Cranberry Insect Pest

Management and Karner Blue

Butterfly Protection:

A Wisconsin Case Study

Kenneth D. Racke, Dow AgroSciencesLori Bowman, Wisconsin DATCP

Cathy Carnes, USFWS

Cranberry Insect Pest

Management and Karner Blue

Butterfly Protection:

A Wisconsin Case Study

Transferable lessons from the case which led to development of the first

modern EPA ESPP county bulletins

Topics

Cranberry pest management and

protection of the Karner blue

Intrepid® 2F and cranberry use

Registration approval

ESA consultation

Reflections

Wisconsin Cranberry Agriculture

18,000 acres (2010)

47% of US market

Value: $189M

Photo: Courtesy of Wisconsin State Cranberry

Grower Association Map: Courtesy of Wisconsin State Cranberry

Grower Association

Wisconsin Cranberry Agriculture

Low-lying vines in beds layered with sand, peat, gravel and clay of glacial origin.

Commercial bogs – irrigated during season with flooding at harvest (ditches, flumes).

Cranberry Pests and Management

Pest management practices

IPM, foliar insecticide sprays

Historic: Broad-spectrum products such as acephate,

azinphos-me, Bt, chlorpyrifos, carbaryl, diazinon

Photos: Courtesy of Univ. of Maine, BC

Cranberry Growers Assoc., Big Sky Institute

The Karner Blue Butterfly (KBB)

Lycaeides melissa samuelis

Lepidoptera (1”)

Life cycle: 2 gen/year

Larvae feed on wild lupine

Most populations occur in WI and MI

Decline primarily due to habitat loss, fragmentation

ESA listed in 1992

Map and photos: Courtesy of USFWS

The Karner Blue Butterfly

Wisconsin Habitat Conservation Plan (HCP) of 1999 (updated 2010)

>260,000 acres

Growers members via DATCP

USFWS BiOp of 1999

No jeopardy from agriculture via HCP

Incidental Take Permit (ITP) for HCP and pesticide use

Provisions for expansion of ESA Sec 7 coverage Map: Courtesy of USFWS

Topics

Cranberry pest management and

protection of the Karner blue

Intrepid® 2F and cranberry use

Registration approval

ESA consultation

Reflections

Intrepid® 2F

AI: Methoxyfenozide

Insecticide

Narrow activity spectrum

Lepidoptera

Molt-accelerating compound (MAC)

Mimics the insect molting hormone ecdysone

Class received Green Chemistry Award 1998

Intrepid® 2F

First registered by EPA in 2001

Pome fruit, cotton

Key regulatory properties

Low mammalian toxicity (<5,000 mg/kg)

Low toxicity to birds, fish, earthworms, honeybees

Stable to hydrolysis, photolysis in water

Moderately persistent in soil (Field DT50 92-327 D)

Slight-to-moderate mobility in soil

Designated by EPA as a “reduced risk/OP

replacement” priority

Intrepid® 2F

Ecological risk – screening-level assessment

Some level of concern for non-target aquatic

invertebrates

Label mitigation: 150 ft aerial spray buffer, 10 ft VFS

Endangered species assessment – apples (2000)

“Likely to impact” 3 insects

Valley elderberry longhorn beetle (CA)

Hine’s emerald dragonfly (WI)

Karner blue butterfly (IL, IN, MI, MN, NH, NY, WI)

To protect the Karner blue butterfly, do not apply within one

mile of sandy habitats that support wild lupine plants

Intrepid® 2F and Cranberry Use

USDA IR-4 minor crop program (’99-’02)

Black headed fireworm, sparganothis fruitworm

Residue field trials completed

New use petition submitted to EPA in 2002

EPA classified “reduced risk” vs. alternatives

EPA approved new use in 2003

Existing use restrictions for apples in WI and MI

were carried over to cranberry use

1-mile buffer to wild lupine habitat

Intrepid 2F® and Cranberry Use

The problem: Growers had no way of knowing whether sandy habitats

supporting wild lupine were within one mile of cranberry areas

Therefore, in order not to violate ESA, growers avoided use of Intrepid 2F and continued to use broad spectrum insecticides

Grower requests to WI DATCP and USFWS in 2005 for revised label mitigation

USFWS request of March, 2007 to EPA for action based on interests of growers, WI DNR, KBB HCP Coordinator, and WI DATCP

For KBB sites near agricultural land, recommended modified label mitigation:

1-mile buffer to apply except on land where ITP has been recognized as a result of the HCP

Suggested EPA initiate Sec 7 consultation

EPA Interim Assessment (2006)

Screening level assessment indicated use of

Intrepid 2F on cranberry was “Likely to

Adversely Affect” KBB within 5.4 miles

Discussion of alternate drift control

measures

Windspeed restriction, lower spray boom

height, coarser spray nozzles, use of spray

drift retardants, limit application to midday

Intrepid® 2F – Karner BB Consultation

EPA formally requested Sec 7 consultation of USFWS in Jun-2007

USFWS reply of Mar-2008 Use covered by KBB HCP Incidental Take Permit

Alternate mitigation recommended based on grower inputs

Ground application only, coarse droplet sprays, drift retardant

Apply when wind direction away from known habitat unless wooded vegetation barrier

Cranberry Institute pressed for action by EPA

Growers continued spraying older products

EPA Endangered Species Protection

Program (ESPP)

County bulletins

Growers referred to

website from product

label

Bulletin provides

Map showing affected

area

List of specific

restrictions for a given

pesticide

EPA Development of ESPP Bulletins

for Karner Blue and Intrepid® 2F

EPA discussions with stakeholders led to near-final draft bulletins in January, 2009

EPA provided to registrant via email

21 draft bulletins

Maps

Bulletin restriction

Label referral statement

Bulletins final ~May, 2009

Label Referral Statement for

Intrepid® 2F

Endangered Species

The following applies to use of this product in Michigan (6 counties) and Wisconsin (16 counties). When using this product, you must follow the measures contained in the Endangered Species Protection Bulletin for the county in which you are applying the product. To obtain Bulletins, no more than six months before using this product, consult http://www.epa.gov/espp/ or call 1-800-447-3813. You must use the Bulletin valid for the month in which you will apply the product.

ESPP Bulletin Restrictions for Karner

Blue and Intrepid® 2F

Do not apply this product within the pesticide use limitation area, unless (1) you are a partner to the Wisconsin Statewide Karner Blue Butterfly Habitat Conservation Plan (HCP) who is authorized to use the pesticide or (2) you are included under the HCP 'Voluntary Participation Category', which includes all agricultural lands, activities, or uses in Wisconsin

Pesticide application within the pesticide use limitation area is limited to: Ground application methods or chemigation Spray drift retardant Nozzles that produce a coarse droplet size distribution

(median droplet size of 450-500 microns) Wind speed between 2-10 mph

Current Status of the Situation

With revised labeling and ESPP bulletins in place, Intrepid 2F is now utilized by growers as integral part of cranberry insect pest management

Cranberry production is growing in WI

Karner blue butterfly populations are stable

The 21 county bulletins developed for Intrepid® 2F in WI and MI for protection of the Karner blue butterfly in cranberry are the only active EPA ESPP bulletins among 3,143 U.S. counties for more than 700 pesticide active ingredients, and for more than 1,000 endangered species

Topics

Cranberry pest management and

protection of the Karner blue

Intrepid® 2F and cranberry use

Registration approval

ESA consultation

Reflections

Reflections

First successful implementation of ESPP bulletins

as a result of ESA pesticide consultation process.

Having a statewide Habitat Conservation Plan

(HCP) in place with the voluntary participation

category helped facilitate the consultation

process.

Set up a process whereby Sec 7 coverage could be

extended to Federal Agencies involved in

programs or activities that resulted in incidental

take of KBBs on private lands in Wisconsin.

Reflections (con.)

The consultation process can work to the benefit

of both endangered species and agricultural

interests when the appropriate engagement

occurs between Federal and state agencies,

growers and registrants.

Early involvement of the FWS field office helped

facilitate the ESA Sect 7 consultation process.

WI DATCP’s involvement facilitated the

development of the bulletins and helped

coordination with EPA on the issue.

Reflections (con.)

It may be very important to determine the feasibility of proposed label mitigations on grower practices before their implementation in order to avoid unintended consequences.

Implementation of initial 1-mile buffer forced growers to continue to rely on older, broad-spectrum insecticides.

Factual information on application techniques provided by the cranberry growers to the FWS and EPA helped development of workable label restrictions for the pesticide.

Reflections (con.)

A considerable time span may be involved in

sorting out ESA-related assessment issues and

developing appropriate protections for even fairly

straightforward cases.

Cranberry Insect Pest

Management and Karner Blue

Butterfly Protection:

A Wisconsin Case Study

Thank you!