EXECUTIVE SUMMARY
A STUDY OF THE SHORT TERM
AGRICULTURAL USER ADJUSTMENT
PROBLEMS ASSOCIATED WITH MAJOR
PESTICIDE REGULATORY RESTRICTIONS
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF PESTICIDE PROGRAMS
CRITERIA AND EVALUATION DIVISION
WASHINGTON, D.C.  20460
EPA-540/9-77-014

-------
EXECUTIVE SUMMARY
A STUDY OF THE SHORT TERM
AGRICULTURAL USER ADJUSTMENT
PROBLEMS ASSOCIATED WITH MAJOR
PESTICIDE REGULATORY RESTRICTIONS
Contract Number 68-01-1917
Prepared for:

Environmental Protection Agency
Office of Pesticide Programs
Criteria and Evaluation Division
Crystal Mall Building Two, Room 815
Washington, D.C.  20460
Prepared by:

CONSAD Research Corporation
121 North Highland Avenue
Pittsburgh,  Pennsylvania  15206
November 30, 1976

-------
                             PREFACE
      CONSAD Research Corporation prepared this report during the
period of July 1,  1975 to November 30,  1976, under Contract Number
68-01-1917 for the Criteria and Evaluation Division,  Office of Pesticide
Programs, Environmental Protection Agency.  The field work phase
of the study (on which this  report is based) took place during the period
of January 1,  1976 to March 15, 1976.  Dr. Robert R. Reynolds was
the EPA Project Officer.

      Mr.  Alan Bernstein, Dr. Douglas Stewart and Mr. Robert Lowrey,
were the principal CONSAD personnel assigned to this project.  Mr.
Roger Mayland and Mr.  Larry Koch performed the field interviews
during the study.

      Dr. Herbert Cole, the Pennsylvania State University, Dr. Gerald
Klonglan, Iowa State University, and Dr.  Jerry Stockdale, University
of Northern Iowa, were the principal consultants.
                                 il

-------
                        ACKNOWLEDGEMENTS
      CONSAD would like to express our gratitude to all those who
cooperated with us on this study,  particularly during the field work
phase of the effort.  Without their cooperation, this study would not
have been possible.

      A thank you goes to the Iowa State Extension Service and Agri-
cultural Experiment Station,  the Missouri State Extension Service and
Agricultural Experiment Station and the Louisiana State Extension Ser-
vice and Agricultural Experiment Station, for their time and  assistance
in this effort.   Also a thank you to the Agricultural Stabilization and
Conservation Service in each state for their assistance.

      Finally,  and most importantly,  a special thank you to all those
individuals --farmers,  pesticide dealers,  implement dealers,  local
financial institutions,  professional scouts,  professional applicators,
local educators,  chemical company representatives,  extension agents,
ASCS directors,  etc.  -- who  provided us with information while we
were in the field.
                                iii

-------
TABLE OF CONTENTS


                                                           Page

      PREFACE                                            ii

      ACKNOWLEDGEMENTS                                iii

      ABSTRACT                                           v

I.     RATIONALE FOR  THE STUDY                         1

II.    PROJECT OBJECTIVES AND CONSTRAINTS            3

III.   STUDY APPROACH                                    4

IV    CROSS  COMMODITY COMPARISONS                    8

     A.   Crop Production Factors Affecting User Adjustment  8
      B.   Institutional Arrangements and Activities            10

V.    THE USER ADJUSTMENT R^SKJNSE PROCESS         14

      A.   Comparison of User Adjustment                    14
          Responses and Probl'ems
      B.   Influential Forces in the User                      18
          Adjustment Response Process
      C.   Important Concerns for EPA                       21

VI.   RECOMMENDATIONS                                  25

      A.   Procedural Recommendations for                   25
          Pesticide Regulatory Actions
      B.   Areas for Future Work                            27
      C.   Methodological Concerns                           28
                               iv

-------
                             ABSTRACT
      The objectives of this study were to identify the range of short-
term (tentatively defined for purposes of this study as three years) "on
the farm" user adjustment problems associated with major pesticide
regulatory decisions, as well as to explain user problems  and responses
to those problems. The existing knowledge base  relative to these
phenomena was not one which could support a rigorous, quantitative
study.

      Not knowing the potential problems or the explanatory mechanisms
which could emerge required that the data collection activities be
extremely flexible and utilize a  case study ("ethnographic") approach.
As distinct from  the standard social  science survey in which  all ques-
tions are  known prior to initiation of field work, the case study or
"ethnographic" approach adopted here was  one  in which field  activities
for the second week were planned by the field observer  and field direc-
tor on the basis-of data collected and interpreted during the first week
(and so on throughout the field work phase).

      Two case stndip.s were performed,  each focusing  on  a particular
pesticide/crop/pest problem combination.  Criceria for the selection
of study pesticides and study crops were  identified.  Once  these cri-
teria were applied, the two case studies emerged -- one focusing on
field corn where  aldrin/dieldrin and  chlordane/heptachlor  were used
to control the black cutworm and the other focu.sing on cotton where
DDT was used to control the tobacco budworm.  The study  site for
each case study consisted of two counties,  which were selected in light
of the pesticide/crop/pest problem combinations described above.

      The field work phase  (i. e.,  the data collection phase) began in
early January,  1976 and lasted  ten weeks.  Once  the field work phase
was completed, post field work  activities  took place including the
analysis  of the  data generated in the  field  and the writing of the final
report.

      In reviewing  the farmer adjustment responses and problems and
the influential forces  associated therein,  a number of conclusions were
found to be pertinent for providing EPA with a better understanding of
the process associated with replacing a banned pesticide in the short
term (i.e., within a period of three years):

-------
Although farmers may become aware  (i.e., "hear
something") of a pesticide regulatory  action near
the time Federal decisions are made via the news
media,  they do not  necessarily act on this infor-
mation  (i.e.,  take the message seriously,  attend
to it, solicit and receive detailed information, etc. ).
Indeed,  the regulatory restriction does not become
problematic until carry-over supplies of the banned
pesticide become scarce.  Thus,  little experiment-
ing with alternatives is done prior to this time and
no preparatory or anticipatory adjustments are made.

The initial user adjustment response amongst farmers
is usually an attempt to maintain their current pest
control  practice and hence they continue  using the
banned  pesticide.  Indeed, many farmers augment
their supply by stockpiling and are encouraged to do
so through advice received in the community -based
institutional service network.

User adjustment responses that simply entail the
substitution of the banned pesticide with a new
of new pest control practices not utilized in the
past (e.g., alternate crops, intensive use of scout-
ing with contingent use of rescue insecticides, etc. )
are met with greatest resistance by the farmer and
are usually only adopted by the larger, more esta-
blished and higher resource farmers in the short
term.

These user adjustment responses are not without
their reported difficulties by farmers.  Most of their
concerns center around matters that could  inhibit
yield and profit; less concern for health or environ-
mental side effects is apparent.  The following user
concerns are  in evidence:  pesticide  shortages,
increased cost and reduced efficacy of alternate
chemicals  (the latter partially caused by improper
application) resulting in  increased production costs,
reduced yields, reduced income and  increased debt;
allergic reactions and the lack of institutional ser-
vices for alternate crops; and institutional  constraints
and prior practices precluding adjustment responses
involving new pest control practices  (e. g. , intensive
use of scouting).

-------
Farmers look to an institutional service network in
their surrounding  community for alternate courses
of action when faced with replacing a banned pesti-
cide (e.g., the extension service,  the agricultural
experiment stations,  chemical companies, pesticide
dealers, lending organizations,  professional scouts,
neighbors, friends and relatives, etc. ).  However,
institutional constraints which impede responsive-
ness to the pesticide  regulatory  action can preclude
otherwise possible responses by the farmer.

A farmer's past practices (i. e., tradition) and his
beliefs about what kinds of pest control  strategies
are effective for a particular pest, influence his
adjustment responses in the sense that they restrain
the range of attractive options.

Financial resources (e.g. ,  cash and/or credit) also
constitute a significant attribute with respect to a
farmer's response and problems associated there-
with.  That is, those farmers that can weather one
or two poor crop years while the community based
support institutions cock viable alterr.atives to the
banned pesticide are  least likely to have serious
adjustment problems.

Noncontrollable confounding conditions such as
inflation,  the weather,  fluctuating  market conditions
for alternate crops, prior and expected levels of pest
infestation,  and pesticide shortages caused by raw
material shortages (e.g. , a petroleum crunch), all
influence both a farmer's response to a pesticide
regulatory decision and the subsequent problems that
may develop.  Nevertheless, the nature of the rela-
tionships between the farmer and the various support
organizations will, to varying degrees,  mitigate  or
soften the effects  of these otherwise uncontrollable
conditions in the production operating environment.

Hence,  the magnitude or seriousness  of a farmer's
adjustment problems (i. e. ,  the degree to  which a
particular adjustment problem affects his ability to
adapt to a new pest control option with confidence)
                     Vll

-------
           is influenced by both his personal resources (i.e.,
           past practices to pest control, financial resources,
           information seeking activities,  managerial skills,
           and friendship ties with pesticide dealers) and the
           ability of the institutional service network to pro-
           vide timely,  supplementary resources for respond-
           ing to a regulatory action.  Curiously, the extent
           of interphase  of these two resource factors  means
           that adjustment problems can be equally serious
           for different farmers in the same geographical
           locality.

      In summary,  a period of three years appears to be  a reasonable
definition for describing "short term" transitional user adjustment
problems. This  study found that during the first growing season
affected by a regulatory action, many farmers will attempt  to "buy
time" by stockpiling the  banned pesticide.  For  some farmers, such
stockpiles may be sufficient to carry them through the second growing
season as well.   However, in the third growing season affected by a
regulatory action, few carry-over supplies of a  banned  pesticide exist
and, thus, most, if not all, farmers are forced to make an additional
adjustment response.  Nevertheless, the available response options
(i.e., alternate pe^t control stTategie?), thp p.xtpnt to which eacn is
chosen, and the difficulties anticipated in adopting each option are, of
course, influenced by a complex set of personal and community institu-
tional resource conditions. Therefore, the response options open to the
farmer and adopted by him in the "short term"  (i. e., three years) will
vary both between farmers of the same commo'dity sector, as well as
between farmers of different commodity sectors.
                                 Vlll

-------
I.  RATIONALE FOR THE STUDY
      Under Public Law 92-516, the Environmental Protection Agency
is charged with the protection of man and the environment from deleteri-
ous effects of pesticide use.  However, the amended FIFRA (PL 92-516)
requires that decisions the Administrator makes governing the use of
pesticides determined to produce "unreasonable, adverse" environmental
effects shall be made with an awareness of  the prospects for "unreason-
able,  adverse" social,  economic and environmental effects resulting
from  the decision.  Thus, if the substitute pest control procedures avail-
able present different health hazards or, if there are no substitutes
available to maintain food and fiber production, then one problem is
merely substituted for another.

      Congress, in desiring  to minimize the occurrence of such out-
comes, has provided funds for the evaluation of problem pesticides and
the consequences of various  decision options for their use.  The review
program associated with the Substitute Chemical Program is a pivotal
component of this  policy thrust.  Funds have been  targeted in this pro-
gram for the purpose of identifying pest control procedures that can
feasibly substitute for problem pesticides,  and for the purpose of eval-
uating evidence pertaining to probable c^ort and  'nng t*i*m p.ttp.r.ts 01
their  use.  However, information is not always available for certain
classes of problems.

      Data documenting short-term  (tentatively defined for purposes of
this study as three years)* transitional problems experienced by farmers
faced with the problem of replacing  a cancelled or  suspended pesticide
is one of the areas in which  more knowledge is needed. **  Short-term
      *Chosen because the DDT decision was three years old when this
study was undertaken.
     **This problem has been alluded to in past research and in pre-
vious pesticide regulatory decisions.  For  example,  see RvR Con-
sultants, Farmer's  Pesticide Use Decisions and Attitudes on Alternate
Crop Protection Methods,  Report prepared for the CEQ and the EPA,
Contract Number EQC 325, July, 1974; National Academy of Sciences,
Pest Control: An Assessment of Present and Alternative Technologies,
(5 volumes), 1975;  and Opinion of the Administrator,  EPA,  on  the
Suspension of Aldrin and Dieldrin, FIFRA Dockets Numbers 145 et. al. .
October 1,  1974.

-------
user problems can become long-term problems for society,  especially
if major regulatory decisions are made without an adequate understanding
of the scope and magnitude of problems.

      The type and magnitude of farmer adjustment problems experi-
enced were not well understood at the time the study was initiated, but
were thought to possibly include shortages of substitute supplies,
problems associated with the attainment of application skills, occupa-
tional health problems stemming from the use of unfamiliar products,
etc.

      Therefore, in order to upgrade the Environmental Protection
Agency's capacity for identifying and understanding post-regulatory
agricultural user adjustment problems and in order to provide direc-
tion to EPA in areas having optimal policy benefit, this study was
undertaken.

-------
II.  PROJECT OBJECTIVES AND CONSTRAINTS
      Within the limits imposed by the relative lack of knowledge
regarding user response to pesticide withdrawals,  this study was  a
developmental one and was  viewed as  one of discovery and exploration.
That is,  the objectives of this study were to identify the representative
range of "on the farm" user adjustment problems associated with  major
pesticide regulatory decisions,  as well as to establish a testable theo-
retical framework for explaining user problems and responses to  those
problems.

      The primary focus of the study was. on farmers of select com-
modities and the  scope of work stipulated that two major crops be
selected to further focus the study effort.  Moreover,  the contract
stipulated that the study should be targeted to,  but not necessarily con-
fined to adjustment problems associated with decisions to cancel aidrin/
dieldrin  and chlordane/heptachlor.  Overall farmer adjustment prob-
lems were to encompass a range of issues including managerial prob-
lems, resource shortages,  poor results with substitute pest control
procedures,  new pest problems, crop failure,  safety problems, etc.

      Finally, the contract  specified that the sampling design and  data
collection procedures be sufficiently flexible to permit development of
a policy understanding of the user adjustment problems specific to
various crop production systems, without sacrificing the precision
necessary to identify response profiles of the most serious problems.
In addition,  the relationship between user behavior and the influence
of local and extra-local instiutional conditions to pesticide use and
response to regulatory decisions were to be identified.

-------
III.  STUDY APPROACH
      As stipulated in the project objectives,  the focus of the present
study was to identify  the range of "on the farm" user adjustment prob-
lems associated with major pesticide regulatory decisions,  as well as
to explain user problems and responses to those problems.  The
existing knowledge base relative to these phenomena was not one which
could support a rigorous, quantitative study.

      Not knowing the potential problems or the explanatory mechanisms
which could emerge  required that the data collection activities be
extremely flexible aad utilize a case study ("ethnographic") aoproach.
As distinct from  the standard social science survey in which all ques-
tions are known prior to initiation of field work,  the case study or
"ethnographic" approach adopted here was one in which field activities
for the second week were planned by the field observer and field direc-
tor on the basis of data collected and interpreted during the first week
(and so on throughout the field work phase).  In addition, the effect of
two case studies  (one for each major crop selected to focus the study)
on the dynamic nature of the project is significant for it allowed insights
derived from one commodity to be explored through similar data acqui-
sition procedures on  the other.

      Conjoined with  this emphasis on flexibility was a planning approach
which indicated a set of procedures  and initial data sources.   Of partic-
ular importance was  the enumeration of non-farm sources of informa-
tion.  This methodological approach was  supported by  the overall con-.
ceptual orientation -- that the farmer exists within an institutional
context which can serve as an important explanatory basis regarding
the farmer's responses.  A wholistic view of the social structure and
process pertinent to the farmer's use  of pesticides and exposure to the
banning of a pesticide was sought.  That is, those  conditions (includ-
ing the various institutional structures erne shed in the agricultural com-
munity) that either alleviate or aggrevate the  user adjustment process
were of concern to the study.

      It should also be emphasized that this study is based on what
respondents (farmers and others) reported, given that the thrust of the
study was to discover and explain user adjustment responses and
problems.  These reports are,  in turn, based on respondent's perceptions,
Thus, the study is reporting on the perceptual world's  of various actors
in the crop production system.  The implications should be clear:  this

-------
report was not to address the "real" or "objective" consequences of
specific pesticide regulatory decisions and therefore, this study was
not to be an assessment of the "real" impact experienced by farmers
when faced with the banning  of a particular pesticide.  However, the
important point to be recognized here is that "real" behavior and deci-
sions are based on perceptions,  whether valid or not, and thus are  of
utmost concern in policy decision making and program implementation.

      In order to implement the above approach and fulfill the project
requirements, a three phased effort was utilized.   Pre-field work
activities were first undertaken to select study crops and study sites
in order to focus the field work phase.  Utilizing the "ethnographic"
approach, the field work phase was then implemented and involved the
development of a field manual to guide the data collection activities,
the selection, training,  and  installation of field observers,  as well  as
the actual field work, i. e. ,  data collection activities,  which began in
early January,  1976 and lasted ten weeks. Once the field work was
completed, post field work activities  took place including an initial
coding,  analysis and debriefing session, an analysis plan meeting,
final analysis, and the writing of the final report.

      UctCti phciSe 10 u^ic-iiy uiaCuoScu ill tile pcll'o.gi"a|.
-------
dieldrin and chlordane/heptachlor applied on crops have been used on
corn* and (2) the black cutworm (a corn pest prevalent every year in
various parts of the U. S. ) is effectively controlled with these pesti-
cides and suitable alternatives for  this pest problem (i. e. , pesticide
alternatives having a similar cost and providing equal efficacy as  these
pesticides) are non-existent in the  eyes of many corn farmers. **
Cotton was chosen because:  (1) almost all DDT applied on crops was
used on cotton* and (2) farmers considered DDT to be an effective
inexpensive control for the tobacco budworm,  a cotton pest which  has
increased in recent years. ***

      The selection of study sites (i. e., two counties for each crop),
primarily revolved around satisfying the two pesticide/crop/pest pro-
blem combinations delineated above, i. e. ,  the use of aldrin/dieldrin
and chlordane/heptachlor on corn where black cutworm problems
typically exist and the use of DDT on cotton where tobacco budworm
problems typically  exist.  Also of concern was the location of each set
of counties, i. e. , attempts to find  adjacent counties  for  each crop
were made to maximize  the results given the resources  available  for
field work.  After carefully reviewing published reports and  EPA  in-
house data,  and after discussions with numerous state  and county  exten-
= i=n pcr^^^r.?!,  the fallowing pfiirly sif-ps were chosen:   for corn -
Fremont County, Iowa and Atchison County, Missouri,  and for cotton -
Richland Parish, Louisiana and Franklin Parish, Louisiana.

      As described earlier,  the approach adopted for the field work
can most appropriately be termed "ethnographic".  This required  the
preparation of a field manual to assure common understanding  of the
field related tasks to be  undertaken by the field staff.  The careful
selection and training of field staff was also required.   Selection of
field staff was facilitated by "nominations" made by project consultants
      *Andrelinas, P.A., Farmer's Use of Pesticides in 1971: Quanti-
ties,  USDA,  ERS, July,  1974.
     **EPA Cancellation of Chlordane/Heptachlor:  Economic and Social
Implications, Economic Analysis Branch, Criteria and Evaluation  Divi-
sion, Office  of Pesticide Programs, EPA, May,  1975; conversations
held with extension personnel in Illinois, Indiana,  Iowa,  Missouri and
Ohio prior to the field work phase.
    ***State  of Louisiana's emergency request to use  DDT in the 1975
growing season; conversations with Louisiana extension personnel  prior
to the field work phase.

-------
located at universities.  Telephone interviews were conducted with
several candidates and final selection made only following face-to-face
interviews.  Both field people selected held social science degrees and
had grown up in agricultural areas.

      Following an intensive training session at CONSAD,  the field
director accompanied the field people into their respective geographic
locations.  In the case of cotton, prior to installation, the field direc-
tor and field person spent two days in discussions with state research
and extension personnel,  followed  by one day of interviews with exten-
sion staff in two parishes not subject to in depth study.

      During the period of field work, the field director visited each
site on a bimonthly schedule.  Additionally, reports were submitted
every Friday afternoon (both in writing  and  by telephone).  Moreover,
additional communications occurred when necessary to provide infor-
mation to the field observers. In sum,  very tight control was main-
tained over the very flexible design.

      At the conclusion of field work,  each field person spent several
days with the field director in order to organize data files,  code inter-
view- vr'te-ups, not*> »nH fill  rtate caps, and formulate a series of des-
criptive propositions.  Subsequently,  a  two  day meeting was held a.L
CONSAD, involving all project staff members (including field people
from both sites),  several project consultants and the EPA monitor.  The
outcome of this  meeting was the  intended analysis plan and structure
of the final  reports to be undertaken by the project and field directors.

-------
IV.  CROSS COMMODITY COMPARISONS
      The purpose of this chapter is to provide a summary of some key
similarities and differences found in the two case studies performed,
i.e.,  corn and cotton.   First, pertinent crop production factors affect-
ing user adjustment are discussed.  This is then followed by a presenta-
tion of various institutional arrangements and activities found in the
two study sites,  including some implications for possible adjustment
responses and problems.
A.  Crop Production Factors Affecting User Adjustment
      In comparing the two crop-pesticide-pest combinations that were
utilized to focus the effort in this study (i. e. , corn - aldrin/dieldrin and
chlordane/heptachlor - black cutworm, and cotton - DDT - tobacco bud-
worm), a number of significant differences emerge.  First, not all corn
farmers  in the study site had black cutworm infestations and those that
did have  the problem typically  did not have it on all of their corn crop
since soil type is a key factor,  i. e.,  black cutworms are found pre-
dominantly in gumoo tor aiuiviaii soil.  All cotton farmers, iiu\vever,
were or had been plagued with  the tobacco budworm over the past three
years. Moreover,  black cutworm control traditionally involved the use
of preventive type insecticides, whereas tobacco budworm  contol was
addressed with a series  of rescue treatments once a  given  level of
infestation was evident.   Finally, in general insect problems and the
control of them have typically been more severe in cotton production;
that is, a long history of pest control problems (e.g., insect resistance
to pesticides) can be found in cotton production  (of particular interest
is tobacco budworm resistance to DDT), more so than in corn produc-
tion.

      Consequently, the  chemical solution appeared to be the primary
means of control by those corn farmers having  black cutworm infesta-
tions as various preventive type insecticides were always available and
were regarded as a highly effective means of control.  In contrast,
cotton farmers have found that sole reliance on insecticides did not
adequately control their  insect problems (e.g. , the tobacco budworm)
and preventive type insecticides could not be used.  Rather,  rescue type
insecticides had to be used in conjunction with other crop production
practices designed to determine and minimize insect populations (e.g. ,
scouting, diapause control, use of beneficial insects,  stalk destruction,
etc.).

-------
      Weather conditions in each study site deserve mention as well as
they affect the level of insect infestation.  Dry weather for the past two
years in the two corn counties studied has reportedly somewhat reduced
the black cutworm infestation levels (and caused another problem -
drought), whereas wet spring weather in the cotton counties in 1974
delayed planting and summer rains induced regrowth,  thus making cotton
extremely  attractive to the tobacco budworm from mid August into
September when their control is most critical. Moreover fall rains
reportedly delayed harvesting and reduced pesticide  efficiency.   Thus,
weather  conditions in the cotton study site appeared to favor tobacco
budworm infestations whereas this was not the case with black cutworm
infestations in the corn study site.

      Another area of variation lies in the mechanism utilized by farmers
to determine the crops that they will grow.  In the corn study site, a
rotation  plan of corn and soybeans (which dictates  each crop in each
field  each year) appears to be a common practice,* although continuous
corn  is also grown.  Alternative crops such as wheat and milo have also
been planted recently,  partially due to the aldrin/dieldrin and chlordane/
heptachlor suspensions,  but  also because of the dry weather conditions
(i.e., these crops are drought resistant). Thus, the rotation plan, the
price and availability of fertilizer and pesticides,  and the weather  all
p)ay a parr in the. crop selection process. In the cotton study site, how-
ever, farmers reported  that little crop rotation occurred.  Some farmers
grew nothing but cotton (i. e. , they have grown cotton all of their lives
and it is somewhat traditional), .while others appeared to designate their
better land as cotton land and the rest of their land (or most of it) as
soybean  land.  However,  shifting of crops (e.g., to less cotton and more
soybeans) was reported,  particularly in 1975,  due  to the favorable prices
for soybeans compared to cotton, production costs of the two crops •
(soybeans are about half that of cotton according to the FHA), the price
and availability of cotton insecticides, and the  previous bad weather for
cotton production.

      Finally, it is  important to note that many cotton farmers and
others in the cotton  site  reported that once use restrictions  on DDT
were instituted (e.g. ,  the use of DDT around dairy cattle was restricted
by USDA in the late  I9&0's),  they anticipated that further regulatory
action against DDT  would be likely.  Such anticipation amongst corn
farmers was not found to be present in the corn site for the  aldrin/
dieldrin  and chlordane/heptachlor decisions, although use restrictions
pertaining  to milk and  meat products were imposed by USDA in the late
1960's.  A  possible  explanation is that a larger number of restrictions
      *An important reason for this is that a corn-soybean rotation plan
reduces the likelihood of corn rootworm problems,  a common occurrance
when continuous corn is grown.
                                  9

-------
were imposed on the use of DDT than on the use of aldrin/dieldrin or
chlordane/heptachlor prior to EPA regulatory action to cancel and/or
suspend these pesticides. Also,  more publicity about the DDT use
restrictions and DDT's harmful effects may be factors to explain this
variation.
 B.  Institutional Arrangements and Activities
      In each of the two study sites, a number of institutions were found
 to have an influence on a fanner's crop production practices, and more
 specifically his pest control practices. Moreover, co-nparison between
 these two sites indicated a number of significant differences related to
 the kinds and amount of information received by farmers from each
 source,  which in turn have implications for adjustment responses and
'problems.

      For example, the extension service in the cotton study site was
 found to play a very active role in the  area of cotton  insect control and
 sought to maintain direct contact with  the farmer through the local exten-
 sion activities.  Thus, in addition to state and regional meetings for
 pesticide dealers, farmers,  and  others interested in cotton insect con-
 trol,  local  agents hold special meetings for area farmers and maintain
 contact with them throughout the  growing  season via  the local media.
 In contrast, the extension services in  the corn study site, having recog-
 nized the close relationship that exists between the pesticide dealer and
 farmer regarding information about pesticides, hold regional and state-
 wide mestings for pesticide dealers to distribute their pest  control
 recommendations to them.  At the local level, the county agents  also
 work with the area pesticide dealers and  are available to assist any
 farmer with any particular problem.  They also coordinate  educational
 activities through the  local media.   Emphasis is put  on corn and  soy-
 bean production (the two leading crops in the study area) and no massive
 efforts are made to reach every farmer; rather reliance is put on the
 pesticide dealer to transmit the university extension recommendations.

      Closely related  to  the extension  service activity  is the agricultural
 experiment station activity.  Indications were received that the aldrin/
 dieldrin suspension precipitated funding for black cutworm research
 and that prior to the suspension notice, little research was  underway.
 Moreover,  research entomologists did not think that heptachlor,  an
 alternative to aldrin,  would be suspended so soon after aldrin, leaving
 no preventive cutworm alternative to the  farmer.   Thus, the life cycle
                                   10

-------
of the cutworm is still not well understood and some feel they are still
three or four years away.  As a result,  although alternatives to pre-
ventive cutworm insecticides are available (i.e.,  rescues),  many
experts in the study site feel they cannot be used effectively.  In con-
trast to this situation, a rather sophisticated research entomology
operation appears to be at work in Louisiana.  Funding over the years
has been adequate (including funds supplied by the state legislature in
late  1974) for tobacco budworm res-earch and the experiment station
appears to have adopted a long range (5  to 10 year) perspective to cotton
insect control with  the hope of developing resistant cotton strains  and
earlier maturing varieties.  Moreover,  the experiment station, as well
as the extension service, warned the farmer  of pest resistance to DDT
and its likely cancellation, as early as 1971.

      Variations in the  research activities undertaken by the chemical
companies were also noted.  For the black cutworm, little research
was  found to be underway on developing  new preventive type insecticides
as the chemical companies appeared to be content in marketing already
registered rescue insecticides.   For the tobacco budworm,  however,
development of a number of promising new pesticides to replace DDT
and other tobacco budworm insecticides  is underway by the  chemical
companies.   These products are  also  being field tested at agricultural
c?!pCTini5~t stations z"d the czitcnci.n. rs'-v'c'* **c—~s  j-v-i. M.... ...:n  u«
registered for  the 1977 growing season.   Thus, cooperation between the
extension service,  agricultural experiment station and chemical com-
panies (with the farmer benefiting as a result) appeared greater in the
cotton study site than in the corn study site.   That is, in the corn  study
site  the farmer was placed in a dilemma, with the extension service ana
agricultural experiment station indicating that rescues could not be
used effectively as  yet and desiring a new preventive type insecticide
as an interim solution,  while the chemical companies remained idle on
further cutworm research and content with marketing the  already regis-
tered rescue products and preventive type insecticides, although the
latter did not amount to much.

      As previous research has shown*  and as indicated above,  pesti-
cide dealers in both study sites were found to be an important source
of information to the  farmer regarding pesticide usage and they (the
dealers) too were in close contact with the chemical companies, (as
      *For example, see RvR Consultants, Farmer's Pesticide Use
Decisions and Attitudes on Alternate Crop Protection Methods,  Report
prepared for the CEQ and the EPA, Contract Number EQC 325, July,
1974.
                                11

-------
well as the extension services) for information, so that their product
line and advice reflected the latest recommendations.* In both study
sites,  promotional dinners were held in the winter for their  regular
customers to present their product line for the upcoming  season and
these meetings were thought to be very influential with respect to the
pest control strategies utilized during the growing  season.  Moreover,
in the  cotton study site, some  dealers offered informal scouting  ser-
vices to their long time customers if requested to do so.

      In addition,  the phenomenon of formal scouting by professionals
(which included pesticide recommendations and application schedules)
was widespread throughout the cotton study site.   These consulting
entomologists can be seen as links between state research entomologists
and the individual farmer,  as well as an arm of the extension service,
since they are commonly former students of the LSU entomology depart-
ment and  have earned  the respect "and friendship of the state experiment
staff.  Moreover, the  State of  Louisiana has taken legislative cognizance
of these professionals and regulates  their activities.  In contrast,
scouting as an institution does  not exist in  the corn study site and few
farmers were found to  have a great deal of knowledge about scouting
because they never felt the  need to scout their fields given the  insect
problems and the availability of preventive insecticides,  which were
thought to be highly effectivp.  Thus, there is evidence of a higher
degree of specialization among the cotton service  institutions ie.g. ,
professional scouting) as well  as more direct lines of contact to the
farmer.

      Professional pesticide application was also widespread in  the
cotton study site,  whereas the  individual farmer applied his own pesti-
cides in the corn study site. When professional applicators are  used,
it is not uncommon for them to consult with the farmer's  scout to verify
application schedules and recommendations.

      In the area of financial arrangements, both study sites were some-
what similar.   Local banks, production credit associations  and the
Farmer's Home Administration (FHA) were utilized to obtain opera-
tional loans.   The financial institutions usually did not request detailed
information about a farmer's pest control strategy,  although all  expected
that good  management practices would be used, including the use of
pesticides if past history indicated the need to.  The FHA, in particular,
closely supervised their customers'  overall cash flow and encouraged
      *Note should be made, however, that pesticide dealers in the corn
study site did not stock large quantities of the recommended (or any)
rescue insecticides.

                                 12

-------
the farmer to attend local extension programs.  In the cotton study site,
the production credit associations  strongly recommended that their
customers diversify their crops (i. e. , plant both cotton and soybeans)
and the FHA  made this a requirement for the 1976 growing season in
light of the poor cotton crops in previous  years.  Specifically related
to the pesticide regulatory actions, the lending institutions have not yet
reacted because they will continue to carry the farmer if loan limits
are not reached and if payments are received,  which apparently have
both occurred.

      Farmers can use their Federal Crop Insurance (FCI) as collateral
when securing a loan, although FCI was not commonly bought by cotton
farmers in the study site. In the corn study site,  it was utilized but
was not obtainable for certain crops such as milo,  making  this  alterna-
tive crop less desirable than others.

      Other institutions (e.g.,  marketing institutions - grain elevators,
cotton buying, etc. ) were found to have little influence on a farmer's
pest control  strategy and consequently on his adjustment response
because the farmer did not have difficulty finding a local elevator to
handle any particular alternative crop.  Nevertheless,  this is an im-
portant consideration vis-a-vis the viability of alternate crops.

      Finally, the mass media (i.e., radio, television,  farm magazines,
•farm newspapers,  etc. ) was highly utilized by  the representatives of  the
various institutions mentioned above and was heavily relied upon by the
farmer in both study sites for information.   In particular,  farm maga-
zines were utilized by farmers for pesticide recommendations.

      Overall then,  it was observed that the components of the  institu-
tional network providing the farmer with  information are quite  different
for each study site.  In the corn study site, pesticide dealers,  the
pesticide label,  farm magazines,  and neighbors, friends and relatives
were utilized most often for pesticide information.  In the  cotton study
site,  pesticide dealers, professional scouts, professional applicators,
the extension service, and neighbors,  friends and relatives were widely
mentioned for obtaining information concerning which pesticides to use
and how they should be applied. Indeed,  cotton farmers receive infor-
mation from a larger number of professional sources and this informa-
tion is tailored to their  specific pest control problems.  Whereas the
pesticide dealer in the corn  study  site was found to be the farmer's
primary institutional source of information for pesticide recommenda-
tions supplied by the extension service and chemical companies, a
number of institutions (as indicated above) were found to provide the
cotton farmer with this  information and at a more.detailed level and
on a more personal basis.

                                  13

-------
V.  THE USER ADJUSTMENT
    RESPONSE PROCESS
      In the previous chapter, a number of crop production factors and
institutional arrangements and activities were described which have  an
underlying influence on the farmer's user adjustment response process.
In this chapter,  a comparison of the user adjustment responses for each
of the two case studies is first presented followed by a discussion of
those forces influential in the adjustment process and  the important
concerns for EPA.
A.  Comparison of User Adjustment
    Responses .and Problems
      Presenting a comparative analysis of the user adjustment responses
for the two crops and sites is made difficult by the phase difference
between the two.   In the case of cotton, three years have past since the
DDT decision became effective.  Thus, sufficient time had elapsed in
order to view both the evolution and range of adjustments and problems
associated therewith.  For the corn farmers, the full impact of the
ZPA regulatory decisions lias yd Lo be leli. iu thai, carry-ovc* supplies
of similar products (i. e. , aldrin/dieldrin  and chlordane/heptachlor)
had not run out and therefore adjustment responses to date (i. e. ,  as of
March,  1976) had been minimal.

      The problematic nature of this contrast should  not be overdrawn,
however,  as  the phase difference allows the delineation of response
problems  at different stages  in the post-regulatory decision period.
Moreover, similar user adjustment response trends  that have occurred
over the three year period since DDT was cancelled appear to be
beginning  for the aldrin/dieldrin and chlordane/heptachlor  decisions.
More specifically, the user adjustment responses to  these  regulatory
actions can be categorized as follows:

           No  response to the regulatory  action (i. e. , no reaction
           to the regulatory decision because the affected
           pesticides were not used);

           No  change in current pest control practices (i. e. ,
           continued use of  the banned pesticide);
                                14

-------
           Use of new chemical pesticides (i.e. , switch to
           alternatives to the banned pesticide);

           "Take a Chance" (i.e. , attempt to grow the study
           crop without the use of any insecticides for the
           problem pest); and

           New practices  to pest  control, e.g.:

           . .  Use of early to moderate maturing varieties
               and/or  early planting to reduce the  damage
               from the problem pest;

           ..  Reallocation of crop acreage (i.e.,  switch to
               alternate  crops );-and

               Intensive  use  of scouting .with contingent use of
               rescue  insecticides when necessary and use of
               other practices  designed to minimize pest popu
               lations  (such as beneficials,  stalk destruction,
               etc. ).
It SaGulu ue emphasised uiaL Cue be categories aie not necessarily dis-
joint empirically,  but rather are offered as a means of conceptually
organizing data from corn and cotton farmers.  That is,  farmers may
have simultaneously exhiuited more lhaii one adjustment  response
described above or may have switched from one response to another.

      Exhibit V. 1 on the following page presents a summary of the
adjustment responses and key problems voiced by farmers and other
community sources as adjustment response concerns.  Also presented
are the derived resource contingencies underlying these  response con-
cerns, the types of farmers  (from both a production/pest control orien-
tation and a resource class orientation) exhibiting each user adjustment
response and the  institutional inducements for each user adjustment
response.  The reader should also note that throughout the exhibit, the
phrases utilized wer chosen  so that they would (hopefully) succinctly
summarize, and be reflective of, the key similarities and differences
found in the two study sites.

      In reviewing this exhibit, it is significant to point out that an
attempt is made to associate a production planning management orienta-
tion within a pest control  orientation.  Although this combined orienta-
tion offers some explanation to user adjustment responses and problems,
                                 15

-------
EXHIBIT Y. li  Summary of Regulatory Adjustment Response
              • nd Probleme Perceived by r>eati«.de (/••»
laer Adjustment
lesponae to KPA
'No change" In cui-
•tnt pesl control
lorn-use of aldrln;
or colton-uac of
DOT)*.
•New chemicals"
icplachlor and
col ton -use of
and atdr.n).
'Tkko a fh«ace"



practices"
1) RcaLlocation of
(e. g. . corn sKift
«hcal and/or
shifting to soy-
beans).
2} Pesl avoidance
planting prac-
tices (use of
early to
moderate matur-
ing varieties
and/or planting
earlier).*
3) Intensive use
of scouting.
,
Consensus ••( Key
PruMerns Vulred
Other Community
AJ)uiltiirn|
Supply shortages
anij higher prices
duct (I.e., atdrtn).



IncrsaaeJ debt/

problemi. Recall-
bralion of cquip-
live tfficacy.
Replanting may be


planting. Weather
may preclude
rcpUnling. The
Inability to replant
. ', .
may Incrcajc debt
liability
duct ion technology
of alternate crops.
tu alternate crops.
rnk in (rowing

drained mfflcicnl-
ly by early spring
before planting can
proceed.
Not applicable.
Ltirn Mh

Underlying Cnn-
Usor Arijusinient
Personal resource
slrfrm. Cunfuund-
Ing conditions*
lnfl«llon.
llmilalian.i


ing payment within
30 dlys of jhip.
m«nt. pesticide
difficulties in
getting new chemi-
cals from distrl-
buto r s . Confound •
tng eondi'ions*
petroleum crunch,
He- June L riavuixc
limitations


founding condi-
tions, weatner.
lir-.itations. time
available for
ne'ic.cnt sVi.1
crop Insurance
and marketing
facilities.
ditiona* wcAthor
(spring rain
levels).
Practice is with-
out hlslory or
tnatltutlonal
basis In study
site. Rescue
Insecticide* srr
not flocked.
The value of the
approach Is
qurstlonfd by the
vice and agricul-
tural eatMMiiicnt
*lv '•'*•

R««|ton«ei Pro-
ductiiin/l'esl
Cuntrul
Orlrniatinn
"Moderate
Advance llaniuny
Ortentatian" (nan-
conti gent Uier
product).
"MLilnul

Orientation" (rton-

"Muuinal
Advance Plaru.ing
Management
Orient tion ( on

product).
Advance Planning
non-contingent
duct).
Advance Planning
Management
Orirnutlon" (both
non*contiiigenK
and eonlmeent
users of restrict-
ed product).
No farmers
anticipated mak-
ing this response-
nor had any made
II previously.


ttienl Iles|ions« ami


Resource classes*
medium to hi$h
Institutional imlui.tr
me s e c 10
Micndaiions lu use
sny carry-over
supplies, kjiowlcdgi
of dealer* stock-
piling aldrm.
credil sources
enpecUlmns Uiat
pesticides will be
used.
Resource classes

Inslitutlo ial induce
alternate chemical
expectation* that
pesticides will be
used.
Iloiourcc elassei,
low and rneduT*



reacue injrcti-
cides; lack of
suggested aherna-
1
(letource elasaei:
medium to high
me-Ui dealer
clda, knowledge of
drought conditions
governing i orn.
high reiourca
farmers.
Not applicable.
Col tun .Sludy bite

Uiher Cuiiimuiiiiy


Supply shortafes
and higher prices
nr^'KiCl (t. e..
L>UT}.
bupply shorugca

Critical timing of
coinpheatiois due
Increased debt.
Not applicable.
'
V.iost «ould prefer
to renuin "eottoo
men i sitting idle
and poisiuly

drained •ut/iclent-
ly by *irly iprlsig
before planting ear
proceed.
Supply ihartj««.
and Increased
coita of new pestl'
timing of applica-
tion*. Handling
problems due la
• cutely tonic sub-
stitutes. Cnm-
bicteasvd d«bt.

Underlying C.iin-
Usrr Adjustment
Prrsnnal resourci
Iniiitafinna.
facilities limita-


Pi.rsofial reaourei

deficiencies.
• Confounding eon-
petroleum
crunch, inflation.


professional
scouls, and some
deal«ra.
Personal resourc
Utnitattons.
Inititutional con-
strainti: losi of
la not producing
availability.
Confoundmi con-
ditional *v«»thcr
(aprlng rain
levels).
Personal
reiource llml-
(Ic/tctcncir a.
Inilitutlona | con-
to "tame -day1*
c f op Hu«lin*t
fOMndlng condi-
tional petroleum
crunch; Inflation;

AUjiislnienl
l(i***,ibii«e: I'ro-
Cotitrnt
Or it ntation
Moili "Advance

(adopters of new

mat Ad\ance
fanning Manage-
ment Oricntaiiun"
(pesl control
tiadltionahst).
"Minimal Advance
** F „




response.
Doth "Minimal
Ad%ancc Planning
trol traditionalist)
and "Advance Plan-
Ont.nta.:ion"
pest control prac-
tices). The latter
group trmnorarily
shifted some (not
all) cotton acreage
lo soybeans due
to the market
alump In cotton
prices, the poor
cotton yields in
the lower produc-
tion costs associ-
ated **UK soybeans
"Advance Planning
(adopters of new
p«st cootrot
practices).
Orient* II nn"
peat control
practice*).

Ing Us*.r Adjust-
nirnl ltr*ifinnjie ami
.MNllluliunal lnin*jucenirnta

plir i bf llie
rcitricled p-nduct.
Resource cla...
eouree
lional inducement!*
application services
and aecuts.
Nat applicable.
i
Resou rce cla 3 j
hi^h and low
men's crcd.t
organizations
loan condition.
Resource clas»-
hlRhcr resource
lional inducement).
advice from exten-
• lon service agent*
and prufcssional
Hecnn rrc c 1' ••
h«(lier resource
adricc from pc in -
• Ion service a^cnt*
profes «Ionjil sc aui •
• nd profrssiona)
applicators.
 •J"or
            in* calton Umi«r«. «rly la mad«f>l« nur
                                                         orl.lto da no« rtl ul
                                                                                       16

-------
a farmer's resource class is also a necessary (and perhaps a more
powerful) explanatory variable.  That is, a farmer's personal resources
-- past practices to pest control (i.e., tradition), level of financial
resources (i.e.,  cash and/or credit), information seeking activities,
sophistication (i.e., managerial skills),  and friendship ties with pesti-
cide dealers -- are linked to adjustment responses and problems.
Moreover, it is important to note that various institutional activities
either preclude or alleviate various responses and problems.  Indeed,
the magnitude or seriousness of a farmer's  adjustment problems (i.e. ,
the degree to which a particular adjustment  problem affects his ability
to adapt to a new pest control option with confidence),  was found to be
influenced by both his personal resources and the ability of the institu-
tional network to supply timely supplementary resources for responding
to a regulatory action.  Thus,  different problems and/or concerns
voiced by farmers in adapting  to a particular response can be equally
serious for different farmers.  For example, a  farmer with  good pesti-
cide dealer contacts but poor credit may find the higher prices of
alternative pesticides more serious than the limited supplies.  A
farmer who has good credit but lacks pesticide dealer contacts, may
find the reverse to be true.

      It is also significant to note that intensive use of scouting was not
a.  response found uy iaru.tji-b in uic  cum btudv site nor was ii buuuesced
for future years largely because of  institutional constraints and no prior
use of the practice. In 1975 (the first growing season affected by the
aldrin decision) most farmers interviewed either maintained current
pest control practices (i.e., used carry-over supplies of aldrin) or
used a new chemical (e. g., heptachlor) in a similar way.  Some
responded by "taking a chance" and few responded by adopting new pest
control practices.  However,  many farmers indicated that the use of
new pest control practices,  specifically reallocation of crop acreage
and/or "taking a chance", would increase in the 1976 growing season
and in subsequent years as carry-over supplies of heptachlor and
chlordane become exhausted.

       In the cotton study site,  those with adequate financial resources
and pesticide contacts were able to  stockpile DDT and maintain their
current pest control strategies for at least  the first growing season
affected by the ban (i.e., the  1973 growing  season).  Once these sup-
plies ran out, they tended to become more innovative and had by 1975
(3 years after the decision), adopted a strategy  based on a more inten-
sive use of prior scouting practices.  Other farmers unable  to stock-
pile DDT, simply began to use the new chemicals in 1973 with little
                                  17

-------
other changes and arc continuing this more traditional practice today.
In 1975,  rcallocation of crop acreage was employed by almost all farmers,
particularly those plagued by financial problems.  However,  this
response was not solely because of the DDT decision as indicated in
Exhibit V. 1.

      Thus, it is significant to note that the use of a banned pesticide
tends to  persist until the supply runs out and the supply may have been
augmented by the individual farmer (i.e. , stockpiling of the banned
pesticide is common).  When the favored (banned) pesticide is no longer
available, a common first adjustment has been to simply substitute an
alternative pesticide for the banned pesticide.  Less likely is the adop-
tion of new pest control practices, e.g.  , a major change in pest manage-
ment strategy (such as intensive scouting if not used before) or a change
in the crop grown.
B.    Influential Forces in the User
      Adjustment Response Process
      In the above section, a number of factors were indicated as having
a key intluenre on the user adjustment response process.

      Knowledge that a  regulatory action is pending or has actually
occurred is, of course, a precondition to the response process.  More-
over, the current study found that such knowledge is highly correlated
to the current use of the pesticide affected by the decision (e.g. , aldrin/
dieldrin, chlordane/heptachlor or DDT).  Farmers who have never
used or have not used the pesticide in recent years tend to know nothing
or very little about the  pending or actual regulatory action; this phenom-
enon was found in the corn study site but not in the  cotton study site for
reasons cited earlier.  Those who have used the pesticide tend to know
little about a pending regulatory action (unless information is  supplied
to them by knowledgeable sources with whom they come into contact
with,  e.g. , the extension service); rather they hear and learn about the
actual regulatory action via the news media, in farm magazines and
(more so) when they come into contact with  their pesticide dealer and
find that carry-over supplies of the pesticide are or will be scarce.

      That is,  farmers do not become fully  knowledgeable of a regula-
tory action (i.e., receive detailed information, take the message
seriously and attend to  it) and view it as being problematic until they
                                  18

-------
have difficulty in getting what they used to use (i. e., the banned pesti-
cide).  Therefore,  farmers tend to do little experimenting with alterna-
tives until carry-over supplies run out.  Some pro-cancellation  experi-
menting with alternatives to DDT was indicated in the cotton site,  but
primarily as a result of insect resistance  to DDT and not the knowledge
of a pending regulatory action.  Hence, pesticide supply appears to be
the primary stimulus for the farmer to change his  pest  control and
production practices and not awareness of a regulatory  action itself
(i. e. , hearing "something" about a pesticide "regulatory action).

      The various changes in production practices  (i.e., responses)
that the farmers employed have been described in Cection A.  Again,
important considerations for the individual farmer in determining  his
response are his personal resources, e. g. , his past practices to pest
control (i.e., tradition), his financial resources (cash and/or credit),
hie information  seeking  activities, his sophistication (i.e. , managerial
skills),  and  his  friendship ties with pesticide  dealers.   Those  farmers who
heard of the ban through the news media and stay in contact with infor-
mation sources  such as  the extension service, have good dealer contacts,
and have adequate financial resources, * were best able to stockpile
the banned pesticide in order to maintain their current pest control
practices.   Indeed, some dealers contacted their long time better  cus-
tomers  shortly after the ban was announced to warn them that carry-
over supplies were tight and tu ui^e  Llitiu  to place  their orders early.

      Those unable to  stockpile or locate a source  of the banned pesti-
cide when the growing season approached was forced to adopt an alter-
nate strategy.  A farmer's personal  resources  and his ability to absorb
a succession of  poor crop years,  i.e. , poor crop yeilds, are again
important considerations in the response chosen.  The smaller, lower
resource farmers tend to respond in the way  that is least costly and
least risky to their overall crop production process.  This may  involve
simply a pesticide  substitution (e.g. , aldrin to heptachlor), or in some
cases a crop substitution (e.g.,  cotton to soybeans).  The latter
response occurs if the crop production costs  are significantly lower
with another crop and  if growing the  alternate crop is less risky than
growing the former crop without the  banned pesticide.   The larger,
higher resource farmers on the other hand, who can more easily absorb
a poor crop year will utilize alternate pest control strategies  (e.g. ,
      *This description fits those who are typically the larger, more
established and higher resource farmers.
                                 19

-------
intensive use of scouting) which arc more costly and possibly more
risky.  However,  the high resource farmers, who arc more likely to
take risky options than the low resource farmers, also tend to have
access to a wider range of information  sources and  so arc more likely
then their less affluent neighbors to adapt in a fashion they regard as
successful, regardless of the  response  option chosen.

      However, the study found that the institutional network within
which the farmer has to operate is critical both for  dictating available
response options as well as  alleviating  associated problems.  When
faced with replacing a banned  pesticide, the  farmer looks to the insti-
tutional setting to provide an answer just as  he docs when he is faced
with a pesl resistance situation.  That is, the buildup of pest resistance
to a particular pesticide has,  in the past, initiated cooperative research
activity from numerous institutions (e.g., agricultural experiment
stations, extension  services,  chemical  companies,  etc. ) to develop
alternative pest control strategies (chemical or other) for the problem
pesticide and to disseminate these alternatives to the farmer through
his local information sources  (e.g.,  the pesticide dealer).  In addition,
pest resistance to certain pesticides has created new institutions (e.g. ,
professional scouting, professional pesticide application, etc.) to help
in this adjustment process when necessary.

      The withdrawal of a pesticide calls for this same  type  of respon-
siveness from these same institutions; however, the time factor can be
more critical with a pesticide  regulatory action, in  that pest resistance
to a pesticide is noticeable and usually evolves over a long period of
time, whereas the knowledge of a pesticide regulatory action may not
be known far in advance and  will impact in a  shorter time period.
Moreover, the withdrawal of a pesticide may increase the risk of grow-
ing the crop sufficiently to warrant a crop substitution.   In this case,
the institutions' ability to provide services similar to those that they
provide for other crops (e.g.,   educational information, operational
loans, crop insurance, markets to sell  the crop), is important if crop
substitution is to be a viable alternative.

      Consequently, the available response options open to a farmer
and the ease with which he can adjust to a pesticide  regulatory action
are, most  definitely, dictated  by institutional responsiveness and insti-
tutional foresight vis-a-vis EPA regulatory decisions.  Indeed, it
appears that certain historical production conditions bearing on produc-
tion related institutions of each study crop, have rendered farmers
for one study  crop (i.e., cotton) better  able to cope  with pesticide
regulatory actions than farmers for the  other study  crop (i.e. ,  corn).
                                 20

-------
      Finally, the user adjustment response process is contingent upon
noncontrollablc and/or confounding conditions unrelated to the regulatory
decision and the actions of farmers and organizations at the community
level.  For example, pesticide supply shortages caused by a petroleum
crunch, inflation, weather, market conditions and levels of pest infesta-
tion, all influence both the response options open to farmers and the
subsequent problems that may develop.  Nevertheless, the nature  of the
relationships between the farmer and the various institutions will, to
varying degrees, mitigate or  soften the effects of these otherwise
uncontrollable conditions  in the production operating environment.
C.    Important Concerns for EPA
      In reviewing the farmer adjustment responses and problems and
the influential forces associated therein,  a number of conclusions are
pertinent for providing EPA with a better understanding of the process
associated with replacing a banned pesticide in the short-term (i.e.,
within a three year time period):

      .     Although farmers may become aware (i.e., "hear
           something") of a pesticide regulatory action near
           llic time Feolcral decisions arc made via the ne>"s
           media, they do not necessarily act on this infor-
           mation (i.e., take the message seriously, attend
           to it, solicit and receive detailed information,  etc. ).
           Indeed,  the regulatory restriction does not become
           problematic until carry-over supplies of the banned
           pesticide become scarce.  Thus, little experiment-
           ing with alternatives is done prior to this time and
           no preparatory or anticipatory adjustments are made.

      .     The initial user adjustment response amongst farmers
           is usually an attempt to maintain their current pest
           control practice  and hence they continue using the
           banned pesticide.  Indeed,  many farmers augment
           their supply by stockpiling and are encouraged to do
           so through advice received in the community-based
           institutional service network.

      ,     User adjustment responses that simply entail the
           substitution of the banned pesticide with a new
                                21

-------
chemical arc also fairly common,  but the adoption
of new pest control practices not utilized in the
past (e.g., alternate crops, intensive use of scout-
ing with contingent use of rescue insecticides, etc. )
are met with greatest resistance by the farmer and
are usually only adopted by the larger, more esta-
blished and higher resource farmers in the short
term.

These  user adjustment responses are not without
their reported difficulties by farmers.   Most of  their
concerns center around matters that could inhibit
yield and profit; less concern for health or environ-
mental side effects is apparent.  The following user
concerns are in evidence:   pesticide shortages,
increased cost and reduced efficacy of alternate
chemicals  (the latter partially caused by improper
application) resulting in increased production costs,
reduced yields, reduced income and increased debt;
allergic reactions and the lack of institutional ser-
vices for alternate crops; and institutional constraints
and prior practices precluding adjustment  responses
involving :icv/peel centre! pre.cl.icec (e.g., intensive
use of scouting).

Farmers look to an institutional service network in
their surrounding community for alternate courses
of action when faced with replacing a banned pesti-
cide (e. g. , the extension service, the  agricultural
experiment stations, chemical companies, pesticide
dealers, lending organizations, professional scouts,
neighbors, friends and relatives,  etc.).  However,
institutional constraints which impede  responsive-
ness to the pesticide regulatory action can preclude
otherwise possible responses by the farmer.

A farmer's past practices  (i. e. , tradition) and his
beliefs about what kinds of  pest control strategies
are effective for a particular pest, influence his
adjustment responses in the sense that they restrain
the range of attractive options.
                      22

-------
           Financial resources (e.g., cash and/or credit) also
           constitute a  significant attribute wilh respect to a
           farmer's response and problems associated there-
           with.  That is,  those farmers that can weather one
           or two poor  crop years  while the community based
           support  institutions seek viable  alternatives to the
           banned pesticide are least likely to have serious
           adjustment problems.

           Noncontrollablc confounding conditions such as
           inflation, the weather, fluctuating market conditions
           for alternate crops, prior and expected levels cf pest
           infestation,  and pesticide shortages caused by raw
           material shortages (e.g. , a petroleum crunch), all
           influence both a farmer's response to a pesticide
           regulatory decision and the  subsequent problems that
           may develop.   Nevertheless, the nature of the rela-
           tionships between the farmer and the various support
           organizations will,  to varying degrees,  mitigate or
           soften the effects of these otherwise uncontrollable
           conditions in the production operating environment.
           Hence,  the i~c.gr.itudc c.i- seriousness of a
           adjustment problems (i. e. , the degree to which a
           particular adjustment problem affects his ability to
           adapt to a new pest control option with confidence)
           is influenced by both his personal resources (i.e.,
           past practices to pest control, financial resources,
           information seeking activities,  managerial skills,
           and friendship tics with pesticide dealers) and  the
           ability of the institutional  service network to pro-
           vide timely,  supplementary resources for respond-
           ing to a regulatory action.  Curiously, the extent
           of intcrphase  of these two resource factors  means
           that adjustment problems  can be equally serious
           for different farmers in the same geographical
           locality.

      In summary,  a period of three years appears to be a reasonable
definition for describing "short term" transitional user adjustment
problems. This  study found that during the first growing season
affected by a regulatory action, many farmers will attempt to "buy
time" by stockpiling the  banned pesticide.  For  some farmers,  such
                                 23

-------
stockpiles may be sufficient to carry them through the second growing
season as well.  However, in the third growing season affected by a
regulatory action, few carry-over supplies of a banned pesticide exist
and, thus, most, if not all, farmers arc forced to make an additional
adjustment response.  Nevertheless, the available response options
(i.e., alternate pest control  strategies),  the  extent to which each is
chosen, and the difficulties anticipated in adopting each option are, of
course, influenced by a complex set of personal and community institu-
tional resource  conditions.  Therefore, the response  options open to the
fanner and adopted by him in the "short term"  (i.e. ,  three years) will
vary both between farmers of the same commodity sector, as well as
between farmers of different commodity sectors.
                                24

-------
VI.  RECOMMENDATIONS
A.    Procedural Recommendations for
      Pesticide Regulatory Actions
      In light of the discussion in the proceeding two chapters,  a num-
ber of activities should be incorporated into EPA's benefit/risk analy-
ses (particularly those performed as part of the rebuttable presumption
against registration (RPAR) process),  in order to determine the local-
ized (i. c., county level) potential short-term  adjustment problems
when an EPA regulatory action is contemplated.

      Initially, the knowledge bases relative to the target pest, alter-
native pest control strategies and alternative  crops in question need to
be assessed as these are the critical areas that dictate adjustment
responses and problems.  Key factors related to the target pest are the
degree to which the basic etiology and  epidemiology of the pest is  known
by the research institutions.  In addition, the  real viability of alterna-
tive pest control strategies needs to be viewed in terms of:

      ,    The t'inanria) and siciii reouirements for a.ctiviiies>
           contrary to pa'st practices  (e.g. ,  scouting of fields
           for insect damage when the practice is without
           history or institutional basis, use of rescue insecti-
           cides when preventive type insecticides were com-
           monly used previously,  planting of -early maturing
           crop varieties, etc. );

       .    The need for services in the local institutional setting
           that are currently unavailable  (e.g. , professional
           scouting, professional pesticide application,  chemical
           company incentives to market pesticides for alterna-
           tive pest control strategies,  stocking of pesticides
           not previously carried by pesticide dealers, etc. ); and

       ,    The conditions under which control of the target pest
           is tenuous (e.g., heavy pest infestations, pest resistance
           to alternative pesticides,  etc. ).

Furthermore, the  real viability of alternative crops needs  to be viewed
relative to:
                                25

-------
      .     Requisite skills and knowledge;

      .     Machinery;

      .     Educational information services;

      .     Marketing structure;

      ,     Lending institutions;

      .     Crop insurance; and

      .     "Other" (e.g.,  potential for allergic  reaction).

      That is, in reviewing the real viability of alternative pest con-
trol strategies and alternative crops in terms of  the above dimensions,
an overall assessment of the existing  institutional service network and
the interrelationships between its components must be made vis-a-vis
their activities on these  dimensions, since farmers  rely on this net-
work when seeking alternate courses of action when  faced  with replac-
ing a banned pesticide.   Indeed, regulatory decisions must be contem-
plated with recognition of the  fact that there are real differences in
inctiUitiO!i?l ?nd, therefor?, farmer coding capacities;,   it i q al
-------
(according to estimates received in this study) if little work prior to
the ban has taken place.  In this instance, much lead time would be
needed and a strong signal must be sent to the appropriate  institutions.
On the other hand,  if an alternative crop is not viable simply because
crop insurance is unavailable, this may be corrected much more readily.

      However,  simply sending these "signals" may not be sufficient
to counteract a "business as usual" attitude on the part of the institu-
tions.  Thus, consideration must also be given to providing financial
and technical resources to these institutions to insure  that  they can and
will react in a way that will serve the best interests of the  farmer.

      Finally, in view of the 1975 amendments to  FIFRA and  the
corresponding FY '77 appropriations in pesticide  to USDA, it is not
appropriate to imply that EPA "should  consider doing everything"
indicated here.  Rather the EPA,  the USDA and the appropriate state
agencies should cooperatively effect the recommendations indicated
above.  Additional comments in this area are provided in Section B
below.
B.  Areas for Future Work
      The preceding topics may be viewed as potential components of
a model of the local agricultural system and its processes.  In order to
better understand the potential impact of future regulatory decisions,
the development of such simulation models would be highly instructive.
Indeed,  the exercise of developing such a model could be as useful as
the operating model itslef.  In sum, the learning experience during
the empirical phase of this study indicates the need for further theo-
retical work.

      More specifically, in light of the user adjustment responses  and
problems found in this study, a number of areas for future work that
would have optimal policy benefit to EPA can be suggested:

      .     An understanding of why certain institutional service
           networks can be  more responsive than others  in facili-
           tating the user adjustment response process should be
           determined. This study has implied that historical
           production conditions involving a pest that is a wide-
           spread threat to  an economically significant crop for
                                 27

-------
           which control has never been simple, tends to
           stimulate the appropriate institutional responses.
           This hypothesis should be further explored (e.g.,
           a comparative study of agencies operating in vari-
           ous  commodity sectors would be appropriate).   In
           so doing, ways to make institutional networks more
           responsive can be delineated, including technical
           assistance and financial assistance.

      .     Mechanisms to promote experimentation (amongst
           farmers) with alternatives  (chemical and  other) to a
           pesticide that is likely to be banned should be explored
           so that some preparatory or anticipatory  adjustments
           can  be hoped for,  rather than simply attempts to "buy
           time" by stockpiling the banned pesticide  once the
           regulatory action has  been  taken.

      .     Ways  to assist farmers in adjusting to the impacts of
           a regulatory decision  (particularly those farmers with
           limited resources) should be explored,  including tech-
           nical assistance as well as financial assistance.

      In pursuit of these activities,  it in again not appropriate to imply
that EPA should consider doing everything mentioned  above.  EPA,  in
cooperation with the USDA and the appropriate state agencies, should
embark on these areas.  Furthermore, to insure that each agency is
participating in  an optional way, additional  research may be appro-
priate to determine the capabilities,  resources" and preferences of
each.  Thus, EPA should explore, with the USDA and the appropriate
state  agencies,  the responsibilities each should take in mitigating short-
term  agricultural user adjustment problems.
C.  Methodological Concerns
      In addition to the preceding recommendations, the following
methodological discussion is of worth.  The experience gained in the
contrasting  styles of work during the first week of field work in the
cases of cotton and corn is instructive.  That is,  in the cotton case
study, the two days of meetings with state level people in  both the
extension service  and research station prior to entering the study site
were very helpful for various reasons:
                               28

-------
      .      The "quick education" regarding cotton culture and
            pest problems gave depth to information previously
            gained through readings;

            Having met with the "elite" served to legitimate the
            field leam in the eyes of people at the county level;
            and

            Subsequent contacts with state people elicited respon-
            sive cooperation on numerous occasions.

Hence,  the overall style of the first week's effort in Louisiana seems
worthy of emulation  in future  efforts.

      Moreover,  the use of a  very, flexible ethnographic design in the
current effort seems well justified in terms of two points:

            If a traditional survey research undertaking had been
            utilized, an understanding of the user adjustment
            response process would have been obscured due to
            the rigid nature of the research questions and the
            design that would  have necessarily been dictated;
           Much of the most important information (in terms of
           the conclusions generated)  came from people other
           than farmers.

      The conjunction of the above  two  points makes  clear that the num-
ber of respondents  will not be predictive of the quality of the results.
What is important is the depth and  mix of relevant data sources (includ-
ing personal interviews), such that the production system and its
operating environment are understood.  Hence, an emphasis on gather-
ing data concerning  relevant institutions is appropriate -- which is not
to say, for example, that every banker in a county needs to be inter-
viewed.

      CONSAD is confident that sufficient learning has been accrued in
the process of the current study that significant efficiencies can be
effected in similar,  future studies.
                                 29

-------