US IPM Standard: Pro-Poison, Pro-Big Business

guymayor

Branched out member
Location
East US, Earth
After Monday August 25, Public Comments on the Integrated Pest Management Part 10 Draft will not be accepted. This is your last chance to advocate for a balanced IPM Standard that gives equal attention to cultural and biological means of managing pests. If you are happy having our industry dominated by big corporations, and seeing piles of dead bees as the face of IPM in the US, read no more.

The current draft focuses on chemical applications by large companies, like the company responsible for the big bee kill in Oregon. That’s who wrote it, so that’s who will benefit. This draft includes not only IPM but also A Guide for Big Companies to Set up and Operate an IPM Program. This does not apply to many users: agencies, smaller-scale operations, or individuals. If it’s in the standard, bigger companies with a more formal program would enjoy an even greater competitive advantage.

Cultural and biological methods are thrown aside with the weakest language possible: ‘Consideration should be given to…’ This document needs better balance, to ensure that the standard fits ecosystem-friendly approaches. Other suggestions in the copy below are to follow chronological order, simplify wording, and streamline the process.
IF you are an individual practicing less toxic pest management, the only way to avoid having the rules rigged against you is to review this draft and comment to rrouse@tcia.org. If you are associated with any of the below committee members, please comment to them as well.

Bartlett Tree Experts -pbecker@bartlett.com
Asplundh Tree Expert Co. gkemp@asplundh.com
Davey Tree Expert Company chris.klimas@davey.com
Tree Care Industry Assn. tmugridge@forestcitytree.com
PLANET Alice Carter acarter@valleycrest.com
Society of Municipal Arborists Nolan Rundquist nolan.rundquist@seattle.gov
International Society of Arboriculture Richard Hauer, PhD rhauer@uwsp.edu
American Society of Consulting Arborists: Torrey Young torrey@dryad.us
Professional Grounds Management Society: Gene Pouly gpouly@efpouly.com
Utility Arborists Association: William Rees (410) 291-3633
USDA/US Forest Service: Ed Macie (404) 347-1647
Alliance for Community Trees carrie@actrees.org

A300Part10-IPM-Drft1-V1 140821
 
little late on the notice Guy,
And thanks ... this is important..
was it Einstein that said without bees, humans would last only 8 years on the planet???
not to mention the whole fascist thing...

Specifically what changes are your recommending.. Would be nice to see your letter to give us something to work from..
 
Dan, you might need Adobe Acrobat Reader; no tricky downloads, just the basic package.

An example: instead of just hinting at this stuff and burying it on page 12, it should be way back up with the resource assessment.

“Consideration should be given to the conservation, introduction,and /or augmentation of natural predators and parasites of pests on the site

Consideration should be given to installing plant species that promote predators and parasites of pests.

Consideration should be given to cultural approaches to maintaining plant health such as, but not limited to, pruning, improving soil conditions, mulching, and irrigation.”

This should be at the top of page 10:

“The site shall be assessed for conditions that benefit pests, such as water drainage, light and air movement, … and all reasonable options reviewed for cultural approaches to maintaining plant health such as, but not limited to, pruning, improving soil conditions, mulching, and irrigation.

The site shall be inventoried for natural predators and parasites of pests, and options reviewed for their conservation, introduction, and /or augmentation.

The site shall be inventoried for plant species that promote predators and parasites of pests and/or contribute to plant health, and options reviewed for their conservation, installation, and /or augmentation.”

See the difference? Without changes like this, anyone offering less-toxic tree care is at a competitive disadvantage. A300 says they set the parameters of what is acceptable practice in the USA, so if your work is not recognized, you will be outmarketed and outbid by Nozzlehead Nation--unless you act now to change this!
 

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