
acres assumed to be treated with chlordane in 1971. It was assumed that a
combination of diazinon plus carbaryl at 2 Ib per acre each would yield
results comparable to chlordane in the control of corn pests. Two pounds
of active ingredient of each of these pesticides was used as basis for
computing differences in cost of chlordane. The result was a cost of $8.80
per acre compared with $2.03 per acre for chlordane, generating a total
cost impact of $1.4 million (208,000 acres x $6.77 per acre). The results
of this analysis are of limited value at this time for the following reasons:
1. The acreage of corn treated with chlordane is thought to be as
much as five times the acreage shown in the USDA study (1.1 million
acres in 1975 as shown in Exhibit H in contrast with USDA's estimate
of 208,000).
2. Costs of the alternative of $8.80 per acre are excessive as compared
with those in Exhibit H.
The heptachlor report (2) includes estimates of cost and yield impact
of non-organochlorine alternatives to heptachlor for the year 1971. A
total of 669,000 acres were assumed to be treated with heptachlor for
corn soil insects, mainly in the state of Illinois (262,000 acres for
rootworms and 407,000 acres for other soil insects). No yield impacts
were assumed for rootworm control, but a yield reduction of two bushels
per acre was assumed for the 407,000 acres where other soil insects are
a problem. The result was a reduction in corn production of about
800,000 bushels, mostly in Illinois but with some reductions in Missouri,
Minnesota and other states. The reduction in corn production of 800,000
bushels amounts to a 0.014%. reduction in production for the year 1971
(based on total production of 5.6 billion bushels in the U.S.). The
reduction for the state of Illinois estimated to be 500,000 bushels
amounted to a 0.047% reduction in production (based on total production
of 1.067 billion bushels). Increased costs for alternative controls
were estimated at $1.55 per acre for rootworms and $1.73 per acre for
other soil insects giving a total costs impact of $1.11 million.
Estimated corn acreage treated with heptachlor in ERS's heptachlor
cancellation impact analysis — 669,000 acres for the year 1971 — is
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inconsistent with USDA's 1971 Pesticide Use Survey which indicates that
heptachlor was used on 1.1 million acres (USDA/ERS Report No. 252, July
1974, p. 43). If adjustment is made for the difference in acreage, and
distribution of acreage treated for rootworms and other soil insects is
maintained, the impact is increased by approximately 1.6 times or to 0.02%
of the U.S. production, i.e., about 1.28 million bushels. It is not known
whether such a transformation is entirely appropriate for 1971.
USDA also conducted a study of impacts of cancelling aldrin and other
organochlorine insecticides for use on the aldrin treated acreage in the
U.S. in 1971 (3). The study did not cover impacts on other acreage treated
with organochlorines in 1971. If assumed no yield impacts for treatment of
rootworms, but 0 to 12 percent reductions for wireworms among the states
depending on whether alternatives were used in affected states and 0 to 30
percent reduction for cutworms. The study indicated reductions in U.S.
corn production of 21.1 million bushels if alternative controls were used
and 55.1 million if alternatives were not used. This reduction equals
0.4 to 0.8 percent of U.S. production in 1971. Taking into account mar-
ket prices affected and cost impacts, the farm corn sector would experience
a net income increase of $12.5 million to $76.4 million, depending on whether
alternatives were used.
Economic: Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September 1975
References
(1) Jenkins, Robert P., Herman W. Delvo, and Austin S. Fox, Economic Impact
of Discontinuing Farm Use of Chlordane, Agri. Report No. wel, ERS, USDA,
Washington, D.C., August 1972.
(2) Delvo, H. W., A. S. Fox and R. P. Jenkins. Economic Impact of Discon-
tinuing Farm Uses of Heptachlor. ERS-509, USDA, Washington, D.C.,
January 1973.
(3) Delvo, H. W. , Economic Impact of Discontinuing Aldrin Use of Corn
Production, Economic Research Service, USDA, ERS-557, Washington, D.C.,
June 1974.
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EXHIBIT L
REVIEW OF DATA ON YIELD PERFORMANCE
OF CHLORDANE/HEPTACHLOR AND OTHER INSECTICIDES
IN CONTROL OF CORN ROOTWORMS, WIREWORMS, AND CUTWORMS
Arnold L. Aspelin
Fred Hageman
Economic Analysis Branch
Criteria and Evaluation Division
Environmental Protection Agency
September, 1975
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Review of Data on Yield Performance
of Chlordane/Heptachlor and other
Insecticides in Control of Corn Rootworms,
Wireworms, and Cutworms
This exhibit summarizes available data on the yield impacts of using
chlordane/heptachlor vs. alternative controls for rootworms, wireworms and
cutworms.
Yield benefits of the use of a given pesticide treatment depend on two
critical factors: (1) ability of the treatment in controlling the target pest;
(2) the level and frequency of infestation. Pesticides generate maximum bene-
fits when they are highly effective in controlling the pest and when infestation
levels are high.
Rootworms
Insecticide recommendations of the states reflect the general view
of entomologists that rootworms are better controlled with non-organochlorine
insecticides or by crop rotations, avoiding corn following corn. Accordingly,
it is likely that there will be some increase in yields as alternates to organo-
chlorines are used to control rootworms. As of 1971, 4.7 million acres were
being treated with aldrin for rootworms (1) and 262,000 acres out of 669,000
acres of corn treated with heptachlor were treated exclusively for rootworms
(39%) (2).
Inasmuch as alternative controls are more effective for rootworm than
chlorinated hydrocarbons, shifting to ne of these will increase yields on
a given field or reduce chances of damage from field-to-field or from year-
to-year. Illinois data suggest yield increases from alternates in control
of rootworms (Kuhlman and Petty, 1973) (3). This is consistent with reports
obtained in 1973 from entomology department charmen in universities of major
corn producing states. This survey, conducted by USDA, indicated that in-
creased yeilds of up to 10 bushels per acre on those acres treated for resist-
ant rootworms would result from going to non-organochlorine alternates in
states of Iowa, Wisconsin, Missouri, Indiana and Illinois (4).
As an example, Turpin and Matthews estimate that in 1974 there were
about 250,000 acres of continuous corn treated with aldrin in the northern
third of Indiana where the western corn rootworm is established (5). They
estimate that the minimum loss in Indiana on uncontrolled infestations of
western rootworms is 5 bushels per acre. Therefore, if organophosphate
or carbamate insecticides were used on those acres, there would be a saving
of 1.25 million bushels (5).
The potential for increased yields from nonorganochlorine alternatives
for rootworms was recognized by Delvo in 1974 (1, p. 6).
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Wireworms
Wireworm yield effects tend to be spotty and most likely to occur in corn rota-
tions following sod, pasture or idle acres. The spotty nature of wireworm problems
was -suggested by Munson (Missouri Survey Entomologist) who feels that wireworms are
not much of a problem in the state and are limited to relatively few counties._!/
The sporadic nature of infestation frustrates the effort to target pesticide appli-
cation so that economic returns cover the cost of treatment. Production impacts from
the lack of organochlorine controls have been estimated variously from increased
yield, to no effect, to yield reduction of five or more bushels per acre. In a USDA
survey in 1973, yield impacts as follows were estimated by state entomologists: Iowa,
5 bu; Wis., 4 bu; 111., 5 bu (Nebr. and Ind., no estimates given) (4). A survey of
state entomologists and other professionals conducted by EPA in 1973 resulted in no
specific estimates of yield reduction due to use of nonorganochlorines on wireworms.
Delvo contacted experts in the major corn growing states in 1973 to obtain
estimates of yield impact from cancellation of organochlorines (1). He estimated
no yield effects from alternatives for control of wireworms in Ohio, Indiana, and
Illinois. He did estimate an 8% reduction in Iowa, Missouri, Lake States and Northern
Plains, assuming alternatives are used under moderate to heavy outbreak conditions
compared to control by organochlorines. The predictions seem rather extreme on the
basis of history of losses in these states. A loss of 10% on the average for organo-
chlorine-treated acres with 33% loss implies 33% of the acreage suffers that average
level of damage (i.e., 33% of acreage x 33% loss = approximately 10% loss in produc-
tion). This is unlikely to occur, judging from historical records on wireworm and
other corn pest infestations during the last 25 years,2j
For some species of wireworms, the necessity for organochlorines is also ques-
tionable based upon conversations with senior entomologists and on information from
states, including their published recommendations. There is a likelihood that aldrin
(or heptachlor) will fail under heavy outbreak conditions as indicated in the 1974
Missouri Recommendations (p. 55). In Iowa, Stockdale and Owens disagree as to the
efficacy of aldrin and as to whether it is needed to control wireworms, thus raising
the same issues relative to chlordane/heptachlor.
I/ Munson indicated to EPA personnel while on a field trip to Missouri
(May, 1974) that wireworms are not much of a problem in Missouri be-
cause infestations are so spotty and difficult to predict and treat.
He prepared a map showing that infestations are limited largely to a
12 county area in the S.W. portion of this state and even there they
are "spotty".
2] Review of pest infestation/damage under USDA's cooperative Economic Insect
Report Program for the midwest states for the last 25 years and review of
weekly pest reports by the Department of Entomology, University of Missouri
for the last 10 years. These data give some measure of insect incidences and
damage, although there may be spotty reporting in the states covered (Review
by Fred Hageman, EPA entomologist).
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Recent test data from Illinois further indicate that certain organo-
phosphate and carbamate alternatives are as effective as organochlorines in
wireworm control. —'
Another dimension to wireworm problems is that their life cycle is three
or more years which makes it possible to achieve reduction in pest populations
without treatment each year. Three year crop rotation and/or treatment schedules
can reduce wireworm pest problems.
Illinois entomologists have tested baiting techniques to determine the
presence of wireworms in sufficient numbers to call for treatment. They
now recommend this practice to growers.
Cutworms
Aldrin and heptachlor are still effective for cutworm control even though
we cannot assume that any chlorinated hydrocarbon will always reduce cutworm
damage to less than economic levels. For example, extension entomologists from
Missouri, a leading state in cutworm problems, cautioned farmers in 1972 that
aldrin, heptachlor and chlordane applications "made at or prior to planting
have not given desired results against cutworms in some instances." (8)
They warned producers that a rate of 1 Ib. a.i. in row treatment, a common
practice, does not give acceptable cutworm control. Tillage and rainfall
factors were also cited.
Turpin of Indiana reported that of five fields which had reported black
cutworm infestation during 1972 and 1973, all of which had a moderate to
severe problem, three had not been treated and two had been treated and two
had been treated with aldrin, one by band and one by broadcast application. (9)
Petty of Illinois states:
"The more serious problem of the black cutworm is not
completely corrected by the use of chlorinated hydrocarbon
pesticides, as evidenced by the fact county Extension
advisers received over 90 complaints of cutworm damage in
1972 in fields in which aldrin, heptachlor and chlordane
were used." (10)
In addition, the cutworm damage in corn fields in the Missouri bottomlands
where aldrin is reported to be used by the vast majority of farmers would seem
!/ Wireworm field trials in Illinois in 1975 (Cerro Gordo, 111.) indicate
that both carbofuran and Counter give good control of wireworms (tests at
Greenview, Illinois, were less impressive). According to Dr. Lucfcman,
who reports these results, Illinois will recommend such treatments where
wireworms are suspected in 1976. This same series of tests also indicated
good control of white grubs with carbofuran and Counter (Rochelle, Illinois,
1975).
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to indicate that aldrin is either being misapplied and/or is not effective
enough to prevent injury under pressure of high populations.!./
Yield impacts were limited if they occurred at all when aldrin was denied
to dairy farmers in Missouri for protecting corn against soil pests — according
to Keaster and Munson, state entomologists, and Taylor, a regional farm manage-
ment specialist.2/
Cutworm damage, in terms of lost plants, can range to near 100% in extreme
cases. Shaw and others reported damage in certain parts of fields in 1974
ranging from 6 to 85% (11), averaging 28% in the hot spots among 15 fields
with damage. Of these 15 fields, 5 had been treated wiih organochlorines
(11). According to Gaddy, a reduction in stand of 17% will reduce yield by
15% on Missouri bottomland (12). He also indicates that a reduction in plant
population of 35 to 40% may result in replanting of corn or possibly planting
of soybeans if the farmer has not used an organochlorine. One disadvantage
of using a pre-emergence organochlorine insecticide in a high risk area is
that soybeans cannot be planted should the corn stand be lost to insects,
flood or other factors. An identical estimate was made by Thomas, Extension
Entomologist, University of Missouri (May, 1974 meeting in Columbia, Mo.).
No doubt some cutworm damage can occur without reduction in yield as some
plants will regrow after being damaged and the loss of plants leaves more
water and nutrients for nearby plants.
A comparison of aldrin-treated and non-treated areas of 13 bottomland
fields in 6 Missouri counties indicated a yield differential of 7.93 bushels
in favor of aldrin (120.69 vs. 112.76 bu.), an increase of about 7% yield
while the plant population averaged only 3.5% higher (17,538 vs. 16,942) (13).
This test was done on farm cooperator fields in bottomland areas. Although
this test is not based on a large statistical sample and did not involve
chlordane or heptachlor, it gives an indication of yield improvement with
organochlorines under field conditions, compared to no treatment. Unfortunately,
data were not available on the extent of infestation nor on any other alternative
insecticides. Entomologists in Missouri indicate that research devoted to
estimating yield improvement due to chlordane/heptachlor and alternatives
has been frustrated by lack of areas with infestations of cutworms ,3_/
I/ Hershell Gaddy, regional extension agronomist in a three county high risk -
bottomland area in Missouri, indicates that 20 to 25% of corn land must be
replanted each year due to all causes, including cutworms and the serious
problems of flooding. Much of it is treated with organochlorines like
aldrin and heptachlor but often in furrow or band which does not control
cutworms well and is not recommended.
2J However, a recent study by Dr. Mahlon Fairchild (August 1975) reports that 27 of 205
dairy farms surveyed in 1973 indicated cutworm problems (13 percent) . For
1972, the ratio was 21 percent. It is not known the extent to which these
farms used organochlorines prior to 1972 or to which they experienced cutworm
problems.
3_/ Letter from Armon Keaster, Entomologist, University of Missouri, to
Arnold Aspelin, EPA, 1974.
-217-
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Dr. Luckman of Illinois (personal communication, 1975) indicates that
the grower, on the average over a period of years will lose 1 bushel per day
in May after the 10th of the month and 1.5 bushels per day in June for each
day lost in the growing season. This means that the farmer who plants May 5
and replants May 30, will lose 20 bushels of yield. If insect, flood or
other damage is widespread over the entire field, it may be completely re-
planted. However, he may also only replant portions of the field if
damage is spotty, as it often is.
The extent of actual loss in a given year depends to a great extent upon
the growing season. If it is a good growing year, replanting may incur little
or no loss.
Key issues in estimating the impacts of shifting to alternative cutworm
controls are the level of damage during an infestation a.nd the probability
or frequency of infestation. Let us now turn to the latter.
Infestations of cutworms are quite sporadic, although they tend to follow
flooding and standing waters, either during the current year or from the pre-
vious year. The result is that even on the most risky cutworm land, one cannot
expect to have a serious economic infestation in a given area more than 2 out
of 5 years (Munson, Missouri - map prepared in May, 1974 (6). Similar fre-
quencies are indicated in the 1974 Missouri insect control recommendations
where treatment is recommended on soils subject to annual or frequent infesta-
tions (3 out of 5 years) and on first year corn after sod (14).
In 1974, an assessment was made of black cutworm damage in four counties
in Illinois in connection with an integrated pest management program (15).
The results were: (1) that black cutworm damage was nominal (less than three
percent damage to plants, even in the most impacted county - Hancock); (2)
that fields treated with aldrin and heptachlor had about the same levels of
damage as untreated fields. Untreated acreage averaged 92.9 percent plants
damaged less than 3 percent, compared with 96.7 with aldrin (100 percent for
heptachlor, but the sample acre was very small for heptachlor). Of the 22,583
acres checked, only 142 acres had losses of 5 to 10 percent due to cut plants
and only 20 acres had more than a 10 percent loss.
An Illinois study (11) indicates tentatively that black cutworm damage
is associated with the following factors: previous outbreak on field, sur-
face debris, soybeans the previous year, bottomland and poor drainage. If
these factors can be verified, by further research, farmers can know whether
to pre-plant treat and/or scout for possible cutworm damage. EPA is partially
funding a large study in this area to determine the bionomics of the black
cutworm, in order that it can be better understood and controlled. Lack of
such data frustrates economic use of pre-plant treatments (as well as rescue).
The time that the black cutworm is likely to strike is much easier to predict
than where and at what level of infestation. Field entomologists can facili-
tate farmer scouting by alerting growers as to the most likely times for cut-
worm damage. According to Mr. Luckman, Illinois, it usually begins between
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May 25 and June 1 and lasts for a relatively short period of time, for example, 3
or 4 weeks (personal communication, 1 August 1975).
According to Dr. Mahlon Fairchild in testimony at the aldrin/dieldrin
suspension hearings, "A high risk field for cutworms.... is one where we believe
that, for one year in three, failure to treat will result in significant pro-
duction loss". (16) Presumably, other fields would have less frequent losses.
Petty testified that cutworm damage at economic levels would not be ex-
pected to occur in more than 3 or 4 years out of 10 in the high risk area of
Illinois (17).
In 1974, in response to a concerted effort by researchers on the corn soil
arthopod research project to locate cutworm problem fields in the midwest, Turpir
reports that very few significant infestations of black cutworms were found.
The number of problem fields per state is as follows:
Indiana 16
Illinois 15
Missouri 4
Ohio 3
Iowa 9
Nebraska 0
Damage level varied from 2% plant reduction to the need to replant in three in-
stances. A few of these fields were treated with chlorinated hydrocarbons (9).I/
An estimated 30 to 40% chance of infestation in high risk areas is con-
firmed by the previously mentioned research results in Missouri on 13 bottom-
land test fields (13). Five of the 13 fields showed a yield improvement from
treatment of more than one bushel per acre (38%). The treated fields averaged
3.5% greater stand count, with treatment, as 5 fields had an improved stand
of more than 500 plants per acre.
Based on the above views and data, it seems that no more than one-third
of the corn fields now treated for cutworms with organochlorine would suffer
significant economic damage in a typical year, in the absence of any treatment.
— There is disagreement among midwest entomologists as to the interpre-
tation of these data. For example, Dr. M. Fairchild does not feel that
this is an accurate reflection of the number of fields with reportable
problems.
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Delvo of USDA, based on his survey of state entomologists in 1973, indicates
the following average percentage yield reductions from cancelling organochlorines
to control cutworms on total 1971 aldrin acreage (whether infested or not):
With use of alternatives Without use of alternatives
percent
Ohio -5 -10
Indiana -10 -25
Illinois -10 -25
Iowa -10 -25
Missouri -15 -30
Lake States & Northern Plains -10 -25
Other states 0 0
The Delvo report shows much higher yield improvement from treatment of
cutworms with organochlorines in Missouri than can be justified on the basis
of the only known Missouri field test on actual commercial farms (11). The
yield improvement of 7.93 bushels per acre on the 13 fields is appropriately
compared with the 30% loss figure for Missouri in the Delvo study, where no
alternative insecticide was assumed to be used. The Delvo study calls for an
impact more than four times larger than the empirical data indicate. Although
13 fields do not constitute a large statistical sample, these results suggest
that Delvo's yield impacts are very high, more than one would expect to occur
even in a moderate to heavy infestation.
A survey of state entomologists by USDA conducted in 1973 indicated yield
reductions due to control of cutworm with nonorganochlorines in the range of
5 to 10 bushels per acre (4).
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General Long Term Productivity of Organochlorines in Control of Corn
Soil Pests
The above review of the productivity of chlordane and heptachlor in
control of corn soil insects has a pest-specific focus and has not
contemplated average productivity, i.e., increases in yields the individual
grower or group of growers can expect to achieve over a period of years
such as 5 or 10 years. There have been 2 such studies which indicate the
general long-term productivity of organochlorines in the control of corn
soil insects (19) (20).
The first of these two studies is by Bigger and Decker published in
1966 (19). This study is a summary of research covering the period
1954 to 1963, on a total of 130 tests conducted by the Illinois Experiment
Station. Over that period, aldrin and heptachlor were tested for yield
increases over no treatment with the result that yields were increased on
the average of 5.7 bushels (6.4%). Differences between heptachlor and
aldrin and between band and broadcast treatment were nominal, although
aldrin and broadcast treatment of the two chemicals had slightly higher
average yield increases during the period. Yield increases varied from
-6.8% in 1962 to 11.7% in 1961 and 11.9% in 1958.
The other long-term study on the productivity of corn soil insecticides
has just been completed by Peters (20) for the State of Iowa . Peters
summarizes yield responses of tests conducted by the Iowa Experiment Station
during the period from 1951 to 1962 on a total of nearly 200 tests. For
corn-after-corn comparisons of aldrin, heptachlor and chlordane, the average
yield improvement (compared to untreated land) was 9.14% (7.55 bushels) and
9.08% for first-year corn comparisons (9.46 bushels). The overall weighted
average increase for both corn-after-corn and first-year corn was 9.13% or
8.05 bushels per acre. Yield increases varied from -12.3 bushels to a high
of 75 bushels. Of the 198 comparisons, there were 10 in which the yield
increase exceeded 20 bushels per acre, 5% Of the time.
Comparable yield increases over untreated land were also reported in
the article by Peters based on actual field observations on 939 fields
during the period from 1961 to 1970 in the State of Iowa. A total of 378
fields treated with aldrin were compared with 561 fields that were untreated.
The average benefit attributed to aldrin by Dr. Peters was 9.3 bushels per
acre for an average increase of 9.33% over the untreated yield of 99.7
bushels during the period. Weather and management and other factors were
not held absolutely constant by the research design. However, Dr. Peters
feels that the benefit attributed to aldrin is appropriately so and in line
with the test data generated during the previous decade.
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These two long-term studies establish quite convincingly that the
benefits of organochlorine treatments in the control of corn soil insects
are generally in the range of 6 to 10% as an average expectation over a
period of years and over a wide geographic area. There are no other
known studies which indicate that benefits of corn soil insecticides on
a long term basis generate benefits greater than those reported in these
two articles.
The yield increases reported in these two studies indicate the
magnitude of benefits attributable to the organochlorine pesticides during
the period immediately following their introduction, befoire pest resistance
developed. In other words, they indicate the benefits of organochlorine
during the period of their most effective use in control of corn soil insects
including the rootworms, wireworms and cutworms. Unfortunately, these data
are not available for other states; however, it is doubtful whether yield
increase in other states would greatly (orders of magnitude) exceed those
in these two states.
Table 1 contains a summary of two sets of yield coefficients for
shifting from use of organochlorines to alternatives and to no treatment
for rootworms, wireworms and cutworms. One set called "EPA Estimates" is
the estimate of yield effects for use in the linear programming analysis,
reflecting typical or average yield impacts to be expected over a 5 year
time-frame such as 1975-80. The method used in deriving these are discussed
below. The second set of coefficients ("Delvo Estimates") are those
developed by Delvo.
The "EPA estimates" are values for yield benefits attributable to
organochlorine insecticides, particularly heptachlor, aldrin and,
to a lesser degree, chlordane in a long-term context such as five years
for the major corn producing states. These estimates reflect the average
benefits attributable to the organochlorines reported in the Illinois
study (6.4%) and Iowa (9.1%). These averages were used along with the
estimates of yield impact with and without alternatives to aldrin re-
ported In Delvo's study in 1974. The general approach used was to
accept Delvo's estimates in terms of their overall structure indicating
relationships between types of control and among states, but to deflate
the data in line with the long-term studies for Iowa and Illinois. The
average amount of inflation in the Delvo estimates was by a factor of
2.89 in the State of Illinois and a factor of 2.23 for the State of Iowa
on a weighted average basis for wireworms and cutworms. These two factors
were based on weighting of wireworm and cutworm damage in proportion to
the 1973/74 average estimates of infested acres treated for the 2 pests
in the 2 states. Yield benefit compared to no treatment for states other
than Illinois and Iowa were estimated at the average benefit in the long-
term studies for Illinois and Iowa which was 7.8% (average of 6.4 and 9.1%).
-222-
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-223-
-------
The Delvo study recognized the possibility that yields could be
improved by control of rootworms with compounds other than organochlorines.
However, no estimate was made of this effect. We have estimated these
rootworm yield effects at one half the yield improvement estimated for
organochlorines over no control, as indicated in the long-term Illinois
and Iowa data for all corn soil insects.
The data presented in Table 1, we believe, are an appropriate set of
yield factors for estimating impacts over large geographic areas over a
period of years, on a typical year basis. Whereas the benefits of control
may vary from year to year, we believe that the estimates in this table are
a reasonable approximation to what would be expected over a five year time
frame in the various corn producing states, and we have, therefore,
utilized these coefficients in a linear programming analysis of the impact
of suspending or cancelling all of the organochlorine insecticides for use
on corn during the period 1975 to 1980.
We have concluded that substantially higher numbers than these would
not be reasonable approximations to what could be expected over a period
of years. This is not to say that a given year could not produce greater
or lesser benefits from control of corn soil insect pests. Undoubtedly,
benefits will vary from year to year. However, our review of the history
of corn soil insect control indicates that the exceptional years where
large cutworm outbreaks occur cannot be fully anticipated, and, therefore,
cannot be prevented by the use of the pre-emergence insecticides in any
case. The improvements in pest scouting now being developed, tested and
implemented to some extent in the states could improve that situation.
Scouting for rootworms and wireworms appears to be well on its way to
success. Much less progress has been made in being able to project
economic infestations of cutworms.
Arnold L. Aspelin
Fred Hageman
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September 1975
-224-
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References
(1) Delvo, H. W., Economic Impact of Discontinuing Aldrin Use of Corn
Production, Economic Research Service, USDA, ERS-557, Washington, D.C.,
June 1974.
(2) Delvo, H. W., A. S. Fox and R. P. Jenkins, Economic Impact of Discon-
tinuing Farm Uses of Heptachlor. ERS-509, ERS, USDA, Washington, D.C.,
January 1973.
(3) EPA, Office of Pesticide Programs, Office of Water and Hazardous Materials,
Production^, Distribution, Use and Environmental Impact Potential of
Selected Pesticides", EPA 540/1-74-001. ~
(4) Kuhlman, D. E. and Petty, H. B., Summary of Corn Production Insecticide
Demonstrations, 1968-1972, Twenty-fifth Illinois Custom Spray Operators
School, Urbana, Illinois, 1973.
(5) Survey coordinated by GSRS, USDA, Washington, D.C., March 1973.
(6) Personal communication of F. T. Turpin and David Matthews, Entomologists,
Purdue University.
(7) Map prepared by R. E. Munson, University of Missouri, May 1974.
(8) Aldrin/Dieldrin Cancellation Hearing Transcript - Shell Exhibit 147; and
EPA Exhibit 71.
(9) Department of Entomology, University of Missouri, Weekly Missouri Insect
Situation Report, June 3, 1973, p. 1.
(10) Turpin, T., Aldrin/Dieldrin Suspension Hearings.
(11) Petty, H. B., Aldrin/Dieldrin Cancellation Hearings.
(12) Shaw, J. T., W. H. Brink, D. W. Sherrod and W. H. Luckman, Predicting
Infestations of Corn Rootworms, and Black Wireworms, Cutworms in
Illinois Cornfields, January 1975.
(13) Hershell Gaddy, Extension Agronomist, statement to EPA personnel while
on field trip in Missouri, May 1974.
(14) Aspelin, Arnold L., Statement for Testimony at Aldrin/Dieldrin Suspension
Hearing, September 1974, Exhibit S-16.
(15) 1974 Missouri Insecticide Recommendations, Missouri Extension Service.
(16) Kuhlman, D. E., Knake, Nelson and Walt, Progress Report: Illinois
Corn Pest Management Programs, December 17, 1974.
-225-
-------
(17) Aldrin/Dieldrin Cancellation Hearings, Shell Exhibit 516, p. 15.
(18) Aldrin/Dieldrin Cancellation Hearings, Transcript.
(19) Bigger, J. H. and G. C. Decker, Controlling Root-feeding Insects on
Corn; A Report of a 10 Year Study, U. of Illinois Experiment Station,
1966.
(20) Peters, D. C., The Value of Soil Insect Control in Iowa Corn, 1951-70,
Journal of Econ. Entomology, Vol. 8, No. 4, 1975.
-226-
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EXHIBIT M
DETAILED INFORMATION ON LINEAR PROGRAMMING
ANALYSIS OF ORGANOCHLORINE SUSPENSION OF CORN USE IN UNITED STATES
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September, 1975
-227-
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Detailed Information on Linear Programming Analysis of
Organochlorine Suspension of Corn Use in the United States
Mathematical models of agriculture are tools for measuring the market
effects of agricultural pesticide use. A subset of mathematical models,
activity analysis, was chosen as the most appropriate tool for pesticide
study because of its inherent assumptions which closely mirror the reality
of the agricultural sector. Activity analysis assumes the maximization
or minimization of a mathematically defined choice criterion (objective
function) by the selection of economically feasible production activities
from a finite set, constrained by available resources and required pro-
duction (demand). The characteristics of the agricultural sector embodied
in these assumptions are:
(1) Profit Maximization or Cost Minimization - Economic theory and
observation of agricultural activity support the proposition
that farmers attempt to maximize economic profit.
(2) Resource Adjustment - In response to changes in the price of
inputs such as fertilizers, pesticides, capital, etc. and output,
for example, a change in the price of corn relative to soybeans or
changes in livestock prices, farmers adjust both their mix of inputs
and their cropping patterns in order to maximize returns.
(3) Constraints - Resource constraints express the fact that economic
activity requires the use of limited resources. Especially in
agriculture, the limited supply of natural resources, particularly
land, makes this a pertinent consideration. Constraints are
defined on a regional basis to assure that available stocks of
resources are not exceeded in the solution of the mathematical
program.
-228-
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A second set of constraints (non-physical) also limit the
freedom of adjustment which farmers can make in response to varying
economic signals. Unlike physical constraints such as a limited
supply of land, this second set is subtle and difficult to specify.
The set includes non-market influences, such as tastes and prefer-
ences, tradition, resource immobility, lack of information and
ignorance. These constraints imply that farmers consider a very
limited number of choices at decision time. Further, they imply
that farmers' decisions, while directed at profit maximization,
may not always be optimal. They are accounted for within the
mathematical model through a system of flexibility penalties
which limit adjustment to mirror observed rigidities.
(4) The fixed production requirements embodied in the model, while
somewhat at variance with demand theory, provide a good approxi-
mation for agriculture. Demands for agricultural products are
determined primarily by population size and are moderated by
price and income. A portion of the demand within the model is
fixed by population within various geographic regions while the
remainder (the particular mix feedgrain consumption by livestock
and poultry) is responsive to feedgrain prices.
The particular form of activity analysis chosen for the agricultural
model developed to support pesticide policy research assumes that the re-
source constraints and production requirements can be defined as linear
functions, and that the objective function is both linear and additive.
Although these assumptions limit precision to some extent, it was felt that
-229-
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for the present, the more general formulation of activity analysis models
would not provide enough additional information or justify the increased
difficulty of construction and solution.
Analysis of the impacts of agricultural pesticide policy requires
that the model be both national and interregional in scope. Markets for
agricultural products are national in that equilibrium prices are deter-
mined through a summation process of individual production decisions.
On the other hand, the model must be regionally specific to account for
the physical relationships and methodology of agricultural production
which vary among regions of the country. This construction places extreme
emphasis on the economic phenomenon of interregional competition which is
an important characteristic of the agricultural economy.
The purpose of the model is to analyze the economic impacts of changes
in the use pattern of pesticides. The approach is to compare the differences
in food costs, resource utilization, location of production, and agricultural
incomes under two sets of conditions: (1) the suspect chemical allowed in
its historical use patterns in combination with substitute chemicals and
(2) the use of substitute chemicals.
Base Model
The base linear programming model contains approximately 19,000 activ-
ities (columns) and approximately 1,500 resource constraints and demands
(rows). The activities include crop production (disaggregated by soil type
and region), commodity transportation, conversion of commodities into feed
nutrients, and conversion of feedgrains into corn equivalents for exports.
-230-
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Resource constraints are defined for land by land class. Demands include
those for specific commodities, livestock nutrients, feedgrains for ex-
port and specific commodity exports.
Seven crops are treated as endogenous to the model. These include
barley, corn, cotton, soybeans, oats, sorghum and wheat. Other agricul-
tural land uses are projected exogenously and subtracted from the total
land base. The livestock sector is also projected exogenously and fixed
at a predetermined level. The non-feedgrain portion of total nutrient
demand for ruminants, non-ruminants and poultry is exogenous to the model
and fixed at historically projected levels. Net nutrient requirements
stated as digestible protein and total digestible nutrients which must
be supplied from endogenous crops were calculated and stated as regional
demands which must be met through local production or import from other
regions. Other, non-feeding demands for endogenous crops, such as barley
malt for brewing, corn for breakfast cereal, etc., are projected as a
function of Series E population estimates and are added to regional de-
mands to form the right hand side constraints which must be satisfied.
A set of activities for production of the endogenous crops by region
with variable yields disaggregated by three soil groups define the feasible
set of activities which can be used to satisfy regional and export demands
(estimated exogenously). Each production activity has a corresponding
budget and yield. The budgets, which are disaggregated by variable input,
e.g., labor, fertilizer, pesticides, machinery, allow the analyst easy
access to the model for purposes of updating or changing the cost and/or
quantity of variable inputs.
-231-
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Regional Delineation
To reflect the real-world homogeneity of production functions and the
national-interregional nature of markets, the 48 contiguous United States
are partitioned into producing areas (PA's) and consuming regions (CR's).
PA's are delineated so that a single production activity can be defined
for a given crop in that area. CR's are defined to represent regions for
which a single commodity market exists.
Producing Areas (PA's)
The United States is partitioned into 129 producing areas, each of
which is an aggregation of counties (usually contiguous). Each PA is
wholly contained within one state, and in some cases one producing area
covers an entire state.
For most of the country, producing areas are defined in accordance with
the Agricultural Production and Technology (APAT) PA's. The Economic Research
Service, USDA, defined the APAT production areas as those areas within which
similar cropping conditions prevail. In most regions the producing areas also
encompass one or more of the Census of Agriculture subregions or state parts of
subregions. Where APAT producing areas exist, the PA's in this study are
consistent with them. The only exception is the case where APAT producing
areas cross state boundaries. In this instance the APAT PA has been partitioned
into two or more PA's which conform to state lines.
Where budget data for APAT regions were not defined, crop production data
and cost estimates were generated with the assistance of economists at the
-232-
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University of Illinois. Whole states for which this information was utilized
include New York, Pennsylvania, New Jersey, Delaware, Maryland, Virginia, West
Virginia, Florida and Kentucky. Portions of other states in the South and
Southwest are also partitioned according to the University of Illinois budget
data.
A map of the producing areas is shown in Figure 1. The first letter
of the producing area name denotes the consuming region to which the PA
is assigned, and the second letter denotes one PA within that CR. For
example, the state of Missouri has been designated as the consuming region
N, within which are four PA's: NA, NB, NC, and ND. Regions which are
coded with a single letter are areas where budget data was not available,
but where production was allowed at or below historic levels. Western
New Mexico, for instance, is signified by the consuming region name, U,
followed by a blank for the producing area code.
Consuming Regions (CR's)
The United States is divided into 27 consuming regions. Each consuming
region is composed of contiguous producing areas. In most cases, the CR's
are whole states or are aggregates of whole states. State boundaries are
not observed in those cases where commodity markets do not follow them.
States split include Minnesota, Oklahoma, Texas, California, and Nevada.
In every instance it was felt that each part of the state lies in a sepa-
rate market area. For instance, the Duluth market (Q) is more likely to
include North Dakota than it is Southern Minnesota, while South Dakota and
Southern Minnesota are more closely related.
Each consuming region is oriented toward a major metropolitan area
and/or transportation center. The basis for selecting the city is central
-233-
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I/I
c
o
CTi
-------
place theory, which considers a city or region as occupying a position in
an existing hierarchy of cities and regions. The central city in each
consuming region is considered to be the city at the highest level within
the region. Throughout this report the name of the central city is often
used to signify the entire consuming region.
A map of the consuming regions is shown in Figure 2. The letters
signifying the consuming regions range from A to Z, and the central city
for each is designated on the map.
Major Regions (MR's)
Major regions are defined for reporting purposes only, and are not
functional in the model. The consuming regions are aggregated into seven
major regions in the United States. The formation of seven MR's permits
an overview of the effects of policy changes on principal sections of the
country. A map of the major regions is shown in Figure 3.
Solution
The model is solved through a mathematical algorithm which simul-
taneously guarantees that: (a) all regional demands are satisfied,
(b) no regional resource constraint, e.g., disaggregated land base, is
exceeded, and (c) the objective function is minimized. In so doing,
the model solution depicts the land use and production pattern which
satisfies all constraints at least cost.
An alternative construction would have been a profit maximization
model which would provide a solution which maximizes returns to the agri-
cultural sector. However, a unique characteristic of linear programming
-235-
-------
-236-
-------
c
o
•r-
cn
tt)
a:
S-
O
n
Hi
-237-
-------
analysis guarantees that the dual solution of a cost minimization model
is a profit maximizing solution; therefore, the activity levels for both
cases are identical. The cost minimization formulation was chosen on
the basis of modeling criteria which does not affect the accuracy or
validity of the solution.
Pesticide Analysis - A Special
Case of the General Agricultural Model
To be useful for pesticide policy analysis, the solution to the
model must depict impacts within a short-run period (a five-year time
horizon). Due to the dynamics of pest control which include development
of resistant pests and new technology, projections and simulations of
impacts extending far into the future are futile. Therefore, the data
base used in the LP model is constructed for a typical year in the
1975-1980 time period. This particular time frame provides an opportunity
to analyze the short-run effects of pesticide policies. Unlike many other
national models which have been constructed, the EPA model permits exami-
nation of immediate adjustments rather than the eventual long-run equilibrium
position of agriculture.
An important criterion for a short-run model is that it generates soLu-
tions which are believable. The base model must closely coincide with
current agricultural production (both crop mix and spatially) and current
pesticide use patterns. However, the real world agricultural sector is not
always optimal in the sense of "most efficient" allocation of resources to
-238-
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minimize or maximize an objective function. Therefore, the previously
mentioned flexibility penalties were introduced into the model in an
attempt to account for non-optimalities. Penalties are added to pro-
duction cost as the acreage of any crop increases significantly over
the historical trend. One purpose of these penalties is to reflect
the cost of change — the implementation of new inputs, the change-over
to new machinery, and risk aversion. Secondly, the flexibility penalties
reflect the insensitivity of farmers to minor price incentives which
otherwise might shift production patterns within the model. The benefit
of using such penalties, which are unique to the EPA model, is that the
model more accurately reflects the observed stability of the real world.
Application to Chlordane/Heptachlor Suspension
Two formulations of the base model have been used to evaluate the
impact of suspension. The first evaluation was made under the assumptions
of extreme yield loss and incorporated a base model which was disaggregated
by nine soil classes. The second evaluation assumed less extreme yield
impacts and included a reformulation of the land base into three soil
groups. The reformulation was made to reduce the size of the model in
order to reduce solution costs after examination and evaluation of the
model in its two formulations.
To evaluate the impact of restricting the use of chlordane and hepta-
chlor, the land base in corn growing regions had to be disaggregated by
insect infestation. Infestations were further disaggregated by soil pro-
ductivity class to enable interaction between the yields associated with
-239-
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various soils and crop loss due to infestations. Base model solutions for
treated corn acreage (as opposed to infested crop acreage) are reported
in Table 1 (for the extreme case analysis and Table 2 for the typical
analysis). As these tables indicate, chlorinated hydrocarbon insecticides
are the primary control agent on cutworm infested land while other insecti-
cides in addition to chlorinated hydrocarbon insecticides are used to control
rootworms and wireworms.
Evaluation of the impact of restricting the use of C/H requires a
system of comparative statics where the solution in the base model which
allows C/H use is compared to the solution of a second model with C/H use
options excluded from the feasible set of production activities. To accom-
plish this, several assumptions were required to define the parameters for
specification of the second model.
Explicit assumptions in the chlorinated hydrocarbon exclusion models
included the areas treated with C/H during the base year (1977) and yield
impacts associated with C/H withdrawal. In both cases, the assumption was
made that following the recent aldrin/dieldrin suspension, C/H would fill
the void created by other chlorinated hydrocarbon withdrawals. Therefore,
the expected use of C/H could be simulated by examining, the most recent
estimates of total aldrin, dieldrin, chlordane and heptachlor use on corn,.
To the extent that other chemicals in addition to C/H fill the void created
by restrictions in aldrin and dieldrin, the models over-estimate C/H use
and therefore over-estimate derived benefits from C/H use (costs associated
with cancellation). Yield inputs for the extreme case analysis, with the
exception of those associated with rootworm treatment, were assumed to be
at the level reported by Delvo. Delvo did not specify yield impacts on
-240-
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Table 1. Base model distribution of corn acreage infested by wireworm,
rootworm and cutworm by treatment option.
State
Ohio
Wireworm
Root worm
Cutworm
Total
Michigan
Wireworm
Rootworm
Cutworm
Total
Indiana
Wireworm
Rootworm
Cutworm
Total
Illinois
Wireworm
Rootworm
Cutworm
Total
Missouri
Wireworm
Rootworm
Cutworm
Total
Iowa
Wii'eworm
Rootworra
Cutworm
Total
Wisconsin
Wire-worm
Rootworm
Cutworm
Total
No
Treatment
0
.03
.12
.15
.'23
0
0
.23
.05
.61
0
.66
.1
.09
.03
.22
".03
.06
0
.09
.04
.01
0
.05
0
.21
.02
.23
Other
Pesticides
* t 1 ' f
0
0
0
0
.13
0
0
.13
.01
.07
0
.08
.37
.93
.03
1.33
.07
.18
0
.25
.26
2.33
0
2.59
0
.77
0
.77
Chlorinated
Hydrocarbon
.!/
.39
.16
.72
.25
0
0
.25
.28
.72
.36
1.36
.49
1.0
.83
2.32
.11
.14
.45
.70
.11
.71
.54
1.36
0
0
0
0
-241-
-------
Table 1 (Continued).
State
Minnesota (N)
Wireworm
Rootworm
Cutworm
Total
Minnesota (S)
Wireworm
Rootworm
Cutworm
Total
Nebraska
Wireworm
Rootworra
Cutworm
Total
Kansas
Wireworm
Rootworm
Cutworm
Total
Total
Mo
Treatment
0
0
0
0
.13
.11
.23
.47
0
.16
.06
.22
.04
.02
.05
.11
2.53
Other
Pesticides
.01
.08
0
.09
.13
1.15
. 0
. 1.28
0
2.26
0
2.26
.05
.21
0
.26
9.07
Chlorinated
Hydrocarbon
0
0
.01
.01
.02
.07
.12
.21
0
.02
.09
.11
0
0
.04
.04
7.12
Table Note: Individual columns may not total due to rounding error.
-242-
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Table 2. Base model distribution of corn acreage infested by wireworms,
rootworms and cutworms by treatment options, typical case assumptions.
CHICAGO
— 000 ACRES -•
HIRE WORM
ROOT WURM
CUT WURM
UNSPEC INFESTN
OTHER LAN-D
TOTAL CORN
CINCINNATI
. --* 000 ACRES -•
WIRE WURM
ROOT WORM
CUT WORM
UNSPEC INFESTN
OTHER LAND
TOTAL CORN
w
C/H
A/D
67.59
345.48
786.67
1260.74
246o|48
,.
C/H
A/D
24.37
113,35
58.05
305,14
50ol9l
OTHER NO. OTHER
1NSIC10E INSICIDE TKEATMT
525,08 ,
1311.28 ,
, ,
786,90 4616,26
OTHER NO OTHER
INSICIDE INSICIDE TREATMT
48,89 ,
65,23 ,
51J62 1673|89
165*74 1673J39
.
TOTAL
CORN
592,67
1656,76
786,67
6663,90
9700§,00
TOTAL
CORN
73,26
178,58
58,05
2030,65
2340|S4
DETROIT
—• 000 ACHES
WIRE
ROOT
CUT
UNSPE
OTHER LANU
TOTAL CORN
WORM
WORM
WORM
INFESTN
C/H
A/D
13,72
6,07
1-7,96
28,57
OTHER NO OTHER
INSICIDE INSICIDE TREATMT
66,33
25.39
33J14
58*,54
25,75
282*,20
307J95
TOTAL
CORN
. 13,72
57,22
17,96
343,9;
432!81
-243-
-------
Table 2 (Continued).
DULUTH
— 000 ACRES
WIRE
RUOT
CUT
UNSPEC
OTHER
TOTAL
C/H
A/0
WORM
WURM
WURM
INFLSTN
LAND
CURN
2.86 .
t
6,28
,
*
9,14
1.79
^6,53
0.77
15. St.
,
94,65
OTHER NO OTHER
INSICIDE INSICIDE TREATMT
0,39
192,22
TOTAL
CORN
5.04
76,5i
7.Ob
207,7b
296J41
INDJAN1APOUS
—- 000 ACRES
WIRE
ROOT
CUT
UNSPEC
OTHER
TOTAL
WORM
WORM
WURM
INFESTN
LANi)
CORN
C/H
A/D
13.9|
296,86
245,29
621.44
.
1179,50
OTHER
INS1C1DE
135,80
151, 7«
•
191.37
fl
478,94
NO OTHER TOTAL
INSICIOE TREATMT CORN
149,71
3399
3399
la .
itt
4^)0,63
245,29
42U.99
.
i>057,62
KANSAS CITY
••- 000 ACRES
WIRE WURM
ROUT WURM
CUT WURM
UNSPEC INFLSTN
OTHER LANU
TOTAL CURN
C/H
A/D
7,63
1.74
OTHER
NO
OTHER
INSICIDE INSICIDE TREATMT
481.4to
10.3b
7,08
67,44 «96,86
109687
1131J35
TOTAL
CURN
42,10
4Q1 ,4&
68,42
1105,69
1697J6/
-244-
-------
Table 2 (Continued).
MILWAUKEE
— 000 ACHES
WIRE WURM
ROOT WORM
CUT WURM
UNSPEC INFESTN
OTHER LAND
TOTAL CURN
C/H
A/0
0,79
14,99
65.64
OTHER NU OTHER
INSICIDE INSICIOE TREATMT
162,92
547.&c> 1103,04
iof|a3 looolsa 1103)04
TUTAL
CURN
163,71
14,99
1726,30
2205J01
MINNEAPULIS
... 000 ACRES
WIRE WURM
ROOT WURM
CUT WURM
UNSPEC INFESTN
OTHER LAND
TOTAL CORN
C/H
A/0
44,03
87)69
97,59
229)31
OTHER NO OTHER
INSICIDE INSICIDE TREATMT
28,62
1153,75
13,63
411,68
1607)69
0,75
.
2665 ',58
2666)34
TUTAL
CURN
73,40
1153,75
101,32
3174.85
4503)33
OMAHA
—- 000 ACKES
HIRE WORM
ROOT WURM
CUT WURM
UNSPEC INFESTN
OTHER LAND
TOTAL CORN
C/H
A/0
OTHER NO OTHER
iNSICIDt INSICIDE TKEATMT
2113.72
59.37
61.46
119,64
240.46 29*58,85 1687,16
TUTAL
CORN
2173,08
61 .46
2681,94
4916,46
-245-
-------
Table 2 (Continued).
ST. LUU1S
-— 000 ACHES
WIRE. WURM
ROOT WURM
CUT WURM
UNSPEC INFtSTN
OTH£R LAND
TOTAL CORN
C/H
A/D
190,16
250.87
2/0,78
293,14
OTHER NO OTHtR
ZNSlClOt INSICJDE TREATMT
141,25
211J22 1451J46
1004.95 352.17 1451,46
TOTAL
CORN
190,16
392,12
270.75
1955.82
2808J88
..........},>( TOTAL COKN TKEATMENTS"
... 000 ACKES -—
WIRE WURM
ROOT WURM
CUT WURM
UNSPEC INFESTN
OTHER LAND
TOTAL CORN
C/H
A/D.
624,57
1484,70
2069,74
.4143,01
.
7322,02
OTHER
iNSlCIDt
740.17
8552.19
2«.7t>
3308,47
•
12625.59
NU
INSK1DE
35.62
25, 7b
t
21910.17
•
21971,55
OTHtR
TREATMT
i
.
i
.
11637.65
11637,65
TOTAL
CURN
1400,37
10062.64
2094,49
28361 ,65
11637,65
53556,81
-246-
-------
rootworm treated land other than to assume "that corn yield would not
change if alternative insecticides were used to replace aldrin for corn
rootworm control" (p. 6). He further stated that "there is some indication,
from Illinois data, that yields may increase if nonorganochlorine insecticides
are substituted for aldrin in corn rootworm control" (p. 6). Further
examination of this issue by entomologists in C&E Division indicated that,
due to widespread rootworm resistance to organochlorines, the increased
yields associated with shifting from organochlorines to other pesticides
may be significant and not unique to Illinois. As a starting point,
the parameters for rootworm damage in the restrictive model specify a
15 percent yield decline if no insecticides are used to replace chlorinated
hydrocarbons on previously treated rootworm land and an 8 percent yield
decline if C/H is used in place of other pesticides. In other words, it
was assumed that the use of other pesticides would produce the average pro-
jected state yields while the use of C/H would lead to 8 percent yield de-
clines on rootworm infested acreage. The full yield file is reported in
Table 3. The yield impact estimates for the typical year analysis are re-
ported in Table 4.
Solution Impacts, Typical Case Assumptions
On a national basis, comparison of the model solutions with and without
organochlorines shows an increase in planted acres of 35,708 acres (Table 5).
This was' distributed among crops as an increase in corn acreage of 88,288, an
increase of cotton acreage of 566 acres, an increase of barley equalling
2,937 acres, an increase in wheat acreage of 1,742 acres, a decrease in soybean
-247-
-------
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-250-
-------
acreage of 49,027 acres and a decrease in grain sorghum of 8,798 acres.
Regional changes in corn acreage planted for grain which result from the
organochlorine restriction are reported in Table 6. The corresponding
changes in total corn production (an increase of 199,986 bushels) are
reported in Table 7.
Several measures of impact on farm income can be derived from the
results of the comparative analyses. One proxy measure for economic profit
from agricultural activity is the residual return to land. For all crops
in the model, the restriction in the use of organochlorines caused an
increase in returns to land of $3.12 million or 0.08 percent (Tables 8 and
9). Changes in land rent derived from corn production were decreased by
$6.1 million (Tables 10 and 11). Residual return over production expenses
including labor for all agricultural activity within the model is decreased
slightly as a result of excluding organochlorines by $8.52 million (Tables
9 and 10). For corn production, residual return increased slightly by
$0.52 million or by 0.02 percent (Table 10).
Production expenses to meet demand for the seven crops increased by
$6.38 million or by 0.06 percent (Table 9). For corn the increase was
$9.69 million or 0.23 percent (Table 11).
Changes in the various indicators of income and cost were more
significant at the regional level, but generally not indicative of major
economic impacts (Tables 9 and 11).
-251-
-------
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-252-
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to_izcr_i4
-------
Table 8. Income components for base (unrestricted) and suspension
(restricted) solutions, seven crops, U.S. by region, 1977
...... riCbJUNAL INCUMk lOMPUNEK'TS . ALL CHOPS -••«
* nILLIOi
Base solution ($ million)
BJSTON
NEW
ATLANI A
HUUiToN
NL* OKLEA.'iS
LUUJSvHLL
C;KCII
10,03
1109,38
ECONOMIC
Pnunis
2.2o
>0, 13
161,23
110,17
6,12
03,37
319,85
10,39
15, 6/
136,33
7^,12
169,66
303,17
99,73
5i7,13
158,30
315,09
361,10
393,55
165,31
6o5,62
1 12 , 0 1
228,09
30,15
156,99
116, 3v>
5511,55
ECOMJr.IC
LOSSES
f
-3,12
"20,56
«eO,5V
•7,7b
"192,70
"13.72
-6,10
"i9, 76
-61,00
• 0,01
-118,16
"225.60
-102,65
-0,00
"1,05
-17,20
-13,311
•232,63
"36,81
-31,15
• -6,10
• 0,01
,
•27,13
"1,OJ
"12,39
•1256,74
RESIDUAL
RETURNS
2,26
26,76
2«3,33
65,67
"1,66
22,62
3e3,60
1,29
15 , 7 1
229,81
79,06
131,20
831,51
190,17
517,13
163,13
720,0i
521,03
5/9,71
1021,31
691,10
226, 6U
2 s 1 . 1 0
30,15
600,61
i D i , y 5
51,0?
6397,19
PKDCTN
EXPENSES
f
35,17
317,09
6 4 5 , 7 1
- M9.30
821 ,6 /
627.Sn
1 H 0 , 7 to
111 1 , 3 1
3 1. 1 , 1 1
93,00
565,27
1139,15
155,35
JOitt, 79
176,62
3.[1,6b
5i5,u7
5>8,7,9
5«1,60
709,37
116,85
06,95
•,
1/8,31
3=7,23
Irfl.Oo
10001,19
TOTAL
SALES
2,28
el ,9i
5oO,12
711, f!
17,64
B1U.29
Iti , I /
105,06
117,05
510, 9o
172,06
999,51
1970,90
6i5 , 52
1592,22
310,03
1 0311,7,;
10J9.SC
ill's, 50
1526.91
J 6o2 , 7 /
3l3,1o
321,35
30,15
6»6,91
531,60
1/9,10
IBUUl ,60
Suspension ($ million)
hE(,luNAL iNCUMfc tOMPUNLNTS
MILLION
BUS 7 ON
Nth
dATLlMllKt
ATLANTA
JAOSONVILLt
- ALL CKOPS i ----
HU'Uilu"
Nth OrtLiAhS
LUUlbVlLLt
CINClNNATi
DtTKOU
IND1ANIAPULJS
CnKAoO
ST, UUUiS
OtS
uLUl M
UKAMA '
KANSAS II1Y
BULlNCs
DENytt*
SALT LAKE CITY
SAN
LiJS ANGELES
*«TUTAL«
LAM)
RENT
,
20,06
102,9?
35,59
t
131,10
27,65
,
69,60
151.95
,
361 ,ei
750,33
loV,«q
,
6,16
390,87
Io7,0l
1 1
-------
Table 9. Changes in income components with suspension, seven crops,
changes $ million and percent, U.S., by region, 1977
INTtK CASt KEiULT CUMPArtJ.JN IABLLS
IM:U*L coi-,PuNLNTS--Aiu (.HUPS
VALUE Of UnST i)UFtRtM.ta
UJSlOr.
Nth Yu'
A[UAN I A
Change in $ million
HuUiTU-i
LUU15AiLLt
CtTKl'l T
I'iDl AnIAPoLJS
CrtKibil
SI, LUU1S
OtS fUlNt*
PuLL Ti-
ll,UnA
KM.'.!,»S tITY
Af.Ah! ,.UU
BJLLl.'.Gi
OuNvth
SALT u»ftE CITY
b*i, t-hANClbl,Q
LUS ANttLtS
»«TUTAU*
LAND
KtNl
0,02
0,31
-0,20
t
•0,85
0, 10
-0, ?2
0,39
f
•3J42
•3,65
t
0,01
-1,35
H, IB
-0,47
• 0 , o 9
0 22
0,0o
0,07
1
-0,31
0,02
•0,13
3, 12
ECONOMIC
PhUflTS
0,00
•0,01
0,0?
ti , 0 J
0,02
0,16
0,12
0,00
0,15
0,99
.0,20
I ,42
7,71
3,57
-1,46
0,24
•0,37
-7,7?
1,11
OJ13
-0,h3
-0,2tl
•0,02
- 0 , 'j a
"0,13
6,29
tCONOMK.
LuSits
,
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2,15
•0 (04
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0,01
•10,94
-1 ,33
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-4,77
-0,35
• 0,0/
• 0,02
0,00
1
0,06
0,00
0,05
•17, 1>
RtSlDUAL
RETURNS
0,00
0,01
0 , 2d
5,9o
-0,01
• 0,75
0, 22
•0,15
• 0,07
0,89
-0,2i
0,49
-6,60
-1,40
•1 ,40
0,24
-3,0'J
1 , 62
0,3o
• 3 , 2o
0 , 2u
• 0,59
-0,21
•O.Ori
"0,3 i
•0,11
• 0,17
• 8,52
PrtDCTN
tXPtNbES
i
0^02
3,h4
0,00
0,00
,
f
f
-0,80
-0,02
0,04
-3,97
•0,24
-0, 32
•0,01
0,07
8,12
•0,00
• 0,0/
0,05
0,06
i
i
,
t
• 0,15
6,38
TuTAL
SALES
0,00
0,01
0,30
9,62
• 0,01
•0,75
0,22
•0,15
•0,07
0,03
• C,23
0,53
•10,62
•1 ,64
-1,70
0.23
. •!•,*£
9,74
0,33
•3 , 3i
0,34
-0,53
•0,21
• 0,0i
-o,:;
•0,1 1
• 0,32
• e.ji
tOKMUl WiTM COKN RJ---
CASt KEiULT CUMHAKI>:'JN
INCOIt COMPuNtNTS--ALL
OIKFEKENCtS
BOSTON
Nt.h YuHr\
rtATuJMOlE
Nth (iKI.tANS
LOJJSvIuLt
C1M.1V.ATI
UtTrtQjT
CniLAbU
ST. LUJJS
DtS MUlNEb
t)UtuT»-
HiMMt'APOUIS
OCAriA
K,.,l5Ao CITY
OtSVtH
S*Lf LAKE CITY
change in percent
LuS
«*TuTAL«
LANl/
RLNf
t
0,08
0.30
•0.57
t
•0,64
0,3b
*
•0,32
0.25
,
-0.2o
-0.45
-1,89
,
0,10
-0,34
9.26
•0.11
-0.12
0.00
0,0b
0,2/
,
-o.ia
0,04
-1,33
O.Oo
CCONOJ-JC
PKOHTS
0,0b
• 0,09
0,04
3,65
0,30
0,20
O.Oi
0.03
0 , 9 /
0,73
"0,26
0,75
2,54
3,5"o
-0.2?
0.15
-0,11
-2,02
0,3o
-0,48
0 , 02
• 0 ,44
•0,12
-O.Oo
-0,13
• 0,11
• 0 | 1 b
0,11
ECONOMIC
LUSbES
*
-0,01
0,40
•2,67
0,45
0,04
-0,01
2,55
o.oo
O.sl
30,25
-0,01
4,85
1,30
2.77
-0,11
7,42
35, bo
0.25
0,94
0,19
0.2o
• 5,60
% ,
-0,23
-0,25
-0,37
1,13
RtSlOUAL
RtTURllS
0,00
0,03
0,12
9,11
0.71
•3,33
0,06
-3,54
-0,15
0,39
-0,2/
0,^ 1
.0,80
• 0,74
-0,27
0.15
-0.42
0,31
0,0&
• 0,3*
0,03
-0,26
• 0,0b
-0,0o
-0,12
-0,06
-0 , 3^ •
•0,10
PKDCTN
EXPENSES
1
f
0,01
0,56
0,00
0,00
,
-0,2d
-0,02
0,01
-0,35
•0,05
-0,03
"0.01
0,02
l,5a
•0,00
• o,or
0,01
0,05
,
i
t
•0 12
0,0t>
TOTAL
SALtS
0 , Oo
O.Ol
0,05
1,35
• 0,02
• 0.09
0.02
-0,14
•0,05
0,01
• 0, 13
0.05
-0,54
-0,25
"0,11
0,07
-0,26
0,94
0,03
•0,22
0,02
•0,15
-0,0b
•O.Ob
-0,10
• 0,02
-0,10
•0,01
-255-
-------
Table 10. Income components for base solution and suspension, corn
grain, U.S. by region, 1977.
REGIONAL IkCUMt COMPONENTS BY
GxAJN
MILLION
BOSTON
Hi* 1u*f.
BATuUiUKE
AFLAN | A
NM CMLtMiS
LOUJSvlLLL
C1NLU.SAU
DETROIT
INDUMAPUUS
CnlLAoO
ST, LuUiS
DlS
OULIITM
MINNEAPOLIS
UflAnA
KA'ii/Si UTY
AI1AK1LLU
BILLING!)
SAL? LAKE C1TV
SAN FktN
LUS ANfct
««TUTAL«
a DT U"Ur"
LANO
RtNT
t
9,27
62, So
15,47
i
4,17
0,47
t
20,94
46,30
t
192.27
3«1 ,35
68,34
t
^ | 1 jl
2,73
358|2o
4 4 , ! 5
25,93
0,03
2,68
,
c,o;
B.19
ECONOMIC ECONOMIC
PriOHlS LUSaES
• ,
0,75 -0,00
129, 70 ,
08, lo »0,00
5.51- ,
1 5 , b4 ,
113,64 ,
8,07 ,
14,15 ,
82, II ,
21,40 ,
152,31 ,
254,42 «0,00
54,53 .0,3.,
441.05 ,
147,24 ,
15,07 -0,20
1 67, S3 ,
104, S6 "230,57
o3,89 »5~ , 2 j
190,00 "0,01
0,89 ,
43,6o ,
• 1,97 ,
17.30 ,
26,73 ,
2 SOJ.UE1
RESIDUAL
RETURNS
•
10,02
191,96
103,63
3,50
19,81
114,31
8,87
35 , OtJ
129,01
il ,4b
344,59
63S.77
122,5-3
441 ,05
1 5 1 , 3 /
17,60
205,68
232, 5o
102,8*
215,92
0 , 9e?
46,34
1.97
17,42
34,92
solution ($ million)
PKOI.TN
£160,60
J209.17
,i U , II t
2?,ho
.40,00
96, 13
43)78
26)93
lbl.0/
7,J6,9o
726)?2
149,94
10.78
4l6)lb
150,87
139.65
32)31
7)50
21,33
4188,08
TOTAL
SAUS
34, 4b
338J86
do, lo
2jo)'li
8,67
10,39
725,65
351,07
1167.77
301,31
«63)79
2b9)70
0)9.;
76,65
1,97
7397,25
Suspension ($ million)
...... KEt,IuNAL iNCuHt COnPUNtNTS BY
CUriN GRAIN
S MILLION
BUSTUN
BATLlflOhE
ATLANTA
JAOSUNVILLL
ML^fMiS
MUUiTuN
'lt« UKLC.ASS
LUUlSVlLLt
IM01A|,I*HUL1S
CMKAuO
ST, LuUIS
OLS
DULUTH
MJNrtt
OMAnA
CITY
SALT LA^fc CITY
PdWTLANu
LiiS ANGcLtS
•«TUTAL"
0 DT LKUr-
LANL)
RtNT
1
9,26
62,48
16,14
,
4,14
0,47
i
20,87
46,42
,
191 ,78
3/5,39
66,90
,
4,14
2,07
J9.3B
358.12
43,99
<:5, 95
0,03
2,69
I
0,04
6,19
ECONOMIC ECONOMIC
PROHTS LOSSES
t t
0,7/ «0,00
129,93 ,
92,19 «0,00
3.52 ,
15,73 ,
114.04 ,
8,8b ,
11,30 ,
83.93 ,
2 1 . i :> ,
153,90 ,
2o2,24 "8,24
57, 66 "2,9b
440, 7 / ,
147.49 ' . ,
14,10 "1,59
lo9,«J ,
106,40 "231 , Ib
o2,4/ -5,43
190.39 -O.Oi
0,09 ,
43,73 ,
1,97 ,
17,40 ,
<:t>,7a ,
KtSIDUAL
RETURNS
,
10,05
192,40
108,63
3,52
19,88
1 14,52
8.60
35.17
130,35
• 21,43
345.68
629. 39
121,60
440,77
151,62
14,58
208,78
233,36
101,04
216,32
0,92
46,42
1,97
17,44
34,97
1278,7o
2180,34
•249,40
3209,69
EXPENSES
24,44
2^4,32
245.22
22,6o
40,00
96, 13
43)78
154,65
26,91
3bl,1 I
7/9,85
228,30
726,40
149,93
10,7/
266,36
« 1 6 , 1 6
156,79
139.65
7,50
24,33
4)97)7^
TOTAL
SALES
34,49
4io,72
353,84
59)87
210,65
8,66
2t>-i)20
4H,34
726,79
1409,24
349,90
Uo7,17
3ut,55'
475)l4
0,92
78,73
59,30
7407,46
-256-
-------
Table 11. Change in income components with suspension, corn grain,
U.S. by region, 1977.
INTtR CASt KEiULT CU^PArtlsON TAULLS
VALUE Of HKST UUfLRUNCES
LANO
RENT
UUbTON
NLW Vu^c*
6ATLI "Out
ATLAMA
jACisSuNYlLLt
NL" OnLLANS
LUUiSvlLLi.
CINCINNATI
DLtrcOlT
SI, LJUIS
DtS
MINN! t
UKAnA
KANjAi CITY
ANAKlLLO
HULUGi
OLNVtrt
SAL1 LAKE CJTY
P(,=fTL '-.'2
SA,s friA.NtJSCO
LL'S AMltLti
0,01
0,21
0,9?
-ojoi
0,00
•0,0/
•0,50
-5,97
"1 ,14
c|eo
• 0,oo
1.54
-0, 14
-O.lo
0,02
O.Oi,
0,01
-0,00
o.oo
Change in $ million
ECONOMIC
PhOf IIS
,
0,04
0,22
4,04
0,04
0,09
0,21
0,31
0.15
1,2,!
-0,014
1,59
7,82
3,15
-0,?t>
0.25
-0,90
t c. K
I.JO
1.^1
-1,42
0,40
0,00
O.O/
0,00
O.Or-
O.Oi
. ECONOMIC
LUSbEi
,
0,00
t
0,00
t
,
,
1
*
,
f
,
-8,24
-2,614
t
,
-1,3V
*o|b9
-0,21
0,00
t
t
t
t
i
r'KDCTN
EXPLNiES
TUTAL
SALES
0,00
f
0,00
f
1
1
f
1
,
t
•8,24
•2,614
•1,3V
t
•0,5V
•0,21
0,00
,
,
,
i
ojo >
0,'H
•(
0,0 >
O.O/
0,21
0,01
0,0*
1,J<
-0,04
1,0V
• 6,3V
-0,94
-0,2b
0,2b
-3,02
3,10
0, 7o
- 1 , e o
0,1.0
o,co
0,(o
0,(0
0,(2
0,(5
1
0,04
9,9V
,
• 0,00
,
,
t
•0,86
-0,02
0,04
•7,11
-0,2n
•0,32
•0,01
-0,01
6,2i
•0,0>>
•0,07
•
,
,
,
»
0,04
0,40
14,90
0,04
0,07
O.?l
0,01
0,09
0,40
-0,05
1,1*
•13.50
•1,)7
• 0,60
0.2s
-3,04
11 ,3o
0,76
-1,8/
0,40
0,00
0,00
0,00
0,02
0,05
»15,Ob
10,21
.-••-COilPARt LOKNUI wjTi tUKN RJ---
INTtR CASL KEt-ULT Cu^KAKIbQN TABUS
Change in percent
LANU
RtNT
BUS 1 Oiv
nth ru!»n
BAlLlrCME
ATLANTA '
JACi\SU«IVILL£
MtUKHJS
HOUSTON
NLK OKLtAsS
LU'JISVlLLL
ClNL^NAU
CLTH HT
ChIC»i.O
ST. LOUIS
OtS rulhbb
"iLBADKtt
OuLUln
UHAni
KANSAS CITY
SALT LAKK CJTY.
SAN MANC1SCO
LOS A,iCLLi.S
••TOTAL*
0,34
-0,<>4
0,4?
• l.be
0. 10
*", 16
«,04
-0,0u
-0,37
0,06
0.04
0,27
•oj25
0,01
•ol«7
ECONOMIC
PHOFI'tS.
,
3,35
0,17
«.V
0,7b
0,56
O.lb
0,10
1 ,0tt
1 ,46
-0,16
1 ,0.4
3,0? 4
S,76
•0,06
0.17
-6,46
0,9g
1 ,«4
•2,24
0,2u
0,0V
0,17
0,0V
0,12
0,10
ECONOrtlC
LUSbEi.
,
-0,66
,
•23,94
f
t
|
t
1
f
t
,
S«5bS39f 96
7Vl,7o
t
6D3t40
•
0,*fo
^.U
-1,69
t
«
i
t
i
RtSjDU.,L
RtTURMi
r
0..14
0,,'3
4,«
,
0,02
4,25
•o.'oo
|
,
-0,55
-0,0o
0,01
-0,90
•0,10
-0,04
•0,01
-0,05
3,20
•0,00
•0,05
,
,
•
TOT.AL
SALLS
,
0,10
0,11
4,42
0, 10
0,11
0, 10
0,10
0,M
0,17
"0,10
0, 16
-0,95
•O.J4
*0,05
0,0e
-10,67
2,4;
0,12
-0,7t
0,11
0,09
0,10
o.ov
0,00
0,00
O.Oi
0,11
-257-
-------
The pattern of insecticide use for corn production following organo-
chlorine restrictions is reported by individual regions and for the aggre-
gate corn belt area in Table 12. In general, the solutions indicate a
continuation of corn production with alternative soil insecticides on most
acreage which had previously been treated with organochlorines. One result
of this continuation is a slight reduction in average yields within the
infested regions. Yield reductions following restriction are reported in
Table 13 and average 0.172 bushels per acre for corn over the entire country.
Solution Impacts, Worse Case Assumptions
On a national basis, the model solution shows an aggregate increase
in planted corn acreage of 200,000 acres. This results from the fact
that corn, even at reduced yields, is still a more desirable feedstuff
than alternative feedgrains in many areas and that farmers would increase
their plantings slightly to offset yield reductions. Total changes
in land use are reported in Table 14. Slack, or idle, cropland (reported
in the last column of Table 14) is reduced by 1,160,000 acres. This means
that in total, 1.16 million acres more cropland would be in production
following a C/H restriction in 1977 than would be used if C/H remains
available. Again, the logic associated with this outcome is found in
the farmers' willingness to plant slightly more acres of feedgrains in
general to replace corn in particular. This change amounts to approximately
a 3.7 percent reduction in slack or idle land between the two solutions.
-258-
-------
Table 12. Base model distribution of corn acreage infested by wireworms,
rootworms and cutworms by treatment .options after restriction
of organochlorines, typical case assumptions.
CHICAGO
... 000
WIRE
ROOT
CUT
.UNSPEC
OTHER
TOTAL
ACKES
C/H
A/D
WORM
WURM
WURM
iNFtSTN
LANO
CURN
OTHER
INSICIDE
587,49
1642,27
779,79
820, 9b
38;>o!50
NO OTHER
INSICIDt TREATMT
•
t
^784*66
5784)66
TOTAL
CURN
1642!
779,
96is|
27
79
16
CINCINNATI
••- 000 ACKE.- ---
WIRE
ROOT
CUT
UNSPEC
OTHUR
TOTAL
C/H
A/0
WURM
WORM
WURM
INFESTN
LANi)
CURN
OTHER
INSICIDE
48,89
178,58
279J09
NU 01HER
iNSlCJDt TREATMT
t
b8 , OS
1979,03
206U44
TUTAL
CORN
73,
2030,'
26
OES KOINES
—- 000 ACRES
WIRE
ROOT
CUT
UNSPEC
OTHER
TOTAL
C/H OTHER
A/D INSICIDt
WURM 260,31
WURM
WURM
INFESTN
LANO
CORN
29/6,79
'lt>2 50
187|l4
3888)74
NO OTHtR TUTAL
INSICIDt TREATMT CURN
260.31
4071
4071
6B
63
29/8,79
42b8J82
7960*42
-259-
-------
Table 12 (Continued).
DETKOIT
—— 000 ACRES
WIRE WORM
RUOT WURM
CUT WURM
UNSPEC INFtSTN
OTHER LAND
TUTAL CURN
C/H OTHER NU OTHER
A/0 INSICJDt INSICJDt TREATMT
TUTAL
CURN
13.78
31.46
17.96
33,14
96*.29
85,75
310J76
57.28
17,96
343,91
DULUTH
--- 000 ACRES
WIRE WORM
RUOT WURM
CUT WURM
UNSPEC INFtSTN
OTHtR LAND
TOTAL CURN
C/H
A/D
OTHtR NU OTHER
INSICIDE iNSiciDE TKEATMT
3,9V
66,61
6,1/4
46,25
0,39
,5fi
TUTAL
CURN
66.61
6.H
14J0.83
257*,96
INDIAMAPULJS
--- 000 ACHES
WIRE WURM
RUOT WURM
CUT. WURM
UNSPEC INFtSTN
OTHER LAND
TOTAL CURN
C/H ointR NU OTHER
A/D INSICJDt INSJC1DE THEATMT
149,71
450,63
245,29
634,05
1479168
3577,94
TOTAL
CURN
149,71
4b0.63
24S.29
4211,99
-260-
-------
Table 12 (Continued).
KANSAS CITY
—- 000 ACKES
WIRE WORM
ROOT WURM
CUT WURM
UNSPEC INFESTN
OTHER LAND
TOTAL CORN
C/H
A/0
OTHER NO OTHER
INSICIOE INSJCIOE TKEATMT
34,10
7.63
«77.U
67,80
8.82
561,35 1120,'97
TOTAL
CORN
41,72
177,11
67,80
1095,70
1662)32
MINNEAPOLIS
»-• 000 ACKES
WIRE WURM
ROOT WORM
CUT WURM
UNSPEC INFtSTN
OTHER LAND
TOTAL CURN
C/H
A/D
OTHER NO OTHER
INSICIDE INS;CIDE THEATMT
71.05
1175, 7t>
103. 2b
554,23
1907)31
0.75
TOTAL
CURN
74,80
1175,76
103,26
3235,42
OMAHA
--- 000 ACRES
WIRE WORM
ROOT WURM
CUT WURM
UNSPEC INFtSTN
OTHER LAND
TOTAL CORN
C/H
A/D
OTHER NU OTHER
INSiCIDE INSICIDt TKEATMT
994,78
1687,l6
TOTAL
CORN
61,46
•2661,94
4916)48
-261-
-------
Table 12 (Continued).
STi LOUIS
—«• 000 ACRES
HIRE WURM
ROOT WORM
CUT WURM
UNSPEC INFESTN
OTHER LAND
TOTAL CORN
C/H
A/0
OTHER NO OTHER
iNSlCjDfc INSICIDE TREATMT
190,16 ,
392,12
270.78 ,
457, lb 1498,67
TUTAL
CURN
190,16
270,78
I9i>5.82
2806)88
,...—. —•!,>, TOTAL CORN TREATMENTS-
«•-- 000 ACRES ——
MIRE
ROOT
CUT
UNSPEC
OTHER
TOTAL
c/t;
A/D
OTHER NU OTHER TUTAL
INSICIDE INSJCIDE TKEATMT CURN
WURM
WURM
INFESTN
LAND
CORN
1335,94
10030.13
2029.97
4326.60
177.22J64
b9,61
25.7S
2400o]39
24143,80
11778,66
11778,66
1395.5i>
100t>5,8ti
2088.01
28326,99
11778,66
53645,10
-262-
-------
O
CJ
«t
z
2
i—
o
UJ
h-
o
to >-
UJ
a: a.
o
UJ C£
o. to o
•ODUOuJJ-tSX-o'
>- O
«i O
!»— Q. -> z ui o u o c->
iz'->-«O3-<'x: a. _iJ>
>i (J Ct •-> U
-263-
-------
01
JD
s.
1
s
6
fB
fj
Q
4J
&
jj
8
5
9
PJ
s
.1
^*
•H
Q
'
O i-l
o o
o o
o
10 O
W O
10
14-1
0
V)
go vo
0 CM
i-l 0 O
i
i
t *-4
1 O
I t
0
0 CO
o o
0 0
1 O O
1 O O
1 1 1 1
in w
(u (u
W W
r ^
s i
c^
CN
O
r-
o
?
en
o
o
c!
o
1
o
,_(
cr\
,_!
1
VD
1-1
o
•3
fl
8
1
r^ irt **o \o
'S' 00 O H
^3 ^5 C3 rH
lit i
HO o in
o in o *r
o o o o
ro r» o
CM 0 •«•
o o o
VO IT)
OJ M
o o
i-l VO O •
0 i-l «*
?r-\ O
1 1
O 1— 00
O O O
• • t •
o o o
0 r- r-( 0 0
CM O O O fS
O i-l O 0 0
H O f-
0 0 i-l
o o o
•
43 • 4J Jj
C EH W 10
ia
5 . 5 5 w
0]
O
n
S
tr>
.5
G
B
1
•H
H
to
'•80 45
ll 1
Q
g -P 60
P ^ °2 1
rt IB g>
o ft S
O i— i CU
o gj J3
ui -jj Q «
c u a
^3 § ^ <
(0 O t>i C^
in fj II n} w
II II -fj p «
d ' S8 «
-264-
-------
As a welfare concept, the model reports total returns to land (net
of variable operating expenses). In general, economic theory would sug-
gest that actions which tend to constrain the agricultural sector (with
an overall inelastic demand for agricultural products) will lead to price
increases which more than offset the income effects of decreased production.
The overall impact is higher total returns and higher aggregate profits.
The results of the comparative models are entirely consistent with this
theory.
As shown in Table 15, the net returns to land for all endogenous pro-
duction activities in all regions increases by slightly more than $71 million.
The regional distribution of this increase varies by region and production
alternative; but, on a national level the directional changes is unambiguously
positive. The only negative entries in the U.S. total column of Table 15 are
for chlorinated hydrocarbon, corn activities. These entries are negative,
signifying the reduced returns to land form these activities after cancella-
tion or alternatively, the returns which these activities generated prior
to cancellation. On a. percentage basis, the C/H cancellation results in
increased returns to corn production in the corn belt ranging from 4.4
percent to 23.4 percent and an overall 2.15 percent increase in returns
to land in general (U.S. total).
At the national level, the overall impact of the C/H restriction caused
the following relative adjustments in the production of the endogenous crops:
barley (+2.4%), corn grain (-0.70%), cotton lint'(+0.02%), soybeans (-0.09%),
-265-
-------
g
C -
iH CO
*•* 12
rH O
ro a>
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-266-
-------
oats (+3.90%), sorghum (+1.90%), wheat (+0.3%). The absolute and relative
changes for these crops are reported in Table 16 for seven aggregate subregions
of the U.S. As expected, the largest adjustments occur in the North Central
and the Mountain and Great Plains regions where corn is the predominant feed-
grain. The largest single adjustment is a reduction in corn production of
194 million bushels in the North Central region (6% of that region's base
model production). Clearly, this represents a major change in -production
patterns and would result in major adjustments in land use. From Table 14
it can be seen that most of the equilibrium adjustments occur by substituting
soybean production for corn production (1.04 million acre increase in soybeans
for a 1.49 million acre decrease in corn). In addition, 160,000 additional
acres of barley and 90,000 additional acres of grain sorghum are produced.
After all adjustments in the land base of the North Central region have
occurred, 140,000 additional acres of cropland are brought into production.
Income adjustments associated with these adjustments are depicted in the
"North Central" column of Table 15 and result in an increase in net returns
to land of $150,000 in aggregate.
Further adjustments which occur in the North Central region (although
not reported completely in this section) show an increase in interregional
transportation of corn into the North Central from other regions of the
U.S. equalling 171 million bushels. As a result, although gross production
of corn in the region is reduced by 194 million bushels, feeding of corn
to meet livestock demands within the region is reduced by only 22 million
bushels. Sorghum grain is the main substitute feedgrain and is increased
by 24 million bushels. Sixteen of this 24 million bushel increase in sorghum
feeding is supplied via interregional trade.
-267-
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Table 16. Absolute and relative change in production of endogencous crops as a
result of C/H restriction, by aggregate U.S. subrcgions, 1977
Commodity
Region
North East
South East
.North Central
South Central
MTN i GT. PLNS.
North West
South West
U.S. Total
Barley
bu.
*
0.09
(8.12)
7.90
(44.85)
0
0.65
(0.25)
*
-0.08
(-3.07)
8.56
(2.43)
Corn
Grain
bu.
0.56
(0.18)
23.80
(12.63)
-194.28
(- 6.00)
15.69
(88.61)
1)5.68
(8.78)
1.19
(6.14)
0.44
(0.24)
-36.91
(- 0.70)
Cotton
Lint
Bales
0
0.01
(6.39)
0
-0.05
(-0.93)
0.03
(0.54)
0
0
*
Soy-
beans
bu.
of units (
-0.04
(-0.28)
-6.04
(-5.15)
38.60
( 3.21)
-0.62
(-0.27)
-33.62
(-11.09)
* •
*
-1.71
(-0.09)
Oats
bu.
y\_
Z)
0.04
(1.07)
0
-1.01
(-2.90)
0
12.64
(4.88)
0
*
11.61
(3.90)
Sorghum
grain
bu.
*
*
7.83
(11.48)
15.13
(7.18)
-2.42
(-0.31)
0
0
20.55
(1.90)
Wheat
bu.
-.21
(-.5)
+.14
(+1.3)
-2.59
(-1.9)
.4
(.6)
5.88
(0.6)
.07
(0)
-.17
(-12)
3.54
(0.-2)
* * Less than 5,000 units
Source: EPA linear programming analysis
-268-
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EXHIBIT N
ECONOMIC IMPACT OF CHLORDANE/HEPTACHLOR
SUSPENSION ON CITRUS PRODUCTION
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
Environmental Protection Agency
-269-
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Economic Impact of Chlordane/Heptachlor
Suspension on Citrus Production
The purpose of this section is to summarize economic and social implica-
tions of the cancellation of C/H and aldrin/dieldrin on citrus. Earlier
studies conducted by the Department of Agriculture on the impacts of cancel-
ling chlordane and heptachlor are reviewed along with more recent studies by
EPA. . These studies indicate that cancellation of C/H and other organochlorine
alternatives can have significant impacts on citrus production, although the
quantities of C/H used on citrus are quite small.
Chlordane Impact Study by USDA
During 1966, 15,000 pounds of chlordane were used to treat approximately
8,300 acres of first and second year citrus plantings to protect them from
termites.(1) By 1971, the acreage so treated was estimated to have declined
to 3,000 acres of new plantings to which 4,500 pounds of chlordane were applied.
The rapid decline in treated acres resulted from the fact that the citrus
industry was expanding rapidly with correspondingly high first and second
year plantings during the middle 1960's.
This USDA study assumed that there were no effective non-organochlorine
substitutes for control of termites on first and second year citrus plantings.
This resulted in an estimated loss in value of production of $93,000 for the
year 1971 based on the assumption that 5 percent of the 3,000 acres of first
and second year plantings would have to be replaced at a cost of $147 per acre
for a total of $22,050. The estimate also included production losses arising
from the need to replace trees which require six years to reach fruit bearing
age and an allowance for cost savings as a result of not treating with insec-
ticides to control termites on citrus trees.
Using the same logic and assumptions inherent in the USDA study, the
impact on citrus growers during 1974 would have been $107,000. Damage from
uncontrolled termites would have required replanting of approximately .02
percent of Florida's 864,000 acres of citrus. The regional and national
economic impacts associated with this loss would be minimal or nonexistent
for producers as well as consumers of citrus.
Heptachlor Impact Study by USDA
Limited amounts of heptachlor were used by citrus producers during 1966.
According to the USDA study, less than 500 pounds were used for spot treatments
to control soil insects and ants in the Southern Plains citrus producing area. (2)
No heptachlor was reported for citrus use during 1971. (3) Because of the limited
use of heptachlor on citrus in recent years, no estimates were made by the USDA
analysis of the economic impact of its cancellation.
-270-
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EPA Analysis of C/H Cancellation on Citrus
Analysis of unpublished data underlying the USDA survey of pesticide use during
1971 shows California having the highest chlordane use on citrus. This data indi-
cates that 17,800 pounds of chlordane were applied to 9,700 acres of citrus in the
United States. California applied about 15,600 pounds to approximately 8,600 acres
while Florida accounted for the remaining 2,300 pounds on an estimated 1,200 acres.
Use in Florida was primarily for termite control while the California use was direct-
ed primarily at control of the Argentine ant which interferes with natural predators
of scale insects. It has been further estimated that 25,400 pounds of chlordane was
used on 8,112 acres (3.2 percent of California citrus acreage) during 1973.
A five percent granular chlordane compound applied either aerially or with
ground equipment at a rate of 100 pounds per acre was the typical dose against
Argentine ants during this period.
Substitute control programs used two to four ground applications of diazinon
for one application of chlordane or foliar sprays to directly control scale insects.
One or two foliar applications of either parathion, malathion, carnaryl, guthion or
supracide would be needed as an effective substitute for the chlordane treatment.
Since only a small proportion of the California citrus acreage (3.2 percent)
requires treatment for control of Argentine ants and since the substitute control
program has a small effect on citrus production costs, the direct regional and
national impacts associated with a restriction in chlordane use for California's
citrus industry are expected to be small. The impact of cancelling this use would
be felt primarily by the grower. Diazinon may not be a long run substitute as it
is not presently supported by EPA registration. Such pesticides as parathion could
upset pest management programs and require a reorganization of foliar spray sche-
dules. The impacts associated with cancellation of organochlorine insecticide use
(including C/H) for citrus production were evaluated by EPA during 1973 in con-
junction with the aldrin/dieldrin cancellation hearings. At that time, aldrin
was the most widely used organochlorine insecticide and was applied through
soil incorporation primarily to control root feeding beetles: use of aldrin for
this purpose was limited to Florida. The expert from Florida during the aldrin/
dieldrin hearings was that chlordane/heptachlor would be used as an aldrin replace-
ment in the event that citrus uses of aldrin were eventually cancelled.
As a result of the recent aldrin/dieldrin suspension, it can be assumed that
C/H will be important alternative insecticides for the control of root feeding
beetles in Florida. It should be noted that registrations of C/H for root feeding
beetles are not consistent between the state of Florida and EPA. The Florida Insect
Control Guide (May 15, 1971) references aldrin, chlordane and dieldrin as recommended
pesticides for control o'f Fuller's Rose Beetle and Citrus Root Weevil. However, there
is no corresponding EPA registration for chlordane for Fuller's Rose Beetle. On the
other hand, Stauffer Chemical Company does have an EPA registration for use of hepta-
chlor for control of these insects (EPA registration numbers 476-1801 and 476-1129).
The use of heptachlor for this purpose does not appear in the Florida recommendations.
-271-
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Since the problem associated with root feeding beetles is potentially severe
for certain geographic regions of Florida, the role of chlordane and heptachlor in
the control of these insects will be analyzed even though this use does not appear
in past insecticide use surveys, and the data realting to C/H efficacy is conclusive.
The efficacy data relating to aldrin, dieldrin, chlordane and heptachlor is
inconsistent. During 1958, King ran several experiments with these compounds. In
one he found that heptachlor provided 96 percent control over Fuller's Rose Beetle
while dieldrin and aldrin provided 92.5 percent and 78.2 percent respectively. In
a second trial, aldrin performed the best by providing 78.9 percent control with
dieldrin yielding 74,6 percent; heptachlor ranked third at 47.6 percent and chlordane
performed poorly (29.5 percent). In these tests no statement of statistical signifi-
cance was associated with treatment means. King concluded from his work that "severe
root injury can be prevented by soil applications of 2.0 to 5.0 pounds of technical
aldrin, dieldrin or heptachlor per acre" (4).
More recently, Bullock has tested the performance of chlordane, dieldrin and
a varied assortment of other compounds. In 1971, the use of dieldrin at a rate of
five pounds active ingredient per acre resulted in emergence of 3 beetles per trap
while chlordane treatment of 5 pounds active ingredient per acre resulted in a count
9.4 per trap. In this test the control plot yielded 11.4 adults per trap. These mean
reported counts were not significantly different from one another at a 5 percent
significant level as evaluated by the new Duncan Multiple Range Test (5).
Very little testing of these compounds has occured in recent years. At the
same time, C/H have not been used by growers for soil insect control. Therefore,
the lack of reliable performance data from experimental work is compounded by a
lack of use data under field conditions with the result that the substitutability
of C/H for aldrin and dieldrin is most difficult to assess.
Although aldrin and dieldrin were used primarily to control the Fuller's Rose
Beetle, they also provided varying control over an associated complex of soil insects
including Citrus Root Weevil (Pa_chnaeus litus) , West Indian Sugarcane Rootstock Borer
Weevil (Diaprepes abbreviata), Tanvmechus lacaena and Citrus Leaf Notcher. Only min-
imal control over Diaprepes abbreviata has been afforded by aldrin, dieldrin, chlor-
dane or heptachlor. This recently introduced pest has been subject to quarantine and
eradication efforts in recent years with only limited success. According to Robert
Brooks of the USDA Cooperative Extension Service, Lake Alfred, sucessful control
for this insect has not yet been discovered.
Damage to the citrus tree is primarily by the larvae as they feed upon the
roots, reducing both the root system and the canopy. This diminishes vitality
and production, culminating in an unecbnomical tree. While the damage is apparent,
the causes are often ambiguous. Several pests can inhabit the groves and cause
similar damage. Often the beetles' infestation can be substantiated only after
the tree is removed from the soil. Persistent soil insecticides such as aldrin and
dieldrin and perhaps C/H have proven convenient and efficacious because of their
persistence (requiring only one soil application every three to five years) to
control both termites and beetles. In addition, the soil application of chlorinated
hydrocarbons has made it possible to introduce natural insect predators at considerable
-272-
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savings to growers. Part of these cost savings are the result of reduced spraying
"(by a factor of 3 to 7 applications) of other pesticides. Without an effective
soil insecticide, the only option for beetle control is increased spraying of
organophosphates to control adult beetles as they migrate fromt he soil to the fo-
liar of trees. This option would probably not provide the same level of control as
was maintained by aldrin. Soil insecticides provide maximum protection to citrus
groves by interrupting the life cycle as the larvae migrate to the soil and by pro-
viding control over the number of adults who can move from the soil back to the
foliage. Foliar sprays can be effective in reducing the adult beetle population
at the time of application and shortly thereafter; however, because of the vari-
ability of the life cycle of the target insects, quarterly foliar applications
would probably be required. In this event, the entire spray schedule would have
to be restructured together with modifications in the current biological control
programs.
Even if chlordane is available for beetle control, due to its lower perfor-
mance, citrus psecialists feel a modification of past spray schedules may be re-
quired. Rather than initiate an additional foliar spray, citrus entomologists
would probably recommend that grove managers redesign their foliar schedule.
One such option would be to change the summer scalicide spray of ethion and oil
which is currently applied in mid-July to parathion and oil in mid-May or June.
This option would still provide the scalicide protection as well as some control
of adult beetles in the foliage to offset lower efficacy in the soil.
If left uncontrolled, the damage caused by Fuller's Rose Beetle could be severe
with impacts distributed unevenly across the citrus growing regions of Florida.
Citrus District Five, made up of Atlantic Coast counties including Brevard, Indian
River, St. Lucis, Martin, Palm Beach, Broward, Dade, and portions of Volusia is
characterized by groves planted on artifically constructed beds, surrounded by
draining ditches, which were once partial sqamp land. High water tables limit the
depth of the root systems; 90% of the roots are often concentrated in the top 18
inches of soil. In the central part of Florida, citrus roots can penetrate up to
twenty feet and average twelve to sixteen feet.
In the coastal counties, a greater portion of the root system is available
for larvae feeding. Thus, the same level of beetle infestation can result in
greater damage for these trees than for inland groves. Discing in the inland
groves to a depth of six inches around the trees may interrupt the pupation stage
of the beetle thereby providing marginal, non-chemical control. In the coastal
regions, discing to this depth would severely damage the root system. Without
cultivation, grass and weeds compete with the tree for available moisture. For
this reason, coastal groves are more susceptible to drought which in turn exerts
a stress on the tree and leaves it more susceptible to damage by any factor that
reduces the root system. The apparent paradox between high water tables and
drought damage is explained by the fact that the root penetration is effectively
limited by the average height of the water table. As the level declines during
dry periods, the peripheral roots of coastal trees are unable to obtain sufficient
moisture.
Without adequate control of root feeding beetles, citrus production in coastal
counties could prove unprofitable for many groves. Using treatment history as a
-273-
-------
.base to define infested acres (and assuming that treatment is made every three to
five years), 25% of Florida's East Coast county citrus acreage could be subject to
root damage if adequate control of soil beetles is unavailable. As a percentage
of total Florida citrus, this coastal county acreage would affect approximately
6 percent of current citrus production (1972 base).
Because of an inelastic demand for citrus at the farm level, the market impact
of a decrease in production would be an increase in farm level income to citrus
growers in the aggregate. However, due to the greater potential for insect damage
in the East Coast region, these growers could be subject to income reductions if an
adequate control agent is not available.
Due to the uncertainty surrounding the efficacy and registration of C/H as soil
insecticides for citrus and lack of information surrounding alternative controls
for Fuller's Rose Beetle, it is difficult to predict social and economic consequences
from C/H restriction. It can be stated that the suspension of aldrin and dieldrin
negated the primary control of Fuller's Rose Beetle. Furthermore, if no alternate
control agent is discovered, the consequences could be severe for Florida's East
Coast growers. Due to currently low income levels and lack of alternative employ-
ment, a significant production decline would cause significant social impacts. The
extent to which C/H can impact on this situation is unknown and, therefore, the
economic and social implications of the C/H cancellation for citrus are difficult
to assess with available information.
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September 1975
References
(1) USDA, Economic Impact of Discontinuing Farm Use of Chlordane,
Agricultural Economic Report No. 231, ERS, USDA, Washington, D.C.,
August 1972.
(2) USDA, Economic Impact of Discontinuing Farm Uses of Heptachlor,
AER No. 509, ERS, USDA, Washington, D.C., January 1973.
(3) USDA, Farmers' Use of Pesticide in 1971, Agricultural Economic
Report No. 252, ERS, USDA, Washington, D.C., July 1974.
-274-
-------
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-275-
-------
EXHIBIT P
ECONOMIC IMPACT OF THE REMOVAL OF
HEPTACHLOR AS A SEED TREATMENT
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
Environmental Protection Agency
-276-
-------
Economic Impact of the Removal of
Heptachlor as a Seed Treatment
In t ro due ti on
Seed treatment is used to decrease stand loss attributable to seed
eating insects. It is intended to protect grain and vegetable seed
up to the germation period. It is estimated that between 4% and 8.7% of
all grain seed (1970-1974) was treated with heptachlor in five mid-
western states. Similarly between 8.6 and 20.2% of all seed was treated
with one of five major insecticides including heptachlor. Estimates are
not available on the intensity of seed insecticide treatment in other
agricultural areas.
Summary
1. Seed treatment provides temporary protection from seed eating
insects (seed corn maggot, seedcorn beetle, thief ant,
wireworms and false wireworms) during germination.
2. Major protection from heavy infestations is provided by more
costly and intensive soil treatments. Seed treatment alone
does not provide adequate protection under such conditions.
3. Commercial seed producers generally do not apply insecticides
to seed for protection during germination.
4. Approximately 9% to 20% of all grain seeds were treated with
one of five major insecticides in 5 midwestern states; only
4% to 9% of all grain seeds were treated with heptachlor.
5. Suspension of heptachlor seed treatment would generally result
in the use of lindane, diazinon, or a combination of lindane/diazinon.
-277-
-------
State recommendations consistently recommend the above as seed
treatment alternatives to heptachlor.
Use Patterns and Practices
Seed treatment, which includes the application of fungicides, insecti-
cides and other chemicals to seeds, is a common practice. This practice
is an economical way to decrease stand loss and prevent costly replant-
ing and/or yield loss. Seed treatment, however, does not control un-
desirable pest populations; its efficacy is manifest by the degree of
protection afforded only during the period of germination.
Heptachlor, and to a much lesser extent chlordane, provide temporary
protection from various soil insects at the time when the plants are most
vulnerable to infestation. Heptachlor seed treatment is frequently
recommended for use on the most common seed eating pests including
seed corn beetles, wireworms, seed corn maggots, thief ants, and false
wireworms in 1975 seed insecticide recommendations for various field
crops and commercial vegetable in many states. This particular
pesticide treatment is used on a large range of grain and vegetable seeds.
While there are other chemicals registered for use as seed treat-
ment, including lindane, diazinon, and Dursban, heptachlor is the most
widely used. In 1973 and 1974, 190 and 269 thousand pounds of hep-
tachlor were used as a seed treatment (Exhibit A). A 1973 USDA estimate
placed total heptachlor usage as a seed treatment of corn, sorghum and
small grain at 11 thousand pounds in 1971(4). A 1972 USDA study estimated
that in 1966, 26 thousand pounds of lindane were used for seed treat-
ment (5). It is currently estimated that approximately 12,000 to 15,000
-278-
-------
pounds of active lindane ingredient were used in 1975 for seed treatment.
EPA estimates show that only 4% to 8.7% of all grain seeds in 1970, 1972,
and 1974 were treated with heptachlor prior to planting in five midwestern
states. However, 9% to 20% of all grain seeds were treated with one of
five major pesticide seed treatments including heptachlor (Table 1). The above
percentages were extrapolated from data given in various state publications
concerning the application of both fungicides and insecticides to seed. The
extrapolations assumed that the major proportion of commercial seed producers
treat seed with a fungicide. Generally, the only insecticide applied by com-
mercial producers is either methoxychlor or malathion for storage protection
against seed eating insects (Launer, et al., 1975). The percentage of
planters that applied pesticide seed treatment themselves or had their own
seed treated commercially (I a-Hb) was evaluated according to the type of
chemical applied. The total percentage of planters having seed treated with
an insecticide (Table 1, Part III) was estimated by multiplying the sum of
those that treated seed themselves (a) or had their own seed treated commerc-
ially (Ib) with fungicides and/or insecticides by the percent that treated
the seed with one of the five major seed treatment insecticides (II a,b,c,d,
e). A similar calculation estimated the seed treatment use percentage.
Seed treatment is not the sole nor most important method of control of
the seed eating insects. Only a small proportion of seeds (9% to 20%) have
been treated with any insecticide prior to planting. Primary control of the
seed eating insects is provided by direct soil application (Park, 1975).
Seed treatment is desirable only to the point where it protects the
-279-
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seed during germination. If infestation by the soil eating insects is a serious
problem, more costly intensive soil applications may be more economically
desirable; soil applications will provide the necessary protection from seed
eating pests during both the germination and seedling stages.
In addition, resistance of seed feeding insects to cyclo-dien insecticides
is prevalent in certain geographical areas. Seed corn maggot and slender seed
corn beetle, for example, are resistant to aldrin, chlordane and heptachlor over
the northern and eastcentral areas of Missouri. Iowa no longer recommends
chlorinated hydrocarbons in the state because of resistance in these insects.
Illinois notes that, among other insects, seed-corn beetles, seed corn maggots
and possibly wireworms are no longer effectively controlled by chlorinated
hydrocarbons (lindane is included in this group).
State Recommendations
An EPA/USDA survey conducted in early 1975, showed that 19 of 44 respondent
states were to recommend either chlordane or heptachlor for seed treatment on
sorghum, soybeans, corn and other grains in 1975. Generally, heptachlor was the
recommended chemical. The only listed alternatives to the heptachlor seed treat-
ment for the grains was either lindane or diazinon, or a combination mixture of
lindane or diazinon. Heptachlor seed treatment, however, was to be recommended
by only one respondent state for vegetable seed use, and by three states for the
various bean seeds (3).
Verification of the EPA/USDA survey can be found in Table 2. This table
includes summary information regarding the official 1975 state insect recommenda-
tions for corn, grain, sorghum, small grains and soybeans in selected states.
Not all states were surveyed; particular emphasis, however, was given to the high
grain producing states. The states surveyed included those that accounted for
-281-
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-283-
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60% of the total United States' planted coin acreage, 90% of the total planted
sorghum acreage, and 60% of the total planted soybean acreage (1). The official
state recommendations list only lindane, diazinon or both as possible alternatives
to the heptachlor seed treatment.
This survey showed six instances where heptachlor seed treatment is recom-
mended but neither lindane, diazinon or any other insecticide is listed as a
viable alternative. The exceptions which include seed treatment recommendations
for wireworms on field corn, and small grain, particularly oats, in Wisconsin
and sorghum seed in Texas are detailed in "Economic Impact of Removal of
Heptachlor as a Seed Treatment".
A less intensive search of vegetable recommendations are conducted. A
brief summary of three vegetable crops, including corn, beans and peas is included,
The cited states accounted for 47% of the total U.S. fresh and processing sweet
corn acreage, 17, 36 and 67% of the dry, green and lima bean acreage and 52% of
the total U.S. green pea acreage in 1973 (1).
Heptachlor does not appear to be the most frequently recommended seed treat-
ment on vegetables. Only one state lists heptachlor as the sole recommended seed
treatment for wireworms on sweet corn.
In addition to the above recommendations for grain and vegetables, sugar
beet seed may be treated with an insecticide for wireworm protection. However,
heptachlor is not the primary treatment as lindane is generally the seed treat-
ment of choice (Lange, 1975).
Review of Alternatives to Heptachlor
Cancellation of heptachlor and chlordane will result in the substitution
of other seed treatments. As previously cited the most likely candidates for
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substitution are lindane, which has been used for a number of years, and
diazinon.
Lindane
Lindane is currently produced in the United States by Hooker Chemical
Company. On an annual basis total current production capacity is estimated to
be approximately 525,000 to 800,000 pounds (Confidential industry sources).
Whereas the total use of heptachlor as a seed treatment was only 190,000 and
269,000 pounds of active ingredient in 1973 and 1974 respectively, the domestic
production capacity of lindane is inadequate to meet potential increased
demand for its use as a seed treatment replacement.
Current efficacy reports on lindane seed treatment vary; additionally the
question of its phytotoxicity due to mutagenicity is not clearly answerable
CThomas^ Lange, 1975). Thus, its substitutability for heptachlor as a seed
treatment is unclear. Though lindane is the most commonly recommended substitute
for heptachlor, lack of data prevents accurate assessment as to whether that
chemical will always substitute well under all circumstances. Insect control
of any chemical can be influenced by many factors including type of seed,
species of insects, moisture content of seed, duration of seed storage, plant-
ing practices, biological differences of soil insects, population of the
infestation, geographic locations (Lange, 1975).
Diazinon
In 1974, diazinon, another frequently recommended substitute for heptachlor
seed treatment, was produced in the United States at an estimated 6 to 7 million
pounds active ingredient (2). In that year 4.8 to 5.6 million pounds were
used domestically for both agricultural and non-agricultural purposes in the United
-285-
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States (2). The production of this particular chemical is not expected to
increase in the next three to four years as there are no current plans for
change of the production capacity. Nevertheless, current domestic production
capacity is adequate to meet any demand for its use as a seed treatment replace-
ment for heptachlor.
Lack of efficacy and phytotoxicity data for diazinon prevents an accurate
appraisal as to whether that chemical will be a good seed treatment substitute
for heptachlor under all conditions. As with lindane many factors may affect
its performance as a widely used seed protection.
Economic Impact of Removal of Heptachlor as a Seed Treatment
In response to the 1975 USDA/EPA study cited above, agricultural specialists
from 9 states provided estimates of the impact of either using a substitute
chemical (i.e., usually lindane, diazinon or a lindane/diazinon mixture) or
having the lack of a chemical substitute for the heptachlor seed treatment.
Seven of the nine respondents anticipated minimal or no effect from the
removal of heptachlor as a seed treatment. A 5% to 20% "effectiveness loss on
corn grain, sorghum or small grain" was anticipated in New Mexico, whereas
possible phytotoxicity resultant from lindane treatment was suspected in
Washington state (3). Losses were not expressed in economic terms.
As stated in the section describing state recommendations, six instances
were noted where heptachlor seed treatment is recommended with neither lindane,
diazinon nor any other chemical listed as a viable alternative (Table 2). Three
to four of the exceptions are found in the recommendations of the state of
Wisconsin. Heptachlor is the only seed treatment recommended for wireworms
on corn, small grains and sweet corn in 1975.
-286-
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The economic impact on sweet corn is anticipated to be minimal as the
wireworm is not of major importance in the areas of Wisconsin where large scale
commercial production exists. Field corn infestation of wireworms is frequently
of such density that soil treatment is not only recommended but is often more
economically desirable. There is, however, no complete picture on the economic
impact regarding removal of heptachlor seed treatment from use on small grains.
The performance of diazinon is unsure due to lack of supportive data; additionally
lindane may not be suitable due to its phytotoxic nature. Therefore, no
realistic estimation can be made of the economic impact of the removal of
heptachlor as a seed treatment for oats and the other less-important small grains
in Wisconsin (Apple, 1975).
The major controversy and discussion that surrounds the question of
heptachlor removal as a seed treatment centers primarily in the Southwest.
It is estimated that removal of heptachlor as a seed treatment may result in a
financial loss of greater than $22 million dollars in the state of Texas
(Thomas, 1975). This estimate includes only the cost of replacing and replanting
grains sorghum, small grain and corn seed. Seed replacement estimates vary
between 10% and 20% of the planted acreage dependent upon crop (Thomas, 1975).
Further detailed economic assessments of additional loss due to reduction in
yield quality or quantity have not been made.
Wireworms are the major seed eating insect problem in Texas. Diazinon
seed treatment is considered to be generally ineffective on wireworms
(Thomas, 1975). Though recommended as an alternative to heptachlor/chlordane
seed treatment for seed corn beetles, seed corn maggot and wireworms on corn
-287-
-------
and small grains, lindane is reported to cause various degrees of phytotoxicity
particularly on sorghum (Thomas, 1975). Therefore, neither chemical is •
considered to be an effective seed treatment alternative in the Texas grain
producing areas.
Furthermore, cultural techniques are not believed to offer protection
against seed eating pests. Planting dates cannot be delayed du£ to either
climatic conditions or to the presence of other pests that can attack at other
vulnerable stages (Frisbie, 1975). Potential control from rotation is limited
by the fact that many grain growing areas in Texas are not adapted to crops
other than grains (Thomas, 1975). Additionally cotton/grain and cotton/
sunflower rotations in other locations are not always plausible as the market
for cotton may be uncertain and sunflower seeds are a crop of limited demand
(Frisbie, 1975). Insect infestations often exhibit densities directly
proportional to the seeding rate, therefore, an increase in the rate of seeding
will not necessarily produce the desired stand (Frisbie, 1975) .
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
-288-
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Bibliography
1. Agricultural Statistics, 1974, USDA (U.S. Government Printing Office).
2. EPA, C&E,Division, Diazinon Chemical Substitute Review, 1975.
3. Hageman, Frederick, Summation of Results of EPA/USDA Questionnaire on
Projected Recommendations for Chlordane and Heptachlor in 1975 and
Corn Belt Recommendations of Corn Soil Insect Control, 1975.
4. USDA, Economic Review Service, Economic Impact of Discontinuing Farm Uses
of Heptachlor, ERS-509, 1973.
5. USDA, Economic Review Service, Economic Impact of Discontinuing Farm Use
of Lindane and BHC, ERS-524.
-289-
-------
Bibliography-Personal Communication
Apple, Dr. John, University of Wisconsin, Madison, Personal Communication
with Frederick Hageman, August 28, 1975, and September 5, 1975.
Frisbie, Dr. Raymand, Texas A&M University, College Station, Personal
Communication, August 27, 1975.
Kelly, Dr. E.M., University of Florida, Gainesville, September 5, 1975.
Lange, Dr. W. Harry Jr., University of California at -Davis, Personal Communica-
tion, August 27, 1975.
Launer, John, Dekalb Seed Co., Dekalb, Illinois, Personal Communication,
August 29, 1975.
McGilvey, Don, Funk Seed Co., Bloomington, Illinois, Personal Communication,
August 29, 1975.
Park, Earl L., Agricultural Statistician, Purdue University, West Lafayette,
Personal Communication, August 29, 1975.
Thomas, Dr. John, Texas A&M University, College Station, Personal Communication,
August 28, 1975 and September 5, 1975.
Velsicol Corporation (Seller, .Conners,and Cuneo), Written Communication to
to William Reukauf, June 23, 1975.
-290-
-------
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-292-
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EXHIBIT S
ECONOMIC IMPACT OF SHIFTING TO
CHLORDANE/HEPTACHLOR ALTERNATIVES ON
LAWN AND TURF
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
Environmental Protection Agency
September, 1975
-293-
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Economic Impact of Shifting to
Chlordane/Heptachlor Alternatives on Turf
Lawns, ornamental turf and golf courses are invaded by numerous insect
pests. These pests can be grouped into one or more of three general categories:
1. Turf or grass damaging insects
2. Nuisance pests of man or his pets
3. Health hazards
Turf/Grass Damaging
A list of Federally registered chlordane uses on insects occurring on
turf was compared with available state insecticide recommendations for these
uses. It was found that chlordane was not recommended for many insects for
which it is registered. Chlordane was recommended for insects in the following
categories: ants (damage by mound building); white grubs (feeding damage of
grass roots by larvae of several species of beetles, including the Japanese
beetle); cutworms, sod webworms, and armyworms, mole crickets along the
Atlantic seaboard, grasshoppers; and leafhoppers (grass feeding damage). Leaf-
hoppers also transmit plant diseases to other desirable plants, and may be
controlled for this reason.
Nuisance
Mites, earwigs, chiggers, ticks, wasps, bees, and fleas are nuisance
pests. These insects may not only attack man but may also bite or parasitize
pets.
Health
Fleas and ticks may be carriers of Bubonic plague (fleas) and Rocky
Mountain Spotted Fever (ticks).
-294-
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Group 1 insects may cause considerable damage to lawns and turf, primarily
by feeding on roots or lower stems of grass causing death of patches of large
areas if left uncontrolled. In extreme cases, this may cause major economic
damage requiring the replacement of established turf. When attack by any of
these insects has been diagnosed, prompt area wide treatment by the several
recommended chemicals can usually be expected to achieve control. In addition
to the pests named above, there are some locally important pests which are
normally controlled with other agents and for which chlordane and heptachlor
are not recommended in the sampled states. These include chinch bugs and
billbugs in local areas. Earthworms and nightcrawlers are considered pests on
golf greens and newly seeded grass, because of their access holes and soil
castings (western states mainly).
Group 2 nuisance pests include some insects which are locally important
and are controlled by the same recommended chemicals.
Future benefits of chlordane in control of lawn and other insect pests
will be affected by development of pest resistance. Widespread use over the
last two decades has resulted in documented resistance in pests (Brown, A. W. A.,
1971, "Pest Risistances to Pesticides," in Pesticides in the Environment, Vol. 1,
Part II, ed. R. White-Stevens). Pest resistance is a phenomenon also in alter-
native controls, but its extent is likely to be less since alternatives have
been used for short periods of time.
Another factor which limits the usefulness of chlordane on lawn/turf is
that when used it reduces the earthworm population resulting in a build-up of
thatch, thus leading to a sod-bound condition, possible build-up on secondary
pests and need for lawn renovation. (Personal conversations with Dr. Luckman,
-295-
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entomologist, University of Illinois, 1975; Dr. Streu, entomologist, Rutgers
University, 1975; Dr. Roscoe Randell, et^ al., University of Illinois, 1975,
including published article).
Cost Impact Analysis
Table 1 presents the costs for controlling major lawn/turf pests on one
acre of land. It is evident that while many pests are limited to a few regions,
white grubs, sod webworms, armyworms and cutworms are widespread. Most states
surveyed recommended one or more alternative controls for their listed pests.
Only in the cases of California and the 1971 USDA recommendations for white
grub control was chlordane the only recommended chemical. Other states recom-
mended on to three alternatives.
Control Costs for Golf Courses and Other Large Area Uses
Costs were computed using 1975 retail prices secured from representative
farm co-op stores for typical purchases by large buyers, such as golf courses
or other institutions. Table 2 summarizes these costs and provides the basis
for evaluating the impact of cancelling these uses of chlordane.
The basis for the golf course analysis was 50 acres of fairways and three
acres of greens. Prices for chemicals were from 1975 price list for farm supply
stores compiled by USDA. Average costs of treatments for 11 pests for chlordane
control were $12.33 per acre ($653.49 for an entire golf course). The average
for the lowest cost alternatives was $10.57 per acre ($93.28 less than chlordane
for an entire golf course). The average of the second lowest alternative costs
is $20.34 per acre which would amount to $424.53 more than chlordane for an en-
tire golf course. It is recognized that the use of alternatives may involve
more frequent applications. However, offsetting this is the fact that many
-296-
-------
greenskeepers have used chlordane for both insect control and as a herbicide
to control crabgrass (often with very heavy applications) for several years.
This has caused increasing problems of insect resistance to chlordane and
dependence on alternatives.
Home Lawns
Control of insects on home lawns requires considerably higher per acre
chemical costs than incurred by institutional buyers. Products available to
homeowners are typically in lower concentrations of active ingredients and in
small packages. For example, control costs for homeowners for sod webworms,
armyworms and cutworms would increase from two to seven times over that paid
by quantity buyers of the three major chemicals used (chlordane, diazinon,
carbaryl), using retain store prices from a typical midwestern city. These
same prices when used to compute costs for insect control on a 1/5 acre lot
reveal a savings for least cost alternatives and some increase in costs for
other alternatives. Any per year increase in costs for an individual, however,
assuming a 1/5 acre lot, is minimal (See Table 3).
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September 1975
-297-
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Sample
EPA States
Region Pest
Table 1. Cf-.tr.'3 Co^ta j.cr Acr* for the Principal Insect
Pests en Turf. Law.s, and Gulf Courses Ij
Chl t^S, fro.
nd rctJect distributor (wholesale) prices.
(1-2 Ib. A
" %
6.40
4.51
12.72
for the states idcntiflet
n data secured frou seven
28.03 (Konncl)
6.40 8.32(llndane)56.C(>(8->nnol)
4.51 (4.62 Ib, AI/AC,Iil'l ic.ij
19.95(Catdoaa)
U.gO(Koptachlar)
14.eO(Heptac>ilor)
14.16(A-,?«n 111. only)
7.90(Kcp:ac:,lor)
5.4S(Kelth.-nj)
7.24(Hept;ichlor)
7.24(Heptachlor)
-298-
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EFA
leglo
Sanple
States
Table 1. (Continued)
CMor-
Chlord«n« Diaslnon Carbaryl pyrlCas Kilky Spore
(Dureban (k)J Disease
Ronnel Lindnnt Ethion Aspdn
Toxaphene Dylox Akton Malachion Cardona Kern,:,* Vra-'uon
and others
(Cost per acre cctive Ingredient,
VI OH.KM
VII K.IA
VIII ET.VD.VY
(Utah uses USDA rec- -
otuGCntiacions. Feu- re-
ceived fro* S2 t. KV.)
IX CA
K OK
Ant*
Vhite 5rub*
Japanese
Beetles
Arayworns, Cue-
worms, Sod web-
worois
ricas
Mites
Crickets
Grasshoppers
Earwigs
Chlggers
Ticks
Leafhoppers
Ants
White Crubs
Japanese
Beetles
Arayworms, Cut-
voras Sod veb-
vorn*
Kite*
Chiggers
Ants
White Crubs
Japanese
Beetles
Armywortns, Cut*
vorms Sod wtb-
voras
Fleas
Kites
Crickets
Grasshoppers
Earwigs
Chlggers
Tlckf
Eiirthworms
lea/hoppers
Vasps Bees
VMce Crubs
Arnywor.-i,, Cut-
worms Sod vttb-
vorms
Kites
Leafhoppers
Aruyvorns, Cut-
-.•orvs Sod wcb-
voms
J3.W
17.31
14.36
.15.45
14.36 .
15.40
18.36
• 7.97
14.99
15.97UA)
15.97
15.97
18.61
14.40
3.98
3.98
9.96
7.97
3.98
3.98
27.73
3.98
9.96
19.94
*
10.24
16.23
19.35
25.31
5.80
25.31
8.37
25.31
9.89
28.36
28.68
26.68
5.81
28.00
9.89
20.75
31.63
9.89
9.1.3
5.81
20.76
50.61
1.09
31.60
31.60
31.91
33.32
33.32 '
33.32
33.32
22.22
15.50
16.42
16.96
17.72
. 22.22
22.22
33.32
2?. 22
22.22
22,22
17.77
'/
46.80
72.00
135.00
10.80
78.40
12.99
1.85
1.85
6.34
6.34
6.34
18.00
18.00
3.9 Ib AI/.AC
2.<0(lindanc)
4.44(M»led)
52.97(Ethle>r)Ia
42.28(Cthlon)
42.28(Ethlo-0
(cutvorns) (sod vobworr.s)
1C.67
-299-
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Table 2 - Average Chemical Costs Per Acre for Control of Turf, Lawn and
Golf Course Insects ]/
A. Ants
EPA
Region2/
Average
Chlordane Diaztnon Carbaryl
Chlorpyrifos
(Dursban)
(Dollars per acre for chemical cost)
19.51
21.80
24.09
24.09
22.37
21.36
21.43
26.95
28.36
25.42
21.16
22.02
32.67
21.91
15.50
22.65
78.40
78.40
72.00
72.00
75.20
Heptachlor
14.80
14.80
B. White Grubs
EPA
Region
1
2
3
4
5
6
7
8 USDA3/
9
Chlordane Diazinoi: Carbaryl
Chlorpyrifos
(Dursban)
Dyl ox
(Dollars per acre for chemical cost)
14.85
7.16
21.80
15.36
11.05
13.04
14.99
18.84
19.94
25.53
29.46
26.26
16.23
28. F8
21.16
32.67
16.42
12.72
135.00
Average
15.23
25.23
23.41
135.00
12.72
y Application rates were taken from the State Extension Office recommendations
for the states identified, and pooled for the region^. Prices were
calculated by Walter Ferguson, ERS, from data secured from seven repre-
sentative Farm Cooperatives and reflect prices, as paid by farmers and in-
stitutional buyers.
2J Sample states, 1-3 per region, were averaged from Table 1 to report
chemical costs for single applications of each chemical. Regions
listed are all those for which state recommendations were found.
3/ 'The Extension Service of Utah uses the recommendation published by the
U. S. Department of Agriculture for the entire country although many
pests covered are not problems in that state; very few pests were
covered in the other Region 8 states, North Dakota and Wyoming.
-300-
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Table 2 - Continued
C. Japanese Beetles
EPA
Region
Average
Chlordane Djazinon Carbaryl
Chlorpyrifos
(Dursban)
(Dollars per acre for chemical cost)
2
3
4
5
7.16
21.80
15.36
22.10
29.46
26.26
—
26.81
16.60
27.51
32.67
32.67
144.00
144.00
Milky Spore
Di sease
36.40
45.50
40.95
D. Army worms, Sodwebworms, Cutworms
EPA
Region
1
2
3
4
5
6
7
81JSDA
9
10
Chlordane
16.83
—
...
11.93
5.31
17.31
15.97
14.40
.._
10.24
Average 13.15
Diazinon Carbaryl
24.05
34.37
26.54
20,76
24.25
19.35
26.68
28.00
62.17
31.91
(Dollars per
17.05
17.66
22.12
29.40
21.90
33.32
16.96
17.72
_-_
---
Chlorpyrifos
(Dursban)
acre for chemical
_-_
78.40
78.40
78.40
75.60
46.80
10.80
—
78.40
---
Djlox
cost)
___
_-_
___
12.99
15.80
—
_-_
28.10
29.91
22.01
63.83
Toxaphene Aspon Ethion
4.16
14.16 52.97
18.96 4.16
14.16 52.97
E. Fleas
EPA
Region
5
6
8USDA
Average
Chlordane Diazinon Carbaryl Heptachlor Malathion
(Dollars per acre for chemical cost)
7.90
14.36
3.98
9.17
6.86
25.31
9.89
14.02
21.91
33.32
22.22
25.82
7.90
6.34
6.34
-301-
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Table 2 - Continued
F. Mites
EPA
Region
4
5
6
7
8USOA
a
Average
Chlordane
Diazinon Carbaryl
Kel thane Malathion Etl-
(Dollars per acre for chemical cost)
4.42
15.97
3.98
8.12
G. Crickets (mole &
EPA
Region
4
6
8USDA
Average
21.43
26.95
5.80
20.75
31.60
21.30
32.67
22.22
27.44
5.48
5.48
4.51
18.00 42
11.25 42
field), Grasshoppers
Chlordane Diazinon
11.80
15.45
9.96
12.40
(Dollars per
27.85
31.63
29.74
Carbaryl
Chlorpyrifos
(Dursban)
Toxaphene
acre for chemical cost)
32.67
32.67
54.00
54.00
1.39
1.85
9.25
4.16
.28
H. Earwigs
EPA
Region
Chlordane
Oiazinon
Carbaryl
Chlorpyrifos
(Dursban)
(Dollars per acre for chemical cost)
4
6
8USDA
9.64
14.36
7.97
21.43
25.31
32.67
33.32
33.32
66.96
Average 10.65
23.37
33.10
66.96
-302-
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I. CMggers
Table 2 - Continued >
EPA
Region
Chlordane
Diazinon
Carbaryl Malathion
Toxaphene
Lindane
Heptachlor
(Dollars per acre for chemical cost)
4
5
6
7
8USOA
1.92
2.29
15.40
15.97
3.98
21.43
6.86
8.37
---
9.89
26.14
— —
— —
18.00
22.22
1.39
—
1.85
...
—
1.88
—
2.60
—
...
7.24
...
...
—
Average 7.91
11.64
24.18
18.00
1.62
2.24
7.24
J. Ticks
EPA
Region
Chlordane
Diazinon
Carbaryl
Chi or
pyrifos
(Dursban)
Mala- Toxa- Hepta-
thion phene Gardona cnlor
(Dollars per acre for chemical cost)
4
5
6
8SJSDA
1.48
2.29
14.36
3.98
21.43
6.86
25.31
9.89
32.67
—
33.32
22.22
21.35
18.00
—
—
1.39 19.95 7.24
— — — —
6.34 —
— — —
Average
5.53
15.87
29.40
19.97
6.34 1.39
19.95
7.24
K. Leafhoppers
EPA
Region
6
8USDA
9
Chlordane
7.97
3.98
Diazinon
9.89
20.76
31.60
Carbaryl
22.22
22.22
—
Malathion
6.34
—
---
Naled
4.44
—
—
Average
5.97
20.75
22.22
6.34
4.44
-303-
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T;il>le 2 - Continued
L. Wasp. Bees, Cicada Killers
EPA
Region Chlordane Diazinon Carbaryl
(Dollars per acre foi chemical cost)
4 12.02
8 USDA 9.96 50.61 17.77
(Dollars per acre for chemical cost)
8 USDA 27.73 5.81
10 16.67
Average 22.20 5.81
Average 10.99 50.61 17.77
M. Earthworms, Nightcrawlers
EPA
Region Chlordane Diazinon
-304-
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TABLE 3
CHEMICAL TREATMENT COSTS FOR LAWN PESTS AS
INCURRED BY HOMEOWNERS USING RECOMMENDED CONTROLS!/
A. Ants; spot treatment of 1000 square feet, where mounds are present.
Chlordane Diazinon Carbaryl Pursban Heptachlor
$3.87 $4.88 $1.94 $1.35 NAl/
B. White Grubs; if found, assume all lawn is treated, 3700 square feet.
Chlordane Diazinon Carbaryl Dursban Dylox
$33.71 $29.33 S12.63 $21.17 MA
C. Japanese Beetles; treat all 8700 square feet of lawn.
Chlordane Diazinon Carbaryl Dursban Milky Spore Disease*
$25.00 $50 95 $53.59 $35.33 $11.65
*NOTE: Milky spore disease is also used to control this pest but
requires wide area application (e.g., subdivisions or larger)
for successful control.
D. Spdwebworms, Cutworms^ Army Storms; treat all 8700 square feet.
Chlordane Diazinon Carbaryl Dursban Dylox Toxaphene Aspon
$9.30 $42.46 $8.41 $10.83 NA MA NA
E. Fleas; though likely localized where pets are kept, assume entire
lawn is treated, 8700 square feet.
Chlordane Diazinon Carbaryl Heptachlor Malathion
$13.64 $42.46 $16.87 NA $15.00
F- Mites; same as for fleas, 8700 square feet treated.
Chlordane piazjjion Carbaryl Kelthane Malation Ethion
$6.20 553.68 $16.87 NA $2.16 NA
G. Crickets (mole and field] and grasshoppers; assume all lawn is -treated,
8700 square feet.
Chlordane Diazinon Carbaryl D'irsba'n Toxaphene
$16.86 $29.54 $16.83 $8.11 NA
J/ See attached price list (prices in Cincinnati, Ohio).
2/ NA - retail prices were not available for these recommended chemicals.
-305-
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Tablf. 3. (Continued)
H. Earwigs; assume all lawn is treated, 8700 square feet.
Chlordane Diazinon Carbaryl Dursban
$13.49 $42.46 $!•"..83 $19.54
I. Chiggers; require area treatment, assume 8700 square feet.
Chlordane Diazinon Carbaryl Malathion Toxaphene Undane Heptachlor
$11.53 $13.66 $53.59 $8.45 NA $1.30 NA
J. Ticks; require area treatment, assume 8700 square feet. .
Chlor- Diazi- Car- Durs- Mala- Toxa- Gar- Hepta-
dane non baryl ban thion phene dona chlor
U.65 $7.60 $16.83 $117.63 $10.57 NA NA MA
K. Leafhoppers; because of plant disease transmission, area treatments
are needed, assume 870J square feet.
Chiordane Diazinon Carbaryl Malathion Naled
$13.49 $9.23 $16.86 $15.00 NA
L. Wasps. Bees, Cicada Killers, etc.; usually spot treatments to nesting
areas, assume the equivalent of 1000 square feet.
Chlordane Diazinon Carbaryl
$1.94 $9.76 $6.16
M- Earthworm. Nightcrawlers; Not a problem on home lawns, mainly on golf
greens and tees.
-306-
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Attachment A
Region V - Comparable Prices
for Chlordane and its Substitutes
(Ohio, Indiana, Illinois, Michigan, Wisconsin, Minnesota)
Retail Prices
Chlordane 10% WP
80% E
45%
6% Dust
72%
Captar - Malathion
DDVP (vapona)
Lindane 12W
25W
Malathion 57%
50%
4% Dust
Ronnel 2E
Sevin 50WP
5% WP
Methoxychlor 25%
50 WP
Dia^inon 1 Ib/gal. cone.
5% Dust
Rotenone 1% Dus£
Dursban 6%
cage Size
1 Ib
1 qt
1 qt
1 Ib
1 qt
1 Ib
1 gal
1 Ib
1 Ib
1 qt
1 qt
1 Ib
1 qt
1 Ib
1 Ib
1 qt
1 Ib
1 qt
1 Ib
1 Ib
1 qt
Range
1.39-1.69
4.65-5.98
7.49-8.49
7.05-8.49
1.37-1.39
2.75-5.00
1.39-1.69
4.49-5.25
2.39-2.49
1.39-1.69
Averagi
1.55
7.50
5.30
1.20
1.62
4.05
2.61
4.55
7.77
6.98
1.38
4.52
3.87
1.54
4.87
4.98
6.79
2.44
1.54
6.49
-307-
-------
EXHIBIT T
INSECTICIDE RECOMMENDATIONS OF
SURVEYED'STATES FOR HOME AND
GARDEN PESTS, 1975
TABLES WITH CHLORDANE RECOMMENDATIONS
Table 1
Table 2-7
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Household
Home Garden
Cabbage
Cucumber
Lettuce
Peas
Potatoes
Tomatoes
TABLES WITH NO CHLORDANE RECOMMENDATIONS
Table 8-13 Home Garden
Table 8 Cabbage
Table 9 Cucumber
Table 10 Lettuce
Table 11 Peas
Table 12 Potatoes
Table 13 Tomatoes
-308-
-------
•a
1
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-309-
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-325-
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EXHIBIT U
ECONOMIC IMPACT OF CANCELLING CHLORDANE AND HEPTACHLOR REGISTRATIONS
ON ORNAMENTAL PLANTS IN COMMERCIAL NURSERIES
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
Environmental Protection Agency
September 1975
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Economic Impact of Cancelling Chlordane and Heptachlor
Registrations on Ornamental Plants in Commercial Nurseries
Summary of Results
1. Estimated increase in cost to industries to purchase substitute insecticide,
$386,940 per year.
2. Average increase in cost to purchase substitute insecticides by individual
nursery firms, approximately $77.39 per year.
3. Cost to consumer — negligible.
4. Estimated use of chlordane in pounds of active ingredient on ornamentals by
nurseries in 1974 — 249,872 pounds.
5. Chlordane is an efficacious and inexpensive insecticide in ornamental use.
Heptachlor is rarely, if ever, used in insect control on ornamentals.
6. The major impacts of cancelling chlordane are in two areas:
(a) Quarantine Program
(b) Unique insects where chlordane is the only effective control
7. Problems associated with the USDA Quarantine Program. A large volume of
nursery plants in interstate commerce are covered by the USDA Quarantine
Program (percent unknown). The unavailability of chlordane would either
prevent the shipment of these plants or increase the cost of quarantine
requirements 10 to 15 times, according to an estimate from the nurserv
industry.
8. Problems associated with unique insects. In some areas of the country,
insects causing damage to ornamental plants are controlled effectively
with chlordane only; an example of this is the black vine weevil (taxus
weevil).
-327-
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Introduction
Velsicol Chemical Corporation provided data on pounds of C/H applied
for 1973 and 1974 by category of use. Two of these categories are: (1)
ornamental and (2) home, garden and lawn. For purposes of this report it is
assumed that household use of C/H for ornamental treatment is included in
the latter category and the former category, ornamental, includes treatment
in the commercial nursery industries .I./ This analysis is restricted to
commercial nursery uses of C/H only.
Ornamental plants include shade, flower and fruit trees, conifers,
broadleaf evergreens and numerous flowers and shrubs.
The Nursery Industry
The nursery industry includes wholesale growing operations, landscape
firms and retail garden centers. A recent study provides an overview of this
industry (1). Retail sales of the nursery industry for 1971 were $2.1 billion
and wholesale value of these sales was $700 million. In that year expenditures
for chemical pesticides used by the industry including insecticides, herbicides
and fungicides was $14.8 million. Additional pesticides were purchased, but
these were for resale at garden centers. Most pesticide use is at the grower
or wholesale level. Pesticide expenditure as a percent of sales to growers
was 2.1% in 1971.
I/ The author attempted to confirm this assumption with officials of Velsicol.
At the time of this writing no reply has been received from Velsicol.
-328-
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Insects Controlled
Ornamentals are attacked by numerous insects. According to Webb of USDA,
the most serious pest in the absence of chlordane is the black vine weevil (2).
One ground application of chlordane per year provides effective control for
this pest. A recent USDA/EPA survey of states concerning C/H use lists
several damaging insects for which chlordane is the preferred control due to
ineffectiveness and/or higher costs of substitute pesticides (3). Some of
the most important insects include hog worms, leaf beetles, leaf miners,
thrips, Japanese beetles (adults), white fringed beetles, mole crickets and
cutworms.
1975 State Recommendations for Ornamental Plants
A review was made of 1975 recommendations for ornamental plants from
15 states. Using these states as a guide, it is clear that chlordane is seldom
recommended for most insect-site combinations. However, chlordane is the only
recommended insecticide in some instances. Table 1 includes the C/H
recommendation from 15 states.
Soil Treatment
Based upon the USDA/EPA survey, many states recommend soil treatment on
ornamentals ranging from flowers to trees. The black vine weevil (or taxus
weevil) and other root weevils are listed as pests in states across the nation.
Other common soil pests are bulb flies, white grubs, and cutworms. More
localized are the depredations of the white fringed beetle in the southeast,
and the Japanese beetle grubs, Oriental beetle grubs and European beetle grubs
in the northeast.
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Table 1
Summary of chlordane and heptachlor
recommendations on ornamental plants for 1975, 15 states
State
Florida
Georgia
Indiana
Alabama
Arizona
-r
Delaware
Louisiana
Maryl and
Ohio
Pennsylvania
South Dakota
North Dakota
Insect
Ants
Ants
Black vine weevil
Ants
Armyworms
Sod Wedworms
White grubs
Pi 11 bugs and Sowbugs
Boxelder Bugs
Caterpillars or worms
Crickets
Cutworms
Dackling Beetles
Earwigs
Snails; slugs
Black vine weevil
Narcissus bulb flies
Grubs
Leaf Miner
Japanese Beetles
Ants
Bagworm
Ants
White grubs
Seed Maggots
Wireworms
Termites
Weevils
Boxelder Bugs
Leaf Beetles
Webworms
Chlordane Heptachlor
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Other
Insecticides
(number)
3
1
4
1
3
2
1
4
8
1
1
2
2
3
-330-
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Table 1. (Continued)
State
Tennessee
Washington
Virginia
Other
Insect Chlordane Heptachlor Insecticides
(number)
Giant hornet
Asiatic Garden Beetle
Taxus Weevil
Rose Trips
Black vine weevil
Strawberry root weevils
White grubs
1
1
1
1
1
1
1
9
0
1
1
2
SOURCE: 1975 State, recommendations, USDA/EPA survey, 1974 (3).
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Chlordane treatment of above ground pests is also advocated in a few
states. The following insects are a composite group of those controlled in
these states: ants, leafhoppers, rhododendron borers, poplar and willow
borers, leaf feeding beetles, blister beetles, grasshoppers, katydids,
various caterpillars, the magnolia leaf miners, and termites.
Foliar Treatment
Seven states will make foliar treatment recommendations for above ground
pests of ornamental plants. Some of these pests are boxelder bug, rhododendron
borer, willow tree borer, adult black vine weevil, magnolia leaf miner,
bagworm, thrips, and adult Japanese beetles. The state of Ohio conducts
regulatory programs utilizing both chlordane and heptachlor to prevent the
spread of some of these pests.
Quarantine Programs!/
The USDA prohibits the movement of nursery stock from federally quarantined
to non-quarantined areas unless certified and treated with an approved insecticide
Chlordane is the only insecticide used on all nursery stock in the quarantine
program. One application of chlordane of five pounds active ingredient per
acre on nursery stock certifies a plant for three years under the current
USDA requirements. According to Brush, 12 to 15 applications of alternatives
would be required to achieve equivalent results using chlordane.2.7 Control
costs would increase greater than 12-15 times, due to higher cost of
alternatives and additional labor machinery and other inputs.
~\J One estimate of the amount of chlordane used in the quarantine program
by USDA is 204,300 pounds in 1972. Source: RvR Consultants. Production,
Distribution, Use and Environmental Impact Potential of Selected Pesti-
cides. Contract No. EPA 540/1-74-001, 1974.
2j Personal communication between Mr. Ray Brush, Secretary, American Association
of Nurserymen and G. K. O'Mara, OPP, EPA, September 4, 1975.
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Brush states that one trend in the nursery industry is towards increased
specialization in the growing of plants. This trend would tend to increase the
volume of plants covered under the USDA quarantine program. According to Bush,
the use of chlordane not covered by the cancellation, viz., the dipping of roots
and tops of non-food plants is inadequate to meet the needs of plants in
shipment. Adequate treatment of balls in this manner results in the loss of
earth around roots causing a sharp decline in the survival rates of plants. In
addition, there would be difficult disposal problems with the chlordane-treated
water because of the large volume and size of many of the plants in question.
Chlordane Use and Cost Data
Data on chlordane use on ornamentals is presented in Table 2. Heptachlor
is not used in any important manner for ornamentals. Personal communication
with USDA confirms that heptachlor is not used to treat ornamental plants (2).
The price of chlordane in 1971 was $1.30 per pound.— The USDA poundage
figure for chlordane in 1971 (Table 2) at $1.30 per pound implies an
expenditure of $172,900 by nurseries for chlordane, or 1.2% of total pesticide
expenditures of $14.8 million.
_!/ 1971 price is an estimate by EPA.
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Table 2. Chlordane used by the nursery industries annually in pounds of
active ingredient
Chlordane used by nursery industries
Year AI Lb
1971 133,OOQl/
1973 227,882l/
1974 249,872i/
Source:
]_/ Andrilenas, P.A., Quantities of Pesticides used by Farmers in 1971.
ERS, USDA. Washington, D.C., 1973
2J Letter: From Sellers, Conner and Cuneo (counsel for Velsicol Chen. Corp.)
to W. Reukauf, Attorney, EPA. Washington, D.C., June 23, 1975.
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Economic Impacts
Comparison of Cost of Chlordane and Substitute Pesticides
Prices of chlordane and six other insecticides are listed in Table 3.
Prices should be representative for 1975. Table 4 lists five major
representative pests which attack ornamentals. In addition to chlordane,
five registered insecticides are included. The entries in Table 4 are
application rates in pounds of active ingredient per 100 gallons of water.
The numbers in parenthesis include the frequency of application per year.
Table 5 provides an indication of costs to the nursery industries if
chlordane is cancelled for this use.— The entries in Table 5 are derived from
information in Tables 3 and 4 and are obtained by averaging the information
across the five insects in Table 4. Rates of application and number of
applications as specified by state recommendations are used to estimate the
pounds of active ingredient of each substitute required per year relative to
that of chlordane. Total pounds of chlordane used in 1974 by nurseries (Table 2)
provides an upper estimate of use and retail price (Table 3) is used to estimate
expenditures for chlordane. Similar analysis is provided for substitute chemicals.
Total cost of chlordane and for its substitutes (assuming each other insecticide
substitutes entirely for chlordane) are shown in column 9 of Table 4.
One method to estimate increased costs due to a chlordane cancellation is to
use an equally weighted average of the total cost of the five substitute
The reader should be aware of the limitations of these cost estimates. Their
accuracy depends upon several assumptions, including comparable efficacy,
reliable use estimate of chlordane in nurseries, and others.
-335-
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Table 3. Price of Pesticide Per Pound of
Active Ingredient for 1975^
Insecticide
Chlordane
Toxaphene
Carbaryl
Malathion
Diazinon
Methoxychlor
Dimethoate
Retail Price 1975
Per #AI
$1.77
1.06
2.27
2.68
.5.12
2.76
8.57
if Source: Prices were obtained from the Economic Research Service, USDA
and represent prices paid by farmers and nurserymen in several
regions of the U.S. in quantities of 5 gallon containers.
-336-
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chemicals from Table 5. The average expenditure for the five substitute
chemicals is $829,440 per year and this compares with $442,500 spent on
chlordane. The cost of the nursery industry to replace chlordane is $386,940
per year.
Summary
To the typical nursery firm and to the nursery industry, impacts measured
in terms of absolute changes in costs are small. An increase in cost of
$386^940 relative to industry sales is in the range of 0.02% to 0.03%. Assuming
there are approximately 5,000 firms in the industry, average cost per firm would
increase about $77.39 per year to replace chlordane with other insecticides.
Costs to the consumer would be negligible.
To assess the value of chlordane, it is also necessary to determine its
value relative to other insecticides in the control of pests. For certain pests,
such as the black vine weevil, chlordane is the only effective insecticide in
some areas of the country, according to 1975 state recommendations. In cases
such as these, chlordane would have a very high benefit/cost ratio. A
qualitative assessment of the value of chlordane in ornamental use should be
determined in the C/H suspension hearings. It cannot be done quantitatively with
available information.
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September, 1975
-339-
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References
(1) Horticultural Research Institute Inc. Research Summary - Scope 11 of
the Nursery Industries. Hort. Res. Inst. Bethesda, Md., 1973.
(2) Personal communication between R. Webb, Animal and Plant Health Inspection
Service, USDA and G. K. O'Mara, Office of Pesticide Programs, EPA.
August 25, 1975.
(3) USDA/EPA. C/H Survey to obtain use estimates and use recommendations
for 1975 by states and territories. Survey distributed by Cooperative
State Research Service, USDA. Washington, D.C., December 16, 1974.
-340-
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EXHIBIT V
SURVEY OF PRODUCERS OF MAJOR SUBSTITUTES FOR
CHLORDANE/HEPTACHLOR
Gary Ballard
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September, 1975
-341-
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Survey of Producers of Major Substitutes
for Chlordane/Heptachlor
The following information is based on telephone contacts with representatives
of the firms producing the major alternatives to chlordane and heptachlor.,
Contacts were made during late August and early September 1975.
Furadan - Furadan is a proprietary compound of the FMC Corporation.
Jim Campbell (Product Manager for Furadan) stated that corn is the primary
market for furadan and this market will be fulfilled by FMC to the extent
possible. A major expansion of production facilities occurred in late 1973,
which increased supplies substantially for 1974 and 1975. The supply
situation will be essentially the same for 1976. There is a large export
market for furadan and the relative proportions allocated to the domestic
and foreign markets can and will be adjusted given the demand situations.
Plans are being reviewed for additional expansion of production facilities
but the expansion would require two or three years to complete. In the
near term any expansion in domestic sales would come at the expense of
exports. FMC is willing to follow this course at least to some degree in
order to meet the needs of domestic corn production and to protect its market
in the Corn Belt.
Dyfonate - Dyfonate is a proprietary product of Stauffer Chemical Company.
Herbert Odin (Manager of Sales Services) stated that there would be full
availability of supplies to meet the foreseeable demand for dyfonate in 1976.
New facilities for production are currently under construction and will be
completed for the 1977 marketing year. The new capacity is expected to in-
crease the supply of dyfonate by 50% over the 1974-75 levels. There will be
a continuing upward trend in the supply of dyfonate.
-342-
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Dasanit - Dasanit is a registered trademark of the Chemagro Agricultural
Chemicals Division of Mobay Chemical Corporation (Chemagro). Ken Schuttler
(Product Manager of Chemagro) explained that the production of Dasanit has
been hampered by a shortage of intermediate feedstocks. Steps are currently
being taken to alleviate the shortages but the prognosis for success is at
present uncertain. There are no plans currently to expand production facilities.
Production should, however, increase by an unknown percentage once the intermediate
shortages are solved. As for the possibility of increasing supplies, Dasanit
is not produced with dedicated equipment, that is, other products are produced
with the same facilities. If there are sufficient intermediate materials, the
product mix could be adjusted to a higher proportion of Dasanit.
Farm Chemicals Handbook (1975) also lists Bayer AG of West Germany as
a basic producer of Dasanit. This presents the possibility of increasing
the domestic supply of Dasanit by importing the compound from West Germany.
Possible levels of importation are not known, however.
Mocap - Mocap is a registered trademark of Mobil Chemical Company. Staley
Felton (product manager for Mocap) stated that Mobil was capable of meeting the
expected demand for Mocap. Mocap is primarily used as a nematicide on tobacco
in the southeast. Mocap is registered for use against corn rootworms and
wireworms. The use of Mocap on corn is now the second largest market in terms
of pounds used. A portion of the use on corn is for control of nematodes in
the southeast but the breakdown between nematode control and soil insect control
is not available. Mobil has test results which show that Mocap is an effective
control of cutworms on corn and an application for experimental use of Mocap
for use against cutworms on corn is being prepared for submission to EPA to
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obtain data for registration. Art Huvar (Manager, Registration and Development)
stated that a bottleneck has occurred in this application in that the appli-
cation must contain the site and name of the persons conducting the tests.
Since cutworm infestation is variable in many areas it is difficult to
contract for test sites in advance and be sure that there will be a pest
infestation that will provide reliable data on the efficacy of the compound.
Mobil hopes to overcome this problem and obtain an experimental use permit
for cutworms on corn for 1976. Three factors are involved in assessing the
availability for mocap. First, approximately 20% of Mobil's production is
exported. The proportion allocated to the domestic market can be varied.
Second, mocap is not produced in dedicated facilities, therefore, the
product mix can be varied to favor higher production of mocap. Third,
the physical plant can be operated for longer periods of time by adding one
or two shifts to the present work force. Thus, given sufficient demand and
new materials, mocap supplies can be increased on relatively short notice.
Sevin - Sevin is a registered trademark of Union Carbide Corporation.
Bill Nissen (Agricultural Marketing Manager) stated that the supplies of
Sevin products were tight in 1974 and in 1975. New production facilities are
currently being added which will expand capacity by 15% by 1976 and a total
of 50% over the next three years. Union Carbide considers corn to be one
of its major markets for Sevin and efforts are being made to expand their
sales in that area. Sevin is currently used in bait formulations to control
cutworms. Union Carbide hopes to gain farmer acceptance of using an oil
formulation of Sevin against the adult rootworm late in the season. The
bait formulations are considered by Union Carbide to be a minor use for
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Sevin since bait formulations contain relatively small amounts of active
ingredient. Union Carbide hopes that a greater gain in sales will occur
in the use of spray treatments against the adult pests.
Bux - Bux is a registered trademark of the Chevron Chemical Company.
Donald Dye (Coordinator for Regulatory Affairs) stated that the use of Bux
is declining due to the development of resistance in corn rootworms. It
is felt that Bux usage will continue to decline and the product will no
longer be a strong substitute for use against corn rootworms.
Dursban - Dursban is a registered trademark of the Dow Chemical Company.
Bob Morgan of Dow stated that the supply of Dursban would be measurably
increased over the current year. Also Dow is actively attempting to expand
the market for Dursban use on corn. Although the increase in supply is not
available, Dow views its supply of Dursban to be sufficient to meet demand
barring unforeseen shortages of intermediates.
Diazinon - Diazinon is a registered trademark of Ciba-Geigy Corporation.
Carl Kensil of Ciba-Geigy stated that there would be no increase in avail-
ability of Diazinon for 1976 over the present level of supply. There are
some recurring shortates of intermediates which have held down the production
of Diazinon. Steps are being taken to solve these shortages. Also the
physical production facilities are being expanded and increased capacity
will be available for 1977 if adequate intermediates are available.
Although Diazinon is used to some extent on corn, it is not as effective
against rootworms as some other products are. Diazinon is, however, used for
wireworm and cutworm control. Although Diazinon is an effective control for
cutworms, Ciba-Geigy feels that the highly variable nature of cutworm infesta-
tions minimizes the demand for Diazinon. The drawback in using Diazinon on
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cutworms is that the cost of the product detracts from its acceptance by
growers since in many cases a treatment for control of cutworms with any
chemical is going to be prophylactic in years when cutworms do not appear at
economic levels. It is Ciba-Geigy's view that growers in most areas regard
rootworm control as the primary consideration in selecting a pre-emergence
corn soil insecticide. Control of wireworms and cutworms then becomes
incidental to rootworm control. Thus, unless a product is effective against
rootworms, the market for that product will not be significant. With these
points in mind, even though Diazinon is felt to be effective against wireworms
and cutworms by Ciba-Geigy, the corn market is not felt to be of major area
in which sales can be expanded.
Ethion - Ethion is a registered trademark of the FMC Corporation. Jim
Campbell (Product Manager at FMC Corporation) stated that Ethion competed with
chlordane for uses on sod and ornamentals. The largest market for Ethion
is on citrus in Florida; this market is not in competition with either chlordane
or heptachlor. The relatively small amounts of Ethion needed for sod and
ornamental treatment should be in sufficient supply.
Aspon - Aspon is a registered trademark of Stauffer Chemical Company.
Herbert Odin (Manager of Sales Services) stated that Aspon is considered a
speciality product used only for cinch bugs and sod webworms in turf. The
market is considered minor in terms of pounds of active ingredient. Stauffer
feels that there will be no availability problems for Aspon.
Orthene - Orthene is a registered trademark of Chevron Chemical Company.
Donald Dye (Coordinator for Regulatory Affairs) stated that 1975 was the first
year for which Orthene was available. The current supply is described as
limited. A pilot plant produced the 1975 supply of Orthene. There will be a
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small increase in supply for 1976 but the availability will still be limited.
A plant is now under construction which is scheduled to be in production of
Orthene for the 1977 season.
Toxaphene - Toxaphene is produced by several firms including Hercules
Incorporated. Henry Pierce (Director of Agricultural Chemicals Division)
stated that the use of toxaphene on corn is variable. Toxaphene is applied
for control of army worms and cutworms on corn. These applications are required
only when periodic outbreaks of the pests occur. There were outbreaks of
cutworms on corn in 1975 and the use of toxaphene rose significantly in the corn
producing states. Hercules had an increase in sales of technical toxaphene to
formulators in the Midwest in 1975. Supplies are also typically available from
formulators in the cotton producing states. Hercules feels that there is
sufficient production capacity to meet the demand for toxaphene when outbreaks
of cutworms occur as they did in 1975.
Lindane - Lindane is produced solely in the United States by the Hooker
Chemical Company. Lindane is made abroad. However, foreign demand prevents
substantial importation of the chemical into the U.S. In 1972, farm use of
BHC and lindane, which is more commonly used, was estimated to be 643 thousand
pounds (USDA, Economic Impact of Discontinuing Farm Use of Lindane and BHC,
1972). Total domestic production of lindane is thought to be less than 1
million pounds, although no specific estimates are available.
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Current total capacity is inadequate to meet total demand for all uses
according to a recent conversation with Mr. Goldman, of Hooker Chemical Company.
Lindane production will be essentially the same until 1977 or 1978 as there are
no current plans for increase production capacity. (Decisions to expand
production have been delayed pending the outcome of carcinogenicity tests).
Gary Ballard
Economics Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September, 1975.
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Contacts
Pierce, Henry F. Director of Agricultural Chemicals Division, Hercules
Incorporated. August 28, 1975.
Kensil, Carl. Ciba-Geigy Corporation. August 25, 1975 and August 28, 1975.
Campbell, Jim. Product Manager, FMC Corporation. August 26, 1975.
Nissen, Bill. Agricultural Marketing Manager. Union Carbide Corporation.
August 27, 1975.
Odin, Herbert. Manager of Sales Services. Stauffer Chemical Company.
August 26, 1975.
Schuttler, Ken. Product Manager. Chemagro Division, Baychem Corporation.
August 25, 1975.
Dye, Donald. Coordinator for Regulatory Affairs. Chevron Chemical Company,
Ortho Division. August 26, 1975.
Morgan, Bob. Dow Chemical Company. August 26, 1975.
Felton, Staley. Product Manager. Mobil Chemical Company. July 9, 1975 and
August 15, 1975.
Huvar, Art. Manager, Registration and Development. Mobil Chemical Company.
September 2, 1975.
Goldman, Richard. Product Manager. Hooker Chemical Company. August 27, 1975.
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EXHIBIT W
REVIEW OF THE SUPPLY OF SUBSTITUTES TO CHLORDANE
AND HEPTACHLOR UNDER SUBSTITUTE CHEMICAL PROGRAM
Economic Analysis Branch
Criteria and Evaluation Division
Office of Pesticide Programs
September, 1975
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Supply characteristics of registered substitutes for chlord/ino and hcptachlor
Type of
Jn&octIcide
Methyl parathion
II)
Azodrin
(2)
O)
Diazinon
(4)
(5)
Aldicarb
(7)
(8)
*, lathi on
(9)
(10)
phorate
(Thi-aet)
furadan
(11)
Dyfonate
(11)
Carbaryl
(11)
(11)
rstlmatfld tit. Dorw'Slic
produc- l'ull Capacity La',lifted Estimated
t jon production lirpott* Fxports , ^.^.Cojnmpn^ •—. _
....._.__ . pounds "--
51 million perhaps aa 1.1 million 12.5 nilUon Some of tho methyl parathlon
(1972) high as (1972) (1972) production capacity can bo
100 million lined to ru.iuf^cturc othiT
organophosphatcs.
•-11 million 14 million none 4.5-6.0 million Production capacity nay
(J973) (1973) expand 25 to 30 percent if
the foodstock shortage
problem is folvod. Additional
supply po!>si!jL 1 it IDS from
foreign proJucrrs conceivable.
5-7 million NA not not Production iu veil below full
(1973-1974) substantial substantial capacity because of the
•hoitago of tho feedstock
prrCT. Construction of a
DCPCT pl'ant is underway. A
dursban pioduction plant is
planned fo r comnloci on in 1976
in Europe to help moot U.S.
demand.
6-7 million $-7 million negligible 1.0-1.5 million Production capacity nay expand
(1974) (1974) (1974) if the feedstock sr.ort.ige
problem is solved. Two foreign
producers arc known to exist.
2 million NA not not Existing plant capacity can be
(1972) substantial substantial used to manufacture other
organophosphat.es,
4 million NA negligible SA Production capacity is lirritcd.
Only by the availability of
feedstocks. One foreign
producer is known to exist.
1.0-1.5 Billion MA none 400,000-700,000
(1972) (1972)
24 million NA 153,600 9 million
(1972) (1972) J1972)
none none 173,000 none
(1971)
6 million 29 raillion none NA Existing plant capacity can be
(1971) (1969) used to manufacture other
organophospha tes, Feed &t ock
shortages will probably con-
strain supply in 1975.
Tight supply expected In 1975
with casing expectec in 1976.
Adequate supplies availably j.n
1975 and it nay be possible to
fill sotnc of the shortages in
phoratc and furadan.
Tight supplies expected, but
capacity should increase by
50 percent at the end of
1976. Supply constraints may
exist because of feedstock
shortages.
High volume of production for
this lew registration c-inr.ot
be expected until 1976-1977.
Perhaps a million pounds can
be produced in 1975 and possibly
* multi-million pound plant will
be available Jn 1978.
SOURCES:
(1) EPA, O?J», Ini.tital Sciontif lc and Jlinipconpmic Pevic''^ of: Ho thy 1 Para t hi on, October 1974.
(2) Arthur D. Little, Tnc,, Axodrin:_-. ___Inj_t_iaI gcjcn^jjjc^and Mir^i-Ecg^riomic Review, draft, Cambridge.
Kassachusetts, October 197T. ——
(3) Arthur 0. Little, Inc., Pui r s ba^n; 1 n i t_t«l__S_c_i_gn t i_f i c a nd M i n J -Econor^i c Revievs . draft. Cambridge,
fta ssachusct ts • December I~9~7*4"^ ' " ""J "
|4) Arthur D. Little, Inc., Initial Scientific and Mini-Eronosic Review of DiaMnon, draft. Cambridge.
ttaasachuscttc, February TiTS. •—
(S) Arthur p. Little, Inc., Initial Scientific and Mini-Economic Review of Dinothgfltc, draft, Cambridge,
Massachusetts, January 1???! ~ ~ ~ r' ^------- ----- - . ... -- .- —--.--^-^.-.^--
(6) Arthur D. Mttlo, inc.. Outhton Initial Scientific and Mini-Econoniic Reviews, draft, Cambridge,
Massachusetts, October l5T4"7 " ' *"
(7) Kldwect Rescorch Institute, Initial Scientific and Kinl-Kconomlc Review No. 5: Aldicarb, draft, Kansas City,
Missouri, Augut-t 1974. ~ '
(0) Kidwfat Kcsearcti Institute. Initial Scientific and Mini-Economic Review of Malathion, draft, Kansas City,
Missouri, 5o;.libber 1974, " " " .
(9) KI»A, OPP, Pgyifjoo Minj-Econo-nir Pcvlrw. draft, Ju)y 1974.
(10) EPA, OPP, Minlvconomic Rpvlow Phornto, drrtft, June 1974.
"" ?Z'™^;^>*^^ .oil Horn, ,.M«. j. Cor, .. ^ ...>...,
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EXHIBIT X
ASSUMPTIONS USED IN COMPUTATION OF
ENERGY IMPACTS OF MANUFACTURING
ALTERNATIVES TO CHLORDANE AND HEPTACHLOR
Chemistry Branch
Criteria and Evaluation Division
Office of Pesticide Programs
May, 1975
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Assumptions Used in Computation of Energy
Impacts of Manufacturing Alternatives to Chlordane and Heptachlor
Tables 21 and 21 (Part I, p. 83, 84) summarize the energy impact of
cancellation of chlordane and heptachlor based on representative substitutes:
carbofuran, diazinon, and carbaryl. Carbofuran, a member of the carbamate
class of pesticides, is the major substitute. Diazinon is an important
substitute among the organophosphate pesticides. It was chosen also for its
chemical complexity. Carbaryl is an inexpensive and widely available
carbmate. Below is a list of the important assumptions made in developing
Tables 21 and 22. These are followed by remarks on the influence of some
general factors.
Assumptions;
1. A private study on chlordane and heptachlor energy requirements was
used to derive energy inputs (Syracuse University Research Corporation).
Comparing process steps, the energy and electricity requirements
from this study were extrapolated to the three substitute pesticides
selected — carbofuran, diazinon, and carbaryl. The dicyclopentadiene
feedstock for chlordane and heptachlor was assumed to be obtained at
no energy cost. The energy costs for the chlordane feedstock were
calculated thermodynamically as 3.44 kWh/lb chlordane and 2.82 kWh/lb
heptachlor, respectively. For the three substitute insecticides
considered, the feedstock chemicals were traced back to natural raw
products or petroleum distillates, with appropriate process energy
(electricity and heat) assigned to each step.
2. The use chosen as representative was that of a soil insecticide on
corn and potatoes.
3. None of the feedstock chemicals are obtained as by-products of
other chemicals. Rather, each has its own independent market and
production economics. An exception was made in the case of chlorine.
Invariably produced with caustic soda, chlorine was assigned only
half its actual energy requirement. The assumption that each feedstock
chemical is produced in a distinct, independent process is in error.
We were unable to evaluate the direction of the error in estimating the
impact of the studied pesticides on petroleum consumption. The American
chemical industry is often able to accomodate supply and price fluctuations
despite joint production. Felicitous by-product relationships are
common, often by design. For example, phenol, raw material for
carbofuran, can be made with either chlorine and caustic or propylene.
If made with the latter, a by-product is acetone, which in turn is
a raw material for diazinon production.
4. Similarly, in calculating "petroleum for feed" in Tables 21 and 22,
it was assumed that petroleum processing can be adjusted to produce
1 Ib of the feedstocks from 1 Ib of crude oil. Since only
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about 10% of petroleum distillates go to petrochemicals, and around 7%
of petrochemicals (by weight) are pesticides, this assumption may be
valid even over a short run.
Despite abundance of divertible petroleum, shortages of particular
chemicals may occur, e.g. because of allocation or limited facilities,
or because joint processes tie production of some materials to that
of others. The effect might be a larger impact on petroleum consumption
than estimated here. On the other hand, carbaryl does not demand a
petroleum base. Its increased use could balance such an underestimate.
Also, phorate, another major organophosphate, requires less petroleum
than diazinon. Since diazinon was taken as the representative
organophosphate, if phorate were the substitute, petroleum use
would be less than estimated here.
5. The mode of application was assumed similar for the substitute,
i.e., soil incorporation and spraying (see Assumption 11 on following
page). Amounts are from entomologists' recommendations published
in Report No. 68-01-2448(6), RvR Consultants.
Based on active ingredient:
Diazinon — 1.3 Ib/lb heptachlor; 0.65 Ib/lb chlordane.
Carbaryl — 1.0 Ib/lb heptachlor; 0.5 Ib/lb chlordane.
Carbofuran — 0.5 Ib/lb heptachlor; 0.25 Ib/lb chlordane.
6. It was assumed that each insecticide is applied one time per season,
with no fuel cost to apply (for example, no tractor fuel). Thus, only
manufacturing energy impact was calculated.
7. Cyclopentadiene, phenol, naphthol, and ethanol, which are feedstock
materials for chlordane-heptachlor, carbofuran, carbaryl, and
diazinon, respectively, may be produced in large quantities from
coal. Only the petroleum source was considered, however.
8. The "total substitute" impact in the tables was calculated taking
diazinon (a typical organophosphate), carbofuran, and carbaryl in
the ratio 7:7:1. It was chosen after consulting with economists,
and taking into account use patterns given in Project Reports #P4-
01-03990, 14 Nov. 1974 (T. Reideburg Assocs.) and # 68-01-2448(6)
(RvR Consultants).
9. The following conversion factors were taken from Chapter 9 of
"Chemical Engineers' Handbook", by J.H. Perry, McGraw-Hill, 1963:
coal 13,000 btu/lb; oil 140,000 btu/gal; 7 Ib/gal, 42 gal/bbl, 294
Ib/bbl; boiler heat 11,500 btu/kWh, 1100 fuel btu/lb steam.
10. Process solvent consumption was ignored. Rather, recovery was
assumed. A quick calculation assuming 5% loss of benzene-like
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solvent gave an increase in "Petroleum for feed and inerts", "Total
substitutes" of 10% for chlordane, and 20% for heptachlor.
11. "Petroleum for inerts" was calculated assuming granular and wettable
powder forms, except diazinon, contain no petroleum inerts.
The inerts were weighted as follows, based on estimated patterns
supplied by Illinois Agr. Extension: chlordane, heptachlor, carbofuran,
and carbaryl — negligible. Diazinon AG500 (46$ inert) x 100% use
= 46% inerts.
12. The effect on natural gas consumption was not considered. Natural
gas was assumed to be of secondary importance as an industrial
energy source. To convert coal in the tables to natural gas, assume
12.5 cu ft of gas per Ib coal.
Remark: It is assumed that all other petroleum and energy-
saving measures with higher benefit/cost indices have been taken.
Energy expense in exchange for decreased human hazard is to be
balanced against alternative uses for the same energy.
Further, it is as'sumed that patterns of crop cultivation and
transportation, and attendant energy use, will not change as an
economic consequence cancellation.
_355_ *U.S. GOVERNMENT PRINTING OFFICE: 1976 626-446/878 1-3
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