EPA-540/4-76-004
  EPA  ACTIONS TO CANCEL AND SUSPEND
  USES OF CHLORDANE AND HEPTACHLOR
                AS PESTICIDES
)o not remove. This document
bhould be retained in the EPA
cegion 5 Library Collection.
                            ECONOMIC AND SOCIAL
                                IMPLICATIONS
  AUGUST 1976
 EPA-540/4-76-004
                  Criteria and Evaluation Division
                   Office of Pesticide Programs
                U.S. ENVIRONMENTAL PROTECTION AGENCY
                    Washington, D.C. 20460

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Limited copies are available from
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  EPA ACTIONS TO CANCEL AND SUSPEND USES
OF CHLORDANE AND HEPTACHLOR AS PESTICIDES:
     ECONOMIC AND SOCIAL IMPLICATIONS
                  PART I
         Prepared for publication
              September 1975
                            V,
                            p, Illinois u-JO-i
         Economic Analysis Branch
     Criteria and Evaluation Division
       Office of Pesticide Programs
   U.S.  Environmental Protection Agency
         Washington, D.C.  20460
             EPA-540/4-76-004
                August 1976

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Mention of trade names or commercial
products does not constitute endorse-
ment or a recommendation for use.

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                                   PREFACE
     This publication is a composite of economic and social  impact studies con-
ducted in relation to the announcements of the Administrator of EPA that he
intended to cancel many of the currently registered pesticidal  uses of chlordane
and heptachlor (November 18, 1974; See Appendix F below for  Federal Register no-
tice) and later (July 29, 1975) that he intended to suspend  these same uses (See
Appendix G below for Federal Register notice of suspension).

     This publication is divided into two parts:

     Part I.   Economic and Social Impact Analysis of Cancelling Certain Uses
               of Chlordane and Heptachlor.

     Part II.  Economic Testimony Presented by EPA at Chlordane/Heptachlor
               Suspension Hearings, September 18-19, 1975.

     The studies presented in Part I are those conducted during the period July,
1974 - May, 1975, relative to the cancellation action for chlordane/heptachlor
(hereafter collectively referred to as C/H).  These studies,  reported in Part I,
provided information for policy review within EPA during the period and were
also used in drafting the Environmental Impact Statement (EIS)  on the C/H can-
cellation action.

     Part II is the economic testimony presented at the C/H  suspension hearings.
It is based on the earlier studies reported in Part I, as supplemented by added
information and analysis generated in connection with the suspension.

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                                ACKNOWLEDGMENTS
The following scientists were the major contributors to this report:

     Fred T.  Arnold, Ph.D.  candidate, Agricultural  Economist
     Arnold L. Aspelin
     Stewart L. Col ten
     Fred Hageman, B.S
     Marco Montoya, Ph
     Gerald K. O'Mara,
  Ph.D., Agricultural  Economist
,  M.Ch.E.,  Chemical  Engineer
,,  Entomologist
,D.,  Sociologist
 Ph.D.  candidate, Agricultural Economist
     Robert R. Reynolds, Ph.D., Sociologist

This report was prepared under the general direction and supervision of
Arnold L. Aspelin, Ph.D., Chief, Economic Analysis Branch, Criteria and
Evaluation Division.
                                        IV

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                            TABLE OF CONTENTS

                                 PART I

           ECONOMIC AND SOCIAL IMPACT ANALYSIS OF CANCELLING
                CERTAIN USES OF CHLORDANE AND HEPTACHLOR
                                                                   Page
SECTION   I.   Introduction and Summary of Findings 	   1

SECTION  II.   Production and Distribution of Chlordane/Heptachlor.  10

SECTION III.   Economic and Social Impacts of Cancelling
               Chlordane/Heptachlor Use on Corn	  21

SECTION  IV.   Economic and Social Impacts of Cancelling
               Chlordane/Heptachlor on Other Agricultural Uses. .  .  65

SECTION   V.   Other Areas of Impact and Concern  	  82


                          APPENDICES TO PART I	99

APPENDIX A.    Tables:  Corn Pests and Controls and Field Test
               Results Using Aldrin 	 100

APPENDIX B.    Substitutes for Aldrin, Dieldrin, Chlordane and
               Heptachlor for Insect Control on Corn and Apples .  . 103

APPENDIX C.    Mathematical Programming Analysis of C/H Restriction 109

APPENDIX D.    Assumptions Used to Derive Energy Impact of
               Cancellation 	 121

APPENDIX E.    Table:  Summary of Registered C/H Substitutes for
               Selected Domestic, Commercial, Public Health and
               Miscellaneous Uses	125

APPENDIX F.    Federal Register Notice of EPA Administrator's
               intent to cancel  certain registered uses of
               chlordane and heptachlor 	 130

APPENDIX G.    Federal Register Notice of EPA Administrator intent
               to suspend certain registered uses of chlordane
               and heptachlor	134
                                       V

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                                Section I

                  INTRODUCTION AND SUMMARY OF FINDINGS
     The purpose of this report is to provide an evaluation of economic
and social implications of cancelling Chlordane/Heptachlor.  In November,
1974, the Administrator of EPA announced his intent to cancel many of the
major and minor Federally registered uses of pesticide products containing
Chlordane and Heptachlor (hereafter referred to as C/H) (1).  C/H are
among the leading insecticides in the U.S.  Significant economic and
social benefits could be lost and dislocations caused in the switch to
alternative pesticides, if and when the cancellation becomes effective.

     The material presented in this report is intended to provide informa-
tion and background for the environmental impact statement (EIS) issued
on the proposed C/H cancellation, in keeping with the Administrator's
policy of issuing voluntary EIS's (2).  The results of recent economic
research on pesticides and related important economic phenomena will be
used in this analysis to draw implications from available data on the
cancellation of C/H.

     This report is devoted primarily to presentation of information on
general production and distribution patterns of C/H (Section II) and to
evaluation of impacts of cancelling agricultural uses (Section III -
Corn and Section IV - Other Uses - largely agricultural).  Section V
relates to other areas of economic/social impact or concern such as
energy implications and user adjustment problems.

     The evaluation of the impacts of cancelling minor agricultural uses
and nonagricultural uses is limited in scope.   Limited data for these
uses are available on the extent of use and on the comparative current
performance characteristics which include cost, yield and efficacy data
of C/H and alternatives.

     The economic analyses to follow are conducted with the explicit
assumption that aldrin and dieldrin will not substitute for chlordane
and heptachlor.l/
]_/  Adrin and dieldrin were suspended by the Administrator of EPA in
    August of 1974.  Generally, a suspension order prohibits production
    of the pesticide in question but may allow use of existing stocks.
    A cancellation order is a less urgent action than suspension and
    allows continued production and use of the chemicals during the
    cancellation proceedings.
                                      -1-

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                           Background on the Nature of
                  Benefits for Agricultural  Uses of Pesticides


     As an input in the agricultural  production process,  pesticides have
played an important role in maintaining high yields per acre.   Over time,
pesticides, including C/H, have made  land and labor more  productive in
important crop uses, thus freeing up  resources for production  of other
crops.  Measured in terms of productivity, pesticides  are extremely im-
portant compared with other inputs.

     Past attempts to measure the productivity of pesticides indicate a
relatively high value on the average.  Headley estimates  marginal  products
of pesticide use in the United States to be about four (3).   In England,
Strictland estimated a 500 percent rate of return for  pesticide use in
that country (4).  These rates of productivity and return are in sharp con-
trast with much lower returns for land and other agricultural  inputs, which
approach the competitive cost of capital in line with  long term interest
rates.

     Pesticides, while being highly productive, are a  small  part of the
total cost of producing a crop.  For  example, the cost of pesticides for
growing corn is approximately one to  three percent of  the budget.   Whether
viewed in terms of absolute cost or cost relative to other productive in-
puts, pesticides are a modest, but important, investment.

     A critical problem in pest management is that it  is  difficult to
predict the likelihood of a pest infestation, its population size, and
the resulting crop damage.  In any given situation, the higher the risks,
the greater is the farmer's incentive to use pesticides.   Farmers tend
to avoid risk and pesticides provide  an economic means to reduce
uncertainty of crop loss.

     Related to this is the large variability in loss  around the average
crop loss.  Carlson showed that for an investment in pesticides of $2 per
acre, the variability in crop loss is reduced $11 per acre (5).  A small
investment in pesticide use has a large pay-off to the farmer  in terms
of reduced risk of crop loss.  This risk-aversion phenomenon makes C/H
appealing.  They are persistent in the soil  and are used  as  pre-emergence
pesticides.  They often are applied early in the season ahead  of any in-
festation, rather than in response to an actual infestation  as is  common-
place with post-emergence applications.  It is possible that much C/H is
applied even though there may not be  an actual infestation during the
growing season.  Although insecticides are applied on  one-fourth of U.S.
corn farms and one-third of the total farm acreage, the implication on
a national level is that large amounts of C/H may have been  applied which
perform no useful insect control and  the risks associated with release
of C/H in the environment may not be  fully compensated by production
benefits (6, 7).
                                       -2-

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     To some extent, optimal use of insecticides in C/H use patterns may
be consistent with cancellation of C/H.  There may be some overuse due
to the combination of (a) high risk aversion on the part of some users,
(b) less-than-optimum scouting of pest infestations, and (c) relatively
low private cost compared with its social cost.  Registered alternatives
may be equally or more efficacious due to trends in pest resistance which
are almost inevitable with extensive use of organic chemical insecticides
over a period of years.   Nonchemical alternatives, including use of
resistant varieties and cultural practices such as crop rotations may" be
more fully exploited as environmental  awareness increases through appli-
cator training, education and regulation.

     For some crops, the transition away from C/H can be made easily and
inexpensively.  In other cases, the transition may be more difficult due
to more expensive and/or less productive substitutes.  Although C/H are
used in many situations, the emphasis  in this report is on those C/H uses
of greatest economic significance in agriculture.
                                       -3-

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                              Summary of Findings


 I.   Production and Use

     A.   Chlordane and heptachlor are products  of  Velsicol  Chemical  Corpora-
         tion,  a subsidiary of Northwest Industries.   Production  capacity
         for C/H currently is  estimated  to  be  in excess  of  30  million  pounds
         annually.  Chlordane  is  used largely  for  nonagricultural  purposes;
         the 1974 estimated use was  as follows:
                                                  Million Pounds
              Agricultural
              Termites
              Home and garden
                and other
                                      Total

     B.   Most agricultural  use of chlordane is  for crop  protection,  particularly
         protection of corn from  soil  insects.  The primary industrial/commercial
         use is the protection of structures against termites.   It is  also used
         against a wide variety of home  and garden pests.

     C.   Heptachlor, which is  produced in much  smaller volumes than  chlordane,  has
         been in the range of  2 to 4 million pounds per  year during  recent years.
         Estimated use in 1974 was as follows:

                                                  Million Pounds

              Agriculture '                              2.0
              Termite control                            1.4
              Home and garden                            0.6
                                      Total             4.0

     D.   Agricultural  use of heptachlor  is  almost  entirely  to  protect  crops,
         primarily corn.

II.   Impacts of Cancelling C/H on Corn

     A.   C/H is used as a soil insecticide  to  protect corn  primarily from root-
         worms, wireworms and  cutworms although it is registered  for use against
         other pests such as grubs,  seed corn  maggots and seed corn  beetles.

     B.   The cutworm, principally the black cutworm,  is  the pest  for which alter-
         natives are most limited, thus  generating the largest potential  for
         benefits of continued C/H use.
                                        -4-

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C.  Several alternatives are registered by EPA and recommended by the
    states for controlling each of the three principal pests:   rootwoMns,
    wireworms and cutworms.  For cutworms, limited pre-emergence alter-
    natives are registered by EPA and recommended by the states.  However,
    post-emergence rescue baits and sprays are registered and  recommended
    in nearly all of the significant corn growing states.

D.  The post-emergence rescue treatments for cutworms have the advantage
    of lowering costs since an application does not need to be made unless
    an infestation appears during the growing season.  However,
    the rescue baits require that the farmer carefully scout his corn
    for pests.


E.  In agricultural uses, more than half of the chlordane and  nearly all
    of the heptachlor are used on corn (56 and 97%, respectively, for
    the year 1971).

F.  C/H is used on only about 2.5% of U.S. corn acreage and 1.8% of corn
    farms (1.7 million acres and 17,300 farms in 1973).  However, these
    numbers would be expected to increase considerably above 1973 levels
    as a result of the cancellation/suspension of aldrin because C/H
    substitutes for aldrin which has been used on about 10% of U.S.
    corn acreage.

G.  Most corn farmers do not use insecticides of any type (75% in 1973)
    and most corn land is not treated (62% in 1973).

H.  C/H use on corn is concentrated in Midwest states, principally Iowa,
    Missouri, Illinois, and Indiana which account for more than 70% of
    C/H use as of 1973.

I.  C/H is much less expensive than other pre-emergence controls, roughly
    half the cost (e-g-> $3.50 per acre compared with $7 per acre).
    Rescue treatments for control of cutworms generally cost less than
    recommended broadcast treatments (e.g., $2-$3 compared with $3-$4 per
    acre).

0.  Use of alternatives to C/H will increase yields on rootworm infested
    land, but will have limited effects on wireworm infested land.  These
    are the views of the preponderance of entomologists and other pro-
    fessionals who have reviewed this matter.  However, some entomologists
    feel that there will be very limited or no yield effects,  even on
    cutworm infested land, as alternatives are used.  Estimates of yield
    reduction from use of alternatives on cutworm infested land vary from
    state-to-state within the range of>0 to 15% (and from 0 to 30% without
    the use of alternatives) under conditions of moderate to heavy cutworm
    infestations.
                                   -5-

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      K.   Earlier studies  by  the  Department  of Agriculture, Economic Research
          Service, indicated  that cancellation of chlordane and heptachlor
          uses  would  have  nominal  impact  on  the corn  sector of the economy.
          However, the  results  of these studies are no  longer current or of
          sufficient  analytical rigor  to  adequately reflect the actual  impact
          generated by  the combined  cancellation of chlordane/heptachlor in
          addition to the  suspension of aldrin/dieldrin.  Therefore, EPA
          further evaluated the possible  cancellation impact.

      L.   The EPA analysis involved  the use  of a linear programming  (LP)
          model for agriculture showing impacts on acreage, production,
          prices, transportation  costs, and  monetary  returns to agriculture
          for 127 regions  of  the  United States, as affected by the combined
          cancellation  of  C/H and aldrin  during the period 1975-80.  Results
          of the LP analysis  are  presented in terms of  the year 1977 which,
          for purposes  of  showing impacts on an annual  basis, is  assumed to
          be typical  of the first five years of the effective cancellation.
          The LP analysis  was based  on moderate to heavy infestations.

      M.   Selected results of the LP analysis in terms  of the year 1977 are
          as follows:  corn production declines by 36.9 million bushels
          (0.7%); acreage  of  corn raised  with no pesticides, up by +5.5
          million acres; total  corn  acreage, +200,000 acres; total crop
          land, +1.16 million acres  (0.4%);  the price of corn and soybeans
          +1 to 3%; grain  transport  costs, +$6.36 million (0.9%); net
          returns to  7  major  feedgrain crops, +$71.25 million (2.2%).

      N.   The worst case analysis of impacts which assumes moderate to  heavy
          infestation levels  of the  cancellation on the corn sector translates
          into  consumer price increases for  meat products ranging between 0.4
          and 0.5% and  0.10%  for  the entire  consumer  food basket.

III.   Impact of Cancelling Other  Agricultural Uses

      A.   Significant impacts are possible from the combined cancellation of
          aldrin/dieldrin  and C/H for  control of root feeding beetles on citrus
          in the state  of  Florida.   Although C/H is not used extensively at
          this  time for this  purpose,  and registrations at the Federal  and
          state levels  are inconsistent for  this use, certain areas may be-
          come  uneconomic  if  alternatives are incapable of controlling  these
          pests.  After a  period  of  ten years as much as 5% of U.S. production
          could be affected if alternatives  fail.  Local  economic and social
          impacts could be significant.

      B.   Significant economic and social impacts, as a result of cancellation
          of agricultural  uses other than corn, seem  unlikely in  most cases.
          Effects on  strawberry and  potato production could be significant in
          local areas.
                                       -6-

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IV.   Other Areas of Impact and Concern

     A.   Energy implications in terms of producing  alternative  chemicals  are
         likely to be slightly positive as somewhat less  energy will  be re-
         quired to produce alternatives on a pound-for-pound  basis.   On the
         other hand, energy implications of bringing 1.16 million more acres
         of land into production to meet needs  have not been  analyzed in
         detail.  This increase in land devoted to  the production of  7 major
         food and feed grains amounts to a 0.4% increase  in  land devoted  to
         production of these crops.!/

     B.   Substantial land use impacts would occur in the  North  Central Region
         of the U.S., resulting in some reduction in the  demand for farm  labor
         in that region.   For example,  9,400 workers could suffer individual
         income losses of $300 to $400  per year.

     C.   Velsicol  Chemical Corporation, the producer of C/H,  would suffer an
         income loss of up to $14 million according to Velsicol  estimates.


     D.   The supply of substitutes for  C/H is likely to be adequate by the
         time cancellation becomes effective and existing supplies are liqui-
         dated.  It is expected that feedstock  shortages  and  other problems
         of the energy crisis will have been resolved by  the  time the can-
         cellation becomes effective.   During a period of two years very
         large increases  can be made in the production of alternative
         chemicals.  There are opportunities to expand domestic supply in
         the short run by reducing exports or increasing  imports of alter-
         native chemicals.  There are opportunities to expand domestic supply
         in the short run by reducing exports or increasing  imports of alter-
         native chemicals.

     E.   The use of alternative chemicals may require improved  pest management
         and scouting by  farmers.  Training may be  required  in  some cases.

     F.   Additional analysis of cancellation imoacts of C/H  use on corn is
         underway and will be completed during  the  cancellation proceeding.
         This further analysis will examine cancellation  impacts in light of
         estimates of average infestation and yield performance of alternatives,
         rather than the  extreme parameters which have been  evaluated to  date.

     G.   Substitutes are  registered for most non-agricultural C/H uses, such
        'as domestic, commercial and public health  uses.   Isolated instances
         of inadequate alternatives are possible.
 I/   The  seven  crops  are  the endogenous  crops  in the  linear programming model :
     corn,  sorghum,  wheat,  barley,  oats, soybeans,  and  cotton.
                                        -7-

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                              Conclusion
     At the national  level, cancellation impacts  on  production  and  prices
of affected commodities are within the range of impacts  due to  normal  year-
to-year weather and market variations, making the impact significant but
not serious.  Local areas and regions could be affected  more seriously,  as
in the case of moderate to heavy infestations of  corn  soil  pests  and poor
performance of alternative controls.   Such outcomes  are  unlikely  to occur
in all areas of the U.S.  in one year, but they are possible.

     Throughout the analyses of impacts of the proposed  C/H cancellation,
limited weight has been given to trends in the development  of substitutes
and the decline in use of C/H due to  pest resistance,  which usually develops
with intensive long term use of a pesticide.   These  factors would be ex-
pected to reduce the benefits of continued use of C/H, over a period of
years compared to substitutes as indicated by current  data  on yield and
cost.  During a 5 or 10 year period,  benefits of  continued  C/H  use  could
decline to negligible levels.
                                       -8-

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                           References  for Section  I
(1)  Train,  Russell,  E.,  Administrator,  EPA,  Notice of  Intent to
     Cancel  Registrations of Certain  Pesticide  Products Containing
     Heptachlpr and Chlordane,  Washington,  D.C., November 18, 1974.

(2)  Train,  Russell E., Administrator, EPA,  Impact Statements -
     Procedures for Voluntary Preparation,  Washington,  D.C., October
     15, 1974.   (Federal  Register.  October  21,  1974, Vol. 39, No. 204,
     RP. 37419-37422]^

(3)  Headley, J.  C.  Estimating the Productivity of Agricultural
     Pesticides.   Amer. Journ.  of Agricultural  Economics. 50:13-23,
     February,  1968.

(4)  Strictland,  A. H.  Economic Principles  of Pest Management.
     Conference on Concepts  of  Pest Management, N. C. State University,
     Raleigh, N.  C.  March,  1970.

(5)  Carlson, G.  A.,  "The Microeconomics  of  Crop Losses," Economic
     Research on  Pesticides  for Pol icy Decision Making.  Proceedings
     of a Symposium.   ERS, USDA.  Washington, D.C., April 1970.

(6)  Aspelin, Arnold L.,  Statement  for Testimony at Aldri'n/Dieldrin
     Suspension Hearing (Exhibit 5-16),  Washington, D.C., September
     1974, Appendix A,  Table 1.

(7)  Midwest Research Institute Report.   A  Study of the Efficiency of
     the Use of Pesticides in Agriculture,  prepared for EPA, February
     1975.
                                   -9-

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                               Section II

           PRODUCTION AND DISTRIBUTION OF CHLORDANE/HEPTACHLOR


     Presented in this section are data on the supply of C/H,  including
production and export/import figures,  and general  use patterns by geo-
graphic area.  Available data on production and use are quite  sketchy.

     Certain production/use data available to EPA are not reported herein
because of confidentiality of sources  (e.g., annual reports to EPA on
registered pesticide establishments under Section 7, Federal  Insecticide,
Fungicide, and Rodenticide Act, as amended, 1972, and confidential industry
estimates).   Principal emphasis is on  production of technical  C/H and general
use patterns.  Data are not presented  on formulation, marketing and applica-
tion of C/H.
                                       -10-

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                                 Production
     C/H are products of Velsicol Chemical Corporation, a subsidiary of
Northwest Industries.  The Chemical Group of Northwest Industries, Inc.
which includes Velsicol Chemical Corporation and Michigan Chemical
Corporation had net sales of $167 million in 1974.  About two-thirds
of Velsicol's annual sales are concentrated in pesticide products (1).
Total production capacity for C/H at this time is probably in excess of
30 million pounds annually as capacity for chlordane production alone
was estimated at 30 million pounds in 1972 (2, p. 152).  In that year
production of chlordane was estimated at 20 million pounds, of which
5 million was exported (2, p. 152).  Production capacity for heptachlor
is estimated to be in the range of 3 million pounds annually for
domestic use, (3) plus some capacity for export.  Apparently, C/H is
not imported into the U.S.
                                     -11-

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                            Chlordane Use Patterns

     Chlordane has been used as a registered commercial  insecticide for more
than 25 years.  It is the second oldest organochlorine insecticide, preceeded
only by DDT.  Although chlordane is an important agricultural  pesticide, most
of its use is non-agricultural.  According to the most recently published
estimates (1972), only 3 million pounds were used in  agriculture compared with
6.5 million for industrial/commercial uses, primarily termite  control;  0.5
million for Government agencies; and 5.0 million for  homes  and gardens, out  of
total domestic use of 15 million pounds (2, p.  153).   A breakdown,  by region,
of these U.S. totals is presented in Table 1.   Most chlordane  is used in the
central and eastern regions of the U.S.

     For the year 1974, total domestic use was  16 million  pounds, according  to
EPA estimates based on informal industry sources.   This total  breaks down as
follows:  agriculture - 3.5 million, termites - 11  million  and home/garden and
others - 1.5 mil lion.I/  It is not clear at this time exactly  what  the  propor-
tional breakdown  is among non-agricultural uses in  view of the differences be-
tween the 1972 and 1974 estimates.

Agricultural Uses

     According to USDA surveys, crop uses account for 70% to 85% of ag/icultural
use of chlordane  in the U.S. (Table 2).  Some is used around livestock  buildings
and less than 5%  is used for other purposes on  farms.  There is no  trend shown
in the USDA surveys as to changes in percentage breakdown  among general types  of
agricultural uses.  However, there appears to be a  trend toward increased use  of
chlordane in agriculture generally, inasmuch as the 1971 use level  of nearly
1.9 million pounds was more than three times that for 1964  and 1966 (Table 2),
and a more recent EPA estimate indicates about  3.5  million  pounds for 1974.  The
suspension of aldrin/dieldrin will increase demand  for chlordane, along with
other substitutes, leading to increased production  and use  of  chlordane begin-
ning 1975 or 1976.

     The major uses of chlordane on crops are shown in Table 3.  Corn is the
leading use, with 842,000 pounds active ingredient  on 533,000  acres in  1971,
followed by apples, nursery and greenhouse uses which together account  for most
of the remainder, according to USDA.£/
I/  More recent use data was provided by Velsicol  Chemical  Corporation  in
    June 1975, subsequent to the completion of this study.   The data indicate
    that a total of 21,177,065 pounds of technical  chlordane was used in 1974.
    The breakdown of this use is as follows:  agricultural  - 6,007,358  pounds;
    termite control - approximately 6,608,030 pounds;  all  other - approximately
    8,561,677 pounds.

2/  The estimate for chlordane use on apples is believed to be in error, as use
    of chlordane on apples is uncommon.
                                      -12-

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     Between 1966 and 1971, large increases occurred in corn,  other grains,  and
nursery greenhouse uses, while alfalfa and Irish potato use declined notably.
Corn, other grain and Irish potatoes accounted for most of the 717,000 crop
acres treated with chlordane in 1971 (Table 3).
 Table 1 __ Domestic use of chlordane by geographic region of U.S.,  1972
Region
NE
SE
NC
SC
NW
SW
Total
Agricul-
tural
0.7
0.3
1.7
0.1
0.1
0.1
3.0
Industrial,
Cotnnercial
1.0
1.3
1.6
1.3
0.3
1.0
6.5
Government Sub-
AgenciesS/ Totals
1.7
1.8
3.4
1.6
0.4
1.1
0.5 10.0
Hone and
Garden^/ Total






5.0 15.0
   Too small to break out;  included in subtotals.
 k/
   Geographic distribution  not known.

 SOURCE:   Midwsst Research  Institute and RvR Consultants;  Production,
          Distribution,  Use and Environmental Impact Potential of
          Selected Pesticides, for EPA/CEQ,  1974.
                                       -13-

-------
      Table 2-- Agricultural use of chlordane by type of use, U.S.,
                1964,  1966 and 1971 (active ingredient basis)
Type of Agricultural
Year
1964
1966
1971
1964
1966
1971
s/
Crops Livestock
i f\f\r\
X, UUU
383 142
452 71
1,496 366
„_ _ — „_ .treiceivc O.L
70.3 26.0
85.9 13.5
79.1 19.4
b/
Other
pounds a.i. —
20
3
28
Total 	
3.7
0.6
1.5
Use
Total

545
526
1,890
100
100
100
 Includes livestock buildings

 Includes all other nonlivestock and noncrop uses.

SOURCE:  USDA/ERS (Agricultural Economic Report Nos. 131, 179 and 252)

         See references (4), (5) and (6).
                                      -14-

-------
              Table 3-- Chlordane use on crops,  U.S.,  1966,  1971
                         Quantities
Acres Treated
Crop

Corn
Other grains
Cotton
Tobacco
Potatoes
Crops
Alfalfa
Other hay and
pasture
Irish potatoes , /
Other vegetables —
Citrus
Apples
Other fruits and nuts
Nursery and green-
house
TOTAL
1966
1,000
159
-
3
26
155
1
41

6
155
18
15
3
24

1
452
1971
pounds active
842
41
-
2
33
29
-

2
33
16
18
373
7

133
1,496
1966
	 1,000
210
-
6
17
38
2
36

23
38
23
83
3
31

NA
472
1971
acres 	
533
78
-
1
55
16
-

3
55
7
10
10
4

NA
717
Note:  In 1964, USDA included chlordane in the category of "Other
       organochlorine insecticides."
—   Includes strawberries.
Source:  USDA/ERS (Agricultural Economic Report Nos. 179 and 252)
         See references  (5) and (6).
                                      -15-

-------
     The USDA estimate of 533,000 acres  of  corn treated with chlordane in
1971 is considerably less than the 1973  acreage according to data presented
at the aldrin/dieldrin suspension hearings.(3)  This data indicated chlordane
was used on 812,000 acres or 1.2% of U.S. corn acreage in 1973.
                                      -16-

-------
                          Heptachlor Use Patterns


 General Use Patterns

      Although heptachlor was introduced and registered more than 20 years
 ago, it is much less widely used than chlordane.  Very limited data are
 available on all uses, especially nonagricultural uses.  Total production
 during recent years has been in the range of 2-4 million pounds, some o^ .
 which is exported.  An approximate breakdown of 1974 use is as follows: —'

                                     Million Pounds          Percent

           Agriculture                    2.0                   50
           Home & Garden                   .6                   16
           Termite Control                1.4                   34
                                 Total    4.0                  100

      In the past, about half of heptachlor was used in agriculture but this
 may be changing due to the aldrin/dieldrin suspension.  As much as 3 million
 pounds may be used for agriculture "in 1975 (3).

 Agricultural Uses

      USDA's Economic Research Service surveys indicate agricultural hepta-
 chlor use in the range of 1.2 to 1.5 million pounds annually during the
 last 10 years, mostly to protect crops (Table 4).  Livestock uses are in-
 significant and other uses accounted for only 5.6% in 1971.  Heptachlor
 is used mainly on corn, as other uses have declined to no more than a few
 thousand acres, according to USDA's 1971 survey (Table 5).
]_/  The 1974 use data for heptachlor in pounds of technical equivalent
    material provided in June 1975, by Velsicol Chemical Corporation sub-
    sequent to the completion of this study is as follows:  agricultural -
    1,456,190 pounds; termite control - approximately 496,502 pounds; all
    other - approximately 99,579 pounds.
                                        -17-

-------
         Table 4-- Agricultural use of heptachlor by type of use, U.S.,
                   1964, 1966 and 1971 (active ingredient basis)
Year

1964
1966
1971

1964
1966
1971

Crops
	
1,301
1,513
1,143
	
99.7
98.5
94.4
Type of Agricultural
Livestock" Other""
	 1,000 pounds a.i.
4
3 20
68
	 Percent of Total 	
0.3
0.2 1.3
5.6
Use
Total
	
1,305
1,536
1,211


100
100
100
 Includes livestock building

"includes all other non-livestock and non-crop uses

SOURCE:  USDA/ERS (Agricultural Economic Report Nos. 131, 179 and 252).

         See references (4), (5), and (6).
                                    -18-

-------
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-------
                     References  for  Section  II
(1)   "Kline Guide to the Chemical  Industry,"  1974,  p. 273.

(2)   Midwest Research Institute  and  RvR Consultants.  Production.
     Distribution, Use and  Environmental  Impact  Potential of Selected
     Pesticides.   For EPA and  CEQ. Midwest Research Institute,
     Kansas City, Mo., 1974.

(3)   Transcript,  Aldrin/Dieldrin Suspension Hearings, Exhibit S-16,
     Statement 64 Arnold Aspelin,  OPP, EPA, September 1974.

(4)   USDA,  Quantities of Pesticides  Used  by Farmers in  1964,,
     AER No. 131, ERS, USDA,   Washington, D.C.,  January 1968.

(5)   USDA,  Quantities of Pesticides  Used  by Farmers in  1966.
     AER No. 179.  ERS, USDA,  Washington, D.C.   April,  1970.

(6)   USDA,  Farmers'  Use of  Pesticides  in  1971-Quantities,
     AER No. 252.  ERS, USDA.  Washington, D.C.  July, 1974.
                                  -20-

-------
                               Section III

     ECONOMIC IMPACTS OF CANCELLING CHLORDANE/HEPTACHLOR USE ON CORN


                              Introduction
     Corn is the most importarit crop in the U.S.  More acres of cropland
are planted to corn, and more farm income is generated from it than from
any other crop.  Corn is grown on about 70 million acres, on 1 million
farms, resulting in production of 5 to 6 billion bushels of grain annually.
Soybeans and wheat are grown on nearly as many acres (45 to 50 million,
compared with 60 to 70 million for corn) but are much less important in
terms of income to agriculture (1).  At $3 per bushel, the corn crop is
valued at $15 billion or more, far in excess of other crops such as soy-
beans ($7 or $8 billion); cotton ($3 or $4 billion)  and tobacco ($2 or $3
billion).  Corn accounts for about 75-80% of all grains fed to livestock
and poultry in the U.S. and is important as both food and feed in much of
the world (2).

     In this section we will evaluate the impacts of shifting to alterna-
tive insecticides for control of corn pests.  Attention is paid to cost,
yield, acreage, production and price effects of the cancellation.  Earlier
studies are reviewed and preliminary worst case estimates are reported by
region for the U.S. based on results of a linear programming analysis of
U.S. agriculture for the period 1975-80, typical year basis.
                                      -21-

-------
                           Principal Target Pests

     Corn is subject to attack by a wide variety of insects including
corn rootworms, wireworms, cutworms, grubs, seed corn maggots, and
seed corn beetles.  Testimony in the aldrin/dieldrin cancellation
hearings established that the primary soil insects presenting economic
threats to U.S. corn production are rootworms, cutworms, and wireworms (3).
This analysis concentrates on these three insects.  Chlordane and/or
heptachlor have EPA registrations for use against a number of other corn
pests, which are of minor economic significance in terms of actual damage
and use of C/H (Appendix A, Table 1).

     Rootworms are by far the principal corn insect pests for which soil
insecticides are used.  About 200,000 farms (14% of U.S. corn farms) are
estimated to consider rootworms a major problem on their farms; 70% of
these are treated.  In 1973, an estimated 15 million acres (21.9% of U.S.
acreage) were treated for rootworms, while an additional 6 or 7 million
acres on farms with problems were not treated (Table 6).

     Approximately 51,000 farms were estimated to consider cutworms a
major problem in 1973; about 58% were treated for them.  This is estimated
at 3.2 million acres, or about 4.6% of U.S. corn acreage (Table 6).  This
percentage was near the estimate for wireworms (4%) but far below the
figures for rootworms (21.9%).

     Wireworm problems were estimated to have occurred on about 35,000 farms
in 1973 (Table 6) leading to treatment of 2.8 million acres.  More than 70%
of farms with wireworm problems used an insecticide, based on the available
1973 data.

     Infestations of cutworms and wireworms are much more sporadic than
rootworms and the acreage treated varies greatly from year to year.  The
number of corn farms with cutworm problems can range to as many as 75,000
(compared with 50,000 in 1973).  Similarly, the number of farms with
wireworm problems may vary from 30,000 to 50,000.

     State-by-state breakdowns, by target pest, on the number of farms and
estimated acreage treated in five principal corn states are shown in Table 6.
Missouri had the highest percentage of acreage treated for cutworms (15.5%,
more than twice Illinois, which ranked number 2 in 1973).  Missouri and
Illinois also ranked above the other states in percent of acreage treated for
wireworms (10.1 and 9.2%, respectively) (Table 6).  Iowa and Illinois are by
far the leading states in acreage treated for rootworms (21.6 and 32.1%,
respectively, in 1973)(Table 6).

     The data in Table 6 indicate that 25 to 40% of U.S. corn farms impacted
by one of these three major corn pests do not treat for the pest.  This
suggests that significant numbers of corn farms troubled by these pests do
not project economic threshold levels of damage.  However, some of these
farms not treating may, in fact, sustain economic infestation during the
year.  Next, we will  consider  alternative means of controlling these pests.
                                       -22-

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-------
                          Alternative Controls
     The purpose of this section is to briefly summarize relevant informa-
tion on registration and recommendations of C/H and  their alternatives  for
control of corn soil insect pests.   Focus is on controls registered with
EPA and those recommended by the states.

     Chlordane and heptachlor are registered with EPA for control of
rootworms, cutworms and wireworms as are a number of alternative controls
(Table 7).

                   Table 7 -- EPA registered nonfoliar controls for
                              rootworms, cutworms, and wireworms in
                              corn, 1974.
Pesticide Chemical                Rootworms        Cutworms     Wireworms
Chlordane
Heptachlor
Bux
Carbaryl
Carbofuran
Counter
Dasanit
Diazinon
Di-Syston
Dyfonate
Mocap
Parathion
Phorate
Toxaphene
X
X
X
-
X
X
X
-
X
X
X
X
X
"™
X
X
_
X
-
-
_
X
-
-
-
X
-
X
X
X
_
-
X
X
X
X
-
X
X
X
X
"
SOURCE:  Preliminary summary of registered chlordane and heptachlor uses
         and alternatives, Criteria and Evaluation Division, OPP, EPA.

NOTE:  Aldrin use against these pests has been suspended by EPA except
       for existing leftover stocks.
                                      -24-

-------
     Alternatives to C/H and other organochlorine insecticides are becoming
increasingly attractive because of insect resistance to this class of in-
secticides, superior performance of alternatives and problems with organo-
chlorine contamination of agricultural food crops. ]_/  Use of organochlorines
is often not recommended under a number of situations such as:  dairy farms;
farms on which any live stock are raised; crop rotations in which soybeans
(a major crop in corn areas) follow corn; continuous corn cropping- rotations
in which root crops follow corn; and corn used for silage or fodder.   Also,
states are limiting recommendations to specific situations and geographic
areas where pest problems are most likely to occur, such as certain types
of land and rotations, where land is known to have a history of soil  insect
problems and where resistance has not yet developed.


Rootworms
     Rootworms are best controlled by crop rotations to avoid corn-after-
corn, and by pre-emergence row treatment with nonorganochlorine soil
insecticides.  Most rootworms have become resistant to C/H and other
organochlorines during the last 15 years with the result that they are no
longer preferred and only rarely recommended for control!inn rootworms in
corn.  C/H and aldrin are not recommended by state entomologists for  use
against rootworms in most major corn growing states according to 1974 state
insecticide recommendations (Table 8).  The only major corn state recommend-
ing use of an organochlorine against rootworms was Indiana where aldrin and
heptachlor were recommended in the Northern 1/3 of the state.  For each Of
the major corn producing states, there are usually five or more EPA registered
pesticides recommended by state entomologists as alternatives to C/H  for
control of corn rootworms.  These controls are commonly applied at planting
time in a 7 inch subsurface band over the row, with an insecticide attach-
ment to the planter.  This method of treatment is in contrast to furrow
and with broadcast treatment which involves treating the entire crop  area,
including space between the rows.  With broadcast treatment, the pesticide
is applied with a spreader and incorporated into the soil  with a disk or
harrow.  Boradcast treatment is recommended for control of wireworms  and
cutworms as discussed below.
]_/  Use of feed contaminated with organochlorine residues resulted in
    more than 4 million broilers being contaminated with illenal  residues
    in 1974, making it necessary to destroy them.
                                     -25-

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Wireworms

     Wireworm damage to corn seeds, emerging seedlings and roots can be mini-
mized by pre-emergence treatment in the furrow with the seed at planting
time, by band treatment and by broadcast treatment using any of several
pesticides which are registered by EPA and recommended by the states.   A two-
year corn-soybean rotation is also helpful.

     Historically, organochlorine pesticides have been the preferred control
for wireworms in corn.  However, increasing resistance or suspected resistance
to organochlorines of some wireworm species and the availability of alternatives
are combining to reduce the importance of C/H and aldrin in control of wireworms.
Presently, EPA-registered alternatives to C/H include carbofuran, counter, mocap,
dasanit, diazinon, dyfonate, phorate and parathion (Table 7).  At least two of
these alternatives to C/H and aldrin are recommended by entomologists  in most
major corn states, excluding Nebraska and Ohio, with four or five in some states
(Table 9).  Toxaphene is not recommended in any leading corn states.

     Aldrin and heptachlor were recommended in most corn states for control
of wireworms in 1974.  However, chlordane was recommended for control  of wire-
worms in only three major corn states (Table 9).  In 1975, Indiana will add
to its recommendations dasanit and mocap as row treatments against wireworms
and Iowa will add diazinon and dyfonate (4).

Cutworms

     The primary cutworm problem in the midwestern corn producing states is
the black cutworm which cuts the corn stalk just above the ground during the
wet weather  and initiates subsurface feeding during dry weather.  Problems
with this insect are associated with flooding conditions following stream over-
flows or standing water.  The areas most heavily impacted are black, heavy,
river bottom soils of alluvial origin.

     The most widely recommended control for cutworms has been broadcast
pre-emergence treatment with aldrin, although heptachlor was also recommen-
ed; it substitutes essentially on a one-to-one basis for aldrin.  As of 1974,
pre-emergence broadcasting of heptachlor was recommended for use in most corn
states (Table 10).  Chlordane is not generally recommended for cutworm control
(only Iowa, Minnesota and Nebraska recommended it in 1974).  Band application
of aldrin and C/H are not generally recommended, with Iowa as the only excep-
tion.  Furrow treatment is not recommended in any major corn state for cutworms.

     The entomology profession is divided at the moment on whether alterna-
tives to C/H and aldrin pre-emergence treatment are effective against  cutworms
attacking corn.  Diazinon was the only recommended nonorganochlorine pre-emer-
gence treatment for cutworms in 1974.  Entomologists, with seemingly similar
conditions, cannot agree on whether farmers can adequately protect their crops
with alternatives, primarily the postemergent sprays and baits.  For example,
in Missouri entomologists recommend pre-emergence treatment with heptachlor
and aldrin, whereas in adjoining Illinois, only post-emergence rescue  treat-
ment with baits and sprays is recommended (Table 10).
                                    -27-

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-29-

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     Each state recommends cutworm rescue treatments such as sprays and baits
as alternatives to pre-emergence treatments (Table 10).   These post-emergent
treatments, when properly applied to an infestation reaching an economic
level, are effective in controlling cutworms.   Weather conditions can alter
insect control as bait formulations are adversely affected by rain and very
dry conditions cause cutworms to feed at subsurface levels.   These controls
have the advantage of avoiding costs, since they are used only when needed,
and are less likely to breed resistance in pest populations.  These post-emer-
gent treatments include the currently EPA-registered carbaryl  and dylox baits
and sprays and toxaphene spray.   The most often recommended  of these treat-
ments is the carbaryl bait.

     The post emergent baits and sprays require careful  scouting by the farmer
during the period when corn is subject to cutworm damage.   There is a need
for more training on the proper application and timing of controls in line
with economic thresholds.

     With aldrin and C/H cancelled, corn producers would have very limited
pre-emergence treatments for cutworms.  However, some recent tests are
encouraging in this regard.  Experiments in Illinois in  1974 to test carbo-
furan as a systemic control of the black cutworm indicates that band and
especially furrow treatments will control the  pest.  Luckmann from Illinois
indicates that they will probably suggest this alternative to farmers in
1975 (6).I/  Peters testified that his tests for cutworm control indicated
that carbofuran was promising (7).

     Existing data reveal that chlorinated hydrocarbons  do not always provide
adequate cutworm control.  Of the 15 fields investigated in  an EPA study, six
had been treated with chlorinated hydrocarbons and damage to these fields
ranged from 6% on the only aldrin treated field to 85% on a  heptachlor treated
field (32).  Damage to the chlorinated hydrocarbon treated field averaged 35%
stand reductions in the heavily infested portions of the fields.

     Peters indicated that alternatives exist to chlorinated hydrocarbons for
control  of soil insects.  He said:  "The trends in the data  lead me to feel
quite strongly that in a given situation, there are one  or more organophos-
phate or carbamate insecticides that will control soil insects as well as
aldrin or heptachlor at the same rate per acre." (8, p.  2)  He indicated
that costs would be higher with the alternatives and the only areas that
should be treated are those where cutworms are a known problem.

     Peters also noted that a major problem in the control of cutworms seems
to be the tendency for farmers to place chlorinated hydrocarbons in the
furrow,  or band a 1 Ib a.i. per acre rather than broadcast at a higher rate
(1.5 to 2 Ibs) as is generally recommended for cutworms. (8, p. 4)   This
point was also made during conversations of EPA and University of Missouri
personnel with a large scale John Deere farm implement supplier in Carrollton,
Missouri in May, 1974 (9).  This dealer indicated that four-fifths of the
]_/  However, follow-up tests in 1975 in Illinois indicate that carbofuran sys-
    temically is not a reliable control for cutworm (Luckmann, personal com-
    munication, 1975).


                                    -30-

-------
farmers purchasing equipment from him purchased insecticide planters adapted
for row applications of insecticides and that such applications were the
common practice in this area where heavy soils and cutworm infested bottom-
land predominate.   This is consistent with cost data available to EPA which
indicate that most aldrin and heptachlor is applied in the row rather than
boradcast applications as is needed to control cutworms according to state
recommendations.!/  Indications are that many cutworms are targeted with row
(furrow or band) treatment, which is not recommended by either EPA or state
recommendations.

     In conclusion, corn farmers have available to them a very limited selec-
tion of recommended pre-emergence  treatments, as alternatives to C/H and
aldrin, to control cutworms in corn (only diazinon in 1974).-  It is thought
that aldrin or heptachlor provide more effective control of cutworms than
diazinon.

     The rescue treatments are not widely used, and require scouting to de-
termine the need and timing for treatment.  Such scouting represents a new
concept for many farmers, some of whom may need additional training and in-
formation to properly use such treatments to maximum benefit.   One survey of
midwest corn states produced the following generalization:  "Experts in the
field generally concur that up to 50% of theoretically infested corn acreage
is treated needlessly."  (11, p. 8)1'
I/  An evaluation of 1973/74 expenditure data for chlordane in the U.S.  indi-
    cates that average insecticide cost per acre treated was $1.91.   At  the
    recommended broadcast rate of 2 pounds active ingredient per acre, this
    implies a price per pound of $0.95, which was far below the going price
    in 1974 (about $2.00/pound).

2/  This has been confirmed by a more recent study which indicates that  50
    percent of insecticides used on corn are used needlessly (Midwest Research
    Institute, July 1975).
                                    -31-

-------
                 Use Patterns for C/H and Other  Controls


National Level

     In 1971, 56% of the chlordane and 97% of the  heptachlor were
used on corn (Table 3 and Table 5).   Although these  figures are
substantial, C/H are not used on very large percentages of U.S.  corn
acreage or corn farms.   As of 1973,  C/H was used on  only  2.5%  of U.S.
corn acreage and 1.8% of farms (1.7  million acres  and  17,300 farms
out of 70.5 million acres and nearly 1 million farms) (Table 11).
Actually most corn farmers (75% in 1973) do not  use  corn  insecticides
of any type and a majority of corn land (61.8% in  1973)  is not so
treated (Table 11).

     Use of C/H to protect corn can  be expected  to increase as a
result of the aldrin suspension.  Aldrin was used  on 10.6% of  U.S.
corn acreage in 1973 (10% in 1974).   It is also  expected  that
heptachlor use would have increased  notably, to  as much as 3 million
pounds in 1975 (10).  Heptachlor substitutes somewhat  more readily  for
aldrin on an economic basis than does chlordane.


Regional and State Levels

     Data on the extent of heptachlor and chlordane  use on corn  are
available from several  sources.  The farm pesticide  use surveys  of  the
Economic Research Service (ERS) of USDA estimated  use  of  heptachlor and
chlordane on corn, by region, for the years 1966 and 1971.  The  data,
presented in Table 12,  shows no clear trend for  total  national use  of
heptachlor, while use of chlordane more than doubled from 1966 to 1971.
Nearly all of the heptachlor is used in the Corn Belt  and chlordane is
used largely in the Corn Belt plus the Lake States,  according  to these
surveys.

     According to data  presented at  the aldrin/dieldrin suspension
hearings, heptachlor and chlordane use on corn is  concentrated in five
Corn Belt states:  Iowa, Missouri, Illinois, Indiana and  Ohio.  These
five states accounted for more than  70% of C/H treated corn acreage in
1973 (1,237,000 acres)  while these states had only 48% of U.S. corn
                                       -32-

-------
Table 11 -- Acreage and number of farms applying insecticides
            on corn, U.S. 1973
Treatment Acreage
No.
(1000)
Aldrin 7,448
Belt (Chlordane) 812
Heptachlor 901
Sevin 360
Other Carbamates 8,753
Phosphates 7,794
Other Phosphates 860
Total treated 26,928
Not treated 43,561
Total 70,489

Percent
10.6
1.2
1.3
0.5
12.4
11.5
1.2
38.2
61.8
100.0
Farms
No.
70,378
8,328
9,054
8,839
92,352
79,251
13,638
241,607i/
728,416
970,023

Percent
7.3
0.9
0.9
0.9
9.5
8.2
1.4
24.9— X
75.1
100
—  Items do not add to totals because many farms applied more than
   one of the pesticides.

SOURCE:  Aldrin/dieldrin suspension hearings - Exhibit S-16.
                                -33-

-------
Table 12 -- Regional  Corn acreage  treated  with  chlordane and heptachlor,
            1966, 1971
Region
Northeast
Lake States
Corn Belt
Northern Plains
Appalachia
Southeast
Delta
Other Regions
Total U.S.
Heptachlor
1966 1971
15 62.1
150 31.4
1,718 1,807.3
131
*
-
11
1
2,026 1,901
Chlordans
1966 1971
3 4.8
85 159.0
102 342.9
-
22.8
20 3.7
-
_
210 533.2
*Less than 500 acres

SOURCE:  Jenkins, et. al.,  "Economic Impact of Discontinuing  Farm
         Uses of Chlordane," USDA-ERS,  1972

         Delvo, et. al., "Economic Impact of Discontinuing  Farm
         Uses of Heptachlor", USDA-ERS, 1972

         Andrilenas, Paul,  "Farmers' Use of Pesticides,  1971",
         USDA-ERS, 1974
                                    -34-

-------
acreage that year (70.5 million acres) (Table 13).-

     Chlordane is used mainly in Ohio, Indiana and Illinois,  on about
2 to 3% of the corn grown in those states (Table 13).

     Heptachlor use is centered in Illinois and Iowa,  where its use
equalled 5.8 and 1.8% of total corn acreage in 1973.   Chlordane use
is less heavily concentrated in remaining states as more than 350,000
acres were treated in states other than the 5 Corn Belt states
identified in Table 13.

     The number of farms using C/H, as reported in Table 14 for 1973,
are in line with numbers of acres treated.  Illinois  has the  heaviest
concentration of C/H users with 5,400 (6% of corn farms).  Iowa was
next with about 3,700 users (heptachlor only).
]_/  Estimates of the extent of heptachlor and chlordane use on  corn  are
    available from several other sources.  Under an EPA contract,
    Theodore Riedeburg Associates (11) derived estimates of soil
    insecticide use in four major corn producing states.  Their estimates
    are higher than those from other sources.   Delvo presented  limited
    data on heptachlor use in his analysis (12) of the impact of cancelling
    farm uses of aldrin.   Also, the five Lake States of Indiana, Illinois,
    Michigan, Minnesota and Wisconsin published use data.   These reports
    give limited data on corn acreages treated in the Great Lakes  region
    (13 and 14).  Estimates for 1974 have been provided by extension  ento-
    mologists and are included in Appendix B.
                                     -35-

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                 Costs of C/H and  Alternative  Controls
     Insecticide ingredient costs  for corn soil  treatments  are generally
$1.50 to $5 per acre depending on  whether broadcast or row  treatment is
used and which chemical  is applied.   These costs are a relatively small
portion of the overall  corn budget and value of  the corn crop.  At $3
per bushel for corn and a yield of 100 bushels per  acre (which is
typical in corn growing areas where  many of the  insecticides  are used),
insecticide costs equal  less than  two percent of the value  of the crop.

     Table 15 includes  a summary of  insecticide  costs per acre for
typical applications to control corn soil pests  in  major midwest corn
producing states (prices current as  of 1974). Broadcast application
generally costs twice as much as row (band or furrow) application
because of higher rates  of active  ingredient applied.  For  example,
band treatment for cutworms with chlordane would cost $1.45/acre
compared with $2.90 for broadcast  treatment due  to  a doubling of the
application rate (Table 15).

     C/H and aldrin are roughly half the cost of other pre-emergence
controls such as diazinon.  However, rescue treatments for  cutworms
such as Sevin (carbaryl) and Dylox (trichlorofon) are in the  same cost
range as C/H.  These rescue treatments are less  expensive than broadcast
aldrin or C/H treatment by $1 to $2  per acre. Also, they are not
applied unless needed,  which lowers  costs to the farmer.  Limited data
are available on added  costs of scouting to use  rescue treatments
effectively.  However,  scouting costs should be  nominal inasmuch as
scouting can, in many cases, be accomplished at  little added  cost in
connection with other field operations, such as  cultivation and routine
observation of growing  crops.!/

     Row treatments of  corn insecticides do not  involve a separate
field operation, as the insecticide  is applied with an attachment to the
corn planter.  The only added cost is for this attachment.   Broadcast
treatment may involve a separate field operation, thus adding fuel and
other costs to producing the crop, possibly reducing the popularity of
broadcast treatment.
\l  Scouting is discussed in more detail in Section V of the report.
                                      -38-

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                             4#/Gal E.G.
                             20% G (granules)
                             20% G
                             33% G
                             72% E.C.F.
                             14% G
                             Ag 500
                             5% bait
                             4#/Gal.
                             4#/Gal.  E.G.
                             4# E.G.
                             20 G
                             20 G
                             33% G
                             72% E.C.F.
                             14 G
                             Ag 500
                             80% S.P.
                             4#/Gal.
2 qts.
10 Ibs.
10 Ibs.
12 Ibs.
2 qts.
14-28 Ibs.
2-4 qts.
10-20 Ibs.
1-2 pts.
2-4 qts.
1 qt.
5 Ibs.
5 Ibs
6 Ibs.
2 pts.
7-14 Ibs.
1-2 qts.
2-5 Ibs.
1/2 Gal.
$ 3.
  3.
  2.
  3.
  98
  20
  90
  60
Table 15--Insecticide costs for typical corn soil pest application in midwest,  1974
Target pest/
Method/Chemical              Formulation           Rate/acre         Cost/acre

Cutworms and wireworms
(also grubsj	

Broadcast
   Aldrin

   Heptachlor
   Chlordane

   Diazinon

   Sevin (cutworm)
   Dylox (cutworm)
Dyfonate

Band
   Aldrin

   Heptachlor
   Chlordane

   Diazinon

   Sevin (cutworm)
   Sevimol  (cutworm)
  4.45
  7.35
 15.00
    70
    90
 10.30
$ 1
  1
  1
  1
  2
  4
  98
  60
  45
  80
  25
  90
7.50
2.25
3.20
Western Rootworm (Band)
Furadan 10G
Thimet 15G
Dyfonate 20G
Modcap 10G
Dasanit 15G
Diazinon 14G
Diazinon 50W
Bux 10G

7.5 Ibs.
6.5 Ibs.
5 Ibs.
10 Ibs.
6.5 Ibs.
7 Ibs.
1-2 Ibs.
10 Ibs.

9 ozs.
8 ozs.
6 ozs.
12 ozs.
8 ozs.
8.5 ozs.
1.25-2.5 ozs.
12 ozs.

$ 3.30
2.50
2.85
3.20
2.85
2.60
4.50
3.80
SOURCE:  Theordore Riedeburg Associates, Pesticide Use for Control of Soil
         Borne Insects in Corn in the States of Indiana, Illinois, Iowa and
         Missouri, November 1974.
                                          -39-

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           Production Impacts of C/H  and  Alternative Controls


     This section summarizes available  data  on  the yield and production
impacts of using C/H vs.  alternative  controls for rootworms, wireworms
and cutworms.

     Production/yield benefits of the use of a  given pesticide  treatment
depend on two  critical  factors:
     (1)  efficacy of the treatment in  controlling the  target pest
     (2)  the  level  of infestation
Pesticides generate maximum benefits  when they  are highly  effective  in
controlling the pest and  when infestation levels are high.  This  section
summarizes available information on the yield impacts of alternative
controls taking into account these two  factors.

     Unfortunately, estimation of yield benefits from the  use of
alternative pesticides is not at all  a  precise  process  because  levels of
infestation vary greatly  from year-to-year and  from area-to-area, even
though efficacy and use patterns may be more stable.

     Ideally we would be  able to make precise point estimates of  yield
and production impacts of a cancellation. However, because of  data
limitations and because of year-to-year variations in economic, weather,
and infestation conditions, this is not feasible.  We are  left  with  only
the option of making estimates of the range  of  possible effects—hopefully
covering the range of best-case to worst-case outcomes. Even if  a very
precise and accurate estimate is made for a  given year, one cannot be
sure'how such a year compares with other  years.  The data  presented  in
this section provide the  basis for making worst case estimates  of impact
which are presented in a  later section.  Studies are in process to
develop necessary data on infestation levels and yield  effects  with
alternative controls such that a typical  or  average case outcome  can be
analyzed as well.

Rootworms

     The recommendations  of the states  reflect  the general  view of
entomologists that rootworms are better controlled with nonorganochlorine
insecticides or by crop rotations, avoiding  corn following corn.
Accordingly, it is likely that there will be some  increase in yields as
alternates to aldrin are  used to control  rootworms.  As of 1971,  4.7
million acres  were being  treated with aldrin for rootworms (12).  No doubt
                                     -40-

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some C/H treatments were also aimed at rootworms at that time and may
still be targeted at them.I/

     Inasmuch as alternative controls do a better job than chlorinated
hydrocarbons, shifting to one 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 (15).  This is consistent with reports obtained in 1973
from entomology department chairmen in universities of major corn
producing states.  This survey, conducted by USDA, indicated that
increased yields of up to 10 bushels per acre on those acres treated for
resistant rootworms would result from going to nonorganochlorine alternates
in states of Iowa, Wisconsin, Missouri, Indiana and Illinois (16).

     As an example, Turpin and Matthews estimate that in 1974 about 250,000
acres planted only to corn each season were treated with aldrin in the
northern third of Indiana where the western corn rootworm is established
(17).  They estimate that the minimum loss in Indiana on uncontrolled
infestations of western corn rootworms is 5 bushels per acre.  Therefore,
if organophosphate or carbamate insecticides were used on those acres,
there would be a saving of 1,250,000 bushels (17).


     The potential for increased yields from nonorganochlorine alternatives
for rootworms was also recognized by Delvo in 1974 (12, p.  6).


Wireworms

     Wireworm yield effects tend to be spotty and most likely to occur in
corn rotations following sod, pasture or idle acres.   The spotty nature of
wireworm problems was suggested by Munson (Missouri Survey Entomoligist)
who stated 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 application so that economic
returns cover the cost of treatment.  Production impacts from the lack
of organochlorine controls have been estimated variously from increased
]_/  According to one survey, as of 1971, 262,000 acres out of 669,000
    acres of corn treated with heptachlor were treated for rootworms
    (39%) (29).

2/  In May, 1974, Munson met with Arnold Aspelin and Fred Hageman of EPA,
~   who were on a field trip to Missouri.  At that time, a map was prepared
    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".
                                      -41-

-------
yield, to no effect, to yield reduction of 5 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.; Nebr.,  not known;  Ind.,  not
known; and 111., +5 bu.) (16).   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 (12).
He estimated no yield effects from alternatives for control  of  wireworms
in Ohio, Indiana, and Illinois.  He did estimate an  8 percent reduction in
Iowa, Missouri and certain other unspecified Lake  States and  Northern
Plains States, assuming alternatives  are used under moderate  to heavy
outbreak conditions as compared to control under the same conditions by
organochlorines.  These predictions  seem rather extreme considering the
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 production).  This is unlikely to occur, judging  from historical
records on wireworm and other pest cost and pest infestations during the
last 25 years.V

     For some species of wireworms,  the necessity  for organochlorines is
also questionable 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
question whether it is needed to control wireworms,  thus raising  the same
issues relative to C/H (18).

     Recent test data from Illinois,  Iowa, Indiana and North Dakota further
indicate that certain organophosphate and carbamate alternatives  are as
effective as organochlorines in wireworm control.(32)2/

     Another dimension to the wireworm problem is  that its 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 (19).
 I/  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 (Review by Fred Hagetnan,
    EPA entomologist).
 2J  Field tests  in Illinois in 1975  (personal communications from
    Luckmann, August  1975) indicate  that carbofuran applied in the
    furrow will  control wireworms.
                                      -42-

-------
Cutworms

     Aldrin and heptachlor are still  effective for cutworm control  even
though we cannot assume that aldrin,  or 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" (20). 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 reported that of 5 fields which had reported black cutworm
infestation during 1972 and 1973, all of which had a moderate to severe
problem, 3 had not been treated and 2 had been treated with aldrin, one
by band and one by broadcast application (32).

     Petty stated:

     "The more serious problem of the black cutworm is not
     completely corrected by the use  of chlorinated hydrocarbon
     pesticides, as evidenced by the fact that county Extension
     advisers received over 90 complaints of cutworm damage in
     1972 in fields in which aldrin,  heptachlor and chlordane
     were used"  (32).

     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 to indicate that aldrin is either being misapplied
and/or is not effective enough to prevent injury under pressure of
high populations.I/

     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 management specialist (21).

     Cutworm damage, in terms of dead plants, can range to near 100% in
extreme cases.  Luckmann observed damage in certain parts  of fields in
V  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.
                                      -43-

-------
1974, ranging from 6 to 85%, averaging 28% in the hot spots  among  15
fields with damage (6).  According to Gaddy,  a reduction in  stand  of 17%
will reduce yield by 15% on Missouri  bottomland (19). 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.!/  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 nontreated areas of  13 bottom-
land fields in 6 Missouri counties indicated a yield differential  of
7.93 bushels in favor of aldrin (120.69 vs. 112.76),  an increase of
about 7% yield while the plant population averaged only 3.5% higher
(17,538 vs. 16,942)(Appendix A, Table 2).  This test was done  on farm
cooperator fields in bottomland areas.  Although this test is  not  based
on a large statistical  sample, it gives an indication of average yield
improvement under field conditions, compared to no treatment.   Unfor-
tunately, 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 C/H and
alternatives has been frustrated by lack of test areas with  infestations
of cutworms.2/

     Key issues in estimating the impacts of shifting to alternative
cutworm controls are the level of damage during an infestation and 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 water, either during the current  year or
from the previous 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 (22).  Similar frequencies  are
indicated in the 1974 Missouri insect control recommendations  where
treatment is recommended on soils subject to annual  or frequent infestations
(3 out of 5 years) and on first year corn after sod  (23).


T7Meeting with  G.W.  Thomas  of University of Missouri  and A.  Aspelin and
     F.  Hageman  of OPP,  EPA  in May, 1974,  in  Columbia, Mo.
2/   Letter  from Armon  Keaster, Entomologist, University  of Missouri,
     to  Arnold Aspelin,  EPA,  1974.
                                     -44-

-------
     According to Fairchild at the aldrin/dieldrin cancellation 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 produc-
tion loss" (24).  Presumably, all other fields would have less frequent
losses.

     Petty testified that cutworm damage at economic levels would not be
expected to occur in more than 3 or 4 years out of 10 in the high risk
area of Illinois  (25).

     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, Turpin 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 instances.  A few of these fields were treated with chlorinated
hydrocarbons (26).

     An estimated 30 to 40% chance of infestation in high risk areas
is confirmed by the previously mentioned research results in Missouri
on 13 bottomland test fields (Appendix A, Table 2).  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 treated for cutworms with organochlorine
would suffer heavy cutworm damage  in a typical year, if not treated.

     Delvo of USDA, based on his survey of state entomologists in
1973, indicates the following percentage yield reductions from cancelling
organochlorines to control cutworms on 1971 aldrin acreages (30).
                                     -45-

-------
                         With use of alternatives     Without  use  of  alternatives
                                             -percent-
Ohio                               -5

Indiana                            -10

Illinois                           -10

Iowa                               -10

Missouri                           -15

Lake States & Northern Plains      -10

Other states                         0
10

25

25

25

30

25

 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 (Appendix A, Table 2).  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.  Surveys of state
entomologists by EPA and USDA, conducted in 1973, indicated yield
reductions due to control of cutworm with nonorganochlorines in the
range.of 5 to 10 bushels per acre (16) (27).
                                      -46-

-------
                    Economic Impacts of Cancellation

     Presented in this section are the results of a linear programming
analysis for U.S. agriculture indicating impacts of the C/H cancellation
during the period 1975-80, on a typical year basis (1977).V  This  section
also 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.

Earlier Studies

     Staff members of the U.S. Department of Agriculture have prepared
brief economic impact analyses of the effects of discontinuing farm use
of chlordane (28) and heptachlor (29).  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 pounds 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 (210,000 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 four times the acreage shown in the USDA study (812,000
         acres in 1973 as shown in Table 11 above in contrast with
         USDA's estimate of 210,000).

     2.  Costs of the alternatives of $8.80 per acre are excessive  as
         compared with those in Table 15.

     The heptachlor report (29) 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 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
]_/  This analysis of impact is based on worst case assumptions of impact.
    Another analysis of impacts with typical  or average yield and cost
    effects will be completed in the near future.
                                      -47-

-------
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 cost 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
inconsistent with USDA's 1971 Pesticide Use Survey which indicates that
heptachlor was used on 1,901,000 acres, (see Table 12 above).  If adjust-
ment 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 2.8 times or to 0.04% of the U.S. production,
i.e., about 2.5 million bushels.  It is not known whether such a trans-
formation is entirely appropriate; it is included here only for illustrative
purposes.

Impact of C/H and Aldrin Cancellations:  1975-80, Typical Year Basis

     This section of the report presents results of a linear programming
analysis of the U.S. agricultural sector focusing on the impacts of the
combined cancellation of aldrin, chlordane and heptachlor for use on
corn during the period 1975-80, typical year basis.  The year 1977 is
selected for purposes of presenting results of the cancellation.  The
approach is to evaluate impacts of the cancellation by comparing a bas'e
solution which reports an equilibrium agricultural sector for the year >
1977 and a solution with the cancellation of aldrin, chlordane and hep-
tachlor with resulting impacts on acreage production and income for agri-
cultural crops in the U.S.  The model consists of crop activities for
127 production regions which are aggregated into 27 consuming regions for
which final demands are specified.  Seven crops (irrigated and dryland) are
endogenous to the model: barley, corn, cotton, soybeans, oats, sorghum, and
wheat.  The model allocates acreage to these crops in the various regions
in optimum least-cost manner as operators employ land in the use which
yields the greatest return.  In the base solution separate activities
are included for corn produced with no insecticides, with insecticides
other than organochlorines and with organochlorines.  Land is used for
these alternative approaches according to type (i.e., whether or not
infested with soil insect pests, land class, etc.) and according to
profits from alternative approaches to raising corn in competition with
other crops.  The alternative solution differs from the base solution by
eliminating the cancelled organochlorines.  Cancellation leaves open
the possibility that land previously treated with those chemicals will
remain in corn production, with or without alternative insecticides.
The land may also be shifted to an entirely different crop or become
idle, possibly under a Government program.
                                      -48-

-------
     The model attempts to simulate how impacts of a restriction will
unfold after a period of adjustment has been permitted to occur and a
new equilibrium is reached.  This type of analysis is preferred to the
more routine procedure of estimating yield and cost impacts on fixed
acreages at state and regional levels because shifts in yields and costs
of a particular crop have impacts not only on that crop but also alter-
native crops which may be grown in its place.  For example, a given type
of land in a region may suffer a 10% reduction in net returns as a result
of a cancellation.  This may shift that land to the production of another
crop.  This means that other land will be brought into use in order to
maintain production.  A more detailed discussion of the logic and para-
meters of the model is presented in Appendix C.

     Estimates of corn infested with wireworms, rootworms, and cutworms
were based upon data presented at the aldrin/dieldrin hearings on the
number of farms and acreage estimated to be infested for the year 1973.
These data presented at the state level were allocated among the appro-
priate 127 regions.  Costs of alternative pesticides are projected forward
to be representative of costs as of 1977 from a base of 1973 costs.

     Yield impacts of cancellation were developed by Delvo for a moderate
to heavy infestation year (12). Delvo, as discussed earlier in this report,
estimated yield reductions at two levels:  a) with the use of alternatives
and b) without the use of alternative controls.  Delvo's estimates of
impact on yield were supplemented by an additional assumption that land
infested with rootworms would generate 8% higher yields if alternatives
to organochlorines were used.  Delvo had assumed that no increase in yield
would occur, although he recognized the possibility that yields could
increase from the use of alternatives on rootworm infested land  (12).
                                     -49-

-------
Solution Impacts

     In this section we have not attempted to report all  details  of
impacts associated with a C/H restriction as  set forth under the  pre-
ceding assumptions.  Rather, the primary impacts will  be  reported.   It
should be pointed out that, while impacts will  be reported here on  a
aggregative basis, e.g. acres of corn per state or regions, the model
solution shows impact by soil (irrigated, nonirrigated or fallowed)
within a region.

     On a national basis, the model  solution  shows an aggregate increase
of 200,000 acres planted to corn.  This results from the  fact that  corn,
even at slightly reduced yields, is still a more desirable feedstuff than
alternative feedgrains; farmers would increase their planting slightly
to offset minor yield reductions.  Total changes in land  use are  reported
in Table 16.  Slack or idle cropland (reported in the last column of
Table 16) 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' willing-
ness to plant slightly more acres of feedgrains in general to replace
corn in particular.  This change amounts to approximately a 3.7%  reduction
in slack or idle land between the two solutions.

     As a welfare concept, the model reports  total returns to the land
(net of variable operating expenses).  In general, economic theory  suggests
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 consistent with this theory.

     As shown in Table 17, the net returns to land for all endogenous
production activities in all regions increase by slightly more than
$71 million.  The distribution of this increase varies by region  and
production alternative; but, on a national level the directional  change
is unambiguously positive.  The only negative entries in  the U.S. total
column of Table 17 are for chlorinated hydrocarbon corn activities,
signifying the reduced returns to land from these activities after
cancellation 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% to 23.4% and an overall 2.15% increase
in returns to land in general (U.S. total).
                                    -50-

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     Any modification of parameters such as yield per acre (as was
assumed to be true with a C/H restriction) causes prior model solutions
to be nonoptimal.   Activity levels in prior solutions no longer repre-
sent least cost solutions and the model will therefore "search" for
new activities which can reduce the overall objective function.  Activity
adjustments can take the form of production levels (acres within a region),
transportation between regions, substitution of production between land
classes (use of higher or lower yielding land within a production
region) and/or substitution of one commodity for another in optimum feed
mixes.  All of these adjustments will lead to changes in total production
within a region.  Therefore, an examination of changes in production of the
endogenous crops within regions provides both an indication of the
severity of the impact as well as the overall level  of the impact.

     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 (+2.43%), corn grain (-0.70%), cotton lint
(+0.02%), soybeans (-0.09%), oats (+3.90%), sorghum (+1.90%), wheat
(0.2%).  The absolute and relative changes for these crops are
reported in Table 18 for seven aggregate subregions  of the U.S.

     Shifts in land use are a result of changes in comparative advan-
tages and prices following cancellation.  The major impact of these
shifts can be evaluated at the national level by examining changes in
production.  In total, corn production is decreased by 36.9 million
bushels (0.70% of base production).  This reduction is offset by
increased production of barley (8.56 million bushels), oats (11.61
million bushels),  grain sorghum (20.55 million bushels) and wheat
(3.54 million bushels).  While the overall reduction in corn production
is modest at the national level, some regional adjustments are quite
significant.  For example, equilibrium adjustments in the North Central
region total to 194 million bushels of corn (approximately 1.5 million
acres).  This was the largest single adjustment in corn production
(6% of base model  production).  Clearly, this represents a major change
in production patterns and would result in major adjustments in land use.
From Table 16 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).
However, in the North Central region there is an increase of 290,000
acres in idle land.  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.
Resulting income adjustments, as depicted in the "North Central"
column of Table 17, result in a very small increase in net returns
to land of $150,000 in aggregate.

     Further adjustments occurring in the North Central region (although
not reported completely in this section) show an increased transportation
of corn into the North Central from other regions of the U.S., equalling
                                     -53-

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Table 18 -- Absolute  and relative change in production of endogeneous crops  as  a
            result  of C/H restriction, by aggregate U.S. subregions, 1977

Region

North East

South East

North
Central

South
Central

MTN & 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 Cotton
Grain Lint
bu. Bales

0.56 0
(0.18)
23.80 0.01
(12.63) (6.39)

-194.2- 0
(- 6.00)

15.69 -0.05
(88.61) (-0.93)

115.68 0.03
(8.78) (0.54)
1.19 0
(6.14)
0.44 0
(0.24)
-36.91 *
(- 0.70)
Commodity
Soy-
beans Oats
bu . bu .
;nf units (t\ 	 „ 	 .
-0.04 0.04
(-0.28) (1.07)
-6.04 0
(-5.15)

38.60 -1.01
( 3.21) (-2.90)

-0.62 0
(-0.27)

-33.62 12.64
(-11.09) (4.88)
* 0

* *

-1.17 11.61
(-0.09) (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.

-0.21
(-0.5)
+ .14
(+1.3)

-2.59
(-1.9)

.4
(0.6)

5.88
(0.6)
.07
(0)
- .17
(-0.2)
3.54
(0.2)
* = Less than 5,000 units

Source:  EPA linear programming analysis.
                                           -54-

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171 million bushels.  As a result, although gross oroduction 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 is supplied via interregional  trade.

     In general, while examination of any one region, commodity or
parameter in the model might reveal major adjustments and/or impacts
associated with the C/H restriction, the overall  evaluation of the
national model suggests minor adjustments which the agricultural sector
can respond to.  In addition, it must be kept in  mind that these solutions
depict the consequences of a C/H restriction assuming extreme impacts.

     The reduction in U.S. corn output of 36.9 million bushels  (0.70%)
is within the range of estimates made Delvo for cancelling use of
aldrin with and without the use of alternatives.   His estimate of impact,
using nonorganochlorine alternaitves on wireworm and cutworm land, was
21.1 million bushels; without alternatives, it was 55.1  million bushels
(0.4 to 1.1%).  The estimate of 36.9 million bushels based on the linear
programming analysis is equal to the low end estimate resulting from a
1973 review of possible impacts of the combined aldrin,  heptachlor and
chlordane cancellation in the states of Ohio, Indiana, Illinois, Iowa and
Missouri. !_/  In that review, the production loss was estimated to occur
within the range of 34.9 - 84 million bushels in  only those five states.
Taking into account the remaining states which would have suffered some
production losses, this review places the minimum range  of possible
production losses somewhat above the linear programming  analysis worst
case estimates.

     The corn production impacts of the C/H cancellation can be brought
into perspective by viewing them within the context of year-to-year vari-
ations in corn production in the United States.  Presented in Figure 1
are time series data on production of corn in the United states for the
period 1962-1974 and year-to-year changes charted on a zero axis to more
clearly visualize the variability of production of corn  in the United
States due to all factors. 2J  Since 1962, corn production has varied from
a low of about 3.5 million bushels to more than 5.5 billion bushels with
year-to-year changes of as much as 500 million to 1  billion bushels. The
impact of 36.9 million bushels is nominal by comparison  with year-to-year
changes to all factors impacting on the production of corn in the United
States.  It is dwarfed by the precipitous decline in production in 1974 and
by the large drop in production in 1970 attributable larciely to the corn
blight.
]_/  Report entitled "On-Farm Effects of Aldrin, Heptachlor, and Chlordane
    Cancellations for Corn," by Ralph Freund, Economist, Office of
    Pesticides, EPA, August, 1973.
2/  Figure 1, presented in Part II of this document, page 165.
                                        -55-

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                    Comparison of C/H and Aldrin Impacts


     Presented in Table 19 are additional data on the impacts  of can-
cellation at the national  level, with a rough breakout of impact
attributable to C/H and those attributable to aldrin.  Allocation of
impacts between the C/H cancellation and the aldrin suspension is on
the basis of 1973 acreage of corn treated with the three  chemicals (18.7%
C/H and 81.3% aldrin).  Because of substitution of one chemical  or
another, a procedure such as this is needed to appropriately attribute
the impact to one or the other action.

     The apportionment of production impacts between the  two actions
is 6.9 million fewer bushels for C/H and 30.0 million fewer for aldrin
(total of 36.9 million).  In percentage terms, the production  impacts
are:  C/H - 0.1%; aldrin - 0.6% and total -07%.

     Acres of cropland used for the seven crops increased by 1.16
million, of which 217,000 acres was due to C/H.  For corn,  the
reduction in corn acres was only 37,000 acres—out of the total  200,000
acres for C/H plus aldrin.

     The LP model indicated a 2.6% increase in the price  of corn (0.5%
for C/H alone).  This figure is larger than one would expect based on
time series price analysis coefficients in which it is generally
recognized that a 1% decline in the production of corn results in a
1.5% increase in price.  A reduction in production of 0.7 percent would  .
indicate a price increase of only 1.05% (1.5 x 0.7).  The higher
price effects in the model solution are due to the assumption  that U.S.
demands for protein and total digestible nutrients from feed grains are
fixed in the model, thus generating a more inelastic demand than is
observed through time series estimation.

     Interregional grain transportation costs increase slightly in
percentage terms (0.9% for corn and 0.5% for the seven crops combined)
and by $3.74 million and $6.36 million, respectively (Table 19).
These increases are attributable largely to the assumption  maintained
in the model that total regional demands for livestock feed are fixed,
whereas in practice one would expect movement of livestock  feeding to
areas near feed production in case of regional chanae in  feed  grain
production.
                                        -56-

-------
*#*•«**    KL
                                    cts of piX)[TOt.i-U concollnticn; onnrtiont-d into C/1I uixi
                                    in, focu'i mi corn, o* liL't (jinini; and cott-on, U.S.
                                    any 197i-CO, 1977 tyiucaJ year
            Information
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'73)
to
ion]
i

;s










































Unit
1,000 acres
Pet.
C/ll
1,733
18.7
cancellation (cancellation


1,000 acres
1,000 acres
1,000 acres
1,000 acres
1,000 acres
(Pet.)
1,000 bu.
(Pet.)
•1,000 acres
n
•
M
»
m
"
M
Pet. •






$mUlion
M
•
$million







•
Percent







M


1,040
26
-1,400
140
37
(0.7)
-6,901
(-.1)
37
32
15
-75
47
75
84
217
0.5
0.3
0.1
-0.1
0.3
0.5
0.1
.70
.49
1.19

-1.19
.95
1.11
7.11
1.29
2.07
1.88
13.32

-.1
1.1
.3
.0
2.5
.8
.4
.4
Aldrin
7,448
81.3
sollution minus


4,510
1,140
-6,080
590
163
(3.3)
-30,009 .
(-.6)
163
138
65
-325
203
325
366
943
2.1
1.2
0.7
-0.2
1.4
2.0
0.5
3.04
2.13
5.17

-5.17
4.11
4.64
30.89
5.59
8.99
8.19
57.92

-.5
5.0
1.4
3.4
10.8
3.4
3.5
1.0
Total
9,101
100.0

/

5,550
1,400
-7,480
730
200.0
(4.0)
-36,910
(-0.7)
200
170
80
-400
250
400
450
1,160
2.6
1.5
0.8
-0.3
1.7
2.5
0.6
3.74
2.62
6.36

-6.36
5.06
5.05
38. CO
6.88
11.06
10.07
•»71.25

-0.6
6.1
1.7
4.2
13.3
4.2
1.9
2.2
Source:   EPA linear programming  analysis.
                                                    -57-

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     The increase in returns to land due to  the  combined  aldrin  and
C/H cancellations is $71.25 million, of which  $13.32  million  is  due
to C/H cancellation (Table 19).  The corn sector has  a  net  reduction
in returns to land at the national  level  of  $6.36 million (-0.6%)  as
a result of the cancellations,  of which $1.19  million is  attributed
to C/H.   Returns to land for the seven crops combined increased  by
2.2% (0.4% due to C/H and 1.8%  for  aldrin).
                                        -58-

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                     Impacts on Food Production Costs
             and Expenditures for Food at the Consumer Level

     The linear programming model estimated changes in the agricultural
economy as a result of the proposed C/H cancellation.  Price levels of
the endogenous crops generally increased as substitution of one crop
for another took place, although the price of soybeans declined.  In
Table 19, the percent change in the price for individual crops is
shown and they vary from -0.3% for soybeans to 2.6% for corn.  In
addition, the model simulates the cost of producing meat and poultry
products and nonmeat foods.  Most of the increased costs occur in the
corn and feedgrain sectors which directly affect the cost of producing
red meat and poultry on grain intensive rations.

     To estimate impacts at the consumer level in response to changes
in production costs at the farm level, it is assumed that all increases
in the prices of endogenous crops and increases in meat and nonmeat
commodity prices are passed on to the consumer.  This is consistent with
the preconditions or restrictions built into the linear programming model
that an equivilant quantity of food would be demanded and therefore supplied
before and after the cancellation decision.]/

     The linear programming model was run for a typical year and 1977
was chosen to estimate expected annual costs.  In the estimation of impacts
all values of relevant variables are projected for 1977.

     The model provided an estimate of $364.8 million as the change in
the production level cost for 1977.  This estimate includes all cost
increases which result from the cancellation, e.g., the impact of higher
prices, changes in production costs and/or yields, changes in transpor-
tation costs, etc.2/  The $364.8 million impact is based upon worst case
assumptions and represents the maximum amount that expenditures for food
would be expected to increase.3_/
]_/  The implicit assumption is that consumer demand for food is not
    affected by the cancellation (demand is completely inelastic).

2J  The model converts feedgrains into corn equivalents.  To project price
    levels for all crops it was necessary to predict corn price for 1977.
    A linear trend regression estimated price at $2.50 per bushel and this
    price is used to represent costs in 1977.

3_/  Food prices would not exceed this dollar amount because the C/H
    cancellation is at the farm level of implementation which is highly
    competitive.  Available evidence is that cost changes at the farm
    level are passed on to the consumer by the amount of change in cost.
                                          -59-

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     Consumer expenditures for food in the most recent year were $164.5
billion.  The percent of disposable personal  income (income net of taxes)
spent for food in 1974 was 16.8% (31).  In the past ten years  it has
averaged 16.66% and the average variations for this period of  time has
been less than one percent.   Expenditure for  food were projected out  to
1977 using a linear trend regression, based upon data in the previous
10 years.  The regression predicted a total expenditure of $191.04 billion.

     In relation to the C/H cancellation, the impact is equal  to 0.19%
increase in price for all food expenditures.   For meat products depending
on large quantities of feed grains price impacts are expected  to range  be-
tween .4 and .5%.  Using a U.S. population estimate of 215 million for
1977, the C/H cancellation amounts to an annual $1.70 per capita, when
analyzed with worse case assumptions.
                                         -60-

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                Conclusions on LP  (Linear  Programming) Analysis
      The foregoing analysis indicates significant differences in economic
 variables during the 1975-80 period, with and without C/H and aldrin,
 under worst case assumptions of yield impact (i.e., moderate to heavy
 infestations over the entire C/H and aldrin use area in a given year -
 which is unlikely).  The LP analysis was utilized to make comparisons of
 economic results during 1975-80 on a typical year basis (focus 1977
 for convenience), on the assumption that the new policy had become
 fully effective, i.e., no C/H and aldrin available, and all other
 necessary economic adjustments had been made in the cropland sector
 to meet regional, national and export commodity demands.  In terms of
 economic theory, a comparison was made in values of economic variables
 (e.g., price, acreage, production) under two differing conditions of
 equilibrium, without regard to transitional impacts of shifting from
 one equilibrium condition to another.

      Some of the key impacts of the combined C/H and aldrin cancellation/
 suspensions at the national level were:
 1.   Corn production

 2.   Acreage of corn raised with no
     pesticides

 3.   Acreage of corn raised with non-
     organochlorine insecticides

 4.   Corn acreage raised with organo-
     chlorines

 5.   Total corn acreage

 6.   Total cropland in use

 7.   Price of corn and other grains

 8.   Grain transport cost

 9.   Net returns to cropland (i.e., net
     farm income)

         Corn

         Total (7 crops)

10.   Consumer prices of meat products

11.   Consumer prices for all food
 -36.9 million bushels (-0.7%)


 +5.55 million acres


 +1.4 million acres


 -7.48 million acres

 +200,000 acres (0.4%)

 +1.16 million acres

 +1 to 3%

 +6.36 million (0.9%)




 -$6.36 million

 +$71.25 million (+2.2%)

+0.4 to 0.5%

$364.8 million

($1.70/capita or 0.19%)
                                       -61-

-------
     These impacts are well  within  the range of year-to-year variations
due to the normal  operation  of the  economy in response  to  economic
factors, weather conditions, etc.

     The estimates of impact can be reduced considerably if one  does
not assume a worst case estimate of yield impact.   For  example,  the
reduction in a most likely case basis  could be in  the range of one-
half the above impacts.  Also, if focus is strictly upon impacts
attributable only to the C/H cancellation based on use  patterns  prior
to the aldrin suspension, the impacts  become quite nominal.

     The magnitudes of difference between the two  LP solutions are
greater than one would expect in a  given year because adjustments  will
be made over a period of several years.  For example, shifts to  alter-
natives already have been under way in 1974 and 1975 in line with  the
aldrin hearings and suspension.  Also, these analyses hold cost  and
yield effects of substitutions for  C/H and aldrin  constant, which  is
not entirely realistic.  It  is reasonable to assume that there are
trends toward development of pest resistance in C/H and in development
of more effective substitutes over a 5 to 10 year time-frame, which
could greatly reduce economic impacts of cancellation.
                                        -62-

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                       References  for  Section  III


 (1)   U.S.  Department  of Agriculture,  Agricultural Statistics, U.S.
      Government Printing Office,  Washington,  D.C., 1973.

 (2)   Schnittker,  John A.,  Study of  the  Economic  Impact of Cancelling
      Aldrin/Dieldrin  for Use  on Corn  in the United States, Prepared
      for Aldrin/Dieldrin Hearings,  Schnittker Associates, Washington, D.C.,
      February 1974.

 (3)   Aspel in, Arnold  L., Statement  for  Testimony at Aldrin/Dieldrin
      Suspension Hearing, September, 1974, Exhibit S-16.

 (4)   Midwest Research Institute,  Substitutes  for Aldrin, Dieldrin, Chlordane,
      and Heptachlor for Insect Control  on Corn and Apples, Draft, Final
      Report, EPA Contract No. 68-01-2448, 13  February 1975.

 (5)   Aldrin/Dieldrin  Suspension Hearings, Exhibit S-16, September 1974.

 (6)   Luckmann, W.  H., Professor and Head of Entomology Department, Univer-
      sity  of Illinois, Letter to  William Reukauf, OGC, EPA, August 23, 1974.

 (7)   Peters, D.  C., Aldrin/Dieldrin Hearings, Shell Exhibit 154B.

 (8)   Peters, D.  C., Aldrin/Dieldrin Hearings, Shell Exhibit 154D.

 (9)   Interview by Arnold Aspelin, EPA,  M. Fairchild, Univ. of Missouri,
      et. al. with John Deere  Farm Equipment dealer in Carrollton, Missouri,
      May 1974.

(10)   Aldrin/Dieldrin  Suspension Hearing Transcript, Exhibit S-16, September
      1974.

(11)   Theodore Riedeburg Associates, Pesticide Use for Control of Soil Borne
      Insects in the States of Indiana,  Illinois, Iowa and Missouri, Report
      conducted for OPP, EPA,  August 1974.

(12)   Delvo,  H..W., Economic Impact  of Discontinuing Aldrin Use of Corn
      Production,  Economic Research  Service, USDA, ERS-557, Washington, D.C.,
      June  1974.

(13)   Illinois Crop Reporting  Service, Pesticide  Use by Illinois Farmers,
      1970,  1972.  Bulletin 71-3 and  73-3, Illinois Extension Service.

(14)   U.S.  Department  of Agriculture,  Statistical Reporting Service,
      Pesticide Usage  on Farms, Indiana, and Five Lake States, 1969. 70.

(15)   Kuhlman, D.  E. and H.  B. Petty,  Summary of Corn Production Insecticide
      Demonstrations,  1968-1972, Twenty-fifth  Illinois Custom Spray Operators
      School, Urbana,  Illinois, 1973.
                                        -63-

-------
(16)  Survey coordinated  by  Cooperative State Research Service, U.S.
      Department of Agriculture, Washington, D.C., March 1973.

(17)  Personal  communication of F. T. Turpin and David Matthews, Entomolo-
      gists, Purdue University.

(18)  Stockdale, J., and  J.  Owens, Aldrin/Dieldrin Cancellation Hearing
      Transcript -  Shell  Exhibit 147; and EPA Exhibit 71.

(19)  Gaddy, H.,  Extension Agronomist,  statement  to  EPA personnel
      while on field trip in Missouri,  May  1974.

(20)  Department of Entomology, University of Missouri, Weekly Missouri
      Insect Situation  Report. June 3, 1973, p. 1.

(21)  Keaster,  A. J., and R.  E. Munson, entomologists and Paul Taylor,
      regional  Farm Management Specialist in Missouri; conversation with
      EPA personnel, May  1974.

(22)  Munson,  R.  E., map  prepared in May, 1974, University of Missouri.

(23)  1974 Missouri  Insecticide Recommendations, Missouri Extension Service.

(24)  Fairchild, M., Aldrin/Dieldrin Cancellation Hearings, Shell Exhibit
      516, p.  15.

(25)  Petty, H.  B.,  Aldrin/Dieldrin Cancellation Hearings, Transcript.

(26)  Turpin,  T., Aldrin/Dieldrin Suspension Hearings.

(27)  Korp, H.  J.,  EPA  Survey of Entomologists, OPP, EPA, 1973.

(28)  Jenkins,  Robert P., Herman W. Delvo, and Austin S. Fox, Economic
      Impact of Discontinuing Farm Use of Chlordane, Agri. Report No. 231,
      ERS, USDA, Washington,  D.C., August 1972.

(29)  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.

(30)  Delvo, H.  W.,  Economic  Impact of Discontinuing Aldrin Use in Corn
      Production, ERS-557, ERS, USDA, Washington, D.C., June 1974.

(31)  USDA, National  Food Situation.  NFS-152.  ERS, USDA, Washington, D.C.,
      May 1975.

(32)  Hageman,  Fred.  "An Entomological Assessment of the Use of Aldrin to
      Control  Corn  Soil Insects in the Midwest."  Criteria and Evaluation
      Division,  Office  of Pesticide Programs, EPA, Washington, D.C.,
      August 1973.
                                        -64-

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                                Section  IV
            ECONOMIC AND SOCIAL IMPACTS OF CANCELLING CHLORDANE
                 AND HEPTACHLOR ON OTHER AGRICULTURAL USES
     This section contains a survey of other agricultural  uses  of  C/H,
for the purpose of identifying possible significant  impacts.   Focus  is
on citrus and several  other aaricultural  uses on which C/H use and/or
impact data are available.  Limited and conflicting  data place  serious
limitations on assessing impacts.

     For C/H use on turf, in greenhouses, in nurseries,  and for insect
control in homes and other buildings, impacts are not evaluated.   Amounts
of C/H uses and the economic significance for these  various categories  are
not guantified as data is unavailable for this type  of analysis.   However,
recent surveys discussed below indicate that these uses  are important and
in some instances, such as use in  nurseries, economically significant (7).
For impacts needing further evaluation, interested parties should
cooperate with EPA by providing data to assess these impacts.

     From the point of view of crop production and other insect control
problems, C/H poses certain desirable characteristics including lower
costs, lower toxicity to users, and persistence which provides  insect
control over a longer period of time.   As a result,  a switch to alternatives
of C/H will tend to increase cost  of production.   Available information
indicates damaging insects on most crops  can be controlled with alternative
insecticides and the adjustment can be made relatively easily and  inex-
pensively.   For others, important  economic impacts can result.
                                        -65-

-------
                                  Citrus
     The purpose of this section is to summarize economic and social
implications of the cancellation of C/H and aldrin/dieldrin citrus.
Earlier studies conducted by the Department of Agriculture on the
impacts of cancelling 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 approxi-
mately 8,300 acres of first and second year citrus plantings to protect
them from termites (1).  By 1971, the treatment was estimated to have
declined to 4,500 pounds of chlordane applied to 3,000 acres of new
plantings.

     This USDA study assumed that there were no effective nonorganochlorine
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% 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 using insecticides to control termites.

     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 both producers and consumers.

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
                                       -66-

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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.


EPA Analysis of C/H Cancellation on Citrus

     Analysis of unpublished data underlying the USDA survey of pesticide
use during 1971 shows California havinq the highest chlordane use  on
citrus.  This data indicates 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 directed
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 use two to four ground applications  of
diazinon for one application of chlordane to directly control scale
insects.  One or two foliar applications of either parathion, malathion,
carbaryl, 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 Aroentine 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.  However, EPA is currently assessinq these problems and
results will be made available in the near future.  The impact of
cancelling this use would be felt primarily by the arower.  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 schedules.

     The impacts associated with cancellation of organochlorine insecticide
use (including C/H) for citrus production were evaluated by EPA during 1973
in conjunction 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
                                        -67-

-------
expert opinion from Florida during  the  aldrin/dieldrin  hearings was  that
chlordane/heptachlor would be used as an aldrin replacement in the
event that citrus uses of aldrin were eventually cancelled.


     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 of 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 the use of
heptachlor for control of these insects (EPA registration numbers 476-1801
and 476-1129), but heptachlor for this purpose does not appear in the
Florida recommendations.

     Since the problem associated with root feeding beetles is potentially
severe for certain 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 relating to
C/H efficacy is inconclusive.


     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 at 29.5 percent.  In these tests no statement
of statistical  significance 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 a.i.  per acre resulted in emergence
of 3 beetles per trap while chlordane treatment of 5 pounds a.i.  per acre
resulted in a count of 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 significance level as evaluated
by the new Duncan Multiple Range Test (5).
                                    -68-

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     Minimal  testing of these compounds has occurred 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
(Pachynaeus  litus), Sugarcane  Rootstock Borer Weevil (Diaprepes
abbreviata), Tanymechus lachena and  Citrus Leaf Notcher.  Only minimal
control over Diaprepes abbreviata has been afforded by aldrin, dieldrin,
chlordane 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,  successful 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 uneconomical 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 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 from the soil
to  the  foliage 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 providing 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 variability
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.
                                     -69-

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     Even if chlordane is available for beetle control, due to its
lower performance, citrus specialists feel a modification of past spray
schedules may be required.  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. Lucie, Martin, Palm
Beach, Broward, Dade, and portions of Volusia is characterized by groves
planted on artificially constructed beds, surrounded by draining ditches,
which were once partial swampland.  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,
nonchemical 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 base to define infested acres (and assuming that
treatment is made every three to fiy_e years), 25% of Florida's East Coast
county citrus acreage could be subject to root damage.  As a percentage
of total Florida citrus, this coastal county acreage would affect approx-
imately 6 percent of current citrus production (1972 base).
                                         -70-

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     Because of an inelastic demand for citrus  at the farm level,  the
market impact of a decrease in production would be an increase  in  farn
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.  Further,  if no alternative control  agent is
discovered, the consequences could be severe for Florida's East Coast
growers.  Due to currently low income levels and a lack of alternative
employment, 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.
                                        -71-

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                            Other Crop Uses  of C/H

Introduction

     This section contains a survey of information  on  the  extent  of  other
C/H crop uses and possible impacts of cancellation.  Surveys  conducted  by
USDA provide an indication of the number of  crops receiving treatment
and the extent of treatment in terms of pounds and  acres per  year.   This
data is presented in Exhibits D (p. 194) and  F (p. 196)  of  Part  II of this
report.  More recently, surveys have been conducted  jointly by  EPA and  USDA.
EPA conducted an informal  telephone survey (1975 EPA survey)  to several
states requesting information on minor uses  of C/H  (6).  In another  survey,
EPA requested USDA to distribute a questionaire to  all  states and possessions
to inquire about recommendations of C/H for  the 1975 growing  season  and to
obtain estimates of total  pounds of C/H used in their  respective  states and
possessions (1975 USDA/EPA survey) (7).  Table 20 summarizes  the  findings
from this questionnaire (1975 USDA/EPA Survey). In  addition, economic
impact analyses for a variety of crops associated with  cancelling C/H were
conducted by USDA in 1972  and 1973 (1) (2).   Using  available  information,
economic impacts are briefly discussed for strawberries, potatoes, hay,
tobacco, peanuts, apples,  and vegetables as  a group.
                                      -72-

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Table 20 -- Results of USDA/EPA cooperative survey of states on  1974  use and  1975
            recommendations of C/H
State or
Territory

Alabama
Alaska
Arizona
Arkansas
California •
Colorado
Connecticut
Delaware
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Plan to recommend in
1975 for uses other
than termites and dip-
ping of nursery stock
Chlordane Heptachlor
X X
X
X X
X X
X
X X
X
X
X X
X
X
X X
X
X X
X X
Total poundage used
from
Chlordane
1,000,000
50
150,000
(down from 1973)
no estimate
estimate not given
40
(down from 1973}
no estimate
no estimate
1,124,193
(1973 estimate -
sold)
no estimate
no estimate
126,000
(1973)
313,000
(up for 1973)
715,708
(down for 1973)
300,000
(plus termite and
small package use)
75,100
(up from 1973)
in 1974 (and change
1973)
Heptachlor
250,000

4,000
no estimates
estimate not given
120
(down from 1973)
no estimate
no estimate
260,367
(1973 estimate -
sold)
no estimate
no estimate
no estimate
no estimate
. 270,645
(down for 1973)
300,000
(plus termite and
small package use)
500,000
                                                   -73-

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Table 20 -- Results  of USDA/EPA cooperative survey of states on 1974 use and 1975
            recommendations of C/H  (Cont'd)
State or
Territory

Kansas
Kentucky
Louisana
Maine
Plan to recommend in
1975 for uses other
than termites and dip-
ping of nursery stock
Chlordane Heptachlor
X X
X
X
X
Total poundage used in 1974 (and change
from 1973)
Chlordane
estate not given
1,000
(down from 1973)
no estimate
slightly more than
Heptachlor
estimate not given
no estimate
no estimate
low - no estimate
Maryland



Michigan


Minnesota
                        (ant only)
      2,700
    (up  from  1973)

    770,000
  (70%'for termites)
    (down from  1973)

      no estimate
    160,000
     (1973 use)
 (does  not include
   PCO,  homeowner,  or
        turf)
  61,000
(down from 1973)
     231.3
    (1973 use)

  20,000
Mississippi
Missouri
Nebraska
Nevada
New Hampshire
New Mexico
New York
X
X
X
X
X
X
X
X
X
X
X

X

448,520
(up from 1973)
no estimate
100,000
8,758 gal
(1973)
no estimate
5,000

258,960
(up from 1973)
no estimate
25,000
1,601 gal
(1973)
none
500

restricted use - ant   used by N.Y State
use requested from     Dept.  Agr.  to
N.Y. Dept. of Environ- control alfalfa
mental Conservation    snout beetle. Amount
                       use requested
                                               -74-

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Table 20 — Results of USDA/EPA cooperative survey of states on 1974 use and 1975
            recommendations of C/H  (Cont'd.)
State or
Territory
Plan to recommend in
1975 for uses other
than termites and dip-
ping of nursery stock
Chlordane Heptachlor
N. Carolina
N. Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
S. Carolina
S. Dakota
Tennessee
Utah
Vermont
X
X
X
X
X

X
X
X
X
X
X

X
X
X


X

X
X

use by permit
only - no per-
mits issued in
1973 or 1974
Total poundage used
from
Chlordane
1,750,000
(up from 1973)
(1,000,000 Ib of this
total used on termites)
79,600
(up from 1973)
no est-'nate
no estimate
no estimate
no estimate
no estimate
no estimate
no estimate
no estimate
5,000
1,600
licensed applicators
only - does not in-
clude formulation und-
in 1974 (and change
1973)
Heptacnior
/b.ooO
(down from 1973)
1,900
(down from 1973)
no estimate
no estimate
no estimate
no estimate
no estimate
no estimate
no estimate
no estimate
1,000
0
 Virginia
                                                  er 10% sold by outlets
                                                  with no records of sale
                                                  (up from 1973)

                                                     no estimate
  48
(1973 use)
                                                  -75-

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 Table 20 --  Results of USDA/EPA cooperative survey of. states  on 1974 use and 1975
            recommendations of C/H  (Concluded)
State or
Territory

Washington
W. Virginia
Wisconsin
Wyoming
Plan to recommend in
1975 for uses other
than termites and dip- Total poundage used in 1974 (and change
ping of nursery stock from 1973)
Chlordane Heptachlor Chlordane
X X 340,700
(Ib sold - up more
than tenfold from
1973 Ib sold).
X no estimate
XX no estimate
X no estimate
Heptachlor
no estimate
no estimate
no estimate
no estimate
Source:  USDA/EPA  survey (1974).   See reference  7.
                                          -76-

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Strawberries

     Results of two surveys, 1975 EPA Survey and 1975 USDA/EPA Survey,
indicate possible adverse impacts on strawberry producers (6,7).   Nineteen
states recommend chlordane for soil  insect control  on strawberries;  one
recommends heptachlor.  The strawberry plant is attacked by the root
weevil and related weevils, and a variety of other  soil  pests, including
wireworms, cutworms, and white grubs,.

     In the absence of chlordane, strawberry danage could be significant
in some areas.  For example, in Missouri where wireworms, white grubs,
and carrot beetles are abundant soil pests, losing  chlordane might result
in losing viable plants 1 to 2 years before they would normally be
discarded and in 5 to 10% more damaged berries in each crop.  Such widely
dispersed states as Oregon, Kentucky, Vermont and Ohio are concerned about
unavailability of chlordane and the related cost, effectiveness, and lack
of substitutes.

     Several states believe that adequate but unregistered substitutes
exist.  For example, in the state of Washington, C/H has not been con-
sistently effective, but Furadan, an effective substitute, is not reg-
istered.  In New York, where the strawberry root weevil  and the straw-
berry rootworm are pests, chlordane is the preferred treatment.  Dianinon
at 4 to 8 Ib/acre and carbaryl at 8 Ib/acre are almost as effective but
are not registered at these dosages.

     New York officials were not aware of an adequate substitute pesticide
to control root weevils, although malathion and parathion are currently
registered for adult root weevil control.  Also reaistered are:  carbaryl,
methoxychlor, ethion, rotenone and endosulfan.  It has been estimated that
approximately 50$ of the New York strawberry crop is susceptible to the
root weevil  or other insect infestations (8).  A 3.3% strawberry loss
related to wireworms resulted from substitution of diazinon for
chlordane(8); 33 to 50% yield reduction could be attributed to white
grubs if chlordane is cancelled and no substitutes  are used (9).  Brann
also estimated a substantial strawberry loss in susceptible areas if
effective alternatives for chlordane-are not used (10).

     Despite extensive damage to the New York crop, strawberry losses at
the national level should be very small.  In 1^71 IISDA estimated that
1,000 strawberry acres were treated with chlordane.  After cancellation,
the national yield would decline by an estimated 3.3% with an associated
$75,000 impact.

     Since California production has been expanding in recent years,
national strawberry supply impacts from long term Pacific Northwest
production changes should be minimal.  There may be short term adjustment
problems as local growers switch to other crops or attempt to grow fewer
protected strawberries.
                                         -77-

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     Most of the other states exnectinn impacts have 200 -  500  acres
each of strawberries grown for fresh market consumption.  The USDA study
may be an understatement of impacted acreage,  but it is  difficult to
assess the net monetary impact of the suspension.  The short term impact
may be considerably higher than $75,000 cited  by the USDA study.
Potatoes

     The 1975 EPA Survey indicates many states use chlordane on
potatoes (6).  Wireworms are the primary insects controlled by chlordane,
but it is also used on white grubs, cutworms,  and tuber flea beetles.
Diazinon and parathion are the most freouently recommended alternatives,
while Dyfonate and Phorate appear on several  recommendations.  The
University of Idaho in 1971  reported that chlordane gives ten  years
effective control.  Dyfonate and phorate were  reported as providing
good or better control, than chlordane, of sugar beet wireworms  in
potatoes but at a higher cost to the grower.   It was indicated that
Dyfonate and phorate were more acutely toxic  to the user than  chlordane.
Extension entomologists in Colorado believe the impact of cancelling
chlordane would be minimal on tuber flea beetle control in that  state.
Kentucky and Maine indicated that wireworms were only a problem  in
potatoes following a sod crop.  Other states  list user hazard, increased
cost, more frequent applications, and decreased efficacy from the use
of alternatives.

     The USDA study on notatoes indicated that the impacts are expected
to be small as other pesticides can effectively control insects  in most
instances (1).


Hay and Alfalfa

     Hay, one of the major animal feeds produced in the U.S.,  is grown
on more than 30 million acres of land.  The lack of major insect pests
precludes the need for insecticides on most hay crops.  Tables 3 and 5
above show that 3,000 acres of hay were treated with chlordane and
2,000 acres were treated with heptachlor.  An estimated 3,000 pounds
of heptachlor were used on alfalfa.  The results of the two most recent
surveys do not provide any indication of adverse imnacts from
cancellation (6,7).


Tobacco

     Tobacco production is one of the largest uses of insecticides on  a
per acre basis.  However, most tobacco is not qrown on a continuous basis
on any aiven location and is usually a small  proportion of a farmer's
                                          -78-

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total croo area.  As a result,  insecticides  which may leave residues  in
neighborina crops throuah drift or on suhseouent crops,  via persistence
in the soil, are generally not  recommended (11).  In  general,  the less
persistent oraanophosphate and  carbanate insecticides are used more
frequently than organochlorines (12).  In 1971, the major foliar tobacco
insecticides were endosulfan, toxaphene, IDE (ODD),  disulfotan,
parathion, malathion, azinphosmethyl  (quthion), and methomyl.
Carbaryl and diazinon were used in large quantities as soil insecticides.

     Three thousand acres of tobacco were treated with heptachlor(2)  and
17,000 with chlordane in 1971.   Tobacco producers would  have incurred an
additional cost of $21,300 for  alternative insecticides, $8,700  for
3,000 acres of field treatment  and $12,600 for seedbed treatment due  to
cancellation of heptachlor.  Unavailability of chlordane would increase
producer's costs for alternative pesticides  by about  $14,000 (1).  Yields
of tobacco are unaffected by cancellation, if alternatives are used.


Peanuts
     Although chlordane is not recommended  for peanuts  because of residue
problems (10, 11), a minute quantity (100 Ib)  was  used  in  1971 (13).  Cancella-
tion for this use should have no impact.


Apples

     A recent(14) survey was conducted to determine impacts of cancellation
of C/H along with aldrin and dieldrin.  The leading anple  producing  states
in the nation, Washington, New York, Michigan, California, Pennsylvania
and North Carolina, do not recommend chlordane or  heptachlor for apple
production.  These six states produced 70% of the  U.S.  apple crop  in 1974.
Of these four pesticides, dieldrin has been the most important pesticide
in apple production in the past, and it is  not known to what extent  C/H
will be a substitute for dieldrin since its suspension. Many registered
pesticides excluding C/H are available and effective; however, costs will
increase as material costs of these alternatives rise.   In Table 3,  Part
II, it is reported that 373,000 pounds of chlordane were applied on
10,000 acres of apples in 1971.  The authors of this study investigated
these estimates and were unable to substantiate these figures (14).   In
fact,' they were unable to establish any significant use of chlordane on
apples.

     This study concludes that apple production does not depend  in any
important manner on C/H and cancellation in this use should have
negligible effects (14).
                                         -79-

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Vegetables

     Chlordane and heptachlor are effective soil  treatments  for  wireworm
and white grubs when pasture is converted to vegetable production.   The
USDA chlordane impact study(l) projected a 3% yield decline  for  a large
group of miscellaneous vegetables.  Approximately 5,OOD acres  are
affected at a loss of $115,nno.
Soybeans

     Only 400 pounds of chlordane were estimated to be used on  8,000
acres of soybeans in the Appalachian region in 1971 (13).   Many
entomologists do not recommend chlordane use in soybeans because of
residues.  Since the treatments represent a minute percentage of both
soybean acres and total insecticide use (0.86% of acreacie and 0.043%
of poundage in the region), economic impact is negligible.
                                         -80-

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                       References  for Section IV
 (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  Pesticides in 1971. Agricultural Economic
      Report No.  252,  ERS, USDA, Washington, D.C., July 1974.

 (4)   King,  John, Entomologist, University of  Florida.

 (5)   Bullock, Robert, Entomologist,  consultant to Indian River Field
      Laboratory, Ft.  Pierce,  Fla.

 (6)   EPA Survey, Informal survey conducted by Criteria and  Evaluation
      Division, 1975.

 (7)   USDA/EPA Survey, "Uses of Pesticides Containing Chlordane and
      Heptachlor,"  CSRS, USDA,  December  1974.

 (8)   "Losses  in  Agriculture,"  ARS, USDA, Washington, D.C.,  1965.

 (9)   Tompkins, John,  Horticulturalist,  Cornell University,  Ithaca,
      New York.

(10)   Brann, James  L.,  Fruit Entomologist, Cornell University, Ithaca,
      New York.

(11)   Smith, J. C., Peanut and  Tobacco Entomologist, Tidewater Experiment
      Station,  Tidewater, Virginia

(12)   Matthews, D.  L.,  Vegetable Entomologist, Department of Entomology,
      Purdue University,  Lafayette, Indiana.

(13)   EPA, "Economic  Impact  of  Restricting Usage of Chlordane and
      Heptachlor,"  Criteria  and Evaluation Division, October 1974.

(14)   Midwest  Research Institute.  Substitutes for Aldrin, Dieldrin,
      Chlordane and Heptachlor  for Insect Control on Corn and Apples.
      Contract No.  68-01-2448,  Mod. 6. Kansas  City, Missouri 1975.
                                         -81-

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                                 Section V

                     OTHER AREAS OF IMPACT  AND CONCERN
     This concluding part of the report covers  a  range  of  remaining
issues related to the proposed cancellation.  An  important consideration
at this time is demand on energy resources.   Presented  here is  an
evaluation of energy impacts due to differences in  energy  requirements
between C/H and selected alternatives.   Consumer  price  impacts  are
considered.  An estimate is made of the percent increase in food prices
and an evaluation is made of changes in demand  for  farm labor that may
result from the cancellation.  The most significant changes in  crops
grown and land use occur in the North Central regions;  the decline in
demand for labor appears to be relatively more  imoortant in this area.
Energy, inflation and employment are the major  macro-economic issues.
Also discussed are the impact to the producer of  C/H,  the  Nation's
productive capacity for registered substitutes  for  certain pest-crop
combinations, use of scouting for crop pests, and safety in the use of
pesticides.  The concluding statement concerns  termite  control, a
use not covered by the cancellation order.
                     Relative Energy Intensity of C/H
                      and Representative Substitutes


     Energy consumed to produce 1 million  pounds  of  C/H and three
representative substitutes was estimated.   To provide net energy
requirements, C/H are compared with these  substitutes at  assumed rates
of application for equivalent pest  control.

     Carbofuran is a major substitute and  is representative of the
carbamate class of pesticides.  Diazinon,  representing the organophos-
phates, is an important substitute  and is  analyzed because of its  chemical
complexity.  Carbaryl, a widely used carbamate, is included  in the
analysis.

     Tables 21 and 22 show the amounts of  electricity, coal and
petroleum used to produce one million pounds of each pesticide.  The three
bottom rows of each table show the  amount  of energy consumed  per category
at equivalent rates of application, for all three substitutes considered
as a group (row 9), and the net effect compared with chlordane and
heptachlor (row 10).  Chlordane tends to be more energy intensive than
the substitutes chosen for comparison while heptachlor consumes less
energy.
                                         -82-

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           T?ble 21--Comparative  energy  impact per  million  pounds chlordane replaced!/
Insecticide Ib/lb Million Coal for Petroleum for Total Total coal,
of chlor. Mh of process feed + inerts, petroleum, for for process
replaced elec.tem- heat, T barrels (bbl) feed + inerts heat + elec.
perature(T) + elec., bbl T
Assuming pound-for-pound replacement:
1.
2.
3.
4.
Chlordane 1
Diazinon 1
Cattofuran 1
Carbaryl 1
Replacement at assumed
5.
6.
7.
8.
9.
10.
11.
Chlordane 1
Diazinon 0.65
Carbofuran 0.25
Carbaryl 0.5
Total y
substitutes
Net
Impact per
million pounds
of chlordane 3/
Net Impact
for 1974 4/
4.21
5.2
6.26
3.3
application
4.21
3.38
1.57
1.65
2.42
-1.79
-28.64
160
480
640
320
rates:
160
312
160
160
232
+72
+1,152
1,090
3,600
(feed alone,
850
-0-
1,090
2,340
(feed alone,
213
0-
1,190
+100
+1 ,600
9,330
13,760
2,040)(ex inerts,
13,130
6,460
9,330
8,960
l,325)(ex inerts,
3,285
3,230
5,925
-3.405
-54,480
2,030
2,790
12,200)
3,420
1,780
2,030
1,812
7,945)
855
8SO
1,307
-723
-11,568
\J  Source:  Chemistry Branch: C&E Division, OPP, EPA

2/  Calculated assuming substitutes will replace chlordane in the ratio diazinon:
    carbofuran: carbaryl « 7:7:1, expressed in units of (chlordane-equivalents + 15).
    T-ls ratio is a composite of projections done for EPA, taking diazinon as a
    representative of all organophosphate substitutes.

3/  Total substitutes less chlordane.

£/  Using an assumed domestic consun.pUon rate of 16,000,000 pounds of chlordane
    for 1974.
                                                         -83-

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          Table  22--Comparative  energy Impact per million pounds heptachlor replaced!/
Insecticide Itylb Million Coal for Petroleum for
of hept. kWh of process feed + inerts,
replaced elec. heat, T bbl
Total Total coal,
petroleum, for for process
feed + inerts heat * elec.
+ elec., bbl T
Assuming pound-for-pound replacement:
1.
2.
3.
4.
Heptachlor
Oiazinon
Carbofuran
Carbaryl
1
1
1
1
Replacement at assumed
5..
6.
7.
8.
9.
Heptachlor
Qidzinon 1.
Carbofuran 0.
Carbaryl 1.
All substitutes
1
3
5
0
y
3.9
5.2
6.26
3.3
application rates:
3.9
6.74
3.14
3.3
4.83
225
480
640
320
225
624
320
320
464
1,200
3,600
(feed alone, 2,040)
850
-0-
1,200
4,680
(feed alone, 2,650)
425
-0-
2,380
8,350
13,760
(ex inerts
13,130
6,460
8,850
17,920
(ex inerts,
6,570
6,460
11,850
1,955
2,790
, 12,200)
3,420
1,780
1,955
3,624
15,890)
1,710
1,780
2,615
10.   Net impr.-t per
     million pounds
     of heptachlor 3/           +.93       +239         +1,180          +3,000          +660

J1    flcv T.-,p~-{
     for 1974 4/              +3.72       +956         +4,720          +12,000         tZ,640
 1.   Source:   Chemistry Branch, C&E Division, OPP, EPA

 2.   Calculated assuning  substitutes will replace he^achlor in the ratio diazinon:
     carbofuran:carbaryl  =  7:7:1, expressed in units of ((lb. of insecticide equivalent
     in insecticidal  action to 1  lb. heptachlor) - 15).  The 7:7:1 ratio is a composite
     of projections  done  for EPA, taking diazinon as representative of all organophosphate
     substitutes for heptachlor.

 3.   Index for total  substitutes  less that for heptachlor.

 4.   Using an assumed domestic consumption rate of 4,000,000 pounds for 1974.
                                                             -84-

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     Total domestic consumption of chlordane exceeded that of heptachlor
in 1974 by an estimated four times.   The bottom row in each table  shows
net energy usage assuming 16 million pounds of chlordane and 4 million
pounds of heptachlor.   These energy impacts which are annual  estimates
are exceedingly small  as the U.S.  consumes approximately 13 million
barrels of crude oil each day.

     Appendix D provides a list of assumptions used to derive energy
estimates.  Other energy implications of the cancellation have not been
evaluated, such as impacts on energy use due to changes in crop acreage.
                                       -85-

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                    Inflationary Impact of Cancellation


     The linear programming model  provided quantitative  estimates  of
changes in the value of feed and food crops associated with C/H
cancellation.  The total change in the cost of meeting final  demand
for food at the farm level  was $364.8 million.

     To estimate consumer level impacts, all  food considered as a  group
was analyzed as a parallel  upward shift in the supply cost of these
grains in the face of an inelastic demand at the retail  level.   This
type of change implies that all of the increase in price is passed on
to the consumer.  It also implies that all adjustments in expenditures
for food take place in the prices of commodities, since  the quantity of
food available remains the same on a per capita basis.  The $364.8 million
impact can be used to estimate the change in food price  at retail  by
determining the cost as a percent of expected expenditures for food  in
1977.  The increase in the price level of all food to consumers was
estimated to be 0.191%.  For those meat products depending heavily on
grain, price increases would be somewhat higher and range from 0.4%
to 0.5%.

     Impacts of cancelling other C/H uses are not expected, individually,
to have a significant impact on the consumer price level.  Generally
these other uses involve products or services which are  small potions of
consumer expenditures.  There could be notable consumer  cost impacts in
isolated instances where alternatives are not highly efficacious or
are much more expensive.  This, however, would not be the general  rule,
based on available information.
                                         -86-

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              Labor Displacement in the North Central  Region


     The assessment of the proposed cancellation,  accomplished through
the use of EPA's linear programming model, indicates  that the greatest
shifts in production and pesticide use will  revolve around an anticipated
reduction in corn production in the seven states  of the North Central
region.  Therefore, this region has been selected  for closer  analysis of
potential post regulatory agricultural adjustment  problems.

     The linear programming equilibrium solution  for  a proposed C/H
cancellation for food crop uses suggests several  problems for the  North
Central consuming region, consisting of Ohio, Michigan, Indiana, Illinois,
Missouri, Iowa, and Wisconsin.   The model indicates most other regions in
the nation will realize gains in the agricultural  sector, both in  terms of
land devoted to production and in net income, largely as a result  of land
in the North Central going out of corn production  and land in other
regions coming into corn production.  Specifically, a net of  1,490,000
acres will shift from corn to other uses, yielding some lower economic
returns in the North Central region.  Another reallocation effect  will be
the placement of between 290,000 - 354,000 acres  in an idle use status.
It is likely, of course, that before too much times passes some portion
of the idle land would be put to other uses.   Some of the uses may be
agricultural, e.g., pasture land; however, land located in urban fringe
areas could be converted to nonagricultural  uses.

     Production reallocation has two important effects.  First, reduced
corn production will force livestock owners  to import more corn from other
regions and at the same time substitute other indigenous grains for  feed.
This could make meat and milk more expensive.  It  definitely  means that
more energy resources will be required to transport feed into the  areas
to the extent that present feeding practices  continue.  The other
important effect is reduced farm labor.

     Of the seven commodities considered by  the LP (linear programming)
model, six are produced on a significant scale; cotton being  a minor
crop in the region.  Among these commodities  corn  is  the most labor
intensive.  Since corn production will be reduced, agricultural  labor
will also be reduced.  In addition, the 290,000 -  354,000 acres of idle
cropland will result in a further decreased  labor  denand.  This acreage
represents only about .5% of land presently  growing the seven
commodities of the LP model.  Nevertheless,  this  drop does entail  a
measurable reduction in labor.

     In Table 23 low and high estimates of reduced labor through shifts
to less labor intensive land uses (includinn  idle  land) are computed
                                       -87-

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                                ID
Table 23.  Labor displacement estimates fr.r the north central
         region due to C/H cancellation, 1977

  (2)       (3)            (4)          (5)
(6)
(7)
; *
|
1 Barley Dryland
2 Corn Dryland
• 3 Cotton Dryland
4 Soybean Dryland
S Oats Dryland
6 Sorghum DryU ,'
7 Wheat CryUnd
S Corn Dryland
(no pesticides)
9. Corn Dryland
(other pesticides)
10. Corn Cr/lani
C/H pesticides
: (lack aldn
11. lane! Use Totals
12. Equtv'ent no. of
can-days based on
10-hour work day
13. Equivalent of workers
u'.IMzed based on 25-
day seasonal level of
effort
14. Dislocation of hired
workers (assuming hired
labor comprises 75 par-
cent of the work force)

•
1 Barley Dryland
2 Corn Dryland
3 Cotton Dryland
4 Soybean Dryland
S Oats Dryland
6 Sorghum Dryland
. 7 Khcat Dryland
8 Ctrn Dryland
(no- pesticides)
9. Corn Dryland
(other pesticides)
10. Corn Dryland
t/H pesticides
Slack land
11. Land Hit Totals
12. Equivalent no. of
tun-days based on
10-hour work day
Before After
Cancel- Cancel-
lation lation
Acrei Shifts
Kan-hcurj Kan-hours
Required: Required:
High Low
/ Estimates Estimates
350,«00 »'..n.OOO 2.80" ' 2.06**
760,000 * 80,000 3.90 4.82
0 0 10.50
36.CSO.OCO »1,0',0,000 4.85 3.44
720,000 -10.000 2.80 2.06
820,000 +90,000 4.74 3.86
3.490,000 -70,000 3.24 • 2.57
15,340,000 +4.260,000 5.90 4.82
6.830,000 +4.260.000 °5.90 4.82
7.030.000 -7.030.000 5.90 4.82
2.320.000
74.140.000 -290,000 - •
lUle ictti) . — - — — —



W
Hourly Wages:'
Low EstlMtt
$1.31"
1.31
1.31
' 1.31
1.38
1.31
1.31
1.31
1.31



(9)
Total Labor
Costs
High Estimate
S 734,720
774, OBO
8,272,160
45,920
674.028
371 ,952
41 ,219760
11.611.200
.68.022,280
5,154 .204

Total labor
Hours Required:
High Estimate
448.000
472,000
S, 044 ,000
-28,000
426,600
-226,600
25.134,000
7,080.000
41,477,000
-3,127,200
-312,720
12,508
9.382
(10)
Total labor
Costs
Low Estimate
$ 430,990
5<0,350
4.686.656
26.200
479.412
235.669
26,898.492
7.577,040
44,388,826
4,037.755

Total Labor
Hours R-nuired: Hourly Ka$os:w
Low Estate High fstlirate
3J9.600 $1.64—
365,600 1.64
1.38
3,577,600 1.64
-20,600 1.64
347,400 1.58
-179,900 1.64
20.533.200 1.64
5.784.000 1.64
33.884.000 1.64
-3.127.700
-312,770
12.511
9.383
(11) (12)
Kean rear,
Ir.co.-* Loss: Incore Loss:
High Estimate Low Estimate


13. Equivalent of workers
utilized based on 25-
day seasonal level of
effort
14. Dislocation of Mred
workers (assuming hired
labor comprises 75 per-
Ctnt of the work force)
*


«»

3.028,16

$412 $323

 *Labor costs are based on 1970 dollars
"Figures were not available for barley;  wage rates for oats were substituted.


  Source-   Worden, 6. eT.  al.,  Selected U.S. Crop Budgets, Yields,  Inputs,  and
           Variable Costs - North Central Region.  U.S. Department of  Agricul-
           tural, Economic Research Bulletin No. 458, Vol. II. Washington,  B.C.
           197V.

           EPA linear programming analysis, 1975.
                                                                      -88-

-------
using USDA budget estimates of man-hour requirements for the various
commodities.  This data is not in a form that easily lends itself to
the task of associating soil type as well  as land use categories to
man-hour requirements.  Therefore, budget data was searched for high
and low figures for each commodity produced among all of the states in
the region.  The application of this data provides estimates of total
reduction ifi man-hours (columns 5 and 6).   It is derived by multiplying
post-cancellation shifts in land use figures (column 2) by per acre labor
requirements (columns 3 and 4).  In row 12, the equivalent of man-days
has been computed by dividing total man-hours by an assumed 10-hour
work day.  Next, in row 13, an equivalent of agricultural  workers is
computed by dividing man-day equivalents by an assumed average number
of work days (25) required during the growing season for the commodities
in question.  Finally, in row 14, the figures are adjusted for owner and
managerial classes of labor (25% of the labor force).  The adjusted
figures represent the hired pool and, thus, the hired farm workers
estimated to be subject to income losses.

     High and low budget figures for hourly wages are then identified
in the same manner that man-hour figures were selected (columns 7-8).
In columns 9 and 10, these figures are adjusted to focus on that portion
of the work force that consists of hired workers.  In the  final column
of the table, average losses per worker are computed by dividing
estimates of the number of workers into the total income loss estimated
for this group.  The overall results for the region indicated by this
analysis are that approximately 9400 workers are subject to
average income losses ranging between $323 and $412 annually.*  If these
Tosses are distributed evenly over all income classes of workers and
uniformly distributed geographically, it would be a matter of little
concern.  This is especially true where the production adjustments which
create income losses occur gradually, as expected here.

     Unfortunately, the anticipated losses may be concentrated in
relatively small areas of the states.  This could be a serious problem
if unemployment remains at high levels through 1977; the North Central
region has been hard hit by industrial unemployment.  The  chances for
hired workers to supplement farm income are uncertain.

     It should be emphasized that the available data did not permit
full consideration of the distributive effects of farm labor income
losses, e.g., groups and sub-regions most affected.  However, one can
surmise that:  (a) where crop shifts are necessitated by increasing
production costs, the older farmers and those with small capital
resources will  have the greatest difficulty in readjusting their land
to profitable uses, and (b) a portion of the families of some farmers
and the families of a still larger number of farm workers  may find
themselves temporarily adjusting to lower incomes.
*These estimates may actually prove to be conservative  since agricultural
budget census data has a tendency to under-represent seasonal  labor.
                                        -89-

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        Impact of Proposed C/H Cancellation Order on the Producing Firm
     Velsicol Chemical  Corporation, the sole producer of C/H,  is a
subsidiary of Northwest Industries, Inc.   The Chemical  Group of Borth-
west Industries, Inc. which includes Velsicol Chemical  Corporation and
Michigan Chemical Corporation had net sales of $167 million in 1974 (1).
The proposed cancellation of C/H for agricultural  and home and garden
uses is cited in 1974 Annual Report of this firm along with an estimated
sales for these uses of approximately $14 million, or 8.4% of net
sales for 1974.

     The proposed EPA cancellation would  affect 31% of chlordane
production and 66% of heptachlor production, based upon 1974 use
breakdowns.  Using prices for technical material at the plant in the
March 31, 1975 issue of "Chemical Marketing Reporter" -- $.69/15 for
chlordane and $1.25/lb for heptachlor --  these quantities are valued
at $6,7000,000 or roughly one-half the sales figure loss stated by the
company.  EPA is unable to explain the differences in the loss estimates
at this time; however, requests have been made to Velsicol to provide
additional information needed to make more accurate determination of
dollar loss.  The real  loss to Velsicol is the discounted value of net
returns from prohected sales of cancelled uses several  years into the
future.  Other data have been requested from Velsicol to more
adequately evaluate impacts on employment, local communities where
plants are located, and formulators.

     The cancellation opens a market to new pesticides to the extent
that replacements are needed.  Environmentally acceptable substitute
pesticides are likely to enhoy a premium price in the market.
                                           -90-

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             Supply of Substitutes for Chlordane and Heptachlor


     The 1971 production estimates for various insectiicdes, including
many substitutes for C/H, can be found in Table 24.  The data is not
indicative of present full  capacity production, since the information
does not reflect changes in physical plant capacity or the effects of
feedstock shortages.

     More recent estimates  on the availability of registered substitutes
were found in reviews of the Substitute Chemical Programs and in a
contract report by Theodore Riedeburg Associates (2) (Table 25).  However,
the more current information represents a very small proportion of the
registered substitutes for  C/H.

     From the provided data, limits on supply expansion were found in 1973
and 1974 because of feedstock shortages.  The feedstock shortage was also
accentuated by the escalated demand for pesticides to treat increased
acreage (3).  In a few situations, the feedstock shortage was a deterrent
to managerial decisions to  invest in additional production facilities.

     The supply of C/H substitutes will become less restricted as inter-
mediates become more available.  Also, if the demand for organophosphates
expands, pesticide manufacturers will have an economic incentive to
manufacture feedstocks or possibly alter nonsubstitute organophosphate
production lines to produce C/H substitutes.   These changes would not be
instantaneous since lead time is necessary to alter raw material orders,
production schedules, and product distribution systems (4).

     In addition, there are opportunities to  expand the domestic supply
in the short run by reducing exports or increasing imports.

     If C/H are cancelled in 1976 or 1977, and if inventories of C/H
can be used, it is likely that the insecticide industry will have enough
capacity to produce an adequate supply of subsittutes.  Within one or
two years, it is possible to increase plant capacities to produce
substitutes or to develop additional supplies of feed stocks to
adequately expand the supply of final products.

     A potential problem, however, is the absence of registered alter-
natives for specific uses.   This question has been explored earlier for
agricultural uses; but gaps in domestic, commerical and public health
uses were not explored.  Sixty-eight percent of the marketed chlordane
and 50% of the heptachlor is used for these purposes (EPA
Estimate, 1974).
                                         -91-

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                    'K'.ble  25 •-  Supply  characteristics of registered substitutes for chlordane and heptachlor
Type of
Insecticide

(1)
Methyl parathion
Estimated
Production

51 million
(1972)
Est. Domestic
Full capacity
Production

perhaps as
high as
• 100 million
Estimated
Imports

1.1 million
(19721
Fstimated
Exports

12.5 million
(1972)
Comment:

Some of the methyl . arathion
production capacity can he
used to manufacture other
Azodrin
         (2)
Dursban
         (3)
         (4)
Diazinon
         (5)
Dimethoate
Guthion
         (6)
Aldicarb
         (7)
Malathion
         (8)
Demeton
         (9)
9-11 million
 (1973)
5-7 million
 (1973-1974)
                                     14  .-.llion
                                     NA
  not
substantial
                     4.5-6.0 million
                      (1973)
  not
substantial
                     6-7 million     6-7  million
                      (1974)          (1974)
                     2 million       NA
                      (1972)
                     4 million
                                     NA
                                      negligible
                                        not
                                      substantial
                                                           negligible
Phorate
(Thimet)
         (10)
1.0-1.5 million NA
  (1972)


24 million      NA
 (1972)
8 million       2R million
 (1971)          (1969)
153,800
 (1972)
                                      173,000
                                       (1971)
                     1.0-1.5 million
                      (1974)
                       not
                     substantial
                                                                               NA
                     400,000-700,000
                       (1972)
8 million
 (1972)
                                                                               NA
Furadan
         (11)
Dyfonate
         (ID
                                                                                                 organophosphates.
                  Production capacity may
                  expand 25 to 30 percent if
                  the feedstock shortage
                  problem is solved.   Additional
                  supply possibilities from
                  foreign producers conceivable.
Production is well below full
capacity because of the
shortage of the feedstock
DEPCT. Construction of a
DCPCT plant is underway. A
dursban production plant is
planned for completion in 1976
in Europe to help meet U.S.
demand.
                  Production capacity may expand
                  if the feedstock shortage
                  problem is solved.   Two foreign
                  producers are known to exist.


                  Existing plant capacity can be
                  used to manufacture other
                  organophosphates.
                                                                            Production capacity limited.
                                                                            Only by ths availability of
                                                                            feedstocks.  One foreign
                                                                            producer  is known to exist.
                                       Existing plant  capacity can  be
                                       used to mamifactutc  other
                                       organophosphates.  Feedstock
                                       shortages will  probably con-
                                       strain supply in  1975.
                                                                            Tight  supply expected 1n 1975
                                                                            with easing expected in 1976
                                                                            Adequate supplied available In
                                                                            1975 and 1t may be possible to
                                                                            fill some of  the shortages in
                                                                            phorate and furadan.
                                                             -92-

-------
                                          Table ?5. (Continued)
                                                                     Tight supplies expected, but
                                                                     capacity should increase by
                                                                     50 percent at 'he end of
                                                                     1976. Supply constraints may
                                                                     exist because of feedstock
                                                                     shortages.

           01)
     Counter                                                            High volume of production for  '
                                                                     this new registration cannot
                                                                     be expected until 1976-1977.
                                                                     Perhaps » million pounds c»«
                                                            .  '       be produced 1n 1975 and possibly
                                                                     • multi-million pound plant will
                                                                     be available 1n 1978.



     Sources:

     (1)  EPA.OPP, Initial Scientific and Uneconomic Review of:  Methyl Parathton. October 1974.

     (2)  drthur u. Little, Inc., Ajodrln: Initial Scientific and Hint-Economic Review, draft, Cambridge,
      '  Massachusetts, October 1974.*

     (3)  Arthur D. little, Inc., Dursban: Iningl Scientific and Hinl-Econonlc Reviews, draft, Cambridge,
        Massachusetts, December T57T!                        :	

     (4)  Arthur D. Little, Inc., Initial Scientific and Mini-Economic Review of Dlazinon. draft Cambridge,
        Massachusetts, February T975.             ™

     (S)  Arthur D. Little, Inc., Initial Scientific and Mini-Economic Review of Dimethoate. draft Cambridge,
        Massachusetts, January 1975."~"

     (6)  Arthur D. Little, Inc., Gythion Initial Scientific and Mini-Economic Reviews, draft, Cambridge,
        Massachusetts, October •174.

   (7) Midwest Research Institute, Initial Scientific and Mini-Economic Review Ho. 5:  Aldicarb. draft, Kansas City.
      Missouri, August 1974.

   (8) Midwest Research Institute, Initial Scientific and Mini-Economic Review of MalatMon. draft Kansas  City,
      Missouri, September 1974.

   (9) EPA, OPP, Demetcn Mini-Economic Review, draft, July 1974.

   (10) EPA, OPP, Minieconomic Review Phorate, draft June 1974.

   (11) Theordore Riedeburg Associates, Pesticide Use for Control of Soil Borne Insects 1n Corn 1n_the_JiUtes_oLIad1ana..
      Illinois. lova. and Missouri.
      An examination of the summary  (Appendix E,  Table  1) for domestic,
commercial  and public health  uses of chlordane/heptachlor  indicates that
there  are  substitutes registered  for most uses.   Under "special  uses,"
a  category which  includes public  health  and  forestry plantations,  for
two of the five pests there apparently are no registered alternatives.
The largest use category, "lawn and  nursery  soil  applications,"  proved
to be  the  category with  the greatest number  of  pests for which
substitutes are not registered.   Of  the  31 pests registered for
chlordane/heptachlor  use, 11  or 1/3  lack registered substitutes.   However,
in categories  where substitutes are  lacking  some of the pests  are  minor,
e.g.,  lawn earthworms.   In other  cases,  an examination of  current  state
extension  service recommendations reveals that  some states have
registered substitutes for certain  pests not covered by federal
registrations.  For example,  Mississippi shows  lindane, zectran,
metaldehyde baits and malathion baits as substitutes for lawn/ornamental
control of pillbugs,  sow bugs, snails and slugs.
                                               -93-

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                                                      -94-

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                          Corn Scouting Programs


     As noted earlier, cutworm infestation of corn is the major problem
in the North Central  region that would be affected by C/H cancellation.
A major alternative control being considered by cornbelt states is a
baiting/scouting program.  This program begins with a survey of the
pest populations in a corn field to determine the infestation level.
The strategy is that chemicals should be applied as needed and not on
a schedule.  The essential requirement is that an economic damage
threshold be established to determine when to apply the insecticide.
Once the decision is made, baits or sprays are applied.  Periodically,
scouts return to inspect fields for insect activity and determine
whether or not the damage  level warrants further treatment.
     Many farmers would be expected to do their scouting in connection
with other routine operations or as a special  activity at no added out-
of-pocket cost.  However, some farmers may need to have the work done
on a custom basis.  Costs of scoutina on a custom basis are available
from the 1973 and 1974 Indiana Corn Pest Management Program (5).
data indicates the estimated cost to the farmer for scouting field corn
(excluding treatments) was between $.50 to $1.34 per acre.  It should
be emphasized that not all infested areas will be scouted during each
growing year.  Thus, scouting costs vary according to the number of
acres that must be sampled for accurate results.

     The scouting costs reflect the farmer's expenditures for specialized
services which are supplied by a single consulting organization for a
single fee.  These services include field data collection, data analysis,
and professional  recommendations for pesticide applications.  While these
services demonstrate an additional cost factor they need to be compared
with the prevailing expenditures for insecticides in order to appraise
cost differences  properly.  It should be noted that scouting has the
potential to reduce the per farm expenses for pest control.  Nevertheless,
other issues need to be considered in order to establish the residual
benefits of this  tyoe of pest control program.

     For the scouting program to be effective on corn, it is essential
that the scouts be provided with some basic knowledge of entomology.
While graduate entomology students are currently being used as scouts
in an experiment  in Indiana and Missouri, it would seein that high
school seniors with some training can be scouts.  Doe to their busy
schedule not all  farmers can do their own scouting.  Since scouting
is a seasonal activity, it mioht provide temnorary employment.
                                        -95-

-------
      There are some important questions  concerninp  scouting  techniques
 and baiting procedures  which cannot  be answered  at  this  time due  to  the
•current state  of the  art.   Certain management cost  problems  have
 to be resolved;  states  that have  experimented with  scouting  have  not
 addressed the  question  of availability of  reliable  labor supplies  for
 scouting, nor  have they addressed the related management problems  of
 prganizing these services.   Will  farmers independently conduct insect scout-
 ing programs or  will  private contractors ~or extension service agents' perform
 this task?  What adjustments in cultural practices  for corn  production
 must be made by  a grower in order to coordinate  scouting/baiting
 practices?  Each of these questions  involves management  problems  which
 may entail some  changes in  farm organization and/or added managerial
 costs not reflected in  the  above  cost figures.   Thus, although
 scouting/baiting strategies appear to be constructive approaches  to
 cutworm control  from an ecological standpoint, it is difficult at present
 to make final  judgment  on short term feasibility.


                 Substitute  Insecticides  and Safety  Problems

      The cancellation of heptachlor  and  chlordane pesticides on corn would
 require the use  of substitutes primarily from the carbamate  and organo-
 phosphate groups (see earlier discussion of substitutes). The acute
 toxicity of many organophosphates presents a health concern. The labels
 detail precautions to be taken, but  if people are not familiar with
 their dangers, understanding the  label may not be sufficient to avoid
 accidents.  Moreover, the effects of organophosphates are not always
 immediate; a person can be  exposed for a number  of  days  before symptoms
 appear.

      Application and field work carry the  greatest  risks of  exposure to
 substitutes.  Yet, all  exposed groups, including field workers and others
 entering a field that has been baited, are subject  to a  relatively small
 risk because dermal or  respiratory contact is likely to  be limited in
 most use situations.   Increased risk to  children on the  farm or in the
 home is possible with storage and use of more acutely toxic  substitutes.
                                          -96-

-------
                               Termite Control
     C/H for termite control in structures is expected to be in strong
demand to prevent damage to buildings of all types.  Chlordane is the
most popular termite control agent and an estimated 68 percent of its
domestic use is for this specific purpose.  Cancellation of C/H would
leave aldrin, dieldrin, BHC and lindane as the major registered termite
pesticides.

     Termite control is a major annual expenditure accounting for not
less than $250 million annually (1/3 for repair to damaged structures
and 2/3 for chemical control).  Additional termite damage to utility
poles, fence posts and other similar wood is estimated at $500 million
annually (6).  The value of protection of structures from C/H is not
known.  In the absence of this information, a reasonable estimate is
that it is substantial.  Alternatives to the chlorinated hydrocarbon
class of pesticides lack the quality of persistence which is essential
for inexpensive and effective control of termites.  A cancellation of
these pesticides could have severe and long lasting economic conse-
quences until equally cost-effective pesticides become available.


     A secondary cost associated with cancelling C/H (and other
chlorinated hydrocarbons) would have adverse effects on the market for
construction of new buildings such as private homes.  A cancellation
of these termite controls would leave exterminating firms without
effective alternative controls and these firms may be unwilling to
provide guarantees of termite protection to owners of new homes, a
condition normally specified in conventional mortgages and required
in VA and FHA mortgages.  A slowdown  in new construction would be
detrimental to the national economy at this time  since  this  market is
countercyclical and has been credited with stimulating the economy
as a whole in recessionary periods.
                                        -97-

-------
                        References  for Section V
(1)  Northwest Industries,  Inc.,  "Annual  Report  1974," Chicago, 1975,
     p.  10.

(2)  Theodore Riedeburg Associates,  Pesticide  Use  for Control of Soil
     Borne Insects in Corn  in  the States  of  Indiana, Illinois, Iowa, and
     Missouri.

(3)  Straube, H.  L.,  (Chairman, Ad Hoc  Committee on Shortages, National
     Agricultural  Chemical  Association).  Statement before the
     Subcommittee on  Agricultural  Credit  and Rural Electrification,
     July 25, 1974.

(4)  Williams, J.  A.  (Chairman of the Board, Helena Chemical Company).
     Testimony presented at the Consolidated Aldrin/Dieldrin Hearing.

(5)  USDA, Indiana Corn Pest Management Program, Project Summary,
     Washington,  D.C.,  1974.

(6)  USDA, "Subterranean Termites, Their  Prevention and Control in
     Buildings,"  Home and Garden  Bulletin No.  64,  Washington, D.C.,
     January 1972.
                                         -98-

-------
APPENDICES
   TO
 PART I
         -99-

-------
                           APPENDIX A

Table 1.  EPA registered insecticides for corn insects other than
          rootworms, cutworms and wireworms.

Table 2.  Results of field testing of an organochlorine (aldrin) to
          control cutworm in corn in Missouri.
                                -100-

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                                           -102-

-------
                     APPENDIX B

     SUBSTITUTES FOR ALDRIN, DIELDRIN,  CHLORDANE
AND HEPTACHLOR FOR INSECT CONTROL ON CORN AND APPLES
                        -103-

-------
     SUBSTITUTES FOR ALDRIN, DIELDRIN, CHLORDANE
AND HEPTACHLOR FOR INSECT CONTROL ON CORN AND APPLES
                 Excerpts from Study
          Prepared by RvR CONSULTANTS Under
      Subcontract to MIDWEST RESEARCH INSTITUTE
         Contract No. 68-01-2448, Mod. #6
              MRI Project No. 3920-C
                RvR Project No. 69
                        -104-

-------
     In Iowa, Illinois, Ohio, Missouri, and South Dakota, aldrin led all
other corn insecticides by wide margins.  Estimates for Indiana are
available only for all organochlorine, and for all organophosphate and
carbamate insecticides combined, not disaggregated by individual products
within each group.

     The state estimates detailed in Table 1 are presented in summary
form in Table 2.  For purposes of Table 2, it was assumed that the
share of individual insecticides within the organochlorine group and
the organophosphate/carbamate group used in Indiana would be identical
to the shares of these products in the group totals in the two neighboring
states, Illinois and Ohio.  Estimates for Indiana by individual products
were derived by applying this assumption to the group totals reported
by the extension entomologists.

     One additional adjustment was made in preparing Table 2.  When the
insecticide quantity estimates from Table 1 were added up, the totals
for the 3 organochlorine insecticides and for carbofuran appeared to be
unrealistically high.  We suspected and subsequently confirmed that most
of the entomologists had made their estimates in terms of acres treated.
Pesticide quantity estimates for 7 of the 8 states were then derived
by multiplying estimated acres treated by the recommended rates per
acre of the insecticides in question.  Only the Minnesota quantity
estimates are based on multiplying estimated acres treated by actual
rates of use per acre as determined in a survey.  Table 1 shows that
in the case of aldrin, chlordane, and carbofuran, 3 of the 4 insecti-
cides whose volume estimates we questioned, the rates per acre reported
by Minnesota are substantially lower than those listed by the other
7 states.

     In preparing Table 2, we used the following "estimated actual"
insecticide application rates for the states other than Minnesota (all
in pounds of active ingredient per acre):  aldrin, 1.25; heptachlor, 1.3;
chlordane, 2.0; carbofuran, 0.85.  Due to these adjustments, most of the
state estimates of the quantities of these 4 insecticides in Table 1
differ from those in Table 2.

     Table 2 thus embodies the extension entomologists'  estimates on the
numbers of acres treated with corn insecticides in their respective
states, and rates of application per acre for each insecticide verified
and, where appropriate, adjusted by RvR Consultants.
                                      -105-

-------
Appendix B,  Table  I—Soil Insecticides  Used on Corn in Eight Midwestern  States  in
                    1974 by States,  Products, Rates, Acres Treated,  Total
                    Quantities Used, and  Target Insects
State
Iowa









Illinois





"•


Indiana
~






Ohio









Missouri











Minnesota








Insecticide
Aldrin
Furadan
Thimet
Bux
Dyfonate
Dasanit
Heptachlor
Hocap
Landrin
Chlordane
Aldrin
Furadan
Thimet
Dyfonate
Chlordane
Heptachlor
Bux
Diazinon
Oas?nit
Aldrin ';
Heptachlor)
Chlordane )
Furadan )
Thimet )
Bux )
Dyfonate)
Diazinon)
Aldrin
Chlordane
Furadan
Thimet
Dyfonate
Carbaryl
Diazinon
Dasanit
Heptachlor
Misc.
Aldrin
Furadan
Thimet
Dyfonate
Dasanit
Bux
Heptachlor
Chlordane
Diazinon seed
Treatment
Misc. seed
treatment
Furadan
Thimet
Dyfonate
Dasanit
Aldrin
Chlordane
Mocap
Diazinon
Misc.
Rate
Lb. a.i.
/ Acre
2.0
1.0
1.0
1.0
1.0
1.0
2.0
1.0
1.0
3.0
2.0
.75-1.0
1.0
1.0
3.0
2.0
1.0

1.0








2.0
4.0
1.0
1.0
1.0
2.0
35,000 bu.
1.0
2.0
1.0
2.0
1.0
1.0
1.0
1.0
1.0
2.0
3.0

140,000 bu.

20,000 bu.
.86
1.14
1.14
.95
.94
1.6
.84
1.0

Acres
Treated
(1,000)
2200.0
875.0
875.0
250.0
250.0
175.0
49.5
50.0
25.0
5.5
1798.3
1762.2
956.3
733.7
204.5
270.6
222.5
1,750 bu.
65.0

1510.0



660.0


500.0
100.0
250.0
150.0
100.0
32.0
35,000 bu.
50.0
5.0
50.0
800.0
105.0
75.0
60.0
30.0
30.0
15.0
5.0

140,000 bu.

20,000 bu.
787.0
176.0
170.0
165.0
130.0
71.0
88.0
30.0
23.0
Total Used,
1,000 Lb.
Act. Ingr.
4400.0
875.0
875.0
250.0
250.0
175.0
99.0
50.0
25.0
16.5
3596.6
1497.9
965.3
733.7
613.5
541.2
222.5
164.1
66.0

3500.0



660.0


1COO.O
400.0
250.0
150.0
100.0
64.0
52.5
50.0
10.0
50.0
1600.0
105.0
75.0
60.0
30.0
30.0
30.0
15.0

13.1

1.3
676.82
200.64
193.8
156.75
122.2
113.6
73.92
30.0

Target Insect(s)
Cutworms & Wireworms
Corn Rootworms
it ii
II M
II M
II II
Cutworms & Wireworms
Corn Rootworms
H ii
Cutworms & Hireworms
Cutworms & Wireworms
Corn Rootworms
ti ii
ii H
Cutworms & Wireworms
H ii
Corn Rootworms
Seed Treatment
Corn Rcct'..'2rr,s

Cutworms & Wireworms



Corn Rootworms


Cutworms & Wireworms
« H
Corn Rootworms
ii ii
H H
Cutworms
Seed Treatment
Corn Rootworms
Cutworms & Wireworms
Corn Rootworms
Cutworms & Wireworms
Corn Rootworms
ii ii
n ii
ii n
n n
Cutworms & Wireworms
n n

Seed Insects

11 H
Corn Rootworms
ii n
ii ir
n n
Cutworms & Wi reworks
n u
Corn Rootworms
ii it
Complex
                                           (Table concludPd or.  next  page)
                                               -106-

-------
   Appendix B, Table l--Soil  Insecticides Used on Corn in Eight Midwestern States
                        in 19'/4 by States,  Products, Rates, Acres Treated, Total
                        Quantities Used, and Target Insects (Concluded)
State
S. Dakota









Nebraska





,



Insecticide
Aldrin
Furadan
Thimet
Dyfonate
Heptachlor
Mocap
Dasanlt
Diazinon
Bux
Misc.
Furadan
Thimet
Dyfonate
Aldrin
Dasanlt
Bux
Oiazinon
Misc.
Misc. Seed
Treatment
Rate
Lb. a.i.
/ Acre
2.0
1.0
1.0
1.0
2.0
• i.o
1.0
1.0
1.0
1.0
1.0
1.0
1.0
2.0
1.0
1.0
1.0
1.0


Acres
Trea ted
(1,000)
Z20.0
250.0
250.0
250.0
55.0
100.0
50.0
30.0
30.0
40.0
1909.5
840.2
305.5
140.0
267.3
248.2
114.6
133.7

1500.0
Totaled Used,
1,000 Lb.
Act. Ingr.
440.0
250.0
250.0
250.0
110.0
100.0
50.0
30.0
30.0
40.0
1909.5
840.2
305.5
280.0
267.3
248.2
114.6
133.7

140.6
Target Insect(s)
Cutworms & Wlreworms
Corn Rootworms
ii ii
H ii
Cutworms 4 Wireworms
Corn Rootworms

-------
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-108-

-------
                     APPENDIX C



MATHEMATICAL PROGRAMMING ANALYSIS OF C/H RESTRICTION
                        -109-

-------
Introduction

     An examination of issues relating to continuation or modification
of established use patterns for pesticides must involve both the costs
and benefits associated with each use.  After the costs and benefits
have been specified, society, or its designee thru public regulatory
bodies, must determine if the benefits of the pesticide outweigh the
costs,  The decision is difficult and, if optimal, would require an
exact specification of a number of elusive parameters associated with
health and environmental effects, biological  processes and measures
of social welfare.  In practice, these parameters cannot be precisely
identified and therefore, society must base its decision on the best
available information and documentation.

     The costs are generally external to market activity and are,
therefore, more difficult to accurately measure than are the corresponding
benefits.  These costs which potentially include such areas as generally
worsening health of pesticide accident victims, subtle ecological insults
with potential for disrupting the food chain as well as the acute health
and environmental consequences associated with misuse or accidental
exposure and contamination are not metered through the market system,
thus negating a common market measure.

     Further complicating the comparison of benefits and costs is the
lack of precise knowledge regarding the biological questions associated
with pesticides.  Aside from the fact that the social costs stemming
from pesticide use are normally of an external nature, biological
scientists have been unable to answer such questions as how much cum-
ulative ingestion of a persistent pesticide will cause ecological or
health problems.  Therefore, even the assignment of market values to
nonmarket impacts is difficult because of the inexact nature of such
impacts.  In the face of such an imprecise measurement, the policy maker
must apply his own judgement of the costs imposed on society and weigh
his subjective determination against the best estimate of benefits
derived by economists and pesticide use specialists.

     In order to assist the policy maker in his role as social arbitra-
tor of pesticide use, a mathematical model of U.S. agriculture was con-
structed to measure the benefits from pesticides and to specify the
national and interregional impacts associated with changes in currently
allowable use patterns.

     Although of a different nature than those associated with cost
measurements, the assessment of social benefits from pesticide use has
several inherent problems.  Benefit related problems are primarily data
oriented and include such areas as accurate descriptions and quantifi-
cation of use patterns, efficacy of alternative control agents and
marginal productivity ratings for problem chemicals.  A mathematical
programming model for policy analysis cannot overcome these data
deficiencies, but can provide a thorough analysis on a national and
interregional basis of the best available information regarding yield
and substitution impacts.

                                     -110-

-------
     Due to a high degree of substitution between feedgrains when com-
parative advantage is modified and substitution between various types
of land within a region and between regions, it is difficult to assess
and predict the national and interregional  impacts stemming from major
changes in input availability and technology within a partial  equilib-
rium analysis, i.e. analysis of only one feedgrain sector or one geo-
graphic region.  Therefore, a national-interregional, mathematical
programming model of the U.S. agricultural  sector was constructed to
evaluate the overall changes in production  of endogenous crops, changes
in return to land, modifications in livestock rations and adjustments
in interregional trade resulting from alteration of available pest
management alternatives.

     The version of the mathematical programming system used to evaluate
the C/H cancellation consists of a base linear programming matrix with
approximate dimensions equalling 28,000 columns by 2,500 rows.   The
models were solved using the MPS/III mathematical programming algorithms
on an IBM 370/168 computer.  Model aggregation consists of 127  production
regions for which all production activities are defined and 27  consuming
regions for which final demands are specified.  Model solutions are
reported for the individual consuming regions, seven aggregate U.S.
subregions, and U.S. totals.
                                     -Ill-

-------
Linear Programming Model  of U.S.  Agriculture

     The specific form of the mathematical  programming model  which
was constructed to aid in the evaluation of C/H restriction is a
cost minimization, optimization model  with  linear resource restraints
and an objective function which is both linear and additive.   While
linear assumptions do not always  mirror real world situations, the
techniques employed in the development of this model  enable the appli-
cation of linear programming techniques to  nonlinear areas.

     The model is national in that it  recognizes that markets for
agricultural products are national (individual producing regions are
not isolated from one another), while  the regional delineation of
producing areas (127 in total) accounts for the unique physical rela-
tionships which are a function of the  location of agricultural production
(soil  type and yield, climate, pest infestation, etc.).   This construction
places extreme emphasis on the economic phenomenon of interregional
competition which is an important characteristic of the agricultural economy.

     Seven crops are treated as endogenous  to the model: barley, corn,
cotton, soybeans, oats, sorghum and wheat.   Other agricultural land uses
are projected exogenously and subtracted from the total  land base.  The
livestock sector is also projected exogenously and fixed at a pre-
determined level.  The nonfeedgrain portion of total  nutrient demand,
stated as digestible protein (DP) and  total digestible nutrients (TON)
for ruminants, nonruminants and poultry supplied from exogenous crops
and land uses is subtracted from total nutrient demand to yield a set
of net demands which must be satisfied through feeding of the endogenous
feed grains.  Other nonfeeding demands 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 demands to form the right
hand side constraints which must be satisfied by endogenous production.
A set of activities for production of  the endogenous  crops by region with
variable yields disaggregated by nine  soil  classes 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.

     Linkage between the production activities and demand constraints is
provided by feed conversion activities (the DP and TON equivalent of each
endogenous crop as defined by NRC specifications) and transportation
activities to allow interregional movement  of endogenous crops to meet
the fixed, regional demands.

     The model is solved through a mathematical algorithm which simu-
taneously guarantees that:  a) all regional demands are satisfied,
b) no regional resource constraints, e.g.,  disaggregated land base is
                                     -112-

-------
exceeded, and c) the objective function is minimized.   In so doing, the
model solution depicts the land use and production pattern which satifies
all constrants at least cost.

     An alternative construction would have been a profit maximization
model which would provide a solution to maximize returns to the agricul-
tural sector.  However, a unique characteristic of linear programming ana-
lysis guarantees that the dual solution of a cost minimization model  is
a profit maximization solution; therefore the activity levels for both
cases are identical.  The cost minimization formulation was chosen on
the basis of modelling criteria which lend nothing to  the accuracy or
validity of the solution.
                                     -113-

-------
 Pesticide  Analysis  -  A  Special Case of the General Agricultural Model


     To be useful for short run policy analysis (a projection within a
five-year horizon), the first criterion for a mathematical programming
model is that it be believable.  Major drawbacks in previous national
agricultural models have been their sensitivity to minor changes in input
coefficients and/or their overall  sensitivity to misspecification.   Many
previous models have offered solutions for agricultural  equilibrium in the
future, such as 1985-2000 and, in  these cases, solutions from the model
which suggest drastic shifts away from observed patterns of land use and
production are difficult to evaluate.

     A number of arguments are put forward to explain the differences
between long run model solutions and short run historical observations.
In the first instance, one can hypothesize that the long run solution
from an LP model is correct and that changes in comparative advantage will
lead to major shifts  in production patterns between regions.  Secondly,
one can argue that any given glimpse of agricultural production patterns
(a one-year historical pattern) depicts the system in disequilibrium and,
in the long run, farmers will follow the profit maximization (or cost
minimization) motive  and trend toward model solutions.  A third, but
trivial argument supporting long run, major deviations from observed
production patterns professes the argument that, in the long run, all
factors are variable  and mobile and, therefore, model results are
believable.  This argument suggests that the long run is represented by an
unknown which cannot  be assessed through examination of historical
observation.

     A more believable scenario for long run deviations from history lies
in the labyrinth of farmers' decision making.  Unlike a mathematical program
which recognizes one-cent changes in the profitability of one crop versus
another and suggests  appropriate adjustments to attain general equilibrium
conditions, farmers are incapable of discerning small, permanent changes  in
relative net returns.  The magnitude of annual fluctuations in prices  and
yields due to natural, stochastic phenomena such as weather plus temporary
market fluctuations due to short term variables like trade adjustments make
long term, permanent  changes in comparative advantage difficult to discern.
In addition, an incorrect guess based on limited data is often more costly
than the failure to immediately adjust to permanent changes.  Therefore,
farmers may tend to resist change when a system of equations suggests  that
change should occur.  In the long run, if the stimuli remain, both the
real world solution and a well specified model should converge on the
same equilibrium pattern.

     Significant effort was expended toward making the EPA pesticide model
believable in the sense that it "tracks well" with historical production
patterns.  In order to evaluate phenomena which are location specific,
                                     -114-

-------
e.g., pest infestations and pesticide applications, the base linear
programming solution must coincide with the patterns of land use from the
most recent historical period.  To assure as much realism as possible, all
data relating to land use and past production was either gathered at the
county level or disaggregated to the county level prior to aggregation up
to production regions.  Detailed statistical procedures were used to
forecast land use (planted acres) and yield for the endogenous crops.
These projections, for the seven endogenous crops in each of the 127
producing regions, served as target activity levels which were, by
construction, consistent with historical trends.

     Deviations from these "P" (projected) activities had associated costs
to represent the basic stability of the U.S. agricultural system and to
model the fact that fanners are:  a) unable to discern and respond to small
changes in comparative advantage in the short run, b) somewhat inflexible
in their production decisions, and c) consider long run vs. short run
production costs when deviating from past patterns.  These costs, termed
flexibility costs, while not unique in theory are operational only in the
EPA national agricultural model.

     As an indication of the ability of the EPA model to generate solutions
which are consistent with historical trends, a comparison was made between
statistical projections for 1977 based on twenty-five years of time series
data and the linear programming solution for 1977 (Table 1).

     To evaluate the  impact of restricting the use of chlordane and
heptacnlor, the land  base in corn growing regions had to be disaggregated
by insect infestation.  Regional acreage estimates were made of infestations
of cutworm, wireworm  and rootworm.  The model's distribution of infested
acres is reported in  Table 2.  Infestations were further disaggregated by
soil productivity class to enable interaction between the yields associated
with various soils and crop loss due to infestations.  Base model solutions
for treated acreage  (as opposed to  infested acreage) are reported in Table 3.
As Table 3 indicates, chlorinated hydrocarbon insecticides are the primary
control agent on cutworm infested land while other insecticides, in addition
to chlorinated hydrocarbons, are used to control rootworms and wireworms.

     Evaluation of the impact of C/H restriction 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 accomplish
this, several assumptions were required to define the parameters for
specification of the  second model.
                                     -115-

-------
Appendix C, Table 1--Comparison of time series projection
                     for endogenous crops, 1977 and LP
                     solution for 1977
Crop
Projection
Model Solution


Barl ey
Corn
Cotton
Soybeans
Oats
Sorghum
Wheat
Slack land


13,848
53,847
7,979
53,519
14,551
15,167
68,855
29,086


12,320
49,900
9,450
59,940
8,820
15,210
69,790
31,260
 Appendix C, Table 2--Base model distribution by insect species,
                      of infested corn
State


Ohio
Michigan
Indiana
Illinois
Missouri
Iowa
Wisconsin
North Dakota &
Northern Minn.
South Dakota &
Southern Minn.
Nebraska
Kansas
Total

Wireworm

0.19
0
0.34
1.09
0.32
0.57
0

0.01

0.40
0
0.16
3.08
Insect Species
Rootworm
mil ion a P v*oc
0.51
0.71
1.43
2.87
0.57
3.63
1.09

0.19

1.82
4.06
0.43
17.31

Cutworm

0.43
0
0.46
1.21
0.59
0.87
0.34

0.02

0.45
0.19
0.16
4.72
 Source:  EPA Linear Programming Analysis.
                                  -116-

-------
Appendix C, Table 3--Base model  distribution of corn acreage
                     infested by wireworm,  rootworm and  cutworm
                     by treatment option
State
Ohio
Wireworm
Rootworm
Cutworm
Total
Michigan
Wi reworm
Rootworm
Cutworm
Total
Indiana
Wireworm
Rootworm
Cutworm
Total
Illinois
Wi reworm
Rootworm
Cutworm
Total
Missouri
Wireworm
Rootworm
Cutworm
Total
Iowa
Wireworm
Rootworm
Cutworm
Total
Wisconsin
Wireworm
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

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

.17
.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
                             -117-

-------
                      Appendix C, Table 3 (Continued)
State
Minnesota (N)
Wireworm
Rootworm
Cutworm
Total
Minnesota (S)
Wireworm
Rootworm
Cutworm
Total
Nebraska
Wireworm
Rootworm
Cutworm
Total
Kansas
Wireworm
Rootworm
Cutworm
Total
Total
No
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.



Source:  EPA Linear Programming Analysis.
                                      -118-

-------
      In general, the parameters were chosen such that the model would
depict a  "worse case" impact associated with restrictive public action.
The decision to model an extreme case was made for the following reasons.
First, the decision makers who must weigh costs and benefits must be
cognizant of the full range of potential impacts.  If, in their weighing
of costs and benefits they can determine that the costs associated with
/continued use exceed the derived benefits under maximum benefit conditions,
the appropriate social strategy is more clearly defined.  Data and
evaluation which provide the spectrum of use associated benefits under a
"most likely" set of assumptions is also necessary to decision making and
will  be provided after subsequent model solutions are generated.  Secondly,
a USDA sponsored study (Delvo, 1974) derived yield impacts associated with
chlorinated hydrocarbon restrictions for the three endogenous insect
species under several assumptions regarding alternative controls.  As
Delvo points out, the yield impacts are representative of "what might
occur with a moderate to heavy insect infestation."  A corollary set of
assumptions for a typical year has not yet been fully specified.  Therefore,
the available data also played a role in choosing to model the extreme
situation first.

      Explicit assumptions in the chlorinated hydrocarbon exclusion model
included the areas treated with C/H during the base year (1977) and yield
impacts associated with C/H withdrawal.  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 stimulated by examining the most recent
estimates of total aldrin, dieldrin, chlordane and heptachlor use.  To
the extent that other chemicals in addition to C/H fill the void created
by restrictions in aldrin and dieldrin, the current model overestimates
C/H use and therefore overestimates derived benefits from C/H use (costs
associated with cancellation).  Yield inputs, 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 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 states 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 indicates that,
due to widespread rootworm resistance to organochlorines, the increased
yields associated with shifting from organochlorines to other pesticides
may be significant and is 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
state yields while the use of C/H would lead to 8% yield declines on
rootworm infested acreage.  The full yield file is reported in Table 4.
                                     -119-

-------














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-120-

-------
           APPENDIX D
ASSUMPTIONS USED TO DERIVE ENERGY
     IMPACT OF CANCELLATION
              -121-

-------
                    Assumption used to derive energy
                        impact of cancellation


     Text tables 21  and 22 summarize the energy impact of cancellation
of chlordane and heptachlor based on representative substitutes:  carbo-
furan, 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
carbamate.

     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 impacts (Syracuse University Research Corpora-
    tion).  Comparing process  steps, the energy and electricity require-
    ments from this study were extrapolated to the three substitute pes-
    ticides 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 di-
    stillates, with appropriate process energy (electricity and heat)
    assigned to each step.

2.  The use 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 dis-
    tinct, independent process is in error.  We were unable to evaluate the
    direction of the error in estimating the impact of the studied pesticides
                                      -122-

-------
    on petroleum consumption.   The American chemical  industry is  often  able
    to accommodate 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 acid  or propylene.  If made with the latter, a by-
    product is acetone, which  in turn is a raw material  for diazinon  pro-
    duction.

4.  Similarly, in calculating  "petroleum for feed" in Tables 21 and 22, it
    was assumed that petroleum processing can be adjusted to produce  one
    pound of the feedstocks from one pound of crude  oil.  Since only  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, either 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  organo-
    phosphate, if phorate were the substitute, petroleum use would  be less
    than estimated here.

5.  The mode of application was assumed similar for  the substitute, for
    example, 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 (e.g. no tractor fuel).  Thus, only  manu-
    facturing energy impact was calculated.

7.  Cyclopentadiene, phenol, naphthol, and ethanol,  which are feedstock
    materials for chlordane-heptachlor, carbofuran,  carbaryl, and diazinon,
    respectively, may be preduced in large quantities from coal.  Only  the
    petroleum source was considered, however.
                                     -123-

-------
 8.  The "total  substitutes"  impact  in  the  Tables was  calculated  taking  dia~
     zinon (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 oal/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 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  qranular 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  -- negliginle.   Diazinon  AG500 (46?  inert) x 10n%  use  =
     45% inerts.

12.  The effect  on  natural  gas  consuption was not considered.  Natural qas
     was assumed to be of  secondary  importance as an industrial energy source.
     To convert  coal in the Table to natural  gas, assume 12.5  cu  ft  of gas  oer
     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 assumed  that patterns of crop cultivation and
     transportation, and attendant energy use, will  not  change as an
     economic conseguence  of cancellation.
                                      -124-

-------
                              APPENDIX E

Table 1:  SUMMARY OF REGISTERED CHLORDANE AND HEPTACHLOR SUBSTITUTES
                  FOR SELECTED DOMESTIC, COMMERCIAL,
                 PUBLIC HEALTH AND MISCELLANEOUS USES
                                 -125-

-------
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                                                  -129-

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                 APPENDIX F
FEDERAL REGISTER NOTICE OF EPA ADMINISTRATOR'S
   INTENT TO CANCEL CERTAIN REGISTERED USES
         OF CHLORDANE AND HEPTACHLOR

              November 26, 1974
                    -130-

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 41293
               NOTICES
           {Docket No. 371(1)

     SERVICE TO STOCKTON CASE
         Preheating Conference
   Notice is hereby given that a prchcar-
Ing  conference In  the  above-entitled
 matter Is assigned to be held on Janu-
 ary 7, 1975,  at JO a.m. (local time) in
 Room 1031,  North Universal Building,
 1875 Connecticut Avenue NW., Washing-
 ton,  D.C., before Administrative Law
 Judge Oreer  M. Murphy.
   In order to facilitate the conduct of
the  conference, parties  are instructed
to submit one copy to each party and
four copies to the Judge of (1) proposed
statements of Issues: (2) proposed stipu-
lations; (3) requests for Information; (4)
statement of  positions of parties; and (5)
proposed procedural dates. The Bureau
of Operating  Rights will circulate its ma-
terial on  or  before December 13, 1974,
and the other parties  on or  before De-
cember 27, 1974. The submissions of the
other parties shall be  limited to points
on which they differ with the Bureau of
Operating Rights, and shfll follow the
numbering and lettering used by the Bu-
reau to facilitate cross-referencing.

   Dated at  Washington.  D.C.. Novem-
 ber 21,1974.
   fsEALl           ROBERT L. PARK.
      Chief Administrative Law Judge.
  |FK Doc.74-»Vt,*2 Filed 11-25-74:8:45 am]

   ENVIRONMENTAL  PROTECTION
               AGENCY
              (FRI.W3-1]
   PESTICIDE  PRODUCTS  CONTAINING
     HEPTACHLOR OR  CHLORDANE

      Intent To Cancel Registrations
  On March  18, 1071, the Administrator
of this Agency announced that active
internal review was being initiated on a
number of pesticide  products, including
those containing chlordane  and  hep-
tachlor. As the result of such review and
for the reasons set forth in the attached
statement of reasons, I find that the con-
tinued  registration  and  use of  these
pesticides appear to  pose substantial
questions of safety amounting to an un-
reasonable risk to' man and the environ-
ment. I therefore  serve  and file this
notice of  intent,  together  with  the at-
tached statement of reasons, to  cancel
all registered uses  of heptachlor and
chlordane within thirty (30) days, pursu-
ant  to section 6  of  the  Federal Insec-
ticide, Fungicide, and  Rodenticide Act,
.as amended, (80 Stat. 973,7 U.S.C. 136d),
with the exception of the use of hepta-
chlor or chlordane through  subsurface
ground insertion for termite control and
the dipping of roots or tops of nonfood
plants. Any nflected party may contest
tills action by requesting a hearing on
specific registered  uses  on  or  before
December 26,1974. Requests for hearings
should  be  submitted  to  the Agency's
hearing clerk at the following address:
Mm. Dotty J. Dllllng*
Hcnring Cltrk
U.S. Environmental Protection Agency
Room 1019. WAtersId* Mall—-East Tow»r
401 M Street. SW.
Washington. D.C. 30400
  The proposed cancellation shall become
final and effective thirty (30) days from
the date of this notice as to those regis-
tered uses for which a hearing is not re-
quested by any affected party. The pro-
posed cancellation shall not take  effect
regarding any resistcrcd use lor which a
hearing is requested  until the hearing
has  been  completed,  unless there is a
concurrence from all parties  to the pro-
ceeding. The Agency reserves the op-
portunity to present evidence on any
registered use affected by this order re-
gardless of whether or not a hearing has
been requested on that use, or whether
or not such use is to be actively defended
in the hearings.
  Dated: November 18.1974.
                 RUSSELL E. TRAIN.
                     Administrator.
STATEMENT or REASONS:  HEPTACHLOR AND
              CKLORDANE
          I. LMAL AUTHORITY
  Section 6(b) of the Federal Insecticide,
Fungicide, and Rodenticlde Act (7 U.S.C.
135 et seq) as amended (7 U.S.C. 136a(c)
(5) (D)) authorizes the Administrator of
the Environmental Protection Agency (or
his deslgnee) to issue a notice of intent
to cancel  the registration of a pesticide
or to hold a hearing "UK it appears  to
the Administrator that a pesticide or its
labeling ' •  • does not comply v/lth the
provisions of this act or, when used  In
accordance with widespread and  com-
monly  recognized  practice,  generally
causes unreasonable adverse effects on
the  envlronm -it  • • *."  Trie  phrase
"unreasonable adverse effects on the en-
vironment" is defined In section 3 of the
Act (7 U.S.C. 136(bb)) as "any unreason-
able risk to man or the environment tak-
ing into account the economic,  social,
and environmental costs and benefits  of
any pesticide."  '
  The Act also prohibits thcTsale of pesti-
cides which are mlsbranded. A product
is considered mlsbranded If the label does
not  contain  directions  for use and  a
warning or caution statement which are '
necessary  and If complied with are ade-
quate to protect  health and the environ-
ment. (7 U.S.C. 136(a) (1) (F) and (O>.)
n.  CHEMISTRY  or  HEPTACHLOR  AND
              CHIORDANE
  Heptnchlor and chlordane  are chlori-
nated hydrocarbon Insecticides, and have
a chemical structure which Is similar  to
that of Aldrin and Dieldrm. Both pesti-
cides  consist of a complex mixture  of
compounds  whose  ratios in th«  final
technical product have  been standard-
ised.   Technical  hcptachlor  consists
primarily of pure rleptaclilor (70-73 per-
cent),  gamma-chlordane  (20-23  Per-
cent),  nonachlor (4.5-5 percent), and
small amounts of both the  initial re-
actant (hcxachlorocyclopentadlene) and
chlorenc. Technical chlordane  consists
primarily   of   approximately   equal
amounts of alpha-chlordane and gam-
ma-chlordane (total:  43±5 percent),
 pure hcptachlor (10±3 percent), •non-
 achlor (8±3 percent), chlordcne Isomers
 (21 ±4 percent), and a number of other
 compounds In varying lesser amounts.
  Both hcptachlor and chlordane  form
 toxic metabolites  (including hcptachlor
 cpoxidc,  chlordcne cpoxidc  and  oxy-
 chlordnne)  which arc found in the urine
 and  feccs  of  mammals.   Chlordene
 cpoxidc may also be formed by soil  or-
 ganisms.  In addition, a caged Isomer
 more toxic to insects  and fresh water
 animals titan heptuchlor has been shown
 to be formed on exposure of heptachlor
 to  sunlight.  Oxychlordane,   a major
 metabolite of chlordane, found primarily
 in animals (including  man). Is formed
 very  slowly in  normal  liver  tissue.  Its
 formation,  moreover,  is  accelerated by
 the presence of compounds such as DDT,
 dieldrin, or heptabarbital.
               m. USES
  Heptachlor  and  chlordane have  been
 used extensively in  the United States
 since the 1950's. In 1971, 70 percent of
 the approximately one million pounds of
 heptachlor used in U.S. agriculture was
 as a soil treatment for a wide variety of
 crops. Its primary use was on corn  but
 also included  vegetables, cereals, forage
 crops, seed crops, and seed treatments.
 The remaining  30  percent was used  for
 the  protection of commercial  and  resi-
 dential structures  against termites and
 for a variety of nursery, lawn, and gar-
 den applications, and for foliar applica-
 tion to ditch banks, roadsides and vacant
 fields. Total  use  of  hcptachlor more
 than tripled in 1D72. of  which over  1.7
 million pounds was used for termites and
 structural  pest control alone, and  1.6
 million pounds was used  on agricultural
 crops. It is estimated that the use of
 heptachlor  on corn alone could increase
 to 3 million pounds in 1975.
  Chlordane Is used  hi much greater
 quantities than heptachlor, and is  one
 of the most widely used household and
 garden pesticides. The quantity used has
 increased from approximately 11 million
 pounds in 1971 to between lb-16 million
 pounds in 1972. About 60 percent of the
 1972 volume was used for termite control
 and other household and commercial ap-
 plications,  including crabgrass control,
 use on shade trees and ornamentals, and
 treatment of indoor pests. An additional
 6.5 million pounds were applied to corn,
 grain, fiber and  fo*-age craps, and a
 variety of fruits anj vegetables. Chlor-
 dane is  also used  as  a seed treatment
 and in summer months is applied directly
 to water in sewage treatment plants  for
 control of Psychoda larvae.
       IV. ALTERNATIVE PESTICIDES
  .There arc alternative pesticides regist-
 ered for virtually all  of the  registered
uses of both heptachlor and chlordane.
 AJ  registered  alternatives, these pesti-
cides should be  effective although there
may be  Geographical  areas  or special
situations where this Is not true. Many
of these substitutes may be more expen-
sive than hcptachlor and chlordnnc.  In
addition,  most  arc less  persistent,  al-
                                                           -131-

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                                                     NOTICES
                                                                        412'J!)
 though persistence Is  frequently not a
 critical factor In terms of efficacy. In
 the case of subsurface termite  control,
 however,  insistence  Is critical.  Aldrln
 and dicldrin are the principal other per-
 sistent pesticides presently registered for
 subsurface application for termite  con-
 trol. These uses of aldrin. and  dleldrin
 werei not included in the recent suspen-
 sion order of the Administrator nor in the
 cancellation action now pending.
   Although some alternatives may be
 more  acutely toxic than'heptachlor and
 chlordane, hazards to applicators may be
 minimized by adherence to labeling in-
 structions and other regulations, with the
 benefit of eliminating the chronic effects
 of hcptachlor and chlordane.
   We  do  not now have Information on
 the usefulness  of nonchemical control
 methods for each of the registered uses
 of chlordane and heptachlor but these
 methods should be thoroughly explored
 in the hearing.
             V. TOMCITY

   Heptachlor and chlorda.'.e are chlori-
 nated  hydrocarbon pesticides which are
 broad  spectrum pesticides and are toxic
 to nontarget organisms as well as to in-
 sect pests. Reductions in bird populations
 following application of hcptnchlor to an
 area have been reported frequently. It is
.difficult, however, to determine what im-
 pact these toxicities  have on  species
 population*;, as opposed to individual fish
 or wildlife or specific local populations.
   Heptachlor   and    chlordane   have
 demonstrated toxic effects  which  may
 have significant adverse effects on human
 health. Heptachlor and its metabolite,
 heptachlor epoxlde, have been found to
 increase  significantly  the  incidence of
 liver tumors including carcinomas in one
 strain  of mouse (C3Hcb/Fe/J) at a single
 feeding level of 10 ppm.  The majority
 of these tumors  were originally reported
 as benign. On the basis of the original
 reported experiment the Cnrcinogenicity
 Panel  of the HEW Secretary's Commis-
 sion on Pesticides and their Relationship
 to Environmental Health judged hcpta-
 chlor epoxide "positive for tumor induc-
 tion on the basis of tests conducted ade-
quately in  one or more species,  the re-
 sults being significant at the 0.01 level."
Subsequent analysis by pathologists re-
 vealed  a high incidence cf carcinomas
 in animals from tlic experiment (greater
 than 90  percent Incidence  in  animals
 given heptachlor epoxlde).
  In addition a  two-year  feeding study
 of heptachlor expoxidc to  225 CFN  rats
showed a significant increase in the num-
 ber of  animals with tumors at  the 0.5
ppm feeding level, and for nil test  ani-
mals at all lecding levels (0.5 ppm to 10
ppm)  when the groups were combined.
The tumors were found primarily in the
endocrine organs, but a substantial num-
ber of  liver tumors were  found in the
treated animals while no liver tumors de-
veloped in the control group.
   There Is evidence of cmbryotoxlclty on
the part of both heptachlor nnd chlor-
dane to some strains of  rats or  mice.
 Embryotoxlcity  Is of  particular impor-
 tance  since hcptnchlor epoxklc residues
have been detected in human fetu&cs and
neonates. There is oddltlonol evidence in
the literature Indicting other toxic effects
of a chronic nature attributable to hep-
tachlor and chlordane. AU>uch evidence
should be further explored in the hear-
ings.
  Since  technical chlordane  generally
contains 8 to 12 percent hcptachlor, nil
of the findings reported above for hepta-
chlor and its metabolites are relevant to
technical chlordane  when adjusted for
the  difference  in concentration.  Pure
alpha and  gamma  chlordane  without
heptachlor are not registered as a pesti-
cide nor is the Agency aware of the ex-
istence  of  adequate  efficacy  data  to
satisfy  registration  requirements.  Suf-
ficient  testing  has not yet been com-
pleted or reported  on highly purified
chlordane to warrant a determination of
the  carcinogenicity  of  pure chlordane
 (without heptachlor).
VI.  ENVIRONMENTAL CONTAMINATION AND
             PERSISTENCE

  Heptachlor and chlordane,  or their
metabolites, are persistent in the envi-
ronment  long  after use.  Residues  of
heptachlor epoxide have been detected
in soil samples for as long as ten years
after  application.  Chlordane  Is  even
more persistent, with  18-20 percent  of
tha  originally applied  dosage recover-
able in soil ten years after application.
In  addition, heptachlor is quite vola-
tile. Chlordane is also  volatile, though
somewhat  less  so  than  I-:ptachlor.
Chlordane vapt-'s can  penetrate pack-
aging material and contaminate food in
homes in which it Is  used.
  Although we do not have data which
can  be considered representative of the
ambient air nationally, limited sampling
of  sites  selected for  other  purposes
showed the presence of heptachlor, and
to a very limited extent, chlordane. This
indicates  that air can  be  a source for
h»man intake of these compounds.
  As persistent compounds, heptachlor,
chlordane, and their  metabolites are
subject to considerable movement from
the  site of actual application.  Residues
of both  hcptachlor and chlordane can
be picked up from the soil and translo-
cated to various parts  of plants.  Rem-
nant residues are particularly significant
in root crops such as carrots,  potatoes,
and beets. In addition, residues of chlor-
dane were detected in alfalfa growth
sampled at 2 months,  4 months, and  1
year after application to soil, at a dosage
of 5 to 10 pounds actual chlordane per
acre. One of the major residues found in
alfalfa was oxychlordane (17 percent).
  Although low in water solubility, their
affinity for lipids and their ability to ad-
here to particulatc matter make hepta-
chlor and chlordane subject  to bioac-
cumulation and  transfer  in  the  foot!
_chn_in, particularly In  aquatic  species.
While heplachlor and chlordane would
appear  to be relatively immobile  once
they are  bound to the soil, C;, labeled
pesticides  from treated fields  east  of
Dallas,  Texas, were monitored and later
found to have been deposited  by rain
over Cincinnati, Ohio. The dust deposits
contained  0.5 ppm  chlordane.  Treated
soil is also subject to water erosion, ulti-
mately leading to aquatic contamination,
including contamination of phytoplank-
ton and fish.
  Chlorinated  hydrocarbon  pesticides
have been detected in surface waters in
concentrations of 10-150 ppt. Hcptachlor'
concentrations in  the  Upper Mississippi
and Missouri River Basins were all in the
parts-per-trillion  range and  in  many
river basins of the country, ranged be-
tween  5-30  ppt.  Hcptachlor  epoxide
concentrations have ranged between 5-40
ppt.
  Heptachlor, heptachlor  epoxide and
chlordane residues have been found fre-
quently in fish, birds, and other  wildlife.
Heptachlor epoxlde has been detected in
birds at levels of 0.01-1.0 ppm. Chlordane
residues  in fish have generally been less
than 0.5 ppm. BluegiH growth  was re-
duced in heptachlor-treated ponds at a
concentration in  the water of 005 ppm.
Heptachlor and heptachlor epoxide resi-
dues of 0.01-8.46 ppm were found in fish
from the Great Lakes  area.
  Heptachlor epoxide has also been dis-
covered in the tissues of several  mam-
mals, including pronghorn antelope (O.C3
ppm), and mountain goats  in  Sout,i
Dakota (0.12 ppm), which Is indicative
of its widespread distribution.
  Heptachlor, heptachlor epoxide, and
chlordane residues have also been found
in food samples. Market basket  samples
for total diet studies were purchased from
retail stores on a bi-monthly basis  in five
regions of the United  States over a fi'/z
year period.  Heptachlor  epoxide was
commonly found in the dairy, meat, fUh
and poultry components of the diet, with
the residue levels ranging from trace
(0.001  ppm)  up to  .03 ppm. The same
surveys have indicated the presence of
ehlordane with first quarter 1974 levels
being found  at 0.01 to 0.3 ppm in sig-
nificant percentages of cattle and poul-
try. The primary source of sue!',  residues
In these  products  is probably the  use of
chlordane and heptachlor on feed crops
like corn and alfalfa.
• The  most  important aspect of  the
movement of heptachlor and chlordane
in the environment is the presence of the
metabolites of these pesticides  in man.
Human monitoiing studies conducted in
thh  country  found i .icentrations  of
heptachlor epoxlde in  the adipose tissue
in 96 percent of the 3451 hospital  patients
studied in 1970  fmcan concentration:
0.08 ppm); 96 percent ot the 3768 patients
stucjiod in 1971  (mean concentration:
0.08 ppm); and 93 percent of the 2854
patients  studied In 1972 (mean  concen-
tration: O.OD ppm). (Level of detection^
0.01 ppm). Oxychlordane residues were
detected in the adipose tissue of 97 per-
cent of 3339 patients sampled  in 1971
(mean concentration:  0.10 ppm), and 97
percent of 2707 patients sampled in 1072
(mean concentration:  0.11 ppm).  (Level
of  dctccUon^C 02 ppm1. Residues  of
hcptachlor epoxide in adipose tissues
ranged as high as 2.68 ppm. while oxy-
chlordane residues \veic as hinli a.s l.Cl
ppm.  Recent  studies  indicate  that  an
additional chlordane metabolite,  trans-
                                                           -132-

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 41300
               NOTICES
 nonacltlor. may also be present In a very
 high percentage of humans.
   Concentrations  of heptnchlor cpoxlde
 residues are found not only In adults, but
 in stillborn Infants as well. The organs
 of 10 stillborn Infants obtained in two
 Atlanta hospitals were found to contain
 on average of 0.54 ppm heptachlor epox-
 Ide.  The  htixhest  levels were found In
 the  heart, adrenal Eland, and liver. The
 finding of residues  in stillborn Infants
 demonstrates that heptachlor cpoxidc is
 transferred  from the mother to  the
 infant across the  placenta. In addition,
 53 human  milk  samples collected  in
 Philadelphia, and  Center County, Penn-
 sylvania, had an average concentration of
 heptachlor epoxide of 0.16 ppm  (in milk
 fat)  in n study reported in 1972. Three of
 the samples were in the 0.40 ppm to 0.49
 ppm range.
   These findings  are disturbing;  since
 organisms that are  exposed  from the
 time of conception  and then  for the
 balance of their life are apt to be more
 responsive than  those whose  exposure
 begins  after wraning. For this reason
 evidence that'human fetuses are exposed
 across the placenta  is considered  espe-
 cially significant even  without quantita-
 tive  evaluation. Similarly, levels in milk
 that may be the sole source of food for
 infants is  of  especial   concern   even
 though that Lv«;l laa/ not l/c  continued
 after weaning. Quantification of the risk
 to man on the basis of a comparison be-
 tween the levels of r. carcinogen to which
 man is exposed and the levels which pro-
 duced cancer in experimental anirr-ils Is
 extremely difficult because of  the  num-
 ber of factors which  mast be considered.
 In the  case of he'ptachlor epoxide, ex-
 perimental animals were dosed  only by
 the  oral  route  v.-hereas  man may bo
 exposed by inhalation of air as well. The
 dosage to which animals  are exposed are
 often In terms  of  concentrations In the
 feed (10 ppm and 0.5 ppm in experiments
 reported above). For a direct comparison
 of oral dosages, the concentration in feed
 (or man's food) must be multiplied by
 the volume  of feed (or food) consumed
 per day to give the  daily Intake of the
 carcinogen.  This must be further ad-
 Justed cither for weight or size of the
 animal  or man. Even such an  adjust-
 ment is incomplete without some  com-
 pensation for differences  in  metabolic
rates. Hjth length  of exposure (probably
 in terms  of  percentage  of normal life
span) and the age at which exposure is
 initiated must be  considered.  Addition-
 ally, an'assumption must be made about
 the relative sensitivities of the experi-
mental animals and man to the carcino-
 gen in question. In the absence  of, data
 concerning the cnrcinogenicity of hep-
 tachlor epoxide to  man, we must assume
 that  the relative sensitivity of man to
 this  effect  is comparable or  possibly
 greater than that of  the  experimental
 animals unless  there is convincing evi-
dence otherwise.
  Thus  even though it Is Impossible, be-
cause of all of the unqtiantiflcd factors
discussed  above, to assign a numerical
probability to the risk that heptachlor
expoxlde may produce cancer In humans.
some generalized  conclusions are  pos-
sible. The presented evidence of measur-
able quantities entering man's body and
further being transferred to fetuses  In
the uterus, indicates that humans are
exposed to hcptachlor epoxide from the
moment of conception  on  throughout
life. Tills is sufficient basis for grave con-
cern for the possibility that humans, like
the experimental mice and rats, may re-
act to such exposure by producing malig-
nant  tumors.
 vn.  ECONOMIC IMPACTS OF CANCELLATION

   On the basis of  present Information,
national macroeconomlc effects from the
cancellation  of chlordane  and hepta-
chlor  are  estimated to be negligible.
Overall national production,  cost and
price effects will be minor for all uses.
However, some micro-economic effects  in
specific- regional and local areas  may
occur for corn, particularly on land sub-
ject to black cutworm infestation.  Some
mlcrocconomic effects are  possible for
citrus and  strawberry  uses.   Certain
specialty crops may also be  Impacted
but this will need  to be  assessed in the
hearing. For oil remaining uses including
hay and forage, tobacco, peanuts,  vege-
tables, livestock, soybeans, cotton,  pota-
toes,  grapes and other fruits and  vege-
tables, there is no Indication of signifi-
cant macro- or micro-economic impacts
or dislocations.
  VIII. BALANCE OF RISKS AND BENEFITS
   For the purposes of the following dis-
cussion, findings with regard to the risk
of heptachlor must apply to registered
chlordane products since chlordane  as
registered  and used always  Includes
heptachlor In substantial amounts.
   A discussion  of  the  risks associated
with a pesticide under question as posing
environmental or   human  health  con-
cerns must be based upon assessment  of
two interrelated factors: the toxlcologl-
cal characteristics of the compound, and
the availability of  the compound In en-
vironmental compartments  which  leads
to exposure of man or of other organ-
isms.  Neither factor taken alone is suf-
ficient to determine or estimate  total
risk. Evidence concerning risk will,  then,
be summarized in  two parts: First, the
effects of chlordane and heptachlor on
man or other organisms;  and second the
levels of exposure which have been found
to occur as a  consequence of the use  of
these two products.
   Concerning  toxicity, hcptachlor epox-
ide has been  demonstrated to be car-
cinogenic  in  two species of laboratory
animals: mice and ratr at levels as low as
10 ppm and 0.5 ppm respectively. In the
rat studies, several organs in addition  to
the liver, including the endocrine glands,
showed  increases   in   tumors.   Both
hcptachlor and  chlordane have  signifi-
cant toxicity for various species of  wild-
life, although it is  difficult to determine
what  Impact  these toxlcities have on
species populations, as opposed to  Indi-
vidual fish or wildlife or .specific  local
populations.
   With respect to exposure,  available
evidence Indicates  that both chlordane
and hcptachlor or their metabolites are
present  in  water,  dairy products, and
other  foods.  Man's exposure to these
compounds at significant levels Is demon-
strated by  residues present  in  human
milk, and the distribution of the com-
pounds throughout the  organs of still-
born fetuses. Analysis of autopsy and
biopsy samples shows  chlordane, hepta-
chlor,  nnd/or their metabolites  at sig-
nificant  levels in human adipose tissue,
further indicating intake and bioconcen-
tration by man.
   Available  evidence of the costs of dis-
continuing  the  use of heptachlor and
chlordane can be summarized as follows:
Economic costs of pest control may rise
but It is expected that the use of alterna-
tive means of pest control will allow con-
tinued control at costs which Indicate no
significant  adverse macroeconomio  ef-
fects. In certain geographical areas  or
for certain  crops, microeconomlc dislo-
cations at the fa cm or county level might
occur. The extent of this Impact, If any,
will need to be assessed  further in  the'
hearings.
            DC. CONCLOSIOW

   Weighing the risks  presented  by  the
continued use of hcptachlor and chlor-
dane against their benefits,  it appears
that they pose an unreasonable  risk to
man.  Although   these   rlsK-s   -cqulre
further definition, a notice of Intent to
cancel these products should be issued in
order that both the risk-! and the benefits
may be more fully developed through the'
public hearing process. Pvbltc hearings
should allow  all pertinent evidence  to
be brought  forth and  examined so that
a  fully  informed, Indepth  analysis  of
risks and benefits may be made, and ap-
propriate remedies fashioned. Remedies
to be considered at the hearings  should
Include strengthening use  restrictions,
should any be appropriate, as well as re-
moval of these products from the  market
for some or  t J uses.
  Because   heptachlor and   chlordane
have a very large number of uses, the
Agency reserves the opportunity  to pre-
sent evidence on any registered use af-
fected by this order regardless of whether
or not a hearing has been requested  on
that use, or whether or  not such use is
to be actively defended In the hearings.
  The only exceptions to the notice of in-
tent to cancel are the use of chlordane
and heptachlor for subsurface  ground
insertions for termite control and  for the
dipping of nonfood  plants. These uses
achieve  the  desired control  of  Insects
without apparent unreasonable environ-
mental contamination.
  A draft environmental Impact state-
ment concerning this  intent  to  cancel
certain products  containing  heptachlor
and chlordane Is being  prepared and will
be available  In approximately 60 days.
  An Order  concerning intrastate prod-
ucts containing hcptachlor and  chlor-
dane is also being Issued today.
  Dated: November 18, 1974.
                 RUSSELL E. TRAIN,
                      Administrator.
 JPB DOC.71-27M5 Piled 11-25-74:8:45 am)
                                                         -133-

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                     APPENDIX G
FEDERAL REGISTER NOTICE OF EPA ADMINISTRATOR'S INTENT
   TO SUSPEND CERTAIN REGISTERED USES OF CHLORDANE
                    AND HEPTACHLOR

                   August 15,  1975
                           -134-

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 34456
               NOTICES
 REGISTRATIONS OF PESTICIDES CON-
TAINING HEPTACHLOR OR CHLORDANE
  Intent To Suspend Findings of Imminent
                Hazard

  On November 18. 1971.1 determined
that the continued registration and use
of  pesticides containing hepUchlor  or
chlordane posed a substantial question of
safety and accordingly I Issued "Notice
of Intent to Cancel" such registrations
pursuant to Section 6(b) of the Federal
Insecticide,  Fungicide, and  Rodcnticlde
Act, as amended ("FIFRA"). New evi-
dence has recently come to my attention
which confirms and heightens the human
cancer hazard posed by these pesticides.
In addition it is now apparent that the
ongoing cancellation proceedings would
not be concluded in time to avert  sub-
stantlal additions of these persistent and
ubiquitous compounds to already serious •
human  and environmental  burdens. In
flew of these recent developments which
are discussed in greater detail below, I
find that continued use of  these pesti-
cides during the time required for com-
pletion  of the  cancellation  proceedings
would be likely to result in unreasonable
adverse effects on the environment. Ac-
cordingly, pursuant to  FIFRA  Section
699 Fed. Reg. 41298 (November 20. 1BT4).
For purposes of clarification, the result of a.
fins', order of suspension will be to prohibit
the  moBufactuie of heptachlor/chlordan*
pending completion of the cancellation pro-
ceedings for any  registered  use except for
subsurface ground Insertion for termite con-
trol  nnd the dipping of roots and  top* of
non-food plants. The permitted termite use •
was clarified bjr notlco published on July 21,
»«15 (40 Feo.. Rrg. 3063?).
  data from  human  milk monitoring
studies showing that heptachlor epoxide
is present in a substantial percentage of
mothers'  mDk at levels ranging  from
trace amounts to 0.49 ppm;
  data from  human  food monitoring
studies showing that heptachlor epoxide
is commonly found in the dairy, meat,
nah and poultry components of the hu-
man diet at levels ranging from 0.001 to
0.03 ppm;
  data from  two test animal feeding
studies showing that heptachlor  and
heptachlor epoxide caused  cancer  and
the conclusion  of the Carclnogenicity
Panel of the HEW Secretary's Commis-
sion on Pesticides and their Relationship
to  Environmental Health  that hepta-
chlor epoxide was "positive for tumor in-
duction"; and
  data from nationwide residue monitor-
ing studies indicating that heptachlor
and chlordane are highly persistent, lipld
soluble and ubiquitous.
  Additional Cancer Evidence. Since the
issuance of the cancellation notice in
November, 1974, I have received addi-
tional evidence which confirms the can-
cer hazard posed by these chemicals.
  First,  additional  expert  pathologists
have reviewed both of the 1659 and the
1965 test animal feeding studies referred
to in the cancellation notice. Their re--
views support and strengthen the finding
that these two studies demonstrate the
carcinogenicity of heptachlor and hepta-
chlor epoxide.
  Second, new evidence of the results of •
additional 1973  test animal  feeding
studies conducted for Velsicol Chemical
Corporation with heptachlor and chlor-
dane have been submitted to EPA.' The
heptachlor study .reported a statistically
significant Increase of hyperplastic nod-
ules in exposed animals with relatively
few carcinomas. This result is itself in-
dicative  of carcinogenic action. In  re-
cent months, independent review of se-
lected heptachlor and heptachlor epoxide
tissue slides from this study by EPA con-
sultant pathologists  found substantial
numbers of carcinomas. The analysis of
the EPA consultant pathologist who re-
viewed all of the more than 650 hepta-
chlor  and  heptachlor epoxide  tissue
slides found1 statistically significant  in-
creases in carcinomas of exposed ani-
mals over controls. In addition, a review
of  the animal  tissues  by  pathologists
consulted by Velsicol which has recently
been brought to my attention found that
substantial numbers of let Ions originally
reported  as hyperplastic nodules  were
carcinomas.
  The chlordane study reported a sta-
tistically significant increase in hyper-
plastic nodules and a substantial increase
in  carcinomas.  Independent statistical •
analysis  by EPA consultants  demon-
strates that at  one fcccUni; level (25 ppm)
male -nice exhibited statistically signifi-
cant  increases  in  carcinomas.  Inde-.
pendent review of selected slides by the
                                        EPA consultant pathologists also found
                                        substantial numbers of  carcinomas.  A
                                        review of virtually all of the chlordane
                                        test slides by an EPA consultant patholo-
                                        gist demonstrated statistically significant
                                        increases in  carcinomas of exposed ani-
                                        mals over controls in both sexes at two
                                        feeding levels (25 ppm and 50 ppm). Se-
                                        lected tissue review by the Velsicol con-
                                        sultants also found substantial numbers
                                        of  carcinomas in  animals exposed to
                                        chlordane.'
                                         Third,  human adipose tissue  studies
                                        for  FY 1973 have  now  been completed
                                        and confirm the residues discovered in
                                        prior years samplings, finding heptachlor
                                        epoxide in 97.71%  and oxychlordane in
                                        98.35% of the people sampled. Similarly,
                                        whereas the  cancellation notice referred
                                        to a 1972 human milk study which found
                                      ^heptachlor epoxide residues in mothers'
                                        milk, new evidence from an EPA survey
                                        Shows heptachlor  epoxide  residues in
                                        35.09% and  oxychlordane  residues in
                                        45.61% of human milk samples taken.
                                         Fourth, it  is now anticipated that the
                                        cancellation  hearing could  require as
                                        much as 18 months of additional litiga-
                                        tion  before  a final  decision  could be
                                        reached. During that period more than
                                        38 million pounds of tecnnJcat hepiaculor
                                        and chlordane are likely to be released
                                        into the environment thnvjgh uses con-
                                        tested in the cancellation proceeding.
                                         In view of  the mounting evidence that
                                        these compounds cause cancer  and in
                                        view of the large quantity which will be
                                        added to human and environmental bur-
                                        dens in the interim, I find that the con-
                                        tinued registration of the contested user
                                        of  heptachlor and chlordane pending
                                        completion of the cancellation proceed-
                                        ing  poses an unreasonable risk  to the
                                        American people and thus constitutes an
                                        "imminent hazard" under Sections 6(c>
                                        and 2(e) of FIFRA.
                                         Legal  Authority.  Section   6(b)  of
                                        FIFRA authorizes the Administrator to
                                        issue notice of intent to cancel if it ap-
                                        pears to him "that a pesticide or its label-
                                        ing . .. does  not comply with the provi-
                                        sions of this Act or, when used in accord-
                                        ance with widespread   and  commonly
                                        recognized practice, generally causes un-
                                        reasonable adverse effects on  the envi-
                                        ronment ...." The phrase "unreasonable
                                        adverse effects on  the environment" is
                                       defined by FIFRA Section 2(bb) to mean
                                        "any unreasonable risk to man or the en-
                                       vironment, taking into account the eco-
                                       nomic, social and  environmc'ntnl  costs
                                        and benefits of the use of any pesticide."
                                         In  accordance  with   FIFRA  section
                                       6(c), where the Administrator finds that
                                        "action is necessary to prevent an im-
                                       minent hazard during the time required
                                       for cancellation . . ." lie may by order
                                       suspend the registration  after providing
                                       an opportunity for an expedited hearing
  •Technical chlordane contain* approxi-
mately 7% ueptachlor and technical bepta-
cnlor  contains  approximately 20% of the
gamma Isomcr of chlordane.
  'A preliminary report of the analysis of
test animal feeding studies conducted for the
National Cancer Institute further Indicates
that corclnogonlclty of heptachlor and chlor-
dane. since the final report of the analysis
of tills study has not been tamed, however,
my decision  to  suspend  heptachlor  and
ehlordano registrations docs cot rely on ;hl»
study.
                                                           -135-

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                                                     NOTICES
                                                                        SM57
 on the question of "whether an imminent
 hazard exists." The terra "imminent haz-
 ard" Is defined by FIFIU. section 2(1)
 to mean a "situation which exists when
 the continued use of a pesticide during
 the time required for cancellation pro-
 ceedlne would be likely  to result in un-
 reasonable adverse effects on the envi-
 ronment or  will involve  unreasonable
 hazard to the survival of  a species de-
 clared endangered by the Secretary of
 Interior under Public Law  91-135."
   The courts have repeatedly "cautioned
 that the term 'imminent hazard' is not
 limited to a concept of crisis: 'It is enough
 II there Is substantial likelihood that se-
 rious  harm  will  be experienced during
 the year or two required in any realistic
 projection ot the administrative  [cancel-
 lation! process.'" Environmental Defense
•Fund, Inc. v. Environmental Protection
 'Agency, 6.10  F. 2d 1292,  1297 (D.C. Cir.
 1975)  (emphasis  in  original),  quoting
 from .Environmental Defense Fund. Inc.
 v. Environmental Protection Agency, 465
 F. 3d 928.540 (D.C. Cir. 1972). Of course,
 as In the  cancellation proceeding, the
 Administrator does not have the burden
 of proving that  a pesticide is unsafe
 since  the  statute and case law  place
 "(tine burden ot establishing the safety
 Of * product requisite for compliance
 with the labeling requirements ...  at
 all times on the  applicant  and regis-
 trant." BDF  v. EPA, 510 P. 2d at 1297;
 EOF v. EPA,  465 F. 2d at 540.
  The courts have consistently held that
 "the function of the suspension  decision
 is to make a preliminary assessment of
 evidence and probabilities, not  an ulti-
 mate resolution of difficult  issues. We
 cannot accept the proposition .  . .  that
 the Administrator's findings [are] insuf-
 ficient because controverted by respecta-
 ble scientific authority.  It  (is!  enough
 that the administrative  record  contain
 respectable scientific authority support-
 ing the Administrator." EOF v. EPA, 510
 F. 2d>t 1298; EOF v. EPA. 465 F. 2d at
 537.
  As I have repeatedly stated,' after ex-
 tensive EPA experience in evaluating the
 cancer hazard of  pesticides, we do not
 begin our evaluation of the cancer threat
 of heptachlor/chlordane in  a vacuum. In
 my pi'jr orders relating to DDT and Al-
 drin/Pleldrin, and in the Preamble to the
 FIFRA registration regulations, I have
 get forth the basis for evaluating  the car-
 cinogenictty of pesticides which I am ap-
 plying in evaluating the cancer hazard
 posed by the use of heptachlor and chlor-
 dane for purposes of this suspension no-
 tice and which shall be applied to evalu-
 ate that hazard in an expedited suspen-
 sion hearing, if a hearing is requested.
  'See Opinion of the Administrator, Envi-
ronmental Protection Agency, on the Sus-
pension or Aldrln-Dlcldrin. 39 Fed. Reg. 37205
(October IB, 1974); State of Louisiana Ee-
qf.Mt tor Emergency Use or DDT on Cotton,
Statement of Reasons for Denial mid Sup-
plemental Statement of IKMWOIIS for Denial,
40 Fed. Reg. 1034, 15949 (April 8, 1076); Pre-
amble to Subpart A—Registration, Heregls-
tratlon and Classification Procedure)*, 40 Fed.
Reg. 28343. 38263  (July 3, 1676).
This basis for evaluation can be  sum-
marized as follows:
  The use of animal test data to evaluate
human cancer risks has been widely ac-
cepted by the scientific community and
by public policy-making agencies.  Such
data are particularly appropriate because
the relatively short life span of test ani-
mals  allows for testing for  the  entire
latency period  for  tumor  development
and  because  of  our relatively well-de-
veloped understanding of the pathologi-
cal development of  tumors in mice and
rats. When compared to the millions of
people who may be exposed to a pesti-
cide, the number of animals used in tests
to evaluate oncogenlcity is extremely
small. The variability of human response
to carcinogens is generally greater than
that of the test animals. Lpidemiological
cancer data are desirable, but because of
the long  latency period of tumor induc-
tion  in humans, because of  trequ.-.itly
encountered widespread contamination
which makes it impossible to establish an
uncontamlnated control  group and be-
cause of  the obvious ethical and  legal
problems associated with conducting can-
cer research on humans, reliable cpide-
miological data are rarely available. Ac-
cordingly a positive oncogenic effect in
test animals is sufficient to characterize
a pesticide as posing a cancer risk to
man. By the same reasoning, negative re-
sults from oncogenic animal  tests  have
only limited  significance. The  number
and  sensitivity of  the test  animals as
compared to the general human popula-
tion  are  the  principal reasons for this
limited utility. Because of these inherent
limitations of animal testing a pesticide
that induces tumors in experimental ani-
mals at any dose level must be considered
to be a carcinogen. As noted above, nega-
tive  results are  of  limited value  since
they do not rule out the possibility that
the chemical  will induce tumors in test
animals if, for example, the number of
exposed animals or  the length of expo-
sure were increased. Although a no-effect
level may theoretically exist for carcino-
gens, as yet there is no scientific  basis
for establishing such a level. Thus, hu-
man exposure to a  carcinogen at levels
below those which induced positive ef-
fects must be considered to present  a
cancer risk. Finally, although the dis-
tinction between "benign" and "malig-
nant" tumors is of primary importance to
the individual, it is not a meaningful dis-
tinction in determining the cancer haz-
ard to man on the basis of  tests  con-
ducted on laboratory animals. Given the
increasing evidence  that many "benign"
tumors can develop into cancers, /or pur-
poses of determining whether a pesticide
poses a cancer hazard  to man on the
basis of  laboratory  experiments, the
terms "benign" and "malignant" should
be considered synonymous.
  With respect to the benefits of con-
tinued use of a pesticide subject  to  a
notice  of  intent to  suspend,  the courts
have ruled that because of the expedited
and provisional natuie of the suspension
process it is not necessary  to explore
all or the available information on alter-
native pest control methods to the *ame
degree as  in a cancellation  proceeding.
Although consideration of such alterna-
tive methods will be undertaken  in the
suspension process, the responsibility  to
demonstrate that the  benefits of con-
tinued registration during the cancella-
tion proceeding  outweigh the risks  is
upon the proponents of continued regis-
tration.
  Some uncertainty has arisen concern-
ing the Agency's burden of going forward
with evidence  of alternative means  of
pest control in its affirmative case. In the
Opinion  of the Administrator with re-
spect to Stevens Industries, Inc. (.31 F.R.
13369) reference was made to the bur-
den of the respondent to show "the avail-
ability of a registered chemical or other
means of  control  which  this Agency's
Pesticides  Office  is prepared  to recom-
mend  as  a  substitute. . .  ."  37 F.R.
13372.  It was not intended by that state-
ment,  nor does  the  applicable law re-
quire,  that the Agency  staff—as part  of
its affirmative case—offer such an Agency
"recommendation" or  that  it provide
evidence that alternatives which are reg-
istered for the uses in  question are ac-
tually  obtainable, efiicacious or available
at reasonable prices, it is sufficient for
purposes  of  its  presentation  that the
Agency staff present evidence that alter-
natives are registered  for the uses  .n
question. This may be  i.^complished by
an  affidavit by  the appropriate official
certifying  that  the substances  listed
therein are registered for the uses in-
dicated.  The burden "of  demonstrating
that any alternatives established  bv re-
spondent in this fashion are not actually
obtainable, are not efficacious or are not
available at reasonable prices remains on
the proponents of contained registration
of the pesticides  under  review in a can-
cellation or suspension  proceeding.
  Finally, the Court of Appeals has held
that the Agency is under a heavy burden
to justify any decision that the benefits
outweigh the risks with  respect  to  a,
chemical known to produce cancer in ex-
perimental animals.
  Findings of Imminent Hazard. On the
basis of the date before me at the tune
of my  November. 1974  cancellation no-
tice and the  additional data which has
been brought to my attention m the in-
tervening  nine  months,  pursuant  to
FIFRA Section 6(c) (1) I make the fol-
lowing findings  as to imminent hazard
which  shall constitute  the issues to be
adjudicated at a suspension hearing.  If
such a hearing is requested:
  1. Virtually every person in the United
States has residues of heptachlor epox-
ide  and   oxychlordane—the  principal
metabolites of neptachlor and  chlor-
danc—in  his body tissues.-Analysis of
human tissue samples by  the EPA  Na-
tional   Human  Monitoring  Program
shows  that during FY  1970. 1071, 1912
and 1973 hcjitachlor epoxidc was pres-
ent in  human aUipose tissue at quantifi-
able levels In 90.29% to 97.11%  of nil
the people tested. During each of these
years the arithmetic mean of the concen-
tration of heptachlor epoxkle in human
                                                             -136-

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  7JM38
               NOTICES
  tissues ranged from 0.12 to 0.17 ppm and
  the highest concentration was 10.62 ppm.
  Oxychlordane. which was first included
  In the EPA Human Monitoring Program
  In FY 71, was present m FY 1872 and
  1973  human adipo&e tissue samples at
  quantifiable levels in 92.33% to  98.35%
  of all the people tested. During each of
  these years  the arithmetic mean of the
  concentration of oxychlordane in human
  tissues was  0.15 ppm and the  highest
  concentration was 1.87 ppm.
   2. Data from human stillborn moni-
  toring studies show  that heptachlor
  epoxide crosses the placenta! barrier and
  enters the human fetus.  The stillborn
  study found that heptachlor epoxide resi-
'  dues were present in 4 out of 10 adipose
  tissue samples in amounts ranging  from
  0.07 to 0.51 ppm. In addition, heptachlor
 epoxide residues  were detected  in the
 brain, adrenals, heart, lungs, liver, kid-
 ney  and  spleen.  The  concentrations
 ranged as high as 1.56 ppm in the heart
 and 1.67 ppm in the liver. Of 30 live term
 babies examined, 90%  had heptachlor
 epoxide residues in their cord blood in
 amounts  ranging  from 0.0002 to 0.0043
 ppm.   '
   3.  Recently obtained data  demon-
 strates that 35.09% of human mothers'
 milk sampled contains quantifiable resi-
  dues  of  heptachlor  epoxide and  that
 45.16% of mothers' milk sampled  con- *
 tains  quantifiable residues of oxychlor-
 dane.
   4. For the most recent reporting pe-
 riod of FY 1974. the Food and Drug Ad-
 ministration, in its market bas'.et sur-
 vey, reports that measurable amounts of
 heptachlor. heptachlor epoxide or chlor-
 dane were found in composite samples of
 73 percent of all dairy products  and 77
 percent of all meat,  fish,  and  poultry
 samples.  Residues of these  chemicals
 have consistently been detected through-
 out the preceding ten years in  dairy
 products and meat, fish and poultry. Dur-
 ing the ten f.-scal years from 14)65 to 1974.
 residues of these  three chemicals  have
 been detected in all  of  the twelve food
 composite categories.
   5. Approximately 50% of vhe  hepta-
 chlcr/chlordane  used  under contested
 registrations is applied  for home,  lawn
 and garden purposes as well as commer-
 cial turf. These uses accounted for  more
 tha • 7,500,000 pounds of technical ehlor-
 dane in 1974. Use of this chemical under
  these conditions presents special prob-
 lems of human exposure. These applica-
 tions  are in and around the home and
  thus arc generally in much closer proxi-
 mity  to  the general  population  than
 agricultural  uses.  Similarly, many of
  these applications are carried out by in-
  dividual homeowners who may  expose
  themselves,  their family members and
  their  neighbors by direct contact  with
  the skin, by inhalation, by contamina-
  tion of clothing as well as by ingestion.
  In addition, many of  these uses  around
  the home appear to result in residues in
  urban and suburban soils. Soil monitor-
  Ing studies of urban and suburban  areas
  show that residues of  chlordane  were
 detected  in the  soils of all 37  cities
sampled between fiscal year*  1969 and
1974.  For  many cities chtord&ne  wa§
detected in approximately 20% to 40%
of the samples.  Residues  of het>tach)or
epoxide were detected in the soils of 28
of the  cities  sampled  and heptachlor
residues were detected in  the soils of 13
of .the cities  sampled.  In several cities
heptachlor epoxide residues were present
in 10%  to 20% of the soil samples. Com-'
mon experience  demonstrates that con-
taminated soil and turf around the home
may present  special hazards to family
members through transport by pets and
direct contact—this hazard would appear
to be particularly alarming in' the case
of young children.
  6. Heptachlor  epoxide has been found
to  produce  significant  increases  in
tumors in a 1965 mouse experiment con-
ducted by FDA,  Based upon data  from
this   experiment  the   Carcinogenicity
Panel of HEW Secretary's Commission
on Pesticides and Their Relationship to
Environment Health found heptachlor
epoxide to be "positive for tumor in^uc-
tlon." Independent review  of this exweri-
ment by EPA consultants has shown that
there was a statistically significant in-
crease in carcinomas in animals led both
heptachlor and heptaclilor epoxide. Sta-
tistical review of a 1959 experiment test-
ing heptachlor epaxide in rats has shown
that tms compound also >yioCu.:e£ si;n:a-
cant increases  in tumors. Histological
review bj  EPA  consultants has shown
that the treated animals in this experi-
ment had substantial increases in carci-
nomas.
  As  noted  above, recent  data  from
mouse experiments conducted for Velsi-
col Chemical  Corporation have shown
that heptachlor  and heptachlor epoxide
significantly increased  the incidence of
hypcrplastic  nodules  in  treated mice.
Although this finding itself is indicative
of carcinogenesis, review  of these data
by  pathology   consultants  for  both
Velsicol and EPA has shown that sub-
stantial numbers of these lesions  were
carcinomas.  These same experiments
have  shown  a  significant increase in
tumors and hyperplastic nodules for ani-
mals fed chlordane. Review of the chlor-
dane data by consultants for Velsicol and
EPA has revealed that substantial num-
bers of lesions  originally diagnosed as
nodules were carcinomas.
  7. Based upon estimated production
figures  supplied  by Velsicol  Chemical
Corporation for the last 6 months of 1975,
a total of more than 38 million pounds of
heptachlor and  chlordane intended for
domestic use under contested  registra-
tions are likely to M produced during the
18 months refiuireu to conclude the can-
cellation hearings. The 18 month pro-
duction of heptachlor for  contested uses
is estimated  to  be  almost 10  million
pounds  while chlordane production for
contested uses is estimated to exceed 28
million  pounds.
  8. Finally, although heptachlor/cWor-
dane  are widely used  as insecticides,
the major agricultural use of heptachlor
and chlordane is on corn, with  over 70%
of the agricultural use  being devoted to
use on corn. According to statistics of the
 United  States Department of  Agricul-
 ture,  the maximum  estimated  loss to
 corn  production from  cancellation of
 hepUchlor/chlordane and aldrin/diel-
 drin  taking  into  account  numerous
 registered  alternative pesticides  would
 be approximately 0.4%  of the nation's
 1973 total  corn  production. The USDA
. forecast of  a .bumper corn harvest for
 1975 demonstrates that even for the cur-
 rent crop year total losses would not ex-
 ceed approximately 0.4%. Although a few
 individual corn growers may experience
 some  losses  in production if heptachlor/
 chlordane are not available .these poten-
 tial losses should not  be w.Jespread and
 in view of the serious risks certainly da
 not justify continued  use.
   Additional agricultural uses of hepta-
 chlor/chlordane are  small and varied.
 Alternative  pesticides are registered lor
 almost all of these  uses and in the few
 instances where no alternative is pres-
 ently  registered, the'-e has been no indi-
 cation that  serious <\op losses would oc-
 cur pending completion of the cancella-
 tion process. Similarly, although we are
 also sensitive to the needs of homeown-
 ers who use chlordane, there  is a wide
 selection of registered alternative pesti-
 cides  to replace the  numerous  uses of
 chlordane in and around the home.
     *       •       •      •      •
   Although we  cannot  determine pre-
 cisely the magnitude of  the human can-
 cer risk as a result «f the past and con-
 tinuing   exposure   to heptauhlor  and
 chlordane, I have found that these com-
 pounds  cause cancer  in laboratory ani-
 mals and that laboratory tests are reli-
 able indications of the human cancer
 hazard. In addition, although any single
 component of human exposure— .'jcn. as
 intake  through  poultry—may  not  ap-
 pear to be  significant, it alone poses a
 cancer  hazard to certain  of  the more
 susceptible individuals and together with
 the sevei • 1  other components of human
 exposure presents a serious human can-
 cer threat. This threat is made even more
 alarming by evidence that human ex-
 posure begins in the mother's v.-omb and
 continues without interruption through-
 out  life. In  addition,  because these
 •chemicals  are  ubiquitous,  the  major
 souces of human  exposure are largely
 unavoidable by  individual action.
   I have invoked the "Special P.u'e" pro-
 vision  of section  15(b)(2) permitting
 continued use of those existing stocks of
 EPA  registered  pesticides containing
 heptachlor or chlordane which have been
 formulated as of the date of this notice.
 It seems clear considering the use pat-
 terns  of heptachlor and chlordane  that
 there would be no stocks realistically re-
 trievable following  a  suspension  notice.
 The major use, home, lawn :md garden,
 which constitutes more than 40% of the
 uses covered by  this notice, is  a nation-
 wide  use made  available to the  home-
 owner through  a  complex distribution
 nctworl. It would not  be feasible to mon-
 itor such a network and to retrieve such
 stocks. Any such stocks  arc probably al-
 ready in the hands of homeowners and
 other users or  local  retail stores1  and
 their  Immediate distributors.  In addi-
                                                       -137-

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,  34459                                              NOTICES

 tlon, use under corn, which constitutes
 more than 35% of the contested  uses,
 has already  occurred and  thus there
 should not be substantial existing stocks
 for that purpose.
  'Dated: July 29,1975.
                 RUSSELL E. TRAIN,
                      Atlminis' ator.
  |PRDoc.76-3H66 FiledB-l*-75;8:45 «m]
                                                          -138-

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   EPA ACTIONS TO CANCEL AND SUSPEND USES
 OF CHLORDANE AND HEPTACHLOR AS PESTICIDES:
      ECONOMIC TESTIMONY PRESENTED BY
EPA AT CHLORDANE/HEPTACHLOR SUSPENSION HEARING
                   PART II
               September 1975
                    -139-

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                              TABLE OF CONTENTS
                                   PART II

                   ECONOMIC TESTIMONY PRESENTED BY EPA AT
                   CHLORDANE/HEPTACHLOR SUSPENSION HEARING
                                                                           Page

Direct Economic Testimony 	   144

Exhibits	187
                                   -141-

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                              List of Exhibits
EXHIBIT A

EXHIBIT B


EXHIBIT C


EXHIBIT D

EXHIBIT E


EXHIBIT F

EXHIBIT G


EXHIBIT H


EXHIBIT I
EXHIBIT J


EXHIBIT K


EXHIBIT L



EXHIBIT M


EXHIBIT N


EXHIBIT 0


EXHIBIT P
                                                           Page

Letter:  SELLERS, CONNER & CUNEO 	   187

TABLE I:  Production and Destination of 25 Selected
          Pesticides (million pounds active ingredient).  .   189

Agricultural Use of Chlordane by Type of Use,  U.S.,
1964, 1966 and 1971 (active ingredient basis)	193

Chlordane Use on Crops, U.S., 1966,  1971	194

Agricultural Use of Heptachlor by Type of Use, U.S.,
1964, 1966 and 1971 (active ingredient basis)	195

Heptachlor Use on Crops, U.S., 1964, 1966, 1971	196

Summary of EPA Registered Insecticides for Corn Insects
Pests and 1975 State Recommendations for Corn	197
Detailed Data on Use of Chlrodane/Heptachlor and Other
Insecticides on Corn, 1973, 1974,  and 1975 	
202
Number of Corn Farms Reporting Cutworms as a Major
Problem on Farm, Number Treating for Problem and
Percent Treating in Major Corn States and U.S.,  Low,
High and Average Years, 1969-1975	
                                                                          208
Insecticide Costs for Typical  Corn Soil  Pest
Application in Midwest, 1974	209

Review of USDA Studies on Impacts of Cancellation/
Suspension of Chlordane/Heptachlor Use on Corn	210

Review of Data on Yield Performance of Chlordane/
Heptachlor and Other Insecticides in Control of Corn
Rootworms, Wireworms, and Cutworms 	   213

Detailed Information on Linear Programming Analysis of
Organochlorine Suspension of Corn Use in United States .  .   227

Economic Impact of Chlordane/Heptachlor Suspension on
Citrus Production	269

Insecticide Recommendations of Surveyed States for
Potato Pests, 1975	275

Economic Impact of the Removal of Heptachlor as a
Seed Treatment	276
                                   -142-

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EXHIBIT Q     Insecticide Recommendations of Surveyed States
              for Strawberry Pests, 1975	291

EXHIBIT R     Insecticide Recommendations of Surveyed States for	
              Tomato Pests, 1975	292

EXHIBIT S     Economic Impact of Shifting to Chlordane/Heptachlor
              Alternatives on Lawn and Turf	293

EXHIBIT T     Insecticide Recommendations of Surveyed States
              for Home and Garden Pests, 1975	308

              Tables 1-7:   Tables with Chlordane Recommendations 	   309
              Tables 8-13:  Tables with No Chlordane
                              Recommendations 	   317

EXHIBIT U     Economic Analysis of Cancelling Chlordane and
              Heptachlor for Ornamental Plants in Commercial
              Nurseries	326

EXHIBIT V     Survey of Producers of Major Substitutes for
              Chlordane/Heptachlor	341

EXHIBIT W     Review of the Supply of Substitutes to Chlordane
              and Heptachlor Under Substitute Chemicals Program 	   351

EXHIBIT X     Assumptions Used in Computation of Energy Impacts of
              Manufacturing Alternatives to Chlordane and
              Heptachlor	353
                                     -143-

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 STATEMENT FOR TESTIMONY AT CHLORDANE/HEPTACHLOR
               SUSPENSION HEARING
                 September, 1975
Requested by the Environmental  Protection Agency
              Dr. Arnold L. Aspelin
         Chief, Economic Analysis Branch
        Criteria and Evaluation Division
        Office of Pesticide Programs, EPA
             Washington, D.C.  20460
                      -144-

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                      CERTIFICATE OF SERVICE

     I certify that I have this day supervised the  filing

of one copy of the attached "Statement of  Arnold  L. Aspelin

to the Hearing Clerk, U. S. Environmental  Protection Agency,

and. I have also supervised hand delivery of copies  of the

attached to:

         Robert Weinberg, Esq.
         Williams, Connolly & Califano
         839 17th Street, N. W.
         Washington, D. C.

         Robert L. Ackerly, Esq.
         Sellers, Conner and Cuneo
         1625 K Street, N. W.
         Washington, D. C. 20006

         Alfred R. Molting, Esq.
         Counsel for the Secretary of
            Agriculture
         Room 2042-A, South Building
         14th & Independence Avenue, S. W.
         Washington, D. C. 20250

         Jacqueline M. Warren, Esq.
         Environmental Defense Fund
         1525 Eighteenth Street, N. W.
         Washington, D. C. 20036
                              Lee Charles Srhroer
Dated:  September 12, 1975
                            -145-

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               GENERAL USE PATTERNS OF CHLORDANE AND HEPTACHLOR


                                   Chlordane


     Chlordane is a commonly used insecticide in agriculture, industry, and

the home, lawn and garden.  About 21 million pounds were used in the United

States during 1974.

     Data provided by Velsicol Chemical Corporation (Exhibit A) indicate the

following approximate breakdown for chlordane use in 1973 and 1974:

                                Million
                                Pounds                       Percent
     Use                    1973     1974                  1973   1974

     Corn                   1.94     4.32                 10.8    20.4
     Potatoes               0.98     1.11                  5.5     5.2
     Other vegetables       0.06     0.07                  0.3     0.3
     Home lawn and garden   5.77     6.33                 32.1    29.9
     Turf                   1.14     1.25                  6.3     5.9

     Strawberries           0.15     0.17                  0.8     0.8
     Tomatoes               0.30     0.33                  1.7     1.6
     Ornamentals            0.23     0.25                  1.3     1.2
     PCO                    7.41     7.34                 41.2    34.7

     Total                 17.98    21.18                100.0   100.0
     The proposed suspension would cover about two-thirds of total chlordane

use (65.3 percent in 1974), not counting some pest control operator (PCO) use

which might also be included.
                                    -146-

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     Chlordane is a leading insecticide in the United States, although it

accounts for less than 6% of total U.S. insecticide use.  It is widely used

in the home and garden and industrial/commercial use areas,  where in 1972 it

ranked number 1 in each use with about 23% and 30% of U.S.  use in those

respective categories as indicated below:


                          	 Amount Used


                          All
Use



Agriculture

Home and garden

Governmental

Industrial/commercial

Overall

(Based on MRI/RvR report for CEQ and EPA, EPA 540/1-74-001,  1974 — Exhibit B) .

     Comparable data on the ranking and relative importance of chlordane in

major insecticide use categories are not available for a more recent year than

1972.  Patterns are not likely to be vastly different now.
All
insecticides
Million
Pounds
218.9
21.8
7.0
21.5
269.2

Chlordane
Million



Chlordane
rank

Pounds Percent
3.0
5.0
0.5
6.5
15.0
1.4
22.9
7.1
30.2
5.5
9
1 (tie)
4
1
5
                                      -147-

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     According to USDA surveys,  crop uses account for 70% to 85% of agricultural




use of chlordane in the United States and protection of corn from attack by soil




insects accounts for more than one half of agricultural use (Exhibits C and D).




There is no trend shown in the USDA surveys as to changes in percentage break-




down among general types of agricultural uses.  However, there appears to be a




trend toward increased use of chlordane in agriculture generally, inasmuch as




the 1971 use level of nearly 1.9 million pounds was more than three times that




for 1964 and 1966, and more recent estimates by Velsicol indicate that




approximately 6 million pounds were used in agriculture during 1974.  The




suspension of aldrin/dieldrin will increase demand for chlordane, along with




other substitutes, leading to increased production and use of chlordane




beginning in 1975 or 1976.




     Numerous other crop uses have been identified in USDA surveys (Exhibit D).




The extent of these uses varies considerably according to available estimates.




     Government agencies use significant amounts of chlordane.  Annual use of




chlordane has been estimated at 0.5 million pounds for Federal, state and




municipal agencies (MRI/RvR report for CEQ and EPA, EPA 540/1-74-001, 1974 -




Exhibit B).
                                      -148-

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Million
Pounds
1973
1.13
0.19
0.61
0.032
1974
1.19
0.27
0.55
0.04
Percent
1973
57.4
9.6
31.0
1.6
1974
58.0
13.2
26.8
2.0
                                  Heptachlor


     Heptachlor is used in a much smaller volume than chlordane (about 2

million pounds in 1974 compared with 21 million for chlordane) and is used in

fewer types of applications.  Data provided by Velsicol Chemical Corporation

(Exhibit A) indicate the following approximate breakdown for use in 1973

and 1974:
     Use
                              /
     Corn
     Seed dressing
     PCO
     Fire ants, misc.

     Total                           1.97*    2.05     100.0*   100.0
     The "Fire ant, misc." category of use in the above table includes use

on pineapple, which is estimated at about 10,000 pounds annually (Exhibit A).

Velsicol Chemical Corporation also indicates that there may be several thousand

pounds of heptachlor used on citrus to replace suspended aldrin use in Florida.

     About three-fourths of heptachlor is devoted to agricultural use, and that

is largely for corn soil treatments (Exhibit A).   Corn accounted for 91 percent of

agricultural heptachlor use in 1971, according to USDA's survey  (Exhibits E and

F).  The remainder was divided among several other crop uses  (e.g., alfalfa,

other hay and pasture and vegetables).  Heptachlor is not used in connection

with livestock production as is chlordane (Exhibit E).  Agricultural use
*Do not add because of rounding
                                     -149-

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of heptachlor is largely in the Corn Belt states, with some use in the Lake




States and the Northern Plains, (USDA/ERS, Agricultural Economic Report No.




252).




     Heptachlor, with agricultural use of about 1.2 million pounds in the early




1970's, equals about 0.5% of U.S.  agricultural use of insecticides (more




than 200 million pounds as of 1972).  The PCO use estimate for 1974 of more




than 550,000 pounds (Exhibit A) equals less than 3% of U.S. industrial/




commercial use  (approximately 21.5 million pounds in 1972).
                                         -150-

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     ECONOMIC IMPACT OF SUSPENDING CHLOKDANE/HEPTACHLOR USE ON FIELD CORN






     This section will consider the impact of the proposed suspension of




chlordane/heptachlor use on field corn as follows:




     1.  Impacts during the year 1976 assuming the use of existing stocks as




         of July 29, 1975, would be authorized under a suspension.




     2.  Impacts during the first five years of suspended use on a projected




         typical-year basis, and on a worst-case basis, focus 1977.






Chlordane/Heptachlor Use Patterns




     Corn is subject to attack by a wide variety of insects including corn




rootworms, wireworms, and cutworms for which chlordane/heptachlor has often




been recommended in the past.  Chlordane and/or heptachlor have EPA regis-




trations for use against these pests (Exhibit G) and a number of other lesser




economic corn pests.  Chlordane and heptachlor are not generally recommended




for use against rootworms because resistance has developed.  These chemicals




are generally recommended by entomologists in the states for use against




wireworms and cutworms (Exhibit G).




     Chlordane and heptachlor together are used on about 2.6 million acres of




corn in the U.S. as of 1975 (3.5% of total corn acreage).  They are used on




about 27,000 farms equalling about 3% of commercial corn farms in the United




States.  A detailed summary of the use of chlordane, heptachlor and other




insecticides used on corn is presented in Exhibit H for 1973 and 1974 on the




average and for 1975 for the U.S. by state for the principal corn states.  A
                                       -151-

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review of these data indicates the following characteristics:




     1.  Chlordane is used on about 1.2 million acres of corn  equalling 1.6%




         of U.S. corn acreage and on about 12,000 farms equalling 1.3% of




         U.S.  commercial corn farms as of 1975.




     2.  Heptachlor is used on about 1.4 million acres of corn equalling




         1.9%  of U.S. corn acreage and on about 15,500 farms equalling 1.7%




         of U.S. commercial corn farms.




     3.  With  suspension of aldrin, its use has declined from  9.6% of U.S.




         commercial corn acreage in 1973/74 to 3.3% in 1975.  Chlordane use




         increased to some extent (from 1.3% to 1.6% of U.S. corn acreage




         in 1975) while heptachlor use increased somewhat more sharply,




         from  1.2% to 1.9% of U.S. corn acreage.




     4.  Total acreage of corn treated with insecticides in the United States




         declined from 27.9 million in 1973/74 to 26.2 million in 1975 even




         though commercial corn acreage in the U.S. increased  nearly 3 million




         acres.  This decline in insecticide use may be associated with the




         aldrin suspension as aldrin use has declined from near 7 million




         acres in 1973/74 to near 2.5 million acres in 1975.




     5.  Two-thirds of the corn grown in the United States is  not treated with




         any insecticide including both soil and foliar applications.




     6.  Most  corn farms do not use insecticides of any type in the production




         of corn (more than 75% in 1975).




     7.  Several organophosphate and carbamate alternatives to chlordane/




         heptachlor for control of corn soil insects are in widespread use in




         the United States as of 1975.  Alternatives for rootworms and
                                       -152-

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     wireworms are used much more frequently than for cutworms.  Diazinon,




     the only registered pre-emergence alternative for cutworms, is used




     on only 0.4 percent of corn acreage and rescue baits  are used on




     limited acreage.




 8.  The leading states in use of chlordane/heptachlor as of 1975 based




     on percentage of corn acreage treated with these chemicals were:




     Missouri, 12.1; Illinois, 6.6; Indiana, 6.2; Iowa, 4.2; Ohio, 3.4;




     and Minnesota, 0.8.




 9.  Aldrin was used quite heavily in several of the corn states in 1975




     (in terms of the percentage of corn acreage treated):  Missouri,




     17.9%; Indiana, 7.9%; Ohio, 7.2%; Illinois, 5.0%; and Iowa, 3.3%.




10.  Missouri is by far the heaviest user of organochlorines with 30%




     of commercial corn acreage so treated in 1975.  The next ranking




     state was far below (Indiana with 14.1%).




11.  The number of commercial corn farms in the United States dropped




     from nearly 970,000 in 1973/74 to slightly under 900,000 in 1975, even




     though total corn acreage increased by more than 2 million acres.




12.  Farms using insecticides are larger acreage corn farms than nonusers.




     This is true of organochlorines as well as other insecticides. These




     generalizations are evident as the percent of U.S. corn acreage




     treated by users exceeds the percent of U.S. corn farms accounted for




     by users.




13.  Corn insecticide expenditures totalled nearly $105.7 million in 1975,




     up considerably from $78.7 million in 1973/74.  Average expenditure




     per treatment acre was $4.04 in 1975 compared with $2.82 per acre
                               -153-

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in 1973/74.  Organochlorine treatments are less expensive than




organophosphate and carbamate insecticides (about $2.50 compared




with $3.50 to $5.00 per acre for alternatives).
                          -154-

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Dynamics of Cutworm Infestation and Control







     Cutworms are the primary corn soil insect pest for which chlordane and




heptachlor are recommended to maintain yields (Exhibit G).   They are seldom




recommended for rootworms.  For wireworms, many alternatives are recommended.




This section is a brief discussion of the nature of cutworm infestations




and alternative controls.




     Cutworm infestations in corn are highly variable from year to year.




Since 1969 the number of farms reporting cutworms as a major problem has varied




from 19,000 to 71,000 in the United States with an overall average of about




53,000 (Exhibit I).  This equals about 2% to 8% of U.S. corn farms.   The




percentage of these farms treated for cutworms during that period ranged from




52% to 71% with an overall average of 61%.  The number of farms treating during




1969 to 1975 averaged about 32,000 and ranged from 13,000 to 48,000 (Exhibit I).




     The sporadic nature of cutworm infestations in corn is somewhat more




pronounced at the state level as the range in the number of farms reporting




problems and/or treating may vary by a factor as high as 7 as indicated in




Exhibit I.




     The extreme variability in cutworm infestations frustrates attempts to




project economic thresholds for treatment.  It is extremely difficult to




determine in the Spring whether pre-plant treatment would be justified except




in high risk fields which have a history of cutworm problems.  Rescue bait and




spray treatments must be depended upon when there has been no pre-plant




treatment or pre-plant treatment has failed in the face of an outbreak.




     The limited prospect for the availability of pre-plant controls for




cutworm areas with the suspension of the major remaining organochlorines
                                     -155-

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increases the need for improved scouting techniques during the critical rela-




tively short period of time when corn is subject to cutworm damage after emer-




gence from the soil.  Scouting is useful even with pre-plant treatment because




such treatments at times fail.  Such scouting can be facilitated by programs




promoted by the extension service, industry and other organizations leading to




improved control of cutworms.  Research currently in progress should facilitate




improved determination of economic thresholds for pre-plant and rescue treat-




ments (EPA Soil Arthropod Project, Grant No. R802547, Dr. Mahlon Fairchild,




University of Missouri, Coordinator).




     Rescue treatments for cutworms such as Sevin (carbaryl) and Dylox (tri-




chlorfon) are in the same cost range as chlordane/heptachlor (Exhibit J).   These




rescue treatments are less expensive than broadcast aldrin or chlordane/hepta-




chlor treatment by $1 to $2 per acre.   Also, they are not applied unless needed,




which lowers costs to the farmer.  Scouting must be practiced in order to use




rescue treatments effectively.  Scouting costs should be nominal inasmuch as




scouting can, in many cases, be accomplished at little added cost in connection




with other field operations, such as cultivation and routine observation of




growing crops.




     Trained scouts working under a pest management project in Illinois in 1974




cost $0.55 per scouted acre for the season plus an additional $0.44 for computer




and other support, bringing total costs to $0.99 per acre (Report of Illinois




Custom Spray Operator Training School, 1975, pp. 33-38).  It is not clear what




costs would be if such programs reach full scale operation.  They could be below




      *.i the current pilot program.  The Illinois project is not intended to




grow into an operating program where costs of scouting are borne by the
                                     -156-

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extension service.  They will need to be borne by the grower, according to pre-




sent plans (Report of Illinoi Custom Spray Operator Training School, 1975, p. 38)







National Economic Effects of Suspension




     This section of my testimony summarizes the national economic effects of




the suspension on corn based on our recent studies on this matter together with




a brief review of earlier studies by USDA.







Earlier USDA Studies




     USDA economists have conducted separate analyses of the impacts of cancel-




ling chlordane and heptachlor use on corn.  The first of these studies to be




done was on chlordane (Economic Impact of Discontinuing Farm Use of Chlordane,




Report No. 231, August, 1972) which indicated that there would be no yield im-




pact from withdrawal of chlordane in the absence of replacement by other organo-




chlorines but that there would be some increase in cost on about 200 thousand




acres of corn in the United States.  These results must be updated as acreage




treated with chlordane has increased greatly and insecticide treatment costs




have changed since that study was conducted.




     Another USDA study evaluated the impact of shifting to alternatives to




haptachlor on 699 thousand acres for the year 1971 (Economic Impact of Discon-




tinuing Farm Uses of Heptachlor Report No. ERS - 509, January, 1973).  This




study indicated an increase in cost of $1.55 per acre for rootworms and $1.73




per acre for other soil insects giving a total cost impact of $1.1 million




dollars.  A yield reduction was projected to cause a reduction in U.S. corn




production of about 800,000 bushels equalling 0.014% of the U.S. total in 1971.
                                     -157-

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     Another USDA study was conducted on cancelling uses of soil insecticides on




corn in 1974 (Economic Impact of Discontinuing Aldrin Use in Corn Production,




Report No. ERS - 557, by Herman Delvo, June, 1974).  This study indicated that




production of corn on acreage treated with aldrin in 1971 would decline in a




range of 0 to 30 percent depending on whether or not alternatives were used and




depending on which pest, rootworms, wireworms or cutworms infested the aldrin




treated acreage.  Corn production was projected to decline by 21.1 million bushels




(0.4 percent) if no organochlorine alternatives were used and 55.1 million




bushels (0.8 percent) if no alternative controls were used on the aldrin treated




acreage in 1971.  Taking into account market price effects 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 ussed.  A more detailed




discussion of the results of these studies is presented in Exhibit K.
                                      -158-

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Economic Impacts of Suspension During
Five Year Period — Focus 1977
     The testimony in this section summarizes results of a linear programming

analysis of the U.S. agricultural sector focusing on the impacts of the

combined suspension of chlordane and heptachlor as well as aldrin for use on

corn during a five year period, typical year basis.  The year 1977 is selected

for purposes of presenting results of the analysis of impacts from the suspension

as representative of the first five years of such suspension.  The approach is

to evaluate impacts of the cancellation by comparing a base solution of

economic conditions in the agricultural sector for the year 1977 and a solution

with the suspension of the organochlorines with resulting impacts on acreage,

production and costs for seven crops (irrigated and dryland) (barley, corn,

cotton, soybeans, oats, sorghum, and wheat).  The model allocates acreage to

these crops in more than 120 regions in least-cost manner as operators employ

land in the use which yields the greatest return.  The evaluation of impacts

is made by comparing solutions with and without organochlorines being

available.

     Two evaluations were made with the use of the linear programming model:

     1.  Typical case — where estimates of yield loss are in line with

         average actual long-term benefits from use of organochlorines

         over a wide geographic area over a number of years.
                                     -159-

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     2.  Worst case — where yield reductions due to use of alternatives or no




         control are far in excess of long-term averages, but could happen in




         a given year if a number of factors work against yields in an atypical




         fashion.




     The rationale for development of these two sets of yield coefficients




is presented in Exhibit L.  The basic approach was to use Delvo's coeffi-




cients for the worst case analysis for a given year and to use adjusted




coefficients for the typical case analysis.  The adjustment was based on long-




term yield benefits associated with organochlorine control of corn soil




insects.  Delvo's estimates of impact on yield were supplemented by an additional




assumption that land infested with rootworms would generate 8% higher yields if




alternatives to organochlorines were used.   Delvo had assumed that no increase




in yield would occur, although he recognized the possibility that yields could




increase from the use of alternatives on rootworm infested land.




     A more detailed discussion of the linear programming model used in this




analysis is presented in Exhibit M.




     A summary of economic effects on key parameters as a result of the




suspension of chlordane/heptachlor use on corn is presented in Table 1 for the




typical and worst case solutions of the linear program and model.  The results




for the typical case solution indicate the projected effects on acres of corn




grown, total corn production, prices and other variables during the period




1975-1980 using 1977 as a typical representative year for that period.  These




results are those which could be expected on the average or in a typical year




during a five year period, as compared to those also presented in the table




which would be representative of an atypical worst case year only.
                                     -160-

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     Although the same basic model was used to generate the results for both




cases, it is inappropriate to assume that worst case impacts would occur on a




regular basis.  In that instance, worst case would imply moderate to heavy




infestation conditions throughout all corn producing states, failure of alter-




natives to control wireworm and cutworm pests, all of which are not likely




to happen simultaneously in a given year or regularly during a five year




period.  Accordingly, my judgment is that the typical case outcomes indicated




in Table 1 are reflective of the future on the average, whereas we should be




mindful that in an individual year the worst case outcome could occur.




     The key results in the analysis in the typical-year case are a slight




increase in U.S. corn production (200,000 bushels) which is statistically




insignificant; and an increase in acreage required to produce corn to meet




domestic and export demands equalling 88,000 acres (which is also statistically




insignificant on a nationwide basis).  The change in total cropland for the




seven major crops in the model was also slight (36,000 acres).  Price




impacts were modes, ranging from -.17% for soybeans and -.16% for wheat to




+.14% for corn, which are very nominal in terms of typical year to year vari-




ations.  Corn prices often move as much as 25% in a year due to weather and




normal market factors.




     The typical case solution indicates a modest increase in returns to land




(which is a proxy for profit to landowners growing the seven crops included in




the model) ($3.1 million or 0.01%).  However, the corn sector experienced a




negative effect in returns to land equalling $-6.1 million or -0.47%.




     Production expenses for the seven crops included in the model increased $6.4




million, about 0.06% nationally (from $10,004.5 million to $10,010.9 million).
                                      -161-

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      Table 1 — Impacts  of  suspension of chlordane and heptachlor on corn,
                 other  grain und cotton sectors, U.S. economy 1975-80,
                 projected typical case and worst case estimates, focus 1977



A.

B.









C.







D.



E.









F.









. Item Unit


Corn production 1,000 bu.
(Pet.)
Acres of cropland
in use
Com 1,000 acres
Barley
Cotton
Soybeans
Oats
Sorghum
Wheat • "
Total "
Price of crop
Corn Pet.
Barley "
Cotton "
Soybeans "
Oats "
Sorghum "
Wheat "
Grain transport cost
Corn Smillion
Other
Total
Returns to land
- change in dollars Smillion
Com "
Barley "
Cotton "
Soybeans "
Oats "
Sorghum "
Wheat "
Total "
Returns to land
- change in percent Percent
Com
Barley
Cotton
Soybeans
Oats
Sorghum "
Wheat "
Total "
Typical case
Change due to suspen
solution minus base
200
(0.0035)


88.3
2.9
0.6
-49.0
- 8.8
0
1.7
35.7

.14
.13
.02
- .17
0
.14
- .16

-1.20
+0.46
-0.74


- 6.10
2.40
0.06
- 0.71
2.33
- 0.06
5.20
3.12


- 0.47
l.ZO
0.07
- 0.08
2.22
- 0.02
0.39
U.01
Worst case
' Con (suspension
solution)
-36,910
(-0.7)


200
170
80
-400
250
400
450
1,160

2.6
1.5
0.8
-0.3
1.7
2.5
0.6

3.74
2.62
6.36


-6.36
5.06
5.95
38.00
6.88
11.06
10.07
+71.25


-0.6
£.1
1.7
4.2
13.3
4.2
1.9
2.2
Source:   EPA linear programing analysis
                                    -162-

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The suspension would have a slight negative effect on a proxy measure of net




income to growers of the seven crops included in the model which was calculated




for comparative purposes.  Net income would drop $8.5 million, from $8.397




billion to $8.839 billion.  While this is true,  income to corn growers nation-




wide would remain about constant.  These negative impacts on income occur in




contrast with the "worst case" analysis which indicates a net reduction in corn




production with the result that prices for the crop produced would rise, thus




increasing net income to the corn sector generally as well as the remainder of




the agricultural sectors included in the model.  In this instance (worst case),




production changes were more extreme touching off price increases which allowed




producers to pass on the majority of impacts to final consumers.




     Impacts on the consumer through reduced production in crops and higher




prices are not significant in total for a typical case year.  Very minor ef-




fects would occur on prices of meat, poultry, eggs, cereals and fiber (inclu-




ding cotton) as a result of the suspension under a typical case outcome.  The




major significance of the suspension is within agriculture itself, as quite




significant cost impacts would occur in affected regions as well as local and




regional adjustments in crop production




     The national impacts under the worst case analysis contrast with the




alternative primarily in that there is a reduction in the production of corn




equalling nearly 37 million bushels (-0.7%) leading to significant increases




in the price of corn (2.6%) and also in other crops.  The effect is to increase




returns to agriculture significantly under the worst case assumptions.  Market




effects are quite significant under worst case assumptions in contrast with
                                     -163-

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the typical case where essentially  there is  no significant market effect.




Alternatively, the prime effect in  the typcial case is a balancing of increased




production costs against higher prices with  a corresponding minor impact on




overall net returns.




     The impacts of the typical and worst case solutions on corn production




as a result of a suspension can be  brought into perspective by viewing them




within the context of a year-to-year variation in corn production in the




United States.  Presented in Figure 1 are time series data on production of




corn for the period 1962 to 1974 and year-to-year changes charted on a zero




axis to more clearly illustrate the variability of changes.  Since 1962, corn




production has varied from a low of 3.5 billion bushels to more than 5.5 bil-




lion bushels, with year-to-year changes of as much as 500 million to 1 billion




bushels.  The worst case impact of  -37 million bushels is nominal by compari-




son to year-to-year changes due to  all factors impacting on production of corn




in the United States.




     The cost of transportation activities required to meet final demands




decreased by $740,420 following restrictions in the use of organochlorines




in the typical case.   Corn transportation cost fell by $1,203,000 and was




partially offset by an increase in  required transportation of soybeans valued




at $631,000.









Regional and Local Impacts




     Rather significant impacts occur at the regional levels in both the




typical and worst case solutions.  However,  in the latter case impacts are




considerably greater in magnitude.   Corn production declines in some regions




by as much as 10 to 12 million bushels in the typical case solution and by
                                     -164-

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  Bil. bu.

      6.0



      5.0



      4.0



      3.0



      2.0



      1.0
Figure 1. Trend and year-to-year changes in U.S. Corn Production


         U.S.  Corn  Production, 1962-1977
         62  63   64   65  66   67  68  69   70   71    72  73  74   75   76  77
       .                                 Year
     . bu.               •  Year-to-year Change in U.S.  Corn Production
      +1.1
      +1.C
      +O.E
      -0.-
      -1.
                                                                Impact of
                                                                C/H Cancellation
            62/3    64/5     C6/7     68/9     70/1      72/3    74/5      76/7
              63/4     65/6     67/8     69/70    71/2    73/4     75/6

                                        Year
Source:   Adapted by EPA, C&E  Economic Analysis Branch from various issues
          of USDA,  ERS, Feed Situation for the 1962  - 1972 period.
                                          -165-

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considerably larger amounts in the worst case solution; however,  in the latter




case these impacts would not be expected to occur regularly over  a period of




years on the average based on available long term yield benefit data for use




of organochlorines on corn.  (Exhibit L).
                                     -166-

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                         IMPACTS OF SUSPENSION IN 1976









     The impacts of the suspension on the corn sector during 1976, the first




crop year of the suspension, would be somewhat less than during a typical year




as indicated in the linear programming analysis.  The major factors leading to




the judgment are that  (a) at least some supplies of chlordane/heptachlor would




be available for use in 1976 from stocks produced prior to the effective date




of the suspension July 29, 1975, (b) the outlook for supplies for substitutes




for chlordane/heptachlor is quite favorable as indicated later in this testi-




mony.  Although we have not undertaken an evaluation of the amount of chlor-




dane/heptachlor that might be available for use in 1976, a significant amount




could be available as well as possible supplies of aldrin, which are autho-




rized for use under the aldrin suspension.  The magnitude of the remaining




supplies for use in 1976 would be significant if the same proportion remained




in the first year of the suspension as was the case with aldrin where 36% of




a year's supply was available for use on corn (2.5 million acres in 1975 com-




pared with nearly 7 million acres in 1973/74) (Exhibit H, Table 1).  Impacts




of the suspension in 1976 would not fall evenly on the various corn producing




states.  Impacts would be greatest on those states, such as Missouri, Illinois,




and Indiana, where organochlorines were used most intensively during recent




years.
                                      -167-

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          ECONOMIC IMPACTS OF SUSPENDING CHLORDANE AND HEPTACHLOR ON




                       AGRICULTURAL USES OTHER THAN CORN







     The testimony presented in this section is a survey of agricultural uses




other than corn for purposes of identifying the nature and extent of economic




impacts of shifting to alternatives to chlordane and heptachlor under a




suspension.  The approach utilized in the review of these uses has included




the following:




     1.  A review of the registered crop uses of chlordane and heptachlor on a




         crop (site)/pest basis.   Registered crop/pest combinations were cap-




         tured under an automated system and a printout made for purposes of




         reviewing the registered chlordane/heptachlor uses and the extent to




         which alternatives are also registered.




     2.  1974 and 1975 state insecticide recommendations have been reviewed to




         determine existence of significant uses for which alternatives are




         limited or absent.




     3.  A questionnaire was sent to the chief entomologists in the states in




         December, 1974 to obtain current information on uses of pesticides




         containing chlordane and heptachlor and problems associated with




         cancellation/suspension.




     4.  Other literature and data were collected for use along with the review




         of registered and recommended uses (Items 1-3 above) to determine the




         extent of economic impacts with suspension.
                                     -168-

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Citrus







     The impacts of suspending citrus use of chlordane and heptachlor is limited




primarily to chlordane and to uses in the states of California and Florida.  In




each case, rather limited quantities of chlordane are used; however, potential




economic impacts from a suspension are significant primarily in Florida.




     In California, chlordane is used on citrus plantings to protect them from




termites.  Chlordane is also used to control the Argentine ant which interferes




with natural predators of scale insects.  In the absence of chlordane to control




the Argentine ant, an alternative method of control would be foliar applications




of parathion, malathion, carbaryl, and guthion to directly control pests.  Foliar




control is likely to upset current pest management programs, thus requiring a re-




organization of foliar spray schedules on about 3% of California citrus acreage.




     In Florida, organochlorines such as aldrin/dieldrin and chlordane/heptachlor




are the preferred treatments for root feeding beetles in the eastern coastal area




of Florida, commonly known as the Indian River Region.  The consensus is that




effective soil insecticide alternatives are not available for these rootfeeding




beetles.  In the area most seriously affected, there is a high water table which




places root systems near the surface thus preventing traditional cultural control




cultivation methods with the result that a foliar control program would need to




be initiated.




     Review of this situation dating back to the beginning of the aldrin/dieldrin




hearings indicates that the Indian River area might cease production of citrus




over a period of 10 years if no alternative methods of control are forthcoming.




This change in the use of land could lead to a loss of 6% of current U.S. citrus




production (Exhibit N).  Income to landholders would be lessened as the land




would probably be used for grass/beef production.





                                     -169-

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Hawaiian Pineapple






     Chlordane/heptachlor is used to control ants which help spread the mealy




bug wilt in pineapple groves in Hawaii.  Velsicol estimated the annual use




of heptachlor at 10,000 pounds.  Mirex is the principal control for this




pest with heptachlor being a back-up chemical.  The Hawaiian pineapple industry




has experienced fierce foreign competition in recent years, especially in the




processed market.  As a result, some areas are going out of production.  If




organochlorines are no longer available for control of the ants in pineapple,




registered foliar alternatives would need to be used such as parathion, mala-




thion, endosulfan, di-syson, disulfoton and diazinon.  Adequate control with




foliar sprays, however, is difficult to achieve.  No economic impact is fore-




seen, however, due to a suspension of chlordane/heptachlor since mirex continues




to be available and provides effective control.
Potatoes







     Velsicol estimated that as many as 1.1 million pounds of chlordane




were used to protect potatoes from insects in 1974.  (Exhibit A).




This large volume of use cannot be confirmed with other available data.




USDA estimated chlordane use of only 33,000 pounds on potatoes in 1971.




USDA No. 252).  Wireworms are the primary insects controlled by




chlordane, although some states recommend use of chlordane to control




white grubs.  Of fourteen states recommending chlordane for wireworms,




only one state recommends chlordane exclusively (Exhibit 0).  Six




other states recommend non-chlordane controls exclusively for wireworms,
                                     -170-

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Major alternatives recommended for wireworms and white grubs include diazinon,




dyfonate, parathion and phorate.




     Idaho, the leading potato producing state, grows 26% of the United States




potato crop (USDA 1974).  While Idaho does not recommend an alternative for




chlordane to control white grubs, the state recommends with regard to the white




grub that:  "Early plowing generally eliminates the need for soil insecticide




treatment."  (U. of Idaho, 1975).




     Thus, a non-chemical technique is available for white grub control in




Idaho.  Washington, the second ranking potato state, did not report problems




with cancellation of chlordane on potatoes (USDA/EPA Survey, 1975).  Maine,




which ranks third in potatoes, indicated crop rotations and diazinon for wire-




worm control in the USDA/EPA Survey.




     Major impacts on potato production from suspension are not indicated.




This is in line with USDA's analysis in 1972.  (Ag. Econ. Report, No. 231,




August 1972).   Added control costs were estimated at $108,000 nationally.
                                     -171-

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Seed Treatment







     Generally minimal or no economic impacts are anticipated from the removal




of heptachlor as a seed treatment providing supplies of alternatives are




available, as discussed below (See Exhibit P).   Controversy surrounds the




removal of heptachlor seed treatment in the Southwest; actual estimates of




impact are undetermined due to lack of data.




     Velsicol Chemical Corporation estimates about 269,000 pounds of heptachlor




were used for seed dressing (treatment) in 1974.




     It is estimated that between 4% to 9% of all grain seed was treated with




heptachlor in five midwestern states (1970-1974), whereas 9% to 20% of all




grain seed was treated with one of five major insecticides (estimates concerning




the overall use of seed treatment in the United States are unavailable).




Cancellation of heptachlor seed treatments will result in the use of lindane,




diazinon or a combination of lindane/diazinon.




     Indications are that lindane is in short supply presently and that plant




capacity is not expanding (Exhibit V).  A substantial portion of the heptachlor




seed treatment use (total of 269,000 pounds in 1974) could not be made up




readily by lindane.  Diazinon is likely to be available, although the overall




outlook for supplies of it is mixed. (Exhibit V).  Volumes needed for




seed treatment are small compared to total diazinon use (7 million pounds




in 1972, EPA 540/1-74-001).




     USDA estimated that seed treatment costs for corn, sorghum and small grains




would increase from $70,400 to $125,400, or by $55,000 for the year 1971 (USDA/




ERS - 509).  Diazinon was substituted for heptachlor on a pound-for-pound basis,




total of 11,000 pounds.  No yield effects were projected.
                                    -172-

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Pest Control on Strawberries


     Chlordane is recommended for use against strawberry insect pests in many

states (Exhibit Q).  The larvae of rootweevils and white grubs are serious

pests in certain areas for which several states recommend chlordane and for

which alternative controls are limited.  Other chemicals such as diazinon and

carbaryl reportedly are effective controls but are not registered at sufficiently

high rates of application to provide effective control (response of New York

entomologist to USDA/EPA survey in 1975).

     Most California production, which equals 2/3 of the U.S. total, would not

be affected.  In 1974, chlordane was used on only 16 percent of 1974 acreage

grown (8,300 pounds on 1,409 acres) (California Pesticide use report for 1974).

The next four ranking states in terms of commercial strawberry production

would be adversely affected at least to some extent.  They are as follows

in rank order according to percent of U.S. production:

     Oregon          10%               Michigan           3%
     Washington       5%               North Carolina     1%

If alternatives are unavailable for control of these pests in these commercially

important production states, significant national impacts would occur on the

production of strawberries.  The extent of economic impact of shifting to

alternative crops for affected growers is not known at this time.  The impact

of shifting to alternatives is minimized to some extent in the state of Washington

since neither chlordane nor heptachlor currently provide consistently effective

control over the weevils attacking strawberries in that state (response to

USDA/EPA Survey, 1975).
                                     -173-

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     The lack of alternatives is likely to have related affects from these




and other pests in isolated less commercially important strawberry producing




states.  In particular, production impacts were projected in the USDA/EPA




survey in Kentucky, Maryland, Missouri, Mississippi, Nevada, North Carolina,




New York, Ohio, Tennessee and Wisconsin.









Pest Control on Tomatoes






     A review of the state insect recommendations for 25 states indicates




that few states are recommending chlordane for use on tomatoes in 1975




(Exhibit R).  Those states are:  Ohio, Florida, Colorado, Maine, Minnesota




and South Dakota.  One of the principal problem pests is cutworms for which




dylox and toxaphene baits or sprays are recommended.  Differentials in cost




on a per acre basis are nominal, particularly in view of the high value of




the crop on a per acre basis ($l,000/acre).  As with control of cutworms in




corn, use of baits can fail due to adverse weather conditions or inadequate




scouting.




     There may be as much as 320,000 pounds of chlordane used on tomatoes in




the U.S. based on estimates provided by Velsicol.  This estimate, however,




seems far in excess of the other estimates of use of chlordane on tomatoes.




An average of less than 9,000 pounds of chlordane per year were used in




California (the leading tomato state) on tomatoes in 1972 - 1974 (California




pesticide use reports).  USDA estimates of 8,000 acres treated in 1971




(Ag. Economic Report No. 231, August, 1972).  This report indicated a very




small impact from cancellation of chlordane — and added cost of $12,000




for alternative controls, with no yield reductions.
                                       -174-

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Pest Control on Other Minor Crops






     A review of state recommendations, the USDA/ERS 1975 State Survey and




available USDA surveys indicates frequent minor localized problems on various




crops for which small amounts of chlordane/heptachlor are used, but no




significant economic impact is foreseen for these crops in the vast




majority of instances.  (Included in this category are apples, hay and alfalfa,




peanuts, soybeans, tobacco, and certain vegetables.)  Growers with long




standing insect control practices involving use of chlordane (and less often




heptachlor) would need to seek out other alternatives and make necessary




adjustments in their operations.  These adjustments could be troublesome at




times.




     Suspension of chlordane/heptachlor would not be likely to adversely affect




apple production.  As much as 373,000 pounds of chlordane were reportedly used




for apple production in 1971 (USDA's 1971 pesticide use survey).  This large




use could not be confirmed by a recent study.  Apparently little chlordane/




heptachlor is used on apples.  Some dieldrin has been used for apple production




in the past for which other organochlorines including chlordane might be a




substitute in view of the aldrin/dieldrin suspension.




     A very small amount of hay and alfalfa has been treated with chlordane




and/or heptachlor in the past.  As little as  20,000  acres are  treated  nationally.




No impact is projected for a suspension of this use.




     While more recent use data has not been available, USDA figures from 1971




show that as little as 100 pounds of chlordane were used on peanuts.  Since
                                     -175

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peanuts are not thought to be treated to any significant extent with chlordane




or heptachlor, no economic impact is expected from the suspension.  Chlordane/




heptachlor is not cited as a recommended treatment for peanuts in Georgia and




Virginia, which account for nearly one half of U.S. peanut production,according




to 1975 recommendations.  In Georgia "insurance" treatment with any insecticide




is not recommended.  If white fringed beetle problems emerge, growers are




encouraged to check with their county agent.




     Limited acreage of soybeans is treated with organochlorines.  Most




entomologists do not recommend organochlorines for use in soybeans because of




residue problems.  In response to the 1975 USDA/EPA State Survey, only Arkansas




and Missouri indicated a need for these materials on soybeans.  No significant




economic impact is likely from suspension of soybean use of chlordane and




heptachlor.




     Some chlordane/heptachlor is used on tobacco in the United States (21,000




acres in 1971 based on USDA survey).  These chemicals are not cited in the 1975




state recommendations for several major tobacco states (Virginia, Kentucky, Georgia,




South Carolina and North Carolina, which account for more than 85% of U.S.




tobacco production as of 1973).  Foliar use of chlordane and other organo-




chlorines on tobacco in crops on nearby fields can cause residue problems




(Publication entitled "1975 Tobacco Information," North Carolina Misc. Extension




Publication No. 126, December, 1974, pp. 30-31).




     Chlordane and heptachlor are used for soil treatments to protect vegetables




from attack by wireworms and white grubs, particularly where vegetables follow




pasture in a rotation.  There could be slight yield reductions in the production




of some vegetables with the use of alternatives, but precise figures are not




available across the country (USDA/EPA Survey, 1975).
                                   -176-

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Lawn and Turf Control






     A review was made of 1975 state insecticide recommendations for lawns,




ornamental turf and golf courses on a representative-state basis by EPA Region,




to determine the extent to which chlordane and heptachlor and alternative




controls are recommended.  These recommendations were summarized by pest




(total of 18 states) and were used as a basis for computing costs of chlordane/-




heptachlor treatments and costs of alternatives.  The review indicated that




recommendations are generally made for three categories of insects:  turf or




grass damaging, nuisance pests and those contributing to health hazards.




     Chlordane is generally recommended for ants, white grubs,  Japanese




beetles, webworms, cutworms, armyworms, fleas, mites, crickets, grasshoppers,




earwigs, chiggers, ticks, leafhoppers, wasps, bees, cicada killers, and




earthworms based on the 18 state review (Exhibit S).   Heptachlor is very




seldom recommended.  Most of the state recommendations include at least two




recommended alternatives to chlordane for control of these pests.  Alterna-




tives often give annual control, but do not give control for as long as




chlordane, which in some cases provides multiple-year control.




     Cost savings are possible in shifting from chlordane to alternative soil




insecticide treatments for lawn and turf.   An evaluation of chlordane treat-




ments compared to alternatives for 18 states in the 10 EPA regions was made




for treatment of 11 pests based on state recommendations for those pests and




1975 insecticide prices typical of those at farm supply stores in the midwest.




Lowest cost alternatives for the 11 pests averaged $10.57 per acre compared




with $12.33 per acre for chlordane and $20.34 per acre if the second lowest




cost alternatives to chlordane were used.   For a golf course with 50 acres
                                     -177-

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of fairways and 3 acres of greens, costs would range from $560.21 to




$1,078.02 compared with the average for chlordane of $653.49.   Other large




scale turf treating, such as at cemetaries and parks, would be similarly




affected on a per-acre basis.




     A similar pattern of impacts is likely for the typical homeowner treating




his yard for lawn insects.  Cost reductions would be possible.  Cost of treat-




ment for a 1/5 acre yard could be affected up or down in a range of $5 or $10




annually.  Considering the possibility for cost savings as well as modest cost




increases depending upon which alternatives are used, a suspension of these




uses of chlordane would not impose a hardship on a typical homeowner with lawn




soil insect problems.









Home and Garden Uses






     Chlordane is federally registered for control of a great  number of insects




inside the home.  A review of 32 state insecticide recommendations for 1975




(Exhibit T) showed that chlo-rdane was not advised as a control against many




of these pests.




     Table 1 is a compilation of controls for only those insects for which sur-




veyed states recommended use of chlordane/heptachlor inside the home.  This




table is suggestive -of the relative importance of chlordane/heptachlor in




control of these insects.  A number of states make no recommendations for these




pests, and when recommendations are made, a wide range of alternative controls




are available and often times recommended in preference to chlordane/heptachlor.




Some of the household pests are of such minor annoyance to the homeowner that




states often recommend purely mechanical control.
                                     -178-

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     The exception may be scorpions, and five of the six states recommending




chlordane do not recommend any alternative chemical control.  These five states




are Alabama, Florida, Georgia, Oklahoma, and Oregon.  However, the sixth state,




New Mexico, recommends five alternatives.  These are diazinon, baygon, vapona,




malathion and ronnel.  Problems due to lack of adequate controls from the




suspension of chlordane or heptachlor will be minor and any increase in cost




to the homeowner would be minimal.




     The 1975 State recommendations also recommended insect controls for home




garden vegetables in the 32 states.  Six common vegetables were selected for




analysis.  The summary of the state recommendations for insects for which




chlordane or heptachlor are recommended are shown in Tables 2-7.  Heptachlor was




rarely recommended.




     It should be noted that in Tables 2 through 7 of Exhibit T the insects




for which chlordane is recommended are practically identical for each of the




six selected crops.  For all selected crops, chlordane is the sole recommended




control for only one insect, the white-fringed beetle.  This insect was




reported as a garden pest by one state.  In addition, a number of cultural




controls are available for the home garden, and are often recommended by the




states.




     Tables 8-13 contain a summary of state recommendations for insects




in the garden for which chlordane/heptachlor was not recommended, even though




it is registered for use on these insects.  There are many pests for which




chlordane and heptachlor were not recommended in the 32 states.
                                     -179-

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     Minor economic significance can be attributed to the: suspension of home




garden uses.  The primary impact would be that home gardeners would need to




become accustomed to using different'chemicals.
                                     -180-

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Use on Ornamentals



     Use of chlordane to treat for insect problems on ornamentals is estimated


to be about 250,000 pounds annually (Exhibit A).  Commercial nurseries may


account for most of this use.  There are some problems with ornamental insect


pests like the black vine weevil for which chlordane is recommended and for
       /

which alternatives are limited (USDA/EPA Survey, 1975).  In several states, it


is recommended for only one pest (in 7 of the 15 states).  A summary of state


recommendations for 15 states indicates that chlordane is recommended for


relatively few ornamental insect/pest combinations (Exhibit U).   Cost impacts


of suspension of commercial nursery use on ornamentals are likely to be nominal


to the consumer purchasing such products, but would be significant to the


nursery operator, e.g., less than $100 per year for an average nursery.  These


conclusions were reached on the basis of approximate cost relationships for


chlordane and six alternates.


     A large volume of nursery plants are treated with chlordane in USDA


quarantine programs.  The unavailability of chlordane for such treatments could


prevent shipment of plants under current regulations.  Costs of alternatives


would be significantly greater than chlordane.  The extent of chlordane use


for this program is not known.  (Maximum authorized USDA Animal Plant Health


Inspection Service use for all programs was 204,300 pounds in 1972).
                                     -181-

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The Availability of Substitutes to Chlordane and Heptachlor






                                   Overview




     The economic impact of the proposed suspension will depend heavily upon




the market availability of substitutes.  Even though substitutes may be




registered and efficacious against target pests, they are of no avail if




industry is not in a position to deliver the substitutes, when and where needed.




A number of factors during recent years have contributed to shortages in




pesticides, e.g., strong export demand, shortages of feedstocks due to energy




crisis, large crop acreages and generally strong demand for pesticides.  The




outlook for supply of insecticides for 1976 is quite good in general and, in




particular, prospects are favorable for many of the major substitutes for




chlordane and heptachlor.




     If the proposed suspension were made effective in 1976 and if existing




stocks of chlordane and heptachlor were permitted to be used, it would appear




that industry could respond with adequate supplies as the transition is made




to alternative insecticides.  During a period of one or two years, it is possible




to increase plant capacities to produce substitutes or to develop additional




supplies of intermediates to adequately expand the supply of final products.




Also, there are opportunities to expand the domestic supply in the short run by




reducing exports or increasing imports.  Increasing efficiency in use of




insecticides with reduction of prophylatic treatment is likely to reduce




demand for insecticides to some extent, with increasing environmental




awareness of pesticide hazards, with integrated pest management programs in




the states and with applicator certification/training programs now being




implemented.
                                     -182-

-------
     It is possible that a significant portion of current insecticide use




involving chlordane and heptachlor may not need to be replaced by other




treatments in view of the above considerations.  Also, in a recent study it




has been estimated that insecticides are needlessly used on significant




portions of crops grown in the U.S. as follows:




             Corn                         50 percent




             Sorghum                   50-60 percent




             Apples                    20-30 percent




(A Study of the Efficacy of the use of Pesticides in Agriculture, by MRI and




RvR, EPA Contract #68-01-2608, July, 1975).




     A similar estimate for corn was reported in another recent study (Theodore




Riedeburg Associates, Pesticide Use for Control of Soil Borne Insects in the




States of Indiana, Illinois, Iowa and Missouri, Report conducted for OPP, EPA,




August, 1974).






                                EPA Survey




     The supply outlook has been reviewed by EPA personnel with product managers




of many of the major substitutes (Exhibit V) .  The review made by phone in late




August and early September, 1975, indicates a generally favorable supply outlook.




The products surveyed were furadan, dyfonate, dasanit, mocap, sevin, bux, dursban,




diazinon, ethion, aspon, orthene, toxaphene and lindane.  The only clearly negative




outlook was for bux,  for which production is expected to decline due to corn root-




worm resistance and for Lindane for which supplies are short.  Diazinon, the only




significant registered pre-emergence cutworm control, is not encouraging in terms  of




expanded production to meet potential demand in the corn cutworm (wireworm)
                                     -183-

-------
market.  If diazinon is not generally available, the only alternative is




rescue baits and sprays for cutworm in corn.




     Several of these products and others have been reviewed as alternatives




to chlordane/heptachlor under EPA's Substitute Chemical Program.  A brief




tabular summary of data from these reviews is presented in Exhibit (W  ) .




These data generally indicate that prospects are favorable for supplies of




these pesticides in the future.




                        USDA Pesticide Survey (1974-76)




     USDA/ERS has just published a survey of the pesticide demand/supply




situation for 1974, 1975 and 1976 (USDA-300).  The survey covered 29 basic




manufacturers of pesticides, those accounting for about three-fourths of U.S.




production.  The study indicates that substantial expansion of production




capacity is planned or under way for 1976, including expansion for 13




insecticides.  Expansion should substantially increase supplies in 1976 and




availability of raw materials should continue to improve according to this




study.  Corn insecticide inventories are expected to be increased in 1975 as




supply is expected to expand relative to demand by 12 percentage points




(20 points in cotton).  The USDA/ERS study also indicated that growers could




usually obtain satisfactory substitute pesticides in 1974, despite frequent




shortages for specific products and that supplies for 1975 were about adequate




for that year's demand.
                                     -184-

-------
Energy Implications


     The production of alternatives to chlordane will involve the use of less

energy than chlordane on a pound for pound basis, based on a comparison with
                /
three carbamate and organophosphate substitutes (diazinon, carbofuran, and

carbaryl)(Exhibit X ).  For heptachlor, slightly more energy would be involved

per pound of active ingredient.  Based on estimates of the rate of substitution

of these alternatives for chlordane and heptachlor, there would be some

reduction in total energy requirements taking into account electricity, coal

for process heat and petroleum for feedstocks and inerts.  The reduction would

be 42,800 barrels of petroleum per year, which is minute compared to total

U.S. petroleum use (about 13 million barrels per day).

     Suspension would be likely to cause a net reduction in the use of some

major insecticides in the United States, as was suggested by the response to the

aldrin/dieldrin suspension in 1975 where total acreage of corn treated with all

insecticides declined significantly on a national basis (Exhibit H).  This

phenomenon would reduce energy requirements for pesticide production.  In some

cases, however, replacement chemicals could require multiple applications, thus

increasing use.  This has not been documented on major uses.

     Additional crop acreage brought into production to compensate for lower

yields such as in corn would increase the amount of energy required to meet the

demand for agricultural output.  The extent of this impact would be small as the

projected increase in acreage of U.S. food and feed grains is only 35,700 acres

in a typical year.

     On balance, the impact of a suspension on the nation's energy requirements

would be very slight.

                                    -185-

-------
 Conclusions

                                                               /
     The review of the economic aspects of this suspension warrants the following

general conclusions:

1.   Chlordane/heptachlor is a major U.S. insecticide equalling about l/20th of

    total insecticide use.

2.   The use of these chemicals, as insecticides, generate significant economic

    benefits,  most of which are available from the use of alternative controls.


3.   Serious national macroeconomic effects on income and employment would not

    result from suspension.

4.   Where significant economic impacts would occur, they would seldom be at the

    industry or sector level but rather in local areas or regions.  Costs and

    incomes of corn growers would be affected where cutworms are a problem.

5.   Economic affects on the consumer of food and other goods and services produced

    with the use of chlordane and heptachlor would not be significantly affected

    during a typical year of the suspension; however, under a worst case outcome

    situation with heavy infestations in many parts of the country and with failure

    of alternatives, impacts on the consumer could be significant in a given year.

6.   The suspension would not contribute to the energy crisis.

7.   The outlook for supplies of alternative controls is good.

8.   Suspension would make it necessary for adjustments in a marketing system for

    pesticides to insure -that supplies reach previous chlordane/heptachlor use

    pattern areas.

9.   Users of pesticides, large and small, will need to make adjustments in the

    procurement and use of insecticides in previous chlordane/heptachlor use

    patterns and in some cases training would be useful to properly target new

    pesticides to economic thresholds.


                                        -186-

-------
                                     EXHIBIT A

                         SELLERS, CONN ER & CUNEO
JOHN Cl. CON*fCf»
OM.ntR* A. CUKCO                     ATTORNEYS AND COJNSCtORS

M?«Br*TLL?reNSTtR                   IC2S K STREET, NORTHWEST

pAMMOro's WLsMKAQ                   WASHINGTON, D. C. ZOOO6
J*MT» j. GAIA<*OHr_«
JOSIPM S W*Gt a                          (2C?> A4'-OT77
WUSIC •' ADAMS. .IH.
jtrrprv F. ALT^A*/-

WILLIAM M. BtUTTL'RFie LD

^"O"»N"O"                '                    June 23,  1975
JOF C, HCLUNC^WOHTM

ALiAN w. MAF/KMAM
• UCL WHITE
               William Reukauf, Esquire  •
               Roorr 519, West Tov;er
               Environmental Protection  Agency
               401 M Street, S.W.
               Washington, D.C.  20460

               Dear Mr. Reukauf:

                    In your letter of March 28,  1975, you
               requested certain sales and  distributJon data
               regarding chloraane and heptachlor.

                   • The distribution data  e.re, of course, not
               readily available to Velsicol because it cannot
               control the. products through the lines of distri-
               bution to the consumer. .  Velsicol personnel have
               made an appraisal, believed to be reasonably
               accurate, based  on customers and uneir location,
               their type of business and  formulations used.
               This appraisal is shown below for chlordane and
               heptachlor for-the two most  recent calendar years
               as requested.

               Lbs. Tech Equivalent Chlordane

               Crop                    1973             191!

               Corn               1,935,041         4,323,526
               Potatoes             975,400         1,111,956.
               Other Vegetables     63,940   ,         72,252
               HL&C               5,773,016         6,328,577
               Turf               1,136,413         1,249,063
               Strawberries         1^1,921           166,541
               Tomatoes             303,842           333,083
               Ornamentals          227,882           249,812
               PCO                7,413,777         7,342,,2J3_5

               Total             17,981,232        21,177,065
                                     -187-

-------
William Reukauf, Esquire
June 23, 1975
Page 2
Lb . Tech Equivalent Keptachlor

Crop                   1973              197*}.

Corn               1,133,128         1,187,393
Seed Dressing        189,760           268,797
PCO                  613,711           551,669
Fire Ants, Misc.      32.735            *m
Total              1,969,331         2, 052,271

     Within the category, "Fire Ants, Misc." there
is included Heptachlor use on pineapples.   Preliminary
information from the Pineapple Research  Institute of
Hawaii indicates that approximately ten  thousand
pounds of Heptachlor is used annually in the production
of pineapples.  Additionally, Velsicol estimates that
in 1975 approximately twenty thousand pounds of
Heptachlor may be used in citrus production.  This
figure is based upon the fact that for the  period
197-"1 through  1973 the Florida Department of Agriculture-
Statistics show annual use of approximately twenty
thousand pounds of Aldrin.  Since the cancellation
of Aldrin, Velsicol expects most citrus  growers will
turn to Heptachlor.

     The PCO  category in each case in the above tables
is estimated  to 'be primarily  (more than  902) termite
use not in issue.  Lastly, the usage breakdown shown
above is distributed largely as you requested but
modified to comprehend major use categories.  Thus,
uses which may be important to the user  but which would
n<>t significantly affect totals are not  shown.

                         Sincerely,
                          Charles A. O'Connor,  III

 CAO/paa
                            -188-

-------
                          EXHIBIT 8
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-189-

-------
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-------
                                 TABLE II

       ESTIMATED PRODUCTION.  IMPORTS.  EXPORTS  AND DOMESTIC SUPPLIES
                OF SELECTED PESTICIDES  BY  CATEGORIES.  1972

                         U.S.
                      Production     Imports      Exports
Herbicides^/

  Organic
  Inorganic

Subtotal

Insecticides^./

  Organic
  Inorganic

Subtotal

Fungicides^/

  Organic
  Inorganic

Subtotal

Fumtgants,—'
Soil Conditioners

Penta- r-nd Tri-
Cl-Phenols

All Pesticides^/

  Organic
  Inorganic

Totals
                         451,300     12,200       76,400
                          41.000  Negligible       400

                         492,300     12,200       76,800
                         442,700      5,600      174,900
                           7.000   Negligible      1.600
                         449,700
5,600     176,500
                          83,000      5,200      24,000
                          60.000   Negligible     5^ 300
                         143,000      5,200      29,300
                         121,000   Negligible    38,900
                          70,000   Negligible     1,500
                       1,168,000     23,000     315,700
                         108.000   Negligible     7.300

                       1,*276,000     23,000     323,000
                       Domestic
                        Supply
                         387,100
                          40.600

                         427,700
273,400
  5.400

278,800
                          64,200
                          54.700

                         118,900


                           82,100


                           6*,500
                          875,300
                          100.700

                          976,000
a/  Includes defoliants, desiccants,  plant growth regulators, chlorates.
b/  Includes miticides, nematicides,  rodanticides,  repellents.
_c/  Excludes sulfur, creosote, coal tar,  panta- and trichlorophenpls.
d/  Excludes p-dichlorobenzene and certain other fumigants (see p.  11).
e/  Excludes sulfur, creosote, petroleum, coal tar, p-dichlorobenzene,  etc.
      (see pp. 11 and  16).

Source:   EPA, OPP, OWHM, op.  cit.  (1974).
                                  -191-

-------






























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-------
                           EXHIBIT C
                Agricultural use of chlordane by type of use, U.S.,
                1964, 1966 and 1971 (active ingredient basis)
Year

1964
1966
1971 .

Crops
	
383
452
1,496
Type of
Livestock
	 1,000
142
71
366
Agricultural
Other ~~
pounds a.i. —
20
3
28
Use
Total
	
545
526
1,890
                 	  Percent of. Total  	
1964
1966
1971
70.3
85.9
79.1
26.0
13.5
19.4
3.7
0.6
1.5
100
100
100
 Includes livestock buildings

"includes all other non-livestock and non-crop uses.

SOURCE:  USDA/ERS (Agricultural Economic Report Nos. 131, 179 and 252).
                                -193-

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                             EXHIBIT D
          Chlordane use on crops, U.S., 1966, 1971
                         Quantities
Acres Treated
Crop

Corn
Other grains
Cotton
Tobacco
Potatoes
Other field crops
Alfalfa
Other hay and
pasture
Irish potatoes , /
Other vegetables —
Citrus
Apples
Other fruits and nuts
Nursery and green-
house
TOTAL
1966
1,000
159
-
3
26
155
1
41

6
155
18
15
3
24

1
452
1971
pounds active
842
41
-
2
33
29
•-

2
33
16
18
373
7

133
1,496
1966
	 1,000
210
-
6
17
38
2
36

23
38
23
83
3
31

MA
472
1971
acres 	
533
78
-
1
55
16
-

3
55
7
10
10
4

NA
717
Note:  In 1964, USDA included chlordane in the category of "Other
       organochlorine insecticides."
 -   Includes strawberries.
SOURCE:  USDA/ERS (Agricultural Economic Report Nbs. 179 and 252).
                              -194-

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                             EXHIBIT  E
                   Agricultural use of heptachlor by type of use, U.S.,
                   1964, 1966 and 1971 (active ingredient basis)

Year

1964
1966
1971
1964
1966
1971

Crops

1,301
1,513
1,143
99.7
98.5
94.4
Type of Agricultural
a/ b/
Livestock Other

4
3 20
68
0.3
0.2 1.3
5.6
Use
Total

1,305
1,536
1,211
100
100 .
100
 Includes livestock building

 Includes all other non-livestock and non-crop uses

SOUPCE:  USDA/ERS (Agricultural Economic Report Nos. 131, 179 and 252).
                              -195-

-------








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-196-

-------
             EXHIBIT G
     SUMMARY OF EPA REGISTERED
INSECTICIDES FOR CORN INSECT PESTS
                AND
1975 STATE RECOMMENDATIONS FOR CORN
     Economic Analysis Branch
 Criteria and Evaluation Division
   Office of Pesticide Programs
          September,  1975
               -197-

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                                Table 1


           EPA registered non-foliar controls for rootworms,  cutworms
           and wireworms  in  corn,  1975
Pesticide Chemical
Chlordane
Heptachlor
Bux
Carbaryl
Carbofuran
Counter
Oasanit
Diazinon
Di-Syston
Dyfonate
Mocap
Parathion
Phorate
Toxaphene
Rootworms
X
X
X

X
X
X
-
X
X
X
X
X

Cutworms
X
X

X
-
-
_
X
-
-
-
X
_
X
Wireworms
X
X .

-
X
X
X
X
-
X
X
X
X

SOURCE:Preliminary summary of registered chlordane and  heptachlor
         uses and alternatives, Criteria  and Evaluation Division,
         OPP, EPA.
                               -198-

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         Table 2.  Controls recommended for cutworms in corn in
                   major corn growing states, 1975.
State

Illinois
Indiana
Iowa
Kansas
Michigan
Minnesota
Missouri
Nebraska
Ohio
South Dakota
Pre-emergence
Aldrin Heptachlor Chlordane
_
Br Br Br
B,Br B,Br B,Br
Br Br
— — —
Br Br Br
Br Br Br
Br,B Br,B Br,B
Br Br
Br Br

Diazinon
_
Br
-
-
F
B
Br
Br
-
B


State

Illinois
Indiana
Iowa
Kansas
Michigan
Minnesota
Missouri
Nebraska
Ohio
South Dakota
Legend: Br -
B -
F -
x -
Rescue
Carbaryl Toxaphene
Bait Spray Bait Spray
XX - -
XX - X
XX X
X X
- X - -
XX X
XX - X
X - - -
XX - X
XX - X
Broadcast Treatment
Band Treatment
Foliar Treatment
Rescue

Trichlorfon
Bait Spray
X X
X X
X
X -
- x
X
X
-
X
X




Source:  State insecticide recommendations, 1975.
                                    -199-

-------

































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XI 
-------
                  EXHIBIT H
DETAILED DATA ON USE OF CHLORDANE/HEPTACHLOR
                     AND
         OTHER INSECTICIDES ON CORN,
             1973/1974 and 1975
              Arnold L.  Aspelin
          Economic Analysis Branch
      Criteria and Evaluation Division
        Office of Pesticide Programs
               September, 1975
                    -202-

-------




















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-203-

-------
                                                              Table  2
                                        o« corn  Insecticide treatments on ccrr^erclil faros, ty chcclc«t.
                                                In wjor corn sutes end In U.S.. 197S
_


«MM.
F'U/Cr.lorijr.e
ttertachlor
Se«fn
hu-ten
furarfan
tc.-nter
Biarlwn
Krcap
t>l-»ysten
IMMt
OtstnU

Icktphene
Otwr
fetal Irtaied
tot Iretted
Tout
AMr«*
Seit/CMcrlfoe
VtattrKlar
Jtvtr.
tiff-tell
Fircdan
CCVt*tT
SllXncn
tecap
O'-wstoa
IHfrei
£isanft
tofcMte
1e»epKsne
O-.Mr
* Total Treated
tot Trc»t-4
lotal



547
33?
330
•
•
1.253
-
59
-
•
'*63

936

100
4.434
6,458
10.892
S.O
t 1
3.S

•
11.5

0.5

.
7. »
0.6

.
0.9
40.7
59.3
loo.o
(


454
242
112
-
-
396
•
26
•
•
36
-
65

(8
1.372
4.348
5.720
7.9
4.2
2.0

-
(.9

0*5

-
0.6

ill

1.2
24.0
• 76.0
100.0
Ohio Ulsconslr


257
123 14
.
* _
17
319 826
- •
25
» •
*
154
30
21

186 43
859 1.315
2.719 Z.rl
3.578 3.413
3.4 . 0.4

_ .
O.S
8.9 24.2
, »
0.7
. «.
-
10.4
0.9
0.6
. »
5.2 1.3
24.0 38.5
76.0 61.5
100.0 100.0



422
40
X!
•
114
1.950
80
•
•
•
1,477
302
701

"125
S.601
7.245
12.846
3.3
0.3
3.9
_
0.9
15.2
0.6

.
•
11.5
2.4
S.5
•
1.0
43.6
56.4
100.0

Minrcsott

* 56
5?
.
.
7
883
«
»
24
•
300
-
339

94
1.738
5.157
6.895
0.8
0.8

.
0.1
12.8
.
.
0.3
-
4.4
.
4.9
-
1.4
25.2
74.8
109.0



523
109
2<5
.
47
132
-
*
-
*
.
.
-

187
1.219
1.704
2.923
17.9
3.7
8.4

1*6
4.S

.
.
-
,
„
»
.
6.4
41.7
' 58.3
100.0



C3
10
..
42
11
1,8)2
^6 "
M
»
re
770
317
324

33
3.382
3.060
6,442
1.0
0.2

(IU

2*. 4
0.9
0.3

0.4
12.0
4.9
S.O '
.
0.5
!.2.5
U.S
100.0

To* •!
(8 .tales

2,332

1.239
42
206
7,<91
'lJ6
131
24
28
3.78}
712
2,386

836
19.920
32,789
52,709
4.4
1.8
2.4
0.1
0.4
14.4
0.3
0.3
0.1
0.1
l.f
1.4
4.5

1.6
3?. 8
62.2
100.0

Otf-er
) 5tateS

191
247
193
390
37
2.557
1S8
193

431
1,082
3S9
669

239
«,276
16,618
22,854
0.8
1.1
0.8
1.7
0.2
11. Z
0.8
0.9
-
1.9
4.7
1.6
2.9

1.0
27.4
72.6
100.0

U.S.

2,513
1,176
1,432
<32
243
10.H8
324
324
24
459
4,865
1.031
3,055

1,075
26,195
<9,<07
75.C03
3.3
1.6
1.9
0.6
0.3
13.4
0.4
0.4
0.1
0.6
6.4
1.4
4.0
•
1.4
34.6
65.4
100.0
WIE5:   (1)  t'U ft for comcrclal f«rns onljr.
        (?)  Toll) treated tcrttjt d«J not reflect twltlplc treatr«nt$ lit therefore wjr te less  trjn total  of  (ndlvldujl Injectlcldes 1Iitt((.
        (3)  Data are preliminary, but najor changes are not circled fn final  data.

Source:  Contract nartet ftu^y for [cononU Analysts (ranch, Of'P, (PA bf Omw  Agrlci/ltural 5cnr1ce,  $1. Uu1l,  Klssojrl  (1CA contract < 18-01-19)3).
                                                                 -204-

-------
                                                          Table  3

                                          uf  curn lusuctlclCe treatments on  curuercial farms, by chemical,
                                              In major corn states and In U.S.,  1973/74 average

Insecticide


Aldrln
felt/Cnlordane
Heptacttlor
Sevln
But- ten
furadan
Counter
Dlazfnon
Kocap
(H-syston
ThlMt
Dasanlt
Dyfonate
Toxaphene
Other
Total Treated
. .t Treated
• Total
Aldrln
telt/chlordine
Heotac.hlor
Sevln
tux- ten
Ftradjn
Counter
Diazlnon
&cap
01-syston
Thfiet
Dasanft
Dyfor.ate
Toxapnene
Otfer
Total Treated
Hot Treated
Total

11 llnols


1,541
229
493

.149
938

98


1,049
51
477

SO
5,015
5,190
10,205
15.1
2.2
4.8
_
l.S
9.2
.
1.0
.
-
10.2
O.S
4.7

O.S
49. T
50.9
100.0




1,187
147
6
.
-
190
_
64

-
S3
.
59

• 31
1,719
3.824
5.543
21.4
2.7
0.1
.
-
3.4
.
1.2
_
:
1.0

1.1

0.6
31.0
69.0
100.0
Akin
WrtlO


720
130
_
.
-
101
_
.
.
-
_
.
.
-
149
1.104
2.464
3,588
3.°6
.
-
2.8
„
.
.
'-
.
.
_
_
4.2
30.8
69.2
100.0
.
Uiscons n


«

.
76
694
f
24

-
337
50
17

53
1,278
1,984
3,262
0.8
.
2.3
21.3
.
0.7
.
-
10.3
1.5
0.5

tie
39.2
60.6
100.0
Iowa



1,548 '
43
273

475
1,587
^
,
_
-
1.347
125
403

232
5,900
'6,381
12,281
12.7
0.4
2.2
.
3.9
12.9
„
_
.
-
10.9
1.0
3.3

1.9
48.0
52.0
100.0



*
88
68

'
142
907
,
_
57
-
254
.
225.

66
1,811
4,660
6,471
1.4
1.1
_
2.2
14,0
.
_
0.9

3.9
.
3.5

1.0
28.0
72.0
100.0




996
11
62
_
106
77
.
.
.
-
„
_
_
-
108
1.336
1,573
2,909
34.2
0.4
2.8
„
3.6
2.7

_
_
-
._
_
_
_
3.7
45.9
54.1
100.0




188
23

241
652
1,852
_
96
.
128
571
245
246
.
119
4,102
2.521
6,631
2.6
0.4
3.6
9.8
£7.9
_
1.5
_
1.9
8.6
3.7
3.7
_
1.8
61.',
38.1
100.0

(8 states


6.268
676
854
241
1,600
6.346
»
282
57
128
3.607
471
1.427
.
808
22,265
28,625
50,890
12.3
1.3
1.7
0;5
3.1
12.5

0.6
0.1
0.3
7.1
0.9
2.8

1.6
43.8
56.2
100 0

) State:


711
44
302
251
1,685
.
314
.
510
1,035
K
474
.
506
5.63*
16, 3?^
21.556
' 2
..1
.2
1.4
1.1
7.7
.
1.4
.
2.3
4.9
.4
2.2
-
2.3
25.6
74.4
100.0

U.S.
s


6.979
921
898
543
1.851
8.031
„
S96
57
638
4,692
5S6
1,901
-
1.31'
27.899
44,977
72,876
9.6
1.3
1.2
0.7
2.5
11.0
.
0.8
0.1
0 9
6.4
0.8
2.6
-
2.0
38.3
61.7
100.0
NOTES:   (1)  Data are for commercial  farms  only.
        (2)  loul treated acreage does not reflect multiple treatments and therefore r^y be less than total  of  individual insecticides listed,
        (3)  Data are preliminary, but major changes are not expected  in final data.

Source:  Contract market study for Economic Analysis Branch, OPP,  EPA  by Doano Agricultural Service, St.  Louis,  Missouri  (EPA cc«tr;ct f 68-01-1928).
                                                                        -205-

-------
                                                           Table A
                                   Corn Insecticide expend)*, res on commercial corn farms, by chemical,
                                                  1n M.1or corn states and  In U.S., 1<>75
Insecticide
Illinois
' Indiana
Ohio
Wisconsin
Iowa
•
Minnesota
Missouri
Nebraska
Total
(8 states)
Other
States
U.S.
	 	 Incoi-tiMrfa f inunSi tllrft. fldOn! 	 . 	 1 	 	
Jtldrfn
tflt/CMordane
Heptachlor
Spy In
Bux-ten
Furadan
Counter
Diailnon
Kocap
01-systcn
Th1r.et
'. • onste

| Other
Total
Alirln
ftlt/Chlordsne
FeotarMor
Sevtn
tux- ten
fbra^en
Counter
Diazinon
Kocap
Oi-systOfl
TMiret
Dasanlt
Gyfonate
Tcxaphere
Other
< .Averase
1,652
939
851

-
5,96*
»
120

-
3,266
220
3,632

421
17.065
3.02
2.77
2.24

-
4.76

2.03

-
3.86
3.49
3.88

4.21-
3.85
1,239
596
272

-
2,146
„
' 61
„
-
'121
241

194
4,870
1.81
2.46
1.50

-
4.21

2.23

-
2.17

3.37

2.85
3.55
547
399
„
-
1,646
,
.
.
-
-
-

502
3.094
1.67
3.24
.
.
-
3.09
.
.
.
-
_
_
_
_
2.70
3.60
861 119
44
»
75
3,659
.
95
.
-
1,066
182
89

141
92
1,170
.
394
8,653
355
-
-
-
5,051
1,075
• 2,468

354
5,351 20,478
2.04
3.14 2.30
_
.
4.44
4.43
.
3.78

-
3.01
6.05
4.24

3. ~28
4.07
2.33
-
3.46
4.44
4.44

.
-
3.42
3.56
3.52

2.63
3.66
136
.
28
4,283
-
-
122
-
1,020
1,539

231
7.478
2.13
2.62
-
.
4.00
4.85
.
.
5.09

3.40
.
4.54
.
2.46
4.30
1,396
272
691
-
135
620
. '
-
-
'
:
- .

978
4,092
(c) 	
2.67
2.50
2.82
-
2.87
4.70
.
-
-
-
_
_
-
-
5.23
3.36
126
22
130
88
8,977
297
57
-
94
2,595
1.249
1,345

106
15,086
2.00
2.20
-
3.1(1
4.1?
4.90
5.30
2.70
-
3.37
3.37
3.94
4.15
-
3.2l
4.46
5,940
2,500
2,984
130
720
35,953
652
333
122
94
13,119
2,726
9,314

2,927
77,514
2.56
2.69
2.41
3.10
3.50
4.74
4.79
2.54
5.09
3.36
3.47 '
3.B3
3.90
-
3.50
3.89
317
515
.410
1,235
108
13,892
952
642
.
1,439
3.909
1,220
2,631

963
28,233
1.66
2.09
2.12
3.17
' 2.92
5.43
5.06
3.33

3.34
3.61
3.31
3.93
.
4.03
4.50
6,?5?
3,015
3.394
1,365
828
49,845
1,604
975
122
1.533
17.W8
3,946
11,945

3,890
105,747
2.49
2.56
2.37
3.16
3.41
4.91
4.95
3.01
5.09
3.34
3.50
3.65
3.91
-
3.62
4.04
NOTES:   (I)   Data are for conriicrcial  farms  only.
        (?)   Data are preliminary, but ma.jor changes are not expects  In final data.
Source:   Contract market study for economic  Analysis Branch, OPP.  tr*  by Ooane Agricultural  Service. St.  touls. KIssouH (EPA contract I 68-01-1928).
                                                                     -206-

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                                                                Table  5
                                     Corn Insecticide expenditures on commercial' com farms, by chemical,
                                                  1n Mjor corn states and  1n U.S., 1973/74
Insecticide
Illinois
Indiana
Ohio
Wisconsin
Iowa
•
Aldrtn
Belt/Chlordane
Heptachlor
Sevin
Box- ten
Furadan
Counter
Piazfnon
Mocap
Dl-syston
Thlnet
Dasanlt
Dyfonate
Tcxaphene
Othsr
Total
Aldrln
Belt/Chlordjne
Hcotachlor
Sevin
tux- ten
Furadan
Countpr
Diazlnon
I'ocaD
01-systcn
Thibet
Casar.it
Dyfoiate
Toxaphene
Other
Average
2,985
470
779

419
3,313
.
259

;
2,708
10S
',340
.
114
12,492
1.94
2.05
1.58

2.81
3.53

2.M
.
-
2.59
2.12
2.81
.
2.28
2.49
2,i54
271
9
-
-
799
-
143

-
115
.
199
.
71
3,759
1.81
1.84
1.50

-
4.2)

2.23
.
-
2.17

3.37
_
2.29
2.19
1,204
244

.
-
312
_
_
_
-
.
.
_
.
371
- . 2.512
68

.
226
2,324
.
72

-
838
153
44
.
177
77
565
.
1,570
5,461
.
_
_
-
3,271 .
363
1,095
~
590
Minnesota

135
15?

.
444
3,402
.
.
219

617

727
_
238
?,129 3,898 15,502 5,932
1.67 - 1.62 1.53
1.88 2.72 1.79 2.24
_
.
-
3.09

_
.
-
_
.
_
_
2.49
1.93
. .
.
2.97
3.35

3.00
.
-
2.49
3.06
2.59
_
3.34
3.05
2.07

3.31
3.'44

_
_
-
2.43
2.90
2.72
_
2.54
2.63
_
.
3.13
3.75

„
3.84

2.43

3. 23
,.
3.61
3.28
Missouri

2',1 16
32
176
.
340
296
_
.
.
-
_
_
_
_
290
3,250
15; 	
2.12
2.91
2.15

3.21
3.84

_
_
-
_
_
_
_
2.69
2.43
Nebraska

257
68
»
538
1,988
6.734
-
267

336
1,575
830
714
.
2ff4
13,500
1.37
2.5?
.
2.23
3.05
3.64

2.78
.
2.63
2.76
3.39
2.90
_
1.71
3.29
Total
(8 states)

11,363
1,372
1,529
538
4,987
22.641
.
741
219
336
9.124
1.454
4.119
-
2,055
60,178
1.81
2.03
1.79
2.23
3.12
3.57

2.63
3.84
2.63
2.53
3.09
2.69
.
2.54
2.72
Other
States

1,439
390
49
898
691
6,610
-
760
-
1,238
2,676
207
1,306
-
1,969
18,233
2.02
1.59
1.11
2.97
2.75
3.92

2.42
-
2.43
2.47
2.44
2.76
-
3.89
3.24
U.S.

12,60?
1,762
1,578
1.436
5.678
29,?51
.
1,501
219
1,574
11,800
1.661
5,425
-
4,t_<4
78,707
1.83
1.91
1.76
2.64
3.07
3.64

2.52
3.84
2.47
2.51
2.99
2.85
••
3.06
2.32
COTES:   (1)  Data are for conMrdal farns only.
        (?)  Averaqp  Moenditures for  total treated acrcaqe does reflect multiple treatments.
        (3)  Data are preliminary, but major  changes  are not expected  in  final data.

Source:  Contract market  study for Economic Analysis  Branch, OW>,  EPA'by  Ooane Agricultural  Service,  St.  Louis, Missouri (EPA contract I 68-01-1928).
                                                                        -207-

-------














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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
                                      -211-

-------
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.
                                         -212-

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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
                        -213-

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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).
                                       -214-

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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).
                                        -215-

-------
     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).

                                    -216-

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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
                                     -218-

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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.
                                    -219-

-------
     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).
                                       -220-

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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.
                                       -221-

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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-

-------
                                    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-

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(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-

-------
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-

-------
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-

-------
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-

-------
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-

-------
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-

-------
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-

-------
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
,
0,00
"0,10
2,15
•0 (04
• 0,0/
0,00
-0,10
-O.Ou
-0,49
"0,01
0,01
•10,94
-1 ,33
-O.OJ
0 , 00
-! , 2B
-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

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tr>
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                                 -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-

-------












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CO
-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-

-------
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-

-------
               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-

-------
                  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-

-------
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-

-------
     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-

-------
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-

-------
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
                                     -284-

-------
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-

-------
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-

-------
     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-

-------
                                 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-

-------
              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-

-------
                        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-

-------
     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-

-------
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-

-------
        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-

-------
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-

-------
 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-

-------
                                                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-

-------
                                             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-

-------
          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-

-------
               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-

-------
                                   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-

-------
                                   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-

-------
                                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
L975 — Household
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-309-

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                                  -310-

-------
U*
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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
                               -326-

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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.






                                    -329-

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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).
                                           -331-

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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.


                                   -332-

-------
     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.
                                     -333-

-------
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.
                                       -334-

-------
                              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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                   -338-

-------
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-

-------
                                  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-

-------
                  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-

-------
                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
                                      -343-

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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
                                   -344-

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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
                                   -345-

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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
                                      -346-

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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.
                                       -347-

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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.
                                      -348-

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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.
                                    -349-

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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
                      -350-

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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, .. ^ ...>...,
                                                            -351-

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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
                  -352-

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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
                                    -353-

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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
                                      -354-

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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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