NAAA Comments in Opposition to EPA Proposed Buffer Zones for Five Insecticides for Pacific Northwest Salmon Waters

NAAA submitted comments today opposing an EPA proposed stipulated injunction that would reinstitute streamside, no-spray buffer zones in an attempt to protect endangered or threatened Pacific salmon and steelhead in California, Oregon and Washington State for the five broad-spectrum insecticides of carbaryl, chlorpyrifos, diazinon, malathion and methomyl. The buffers proposed would prohibit aerial pesticide applications within 300 feet of a salmon stream and ground application within 60 feet of a salmon stream. The stipulated injunction would settle litigation brought against EPA by environmental activist groups in U.S. District Court in Washington State, which in 2004 resulted in a federal judge in Seattle issuing an injunction imposing similar buffers to the EPA proposal.  The U.S. District Court ordered injunction recently expired.

 

NAAA’s comments to the EPA questioned the need for such an aerial buffer, especially such an arbitrary, uncompromisable buffer length.  NAAA referenced the advanced nozzles and other on-board technologies, aircraft set-up procedures, and in-flight maneuvers used by NAAA’s professional member pilots today that significantly increase droplet size, reduce the relative fraction of driftable droplets, and control the precision and width of the spray swath, thereby lowering spray drift potential. NAAA’s comments may be accessed by clicking here.

 

The EPA proposed stipulated injunction, if codified, would be part of a court order but would not be enforceable as a label requirement under the Federal Insecticide, Fungicide, and Rodenticide Act. As such, the buffers will not be included on pesticide labels until EPA implements any necessary protections for Pacific salmon and steelhead based on reinitiated consultations with the National Marine Fisheries Services in connection with its current FIFRA registration review process. Permanent restrictions may be adopted by EPA in the future after the agency reassesses the registrations for these five insecticides. There is no hard timetable for the permanent buffer regulations.

Larry Roth, an Operation S.A.F.E. Originator, Passes

Lawrence O. “Larry” Roth, the R in the original WRK Inc. and one of the creators of the equipment and procedures that formed the basis for NAAA’s Operation S.A.F.E. program, passed away June 28.

For all of his professional accomplishments, Roth remained a “Wisconsin farm boy” at heart. He attended the University of Wisconsin and earned degrees in agricultural and mechanical engineering. In 1951, he joined the agricultural engineering faculty at Oklahoma Agricultural and Mechanical College (now Oklahoma State University) in a teaching and research position. He completed his Ph.D. in agricultural engineering at OSU in 1965 and remained on the faculty for 35 years, until he retired in 1986. Roth taught classes at all levels, co-authored an agricultural engineering textbook, and supervised undergraduate and graduate students. He had sabbaticals at the John Deere Des Moines Works and at the Technion University in Haifa, Israel.

His main research involved pesticide application technology with a special focus on aerial application. Through a NASA grant, Roth and his colleagues developed the equipment and procedures that led to NAAA’s Operation S.A.F.E. program and participated in the inaugural professional application analysis clinic in 1981.

The primary purpose of the grant was to develop a technique to sample and measure spray deposition. The NASA proposal was a joint effort by Richard Whitney and Larry Roth. Although he was not an official member of the NASA project, Dennis Kuhlman became an essential third member of the team. In 1984, the three men officially joined forces by forming the company WRK Inc.

In addition to traveling throughout the United States conducting Operation S.A.F.E. fly-ins, Roth served as a UN/FAO consultant conducting pesticide application equipment workshops in some 24 developing countries in Central and South America, Africa, Southeast Asia and the South Pacific. He received numerous awards for his work, including the USDA Superior Service Award, NAAA’s Delta Air Puffer Award and the inaugural Evans-Christopher Operation S.A.F.E. Award in 2010 from NAAREF’s Operation S.A.F.E. Committee.

NAAA extends its condolences to the family of Larry Roth. His contributions to the aerial application industry are immeasurable.

NAAA Cover Crops Webinar Now Available On Demand

Last month NAAA and Practical Farmers of Iowa (PFI) hosted the webinar, “Successfully Aerially Seeding Cover Crops.” In it, NAAA pilot member Brian Berst and two Midwest cover crop consultants shared their insights, advice and strategies for effectively seeding cover crops by air. Approximately 40 NAAA members participated in the live event. The good news for those who missed the June 17 webinar is that PFI archived it, making it available on demand to watch whenever you would like. Anyone interested in learning more about cover crop applications will find the webinar to be well worth your time. Here are a few of the things we learned during this online educational opportunity.

 

For starters, cover crops could be a real boon to aerial applicators’ business. Based on present-day estimates, cover crop acres may have to increase by as much as 500 percent to reach cover crop advocates’ goal of 20 million acres of cover crops by 2020. Aerial applicators are uniquely qualified to help farmers meet their cover crop objectives because no method of application can seed more acres of cover crops within the allowable window to get good establishment more quickly than an ag aircraft.

 

The meat of the webinar began with Berst describing Klinkenborg Aerial Spraying and Seeding’s experience working with cover crops. The Parkersburg, Iowa, operation added aerial cover crop seeding to its service portfolio because there was a high demand for it in northern Iowa and it allowed Klinkenborg to extend its flying season by three to four weeks at the end of the summer.

 

From his vantage point as Klinkenborg’s head pilot, Berst shared several tips, chief among them the importance of seed selection and proper calibration to ensure the seed disperses in the correct pattern. Klinkenborg finds streamlined seed blends easier and faster to work with, and Berst recommends getting the seed mixes delivered in bulk. When a cover crop blend features a range of seed sizes, he advises determining the swath width based on the lightest seed in the blend. Soil contact, sunlight and water are essential to good establishment, but even when the seeds land on the leaves of the existing crop instead of the ground, Berst noted that wind and rain will cause most of them to fall to the ground.

 

Next, Jamie Scott of Scott’s Cover Crops in Pierceton, Ind., discussed the benefits of cover crops and why he is a proponent of aerial seeding. The biggest advantage aerial seeding has over other cover crop planting methods, of course, is time. To illustrate the importance of timing, Scott pointed out that in Indiana the difference between planting cover crops on Oct. 7 instead of Sept. 7 is that you are losing an hour and a half of sunlight and 12 degrees in temperature. Planting the seeds earlier via aerial application gives cover crops more time to establish themselves with thicker, deeper roots.

 

The formal portion of the webinar concluded with a presentation on seed selection from Sarah Carlson, PFI’s Midwest cover crop research coordinator. Carlson discussed the varieties of seeds available for cover cropping as well as what’s being aerially applied in different areas of the country. She also walked viewers through the Midwest Cover Crop Council’s Cover Crop Decision Tool, a web-based tool designed to assist farmers in selecting cover crops to include in their crop rotations.

 

NAAA extends its thanks to Practical Farmers of Iowa for hosting the cover crops webinar and all of the speakers who shared their insights about aerial cover crop seeding. The webinar concluded with a Q&A session based on audience-generated questions. “Successfully Aerially Seeding Cover Crops” is available to view in its entirety here.

New AD Issued on Certain P&WC PT6A Engines

On July 1, 2014, the FAA published a new Airworthiness Directive (AD) 2014-11-05 applicable to certain Pratt & Whitney Canada Corp. (P&WC) turboprop engines. This proposal would require installation of a reinforcement liner to the power turbine (PT) containment ring. Various models in the PT6A line are affected either as a whole model or certain serial numbers within a model. Pay close attention to the applicability list in the AD. For example, model PT6A-34AG, with serial numbers PCE-57312 and earlier as well as all engines converted to PT6A-34AG are applicable.

 

The AD was prompted by in-service events involving the perforation of engine cases as a result of the liberation of PT blades and the fracture/displacement of the PT containment ring. The AD is issued to prevent uncontained engine failure and damage to the airplane.

 

On Jan. 7, 2014, a notice of proposed rulemaking (NPRM) was issued giving the proposed action of this AD. The public was given the opportunity to comment and those comments were addressed by the FAA. As a result, the proposed compliance time was changed from 24 months to 48 months and estimated labor cost of compliance was changed to about $1,655 per engine.

 

The proposed AD would require, within 48 months of the effective date of this AD, modification of the existing PT containment ring. Use paragraph 2, Accomplishment Instructions, of P&WC Service Bulletin (SB) No. 12076, Revision 3, dated Jan. 17, 1992, or paragraph 3, Accomplishment Instructions, of P&WC SB No. PT6A-72-A1427, Revision 3, dated Jan. 27, 2012, as applicable, to make the modification.

 

The AD becomes effective Aug. 5, 2014. We recommend that you read the AD carefully to determine applicable engines and the action or actions required to comply with this AD.

Save the Date: NAAA, WNAAA, NAAREF Board Meetings: Oct. 10-12

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