State Department of Health and Environmental Sciences* Environmental Sciences Division*Solid Waste Management Bureau •Pesticides Demonstration Program , Helena* Montana FIB 8 1984 3B 1 <• 19* > t l \ •' ' A \ V IRONT^-ftA 1515 E. 0th AVE. HELENA, MONTANA 59620 The Montana Pesticide Demonstration Program is supported by contract no. 68-01-2979 with the Air and Hazardous Materials Division, Pesticides 3ranch, Region VIM, EPA, Denver, Colorado i Digitized by the Internet Archive in 2016 https://archive.org/details/advancementsinpe1975mont Table of Contents Page 1 . Speaker List. iv 2. Participant List vi 3. Keynote Address 1 Kit C, Walther 4. insect Pest Management - The Thinking Man's Pest Control 3 Leon Moore, Ph.D. 5. Nosema locustae : An Alternative Method of Grasshopper Control 16 John E . Henry, Ph.D. 6. Advancements in Herbicides 29 L . E . Warren 7. Di lemma for Disposal of Herbicide Orange ..... 65 Capt. Alvin L. Young, Ph.D. 8. A Plan for Determining Waste Pesticide Disposal Practices in EPA Region Vll! 85 Gary J . Mi hi an 9. Political Factors in Animal Damage Control . 100 Dale A. Wade, Ph.D. 10. Control of Noxious Plants Through the Application of Rest Rotation Grazing Management 120 Harry R. Gosgriffe 11. Remarks by Hurlon Ray, OFFICE OF PESTICIDES, to the Seminar, Advancements in Pesticides 131 Hurlon Ray 12. Effects of Sagebrush Control on Wildlife and Ecosystem Components - Results of a Ten Year Study 145 Eugene 0 . Allen 13. Integrated Pest Management 170 Da 1 1 as Miller 14. Some Future Pest Control Methods 177 L. Hopkins, Ph.D. 15. Zinc Phosphide - A Control Agent for Black-Tailed Prairie Dogs 189 Howard P. Tietjen 16. Registration Procedures and Evaluation 190 Herbert S. Harrison 17. Re-entry Studies in Washington Orchards and Monitoring Pesticides in the Columbia River Basin 200 Lynden P . Baum Discussions by Speakers not Submitting a Presentation for the Proceedings. 206 i i 18. Presentations not Included in the Proceedings 1. Dipel^as a Control Agent for Western Spruce Budworm Mark D. McGregor 2. Efficiency of Seven 4-Oil and Dylox for Control of Western Spruce Budworm Tom Flavell 3. EPA State Assistance Programs James Boland - Ed Stearns 4. Degradation of Pesticides in the Soil 0. D. Kaufman, Ph.D. 5. Use of Strychnine Alkaloid for Striped Skunk (Mephitis mephitis) Rabies Control and Surveillance in Eastern Montana Gary Nesse 6. Experimental Use of Sodium Cyanide Spring Loaded Ejector Mechanism (M-44) for Predatory Animal Control in Montana Ken Seyler 7. Pesticide Incineration Thomas L. Ferguson 3. Montana Applicator Certification Plan Gary L, Gingery 3. EPA Disposal Activities Harry W. Trask i i i Speaker List Eugene 0. A1 len Chief, V/ ? 1 d 1 i f e Research Section, Research Park Bldg., Department of Fish & Game, State Univer- sity, Bozeman, Montana Lynden Baum Pesticide Consultant, Washington State Health Services Division, Chemical Physical & Radio- logical Hazards Section, Wenatchee, Washington J i m Jo 1 and Operations Division, Office of Pesticide Programs, EPA, Washington, D.C. Thomas L. Ferguson Senior Chemical Engineer, Midwest Research Institute, Kansas City, Missouri Tom F 1 a ve 1 1 Leader, Pilot Project Group, Division of State & Private Forestry, Environmental Protection, Region, 1, USFS, Missoula, Montana James \7 . Gillett, Ph.D. National Environmental Research Center, Corval 1 is , Oregon Gary L. Gingery Administrator, Pesticides Control Division, Department of Agriculture, Helena, Montana Harry R. Gosgrtffe Range Conservationist, Bureau of Land Management, Department of Interior, Billings, Montana Herbert Harrison Branch Chief, Registration Evaluation Branch, Registration Division, EPA, Washington, D.C. John E . Henry , Ph.D. Research Entomologist, Rangeland Insect Laboratory, Montana State University, Bozeman, Montana Lemac Hopkins, Ph.D. Technical Advisor, Environmental Quality Chevron Chemical Company, Gan Francisco, California D. D. Kaufman, Ph.D. Microbiologist, Pesticide Degradation Laboratory, Agricultural Environmental Quality Institute, Agricultural Research Center, Beltsville, Ma ry land Mark D. McGregor Entomologist, Division of State & Private Forestry, Environmental Protection, Region 1, USFS, Missoula, Mon tana Gary J. Mihlan Research Associate, Institute of Rural Environ- mental Health, Colorado Epidemiologic Pesticide Studies Center, Colorado State University, Fort Col 1 ins , Col orado Dal las Miller State Program Manager, State Assistance Section, Pesticides Branch, Air & Hazardous Materials Division, Region VIII, Denver, Colorado Leon Moore, Ph.D. Gary Nesse Hurl on Ray Kenneth Seyler Edward L. Stearns Howard Tietjen Harry W. Trask Dale A. Wade, Ph.D. Kit C. Walther L. E. v/arren Capt. Alvin L. Youny, Associate Professor and Extension Entomologist, Cooperative Extension Service, University of Arizona, Tucson, Arizona Predatory Animal & Rodent Control Biologist, Central District Predatory Animal - Rodent Control Bureau, Department of Livestock, Lew is town, Montana Special Assistant for the Deputy Assistant Administrator of Pesticide Programs, Washington, D.C. Chief, Predatory Animal - Rodent Control Bureau, Department of Livestock, Helena, Montana State Program Manager, State Assistance Section, Pesticides Branch, Air & Hazardous Materials Division, Region VIII, EPA, Denver, Colorado U. S. Fish & Wildlife Service, Denver Wildlife Research Center, Denver, Colorado Program Manager, Pesticide Disposal & Storage, Hazardous Waste Management Division, EPA, Washington, D.C. Extension Wildlife Specialist, Agricultural Extension, University of California, Davis, Cal i forn i a Pesticide Disposal Demons trat ion Program, Solid Waste Management Bureau, Department of Health and Environmental Sciences, Helena, flontana Field Research and Development, Ag-Qrganics Department, Dow Chemical Company, Davis, Ca 1 i forn i a Ph.D. Associate Professor Life Sciences, Department of Life and Behavioral Sciences, Department of the Air Force, USAF Academy, Colorado v Participant List Laurence Hoffman Lewis & Clark County Extension Helena, Montana Dennis Hamel U. S. Forest Service Missoula, Montana Ray Peery South Dakota Department of Agriculture Pierre, South Dakota Clarke Brown Washington State Department of Agriculture Yakima, Washington Don Emenegger Thompson -Haywa rd Chemical Company Corva 1 1 is , 0 regon Dave Armstrong Montana Department of Agriculture He lena , Montana George A1 gard Montana Department of Agriculture Helena, Montana Gene Turner Un i vers i ty of Utah Sal t Lake City, Utah Stan Howard Lewis & Clark County Extension Helena, Montana Ken Quicken den Montana Department of Health & Environmental Sciences, Helena, Montana Bob LaRue Montana Department of Agriculture Helena, Montana Wally Jankowski Montana Department of Health & Environmental Sciences, Helena, Montana Ed Burns Montana State University Bozeman, Montana Mike Jackson Montana State University Bozeman, Montana Gary Jensen Montana State University Bozeman, Montana Lawrence Baker Montana State University Bozeman, Montana 'Wayne Gamrath Peavey Company Mandan, North Dakota Don R. Merkley Montana State University Bozeman, Montana Douglas Johnson Cascade County Great Falls, Montana vi J im Freeman Cascade County Great Falls, Montana Le 1 and P . Cade Montana Farmer Stockman Great Falls, Montana Tom Daly Montana Department of Health & Environmental Sciences, Helena, Montana Loren L. Bah Is EQ,C Helena, Montana Lester Severance Federal Aviation Helena, Montana Art Kussman Montana Department of Health & Environmental Sciences, Helena, Montana Randy Perez Fort Belknap Tribal Council Harlem, Montana Douglas Main Fort Belknap Tribal Council Harlem, Montana E rnest H i 1 debrand Gul foil Chemi cal s Bill ings , Montana Neil J . Howarth U. S. Forest Service Bozeman, Montana E. Blair Adams Cooperative Extension Service Seattle, Washington R. Gary Beaver Eastern Montana College Bill ings , Montana Dr. Edward E. Burns Montana State University Bozeman, Montana David Dickins Montana Cooperative Extension Service Butte, Montana Geoffrey E. Greene U. S. Forest Service Great Falls, Montana Roy Linn Montana State University Bozeman, Montana Marvin E. Krook Chester High School Chester, Montana Charles F . Stogsd i 1 1 EPA Helena, Montana V I I KEYNOTE ADDRESS There are continued national and global pressures for more effective pest con- trol strategies to provide for expanding population needs and to have these methods more compatible with environmental quality. Progress to meet these overwhelming demands will be made in only two ways: by developing new pest control strategies - or by evaluating and refining the pest control strategies presently available. In either event, the success of new, as well as old, pest control strategies for the future is dependent upon publ ic support and understanding. In the last decade, a serious credibility gap has developed between the pesti- cide industry and the public, creating a crisis of confidence in the use of chemical pesticides. Ironically, in the face of this public lack of confidence, pesticides remain our only first line of defense, even in the integrated control strategies. Further, we are assured that chemical pesticides will continue to play a major role in the future strategies for pest control. The development of pest control strat- egies has also come at a time when public sentiment for research and technology have peaked and are at a decline. These are difficult odds at best, for those involved in mapping pest control strategies. Continued lack of public support may drive away industry incentive to develop new environmentally compatible chemicals and may hinder long range pest control research vital to pest strategy planning. Neither industry or government can neglect the challenge to close this credibility gap. Both must reach mutually agreeable goals which are openly honest with the public's wishes. After more than a decade of debate, the public has concluded that pesticides constitute a serious threat to the environment. Earlier this concern was for human health and later broadened to include environmental concerns. The issue focused chiefly on DDT, and the evidence of its role in environmental pollution formed the Presented by Kit C. Walther, Project Coordinator, Pesticides Demonstration Program, Solid Waste Management Bureau, Department of Health and Environmental Sciences at the Seminar, "Advancements in Pesticides", Helena, Montana, September 16, 1975* (l) 2 basis for the controversy. Unfortunately, the conclusion drawn about DDT have tended to become generalizations about all pesticides by much of our public, environmental organizations, and many governmental agencies. Nevertheless, we learned some valuable lessons from the DDT controversy: - The conventional wisdom underlying the practice of chemical control in the DDT days was unsound. - Some characteristics of the pests and the molecules being directed at them were not properly assessed. It was found that the initial successes of chemical control with synthetic organic insecticides led to a sense of false security and oversimplification in assessing the nature of the problem. The development of insect resistance, the resurgence of target species, and the disruption of nontarget species was never anticipated, nor was the practical significance of chemical stability, lipid solubility and broad spectrum tox- icity. The interrelatedness of the biosphere was never fully appreciated until the mobility of DDT and its accumulation in living organisms were disclosed. There were three strategic errors in the designing of molecules for pest control previous to 1940. They were the following: the search for 1 ipoph i 1 i ci ty to promote rapid permeation of the living cell; unconcern for absorption to soil colloids and organic matter; and a conscious effort to choose a wide spectrum activity so as to secure as large a market as possible. These errors In judgement in the underlying strategy of chemical control are readily acknowledged by many concerned pest control specialists, but have actually had a most positive effect on the field of pest control. These setbacks led to new thinking about the biochemistry of the species, genetic mechanisms, behavior, and a host of other matters that relate to population dynamics, pest management, and chem- ical development. (2) 3 The past three decades has resulted in the emergence of a new concept of pest control centering on population dynamics as the framework. From the understanding of the factors regulating pest populations, a number of pest control practices are invoked, that in total reduce the population to tolerable levels. This concept de~ emphasizes primary reliance on a single method of control and the anticipated ob- jective of complete control or pest-erad i ction . Although the method does not eliminate the need for chemical pesticides, it does reduce the pressure for chem- ical treatment. Pesticide chemicals have been developed and are being developed by industry which provide greater specificity, a greater margin of safety to the applicator and consumer, and with less effect on the nontarget areas of the environment. Pes- ticides will remain a tool in the overall pest management strategies, however, they will be used more judiciously and timely with less effect on our environment. New pest management strategies are being designed and studied from an integrated approach invoking techniques utilizing proper managerial practices, breeding of crops, introduction of synthetic genes, pest reproductive interference, environmental modi- fications, growth regulators and improved pesticides and sophisticated application systems. The result will be reduced pesticide applications needed higher degree of pest specificity, and less pesticides introduced to the environment. Both government and industry must regain the confidence of the public to insure that progress is made in implementing these new pest control strategies. This will require some straight shooting by both parties and a concerted effort to develop a technical team capable of implementing this system. The public needs to know that more is known about the newer pesticides and pest control strategies than was known in the DDT days, and that continued research and study is providing additional facts to strengthen and make these new pest control strategies more environmental! compatible. (3) The purpose of our seminar, for the next two and a half days, is to bring you these concepts in pest management, the problems which still plague the pestides user and their possible solutions for your discussion and consideration. We invite questions from you as time permits, after each presentation and during the breaks. Thank you. INSECT PEST MANAGEMENT - THE THINKING MAN'S PEST CONTROL I . In troduction What is pest management? What makes it suddenly so important — even popular? How and when did it start? Why should I understand it? Is it compatible and usable in today's technical agriculture? Pest management brings together into a workable combination the best parts of all control methods that apply to a given situation. A somewhat more scientific definition of pest management would be: the practical manipulation of pest populations using sound ecological principles. The emphasis here is on "practical" and ecological." There are many ways of controlling insect pests, only a few of which are practical, and fewer yet ecologically sound, such that you do not create a worse situation. Pest management then, is "putting it all together"--us ing the best combination of control techniques to allow you to "live" with the pest while sustaining non-economic losses . Pest management as a concept is not new. Only the name is. Many of the compo- nents of a sound pest management system were known some 50 years ago through the research of Ssley in Arkansas. His extensive and foresighted work with cotton insects in the mid 1920's was sufficient to provide a sound basis for today's pest management. His management of such pests as the boll weevil, the bol lworm, and spider mites, was based on the principles of a pp 1 j ed ecology , a vital segment of pest management. Why is insect pest management needed? Why not continue to control insects as they have been in the past? The answers to these questions are somewhat complicated and yet they must be dealt with and understood Presented by Leon Moore, Extension Entomologist, University of Arizona, Tucson, Arizona (5) introduction of the organochlor ine insecticide, DOT, began an era of insecticidal control of insects. Entomological research and extension work, largely emphasized the use of insecticides to control insects. One new insecticide followed another and new groups such as organophospha tes and carbamates made their appearance. Insecticidal control provided a quick, inexpensive, and convenient method of controlling insects. It greatly slowed or stopped efforts such as Isely's to develop methods of insect control which were forerunners to the methods which we are using in our insect pest management systems today. There were many reasons for the need to resume emphasis on the development of insect pest management. These were brought to light as problems began to occur resulting from large scale use of insecticides. One of the first problems was the development of resistance or tolerance by certain insects to insecticides used against them. Beginning with the resistance of houseflies to DDT, this problem has continued to increase until today about 250 species have shown resistance to certain insecticides and some are resistant to one or more groups. After a few years of widescale use of insecticides the problem of residues remaining in food and feed crops, in the soil, and in animals became known. Some insecticides such as the organochlor ines , are highly persistent because of their chemical stability. Others such as the organophosphates are less persistent and rapidly degrade into harmless compounds. In order to cope with the residue pro- blem, growers found it necessary to use the more toxic but non-persistent compounds. The shift from persistent to non-persistent insecticides has helped to relieve the problem caused by remaining residues but has been largely responsible for the occurrence of other problems. The non-persistent insecticides are generally more toxic, creating an additional health hazard to persons handling and applying them. They also are generally broad-spectrum in terms of destroying insects in the target (6) area of treatment and require more frequent application to maintain insect control. This has resulted in a disturbance of pest-beneficial insect relationships, permit- ting pests of minor importance to rise to major pest status. It has also resulted in increased costs since the less persistent insecticides are generally higher priced and more applications are required. These factors have contributed to the need for developing pest management systems which emphasize alternate methods of control and minimize the use of insecticides. I 1 . Basic Elements of insect Pest Management Four elements basic to the development of a pest management program are sampling, economic levels, natural control, and insect biology and ecology. A good sampling system is extremely important in that it provides information on insect numbers in each field and must be developed to serve as a base for utilizing knowledge of nat- ural control, economic levels, and biology and ecology of the major insects involved. Once the sampling program is established, these basic elements can be dovetailed to- gether to serve as the foundation upon which practical components can be added to the total pest management program. Before a pest management program can be initiated a great deal of basic infor- mation must be accumulated. This includes information about the agroecosystem, such as the crops grown, agronomic practices employed, soil type, irrigation water, and any other factor which relates to the production of the crops in the system. De- tailed information must be available on the major pests and beneficial insects found in the agroecosystem in order to understand the seasonal occurrence and magnitude of all species of concern. The integration of all information on the agroecosystem it- self with that on the biology and ecology of the pests and beneficial insects will provide significant insight on natural control in any particular area. The level of natural control provides the base on which all management practices are built, some of which enhance natural control. (7) III. Practical Components of Insect Pest Management When the basic elements have been established to form the foundation for the insect pest management system it is possible to build a solid and effective program on this base. There are several single-component control methods that can be incor- porated into a multifaceted insect pest management system. These methods have been, for the most part, used individually for control of specific insect pest problems. The combination of several of these Into a comprehensive insect pest management pro- gram can provide better suppression of key pest species, and, at the same time, place less demand on any one method. The methods currently available and proved effective are: cultural control, biological control, chemical control, host-plant resistance, mechan ical -phys i cal control, and regulatory control. The number of components that can be used in an insect pest management system is limited only by their practical availability. If the available components are to be used most effectively, emphasis must be placed on their use at the appropriate time. Some components are applied when the pest is a problem in the field while others are applied at times when the pest is overwintering or when it is at sub- economic levels. Generally, full utilization of all non-chemical methods should be emphasized on a year-round basis and insecticides should be utilized as a means of reducing populations that have reached or exceeded the economic level. Several potential components are in various stages of development at the pre- sent time. These include peromone control, microbial control, chemos ter i lant control, and other control methods. These should become important parts of insect pest manage- ment systems as they are developed to the point of being practical for use. IV. Example of an insect Pest Management Program - Cotton in Arizona Emphasis in cotton pest control programs in Arizona has been aimed primarily at developing or adapting a cotton scouting program to the state which would serve as the basis for an insect pest management system. Two prerequisites to the effective (8) practice of pest management are: (1) good field sampling, and (2) confidence in and use of sound economic levels of pest populations or damage. Sn Arizona, scouting programs have been developed in two counties. The first was in Graham County which is now well established after six years of operation and the second in Pinal County which was started in 1971* The following is a brief discussion of the history, development and results of these programs. Graham County Program In 1968 the cotton growers of Graham County, through their pink bol Iworm com- mittee, decided upon a cotton insect control program which called for scheduled weekly insecticide applications to the entire cotton acreage involved in the pro- gram. About 13*000 of the approximately 17,000 acres of cotton in the county were included in the program and were treated for six consecutive weeks beginning with the first week in August. The entire acreage was treated each week without regard to the insect populations present. Some of the growers expressed dissatisfaction with the 1968 program because of cost and the appearance of certain secondary problems. Thus the pink bol Iworm committee asked the University of Arizona for assistance in improving the program for 1969* The University assisted the committee in organizing and conducting a scouting program whereby cotton insects could be controlled based on need. Results of the 1969 program were that out of more than 600 fields, one re- quired treatment for stink bugs, 18 for lygus bugs and about 65 for pink bol Iworm. Considering multiple applications on the fields treated for pink bol Iworm a total of 5,500 acre treatments were made. This compares to 13,263 acres treated six times or 70,578 acre treatments in 1 968 . Under continued scouting programs about 3,500 acre treatments were made in 1970 and approximately 14,000 acre treatments in 1971. Cost per program acre was $15.00 in 1968, $2.79 in 1969, $2.54 in 1970, and is estimated to be about $5.00 in 1971. (9) From the standpoint of insect infestations, 1970 was lightest of the four years and 1971 was heaviest. Highest cotton yields were made in 1969 while yields in both 1970 and 1971 were down, primarily because of the weather conditions. Pinal County Program In Pinal County, a similar program was initiated in 1971 assisted by funds made available through a memorandum of agreement with the Plant Protection Division, U.S.D.A. Growers paid about one-half the program expenses initially but have now assumed full financial responsibility for the program. The number and percentages of growers who followed I PM recommendations for the four project years are as follows: 1971 “ 11 growers (21%) ; 1972 - 31 growers (52%); 1973 ~ 57 growers (70%); 1974 “ 44 growers (82%). Actual numbers indicating either increases or decreases in private consultant fieldmen personnel are not available, however, it is believed that there have been no significant changes. Services provided by the two groups have been altered pri- marily in the area of insect control recommendations. Chemical company fieldmen have shown a tendency toward use of economic levels through out the state since the beginning of the pest management effort in 1971. Mew pest management methods and strategies introduced during the four years include strip or block cutting or alfalfa hay, lygus bug control in safflower to stop migration into squaring cotton, cessation of bloom-period spraying to control the pink bollworm, early crop termination to reduce numbers of diapausing pink bollworms, field treatment on an as-needed-bas i s and delayed first treatment to enhance beneficial insect numbers and forestall bo 1 Iworm/budworm outbreaks . The concept of 1PM embraces all facets of the agroecosystem and therefore cannot be locked Into a single crop in a multicrop system. The Arizona project has embraced small grains, grain sorghum, safflower, alfalfa hay and suger beets in Its I PM effort. The grains are particularly vulnerable to excess treatment, (ID) sugar beets call for intensive Insect monitoring during stand establishment and safflower and hay directly Influence cotton insect numbers when these crops are in close association. Interagency and interdisciplinary planning, cooperation, and program exe- cution was carried out at the highest level of competency and interaction. The reciprocal flow of information and ideas as related to applied and basic re- search was both gratifying and rewarding. Pest management personnel were continually up-dated and field-tested through- out the scouting period on a weekly basis. Their initial training was guided by a scouting handbook produced specifically for this program. The level of exper- tise attained by all personnel was very high. Grower response to IPM principles was, as the first paragraph indicates, at a satisfactory level when the program ended. Most noticeable was their acceptance of the fact that spraying cotton in the bloom stage to control the pink bollworm was futile and often led to secondary problems. The use of economic thresholds for all pest insects was accepted very well. Repetition, as is the case in most learning procedures, is the best tool in grower instruction and knowledge expansion. Grower con- tact is one of the keys to successful IPM. G rower Acceptance During the four year period of program operation, the number of growers increased to a maximum of 85 and the acreage to 31 ,508 in 1973* The decrease in growers and acreage that occurred in 197^ resulted from the threefold in- crease in per acre cost as the growers assumed full financial responsibility for the program. (ID Grower Cost Year Number of Growers Acreage Per Ac 1971 51 15,322 0.75 1972 60 18,437 0.75 1973 85 31 ,508 1 .00 1974 54 21 ,458 3.00 Total grower contributions for the four years was approximately $1 21,201.25. In 1971* a five member grower committee was formed and it was through these growers that the Extension Service cooperated in initiating the Pinal County Pest Management Program. Two growers were added to the committee in 1972 to broaden the membership base for different county areas. The committeemen were more active in program planning and development and began considering incorporation. The for- mation of a non-profit corporation occurred in 1973 with corrmittee members becoming the governing board. A slate of officers was elected and growers became corporation members as they contracted to participate in the Pest Management Program. in addition to begin directly involved in implementation of the 1973 scouting season, the board requested that the corporation be involved with crops in addition to cotton. The Growers Pest Management Corporation handles all aspects of the Pro- gram in 1974. The Cooperative Extension Service cooperated with the corporation in providing training for their personnel and serving in a field supervisory capacity. Benefits Reduced operational charges were first realized in 1974. The reduction was due primarily to personnel assignments in relation to number of fields scouted. Work load eff i ciency was the key to operational cost. Additionally fields assign- ed to each team were chosen to produce a cohesive unit, thereby reducing travel cost. Records of net profits due to IPM are not available from individual growers. There was, however, a trend toward reduced production inputs and improved pest control (Table 1). Growers are becoming more conscious of management factors re- lated to IPM. Water management, fertilizer requirements, weed control, good ground (12) preparation, etc., are all part of managing a crop to a successful conclusion. The results of the soil samples taken during the three years of pest management show no significant increase in pesticide residues in the soil. There has been a reduction In the total pesticide usage in Pinal County with a resulting increase in beneficial organisms. Obviously, a reduction in numbers of pesticides applications and recommend- ing chemicals at correct dosage levels when treatment is necessary will delay occurrences of pest- res is tance. New avenues of communication were opened and old avenues restructured and strengthened between growers, the Extension Service, and the University. The activity of USDA- APHIS was well received and many valuable contacts made. The individual handling the monitoring phase had high rapport with growers in and out of the program, Involved University personnel, pertinent state, county, and local governmental agencies, and local business that provided needed services. A good scouting program is the foundation on which the building of integrated control or pest management can be constructed. The stories of this building may include better use of beneficial Insects, improved cultural practices, proper use of insecticides, strip-cutting or strip-planting of alfalfa for lygus bug control, etc. There Is no limit to the size of the integrated control system and new methods can be easily made a part of the system as they are developed to the point of being practical. It should be emphasized, however, that the development of integrated systems is strongly dependent on sampling or scouting programs that provide the information necessary to make good management decisions. (13) Table 1 - Pesticide costs for Pinal County Pest Management Growers for 1971, 1972, 1973, and 197*. Factors 1971 1972 1973 1976 Growers 51 60 85 5* Fields 387 *80 722 503 Acres 15,260 19,313 31 ,582 21 ,*58 Fields Not Treated — 12 29 16 Acres Not Treated -- 95 982 687 Acres Treated 6,390 U 18,115 2/ 29,995 3/ 20, *31 */ Total Acre Treatments 56,232 173,330 156,563 106,252 Range of Treatments 1 - 13 0 - 16 0-12 0-10 Total Cost of All Acre ment T reat- $196,812 $606,655 $626,252 $531 ,260 Average Total Cost per Treated 5/ Acre $ 30.80 $ 33.69 $ 20.88 $ 26.00 T7 Data not ava ilab 1e~for~33 growers with 228 fields totaling 8,870 acres. 2/ Date not available for 7 growers with 38 fields totaling 1,103 acres. 3/ Data not available for * growers with 1* fields totaling 605 acres. */ Data not available for 3 growers with 8 fields totaling 3*0 acres. 5/ Cost calculated @$3 . 50/a. /Treatment - 1971 and 1972, @$*. 00/a. /Treatment - 1973 and @$5*00 /a. /Treatment - 197*. (14) - Leon Moore, Ph.D. - Q: Leon, you mentioned your group of growers incorporated. What is the advantage of their incorporating. You also mentioned a contract, a contract with whom and does the contractor assume any liability if I PM does not work in the state of Arizona? A: Probably all of those are tied together. One of the things is liability. If they are incorporated, it sort of takes away from, let's say, the board or from the committee that is running the show. !n other words, liability is spread around more if they have a corporation, and so they have done this from the standpoint of obtaining insurance and all the other things that might be involved from a liability standpoint. They just think that incorporating is the way to do this. Now the signing of the contract is also part of It and as a man signs a contract, he then becomes a part of the corporation and, of course, he is suing himself to some extent, if he goes in and sues. We have really had no problem from the standpoint of liability, but it is just a move that we think is necessary to avoid any unpleasant thing that might come along in terms of a president or somebody being called. Q: Who are the contracting parties, the University of Arizona and the growers? A: No, absolutely not, no the University is not involved, we are only in an ad- visory role. The grower, pest management corporation and the grower are the contracting parties. Q: What is the psychology that you use to get your growers together to practice integrated control? A: We started with a sort of corp of people who are the progressive type. They like to look into this sort of thing and we showed that by working with them that you can use economic levels, for example, and not endanger this high amount of money per acre. Now we're not talking about cotton like what you are talking about, tree fruits and the same thing is true for lettuce, for example, and those are much tougher to crack than another situation, but 1 think that you simply got to demonstrate to them, maybe on a small scale basis first, that economic levels are valid, you got to get their confidence and then from this you can begin to branch out, until you gain the confidence of the people, you might as well not try to do too much. That's the thing that we try to work on and we try to do it through the growers by having a grower committee out front and center because the other growers will then follow that commi ttee where they wouldn't if S, as an extension entomologist, went out there they would say, well that is his business to do this sort of thing. Q: Have you tried this with any other group? A: Yes, we are just beginning to get into lettuce, we do not have an actual pro- gram in lettuce. Most of our applications in practice are now scheduled for lettuce Insect control. But we have had some demonstration work going for the last two years now, which we have been able to exactly cut in half the use of insecticides and produce the same quality and quantity of marketable heads of lettuce and what we got to do then is show the grower and gain enough confidence out of them that we can do this. Now the problems that you run into, doing something like this, are they have been doing something like this for a number of years and are scared to death of the market situa- tion and all the other things making it tougher to get to. But we know by doing this demonstration work and research work that we have and doing it over enough years that eventually we are going to be able to proceed in those 15a areas that we definitely need it. Q: You mentioned four approaches, four separate approaches, acreage wise, what percentage of the total state is it? A: We new have 300,000 acres and four programs that cover probably around 40,000 acres. So we are still relatively small in terms of percentage of total. Now, of course, a lot of our growers have different methods of sampling, they do their own or hire someone specifically to do this and I am not including these in this program because they are private consultants that are working chemical company field men and I have a lot of people out sampling and so there are various ways of having coverage, but there were simply not enough of these to do the job and do it right. Q: The Pink Bowl Worm pheramone traps, was there any other economic benefit other than concentration of natural enemies or were they pretty much the same if they used chemicals? A: We have just gone into that in a big way this year, and as I say, the whole Safford Valley we have treated with traps and doing it from an early season standpoint only, in which you know we are not interested in the late season In which we get most of the damage. We are trying to reduce it and trying to step back say one generation, the economic level. I think maybe we have done that. Now If we suppress the population enough to set them back a gen- eration, then you see what you are doing with maybe as much as four or five treatments setting the population back. We do know that we have had to treat almost no cotton in that valley till the time I left, last week, 500 acres was the amount of treatment or a little less. So it would appear to be doing some good, but we want to be conservative on that and try it under different circumstances, maybe it was a light year in the area. We know that the Pink Bowl Worm is not as severe this year as it has been in some other years in all areas, but it's still in the other areas we are having to treat. Q.: You mentioned In the control of lygus bug that you sprayed safflower. Was that, the safflower, grown by these growers too, or was that on an adjacent farm? A: Good question, it is a little bit of a problem when it's an adjacent farm and the guy is a safflower and hay producer and not a cotton grower. In cases, the cotton growers have been willing to pay for this, for the neighbor. In other cases, they are just good neighbors so they will treat. We have not been able to show an economic benefit to the safflower grower, and that's one of those things where you have to hope for community action and we have re- ceived good cooperation. Better than I would of thought we could, but again growers are essentially good people and they like to think they are good neigh- bors. They usually participate in this type of thing, if they know it is doing some good. If they are, let's say, a hay producer, one of the reasons why we had to get into this kind of thing was because of the residue problems we were having in our hay and dairy a few years ago, so they are pleased to hold down the number of insecticide applications as much as we can. Q: Have you used the sterile male technique for the Pink Bowl Worm at all? A: No, that's only in the San Joaquin Valley. We produce them in Phoenix and ship them to the San Joaquin Valley and they've been doing that by the millions. We have not been able to produce enough of the sterilized males to use them in any other area except the San Joaquin. So we don't really know because of the cir- cumstances there, just exactly how much good these are doing. You see, the San 15b Joaquin has never been infested by the Pink Bowl Worm and it's just that they find a few there every year, and we said that this is the logical place to use this to keep them out and so they go in and dump millions of these things every year. They have not yet developed a Pink Bowl Worm problem in the San Joaquin, but would they have developed one if they weren't dropping these, that's the $6*1,000 question. I 'd 1 ike to see it incorporated now on top of our pheramone program in Graham County, Arizona, because we know what the situation is over a number of years and 1 think we could get a better yard stick of what is going on, maybe we wi 1 1 be able to do that eventually. Was the problem noticeably improved, or was it a real problem in those four areas? A: Yes, it is definitely quite a problem in all those areas and we still have a lot of improving to do, because even in the Pinal Co. program, it shows that we are down to an average of about five to six applications on the average, that is still a lot of applications and when you are doing this over an area- wide basis, there is just about no way that you are going to have the ability to make it any less, but over in Graham County where we've been able to pull this thing to such a low level, it's of great help to the industry. ! had one bee keeper come to me last year and said the pest management program made me $20,000 this year. It makes you feel good to hear results as a spinoff of the the program and it is a very healthy industry and it's helping the cotton growers a heck of a lot to have those honey bees because they do help the long stapile cotton, there's no question about it. Graham County is almost entirely long stapile from the standpoint of pollination. What is the current beginning salary of a beginning scout and what would you make after you were trained for one year? A: Okay, we have adjustment levels, $100 beginning and $110 with a year of ex- perience, per week. We have different levels of pay, of course, there are certain factors there at a higher level. We've found that our scouts will average about 22, 23, or 2b years of age. They are college age mostly, we have both male and female involved and actually, I have to admit that some of our best scouts have been girls. They seem out to prove that they can really do the job, but they have really done a good job for us and we also use a lot of school teachers. 15c Mosema locustae: AN ALTERNATIVE METHOD OF GRASSHOPPER CONTROL In troduct Son Grasshoppers are the most important insect pests on rangeland in the western United States. Economic infestations are usually controlled by aerial application of insecticides. The use of chemical insecticides against grasshoppers, as well as other insects, has been criticized because of possible harm to the environment. This concern has provided support for developing alternative methods of insect control, of which this work with Nosema locustae as a microbial control agent against grasshoppers is but one example. Microbial control can be defined as the method of using pathogenic micro- organisms for control of noxious pests. Grasshoppers, like most insects, are associated with numerous microorganisms, some of which are pathogenic. Known pathogenic microorganisms in grasshoppers include bacteria, fungi, viruses and protozoa, but the viruses and protozoa have received greatest attention because most bacteria and fungi are rather restricted to specific temperature and mois- ture regimens for growth and dissemination. A number of protozoa and viruses that have been isolated appear potentially useful in applied microbial control; however, because of financial and physical limitations, it has not been possible to develop all of them simultaneously. To select one of them for concentrated effort, criteria based on the needs and objectives in control of grasshoppers were devised for comparing these pathogens. in this paper, I will present the criteria we used to select N os ema locustae for major emphasis. Grasshoppers, Environment, and Pathogens Steinhaus (195*0, considered the interdependence of the insect, environment, Presented by John E. Henry, USDA, Agricultural Research Service, Rangeland Insect Laboratory, Montana State University, Bozeman, Montana (10 and pathogens as the determinant of natural epizootics. I feel this same inter- dependence exists in the applied use of the microbials, particularly in programs directed at long-term control. Therefore, in order to develop a successful sys- tem, decisions and designs of experiments should be based on knowledge of the factors tn this triad. Grasshoppers : There are about 200 species of grasshoppers in western United States, most of which belong to one of three main subfamilies. Only about 15 * 20 species are of economic importance because they are frequent or abundant in outbreaks and/or they compete with man or his domestic animals for preferred forage and crops. The remaining species either do not occur at high densities, do not compete for important plants, or both. A few species may be beneficial because they feed primarily on undesirable plants. Virtually all species of grasshoppers exhibit ranges in food plant pre- ferences and utilization (Mulkern et al. 1969). The food plant preferences for some species are very broad, including broadleaf plants, grasses, sedges, plant debris, and animal tissue including other grasshoppers. At the oppo- site extreme some species are very restricted in host plant selection and feed only on several closely related species of plants. These species con- sidered as economically important vary from being highly omniverous to highly selective in food preferences. Env i ronmen t : Although grasshoppers inhabit most areas of the world, our main concerns are with those that inhabit semiarid rangelands. Grasshoppers, as well as their natural enemies such as other insects, microorganisms, insectivorous vertebrates, etc., are well established in these areas. The interactions among grasshoppers, their natural enemies, and the variable climatic conditions (17) that characterize semiarid rangelands can cause marked fluctuation in population densities from one year to the next and from one area to the next. Generally, however, the densities of grasshoppers are cyclic and usually reach maximum levels every seven to fifteen years. Grasshoppers compete with grazing animals for available forage and, when this is in short supply, are capable of migrating to nearby crops and pastures. Grasshopper densities of more than eight per yard square generally are considered to be economically important. However, the need for control also depends on the quantity of available forage and the financial capabilities of landowners. Con- trol programs seldom have been conducted in areas where densities averaged less than 15 per yd . Cooperative control programs covering from 5>00Q to more than a million acres in solid blocks are conducted on cost-sharing arrangements be- tween the Federal government, state government, and private landowners. Pathogens All microorganisms that are considered potentially useful for grasshopper control are natural pathogens. The viruses include two that have been charac- terized as to structure and pathogenicity, two that have been partly characterized and several that are known to occur but have not been investigated. The protozoa include an amoebic-type organism and a number of Sporozoa. Among the Sporozoa are three Microsporida within the genus Nosema . Each of these pathogens exhibit characteristics that might be useful in an applied program. The characteristics considered most important in microbial control of grasshoppers are (a) suitable virulence, (b) suitable host range, (c) potential for mass production and pro- longed storage, (d) adaptability to efficient low-cost application techniques, (e) suitable viability in the habitat of the host following application, and (f) potential for registration as a microbial insecticide. a . Suitable Virulence: Because low densities of grasshoppers can be tolerated, the objective has been to select an agent sufficiently virulent to cause some short-term control, (13) but at the same time sufficiently non-virulent to persist in the host population for a number of years and thereby reduce the extent and frequencies of outbreaks. An ideal approach to the management of grasshoppers would be to apply a microbial agent during the early stages in the density cycle and prevent any additional in- crease. However, this approach may not be realistic because reproductive and survival potentials among grasshoppers are at the highest levels and losses to natural enemies are at the lowest levels during the early phases in the density cycles. Conceivably, applications of a microbial that caused 70 percent reduc- tion in densities at this time might not be as effective as a 20 percent reduc- tion when pressure from natural enemies is more intense. Also, even if this approach was effective, implementation might not be possible because landowners and operators usually are reluctant to enter into control programs prior to the existence of threatening or damaging population densities. Most land managers are familiar with the potential variability in rangeland conditions and of the severe fluctuations that often occur in the densities of grasshoppers. There- fore, from a practical standpoint grasshopper control programs, including microbial applications, will not be initiated until densities exceed the economic thresholds. For this reason some short-term reduction is required to satisfy the immediate needs of the land operator and persistence is re- quired to maintain the densities at sub-economic levels, b . Host Range: Usually 30 to 50 species of grasshoppers occur in an outbreak area. Of these about five or fewer species usually predominate and often are the only economically important ones. For this reason, a pathogen must be able to infect or reduce the densities of the predominant species. Also, because the predominant species usually include one or more species of each of the 09) three main subfamilies, the pathogen must be effective against virtually all grass- hoppers. It is equally important that the host range be limited to grasshoppers, not only for safety in applied use, but also so as not to diminish the effectiveness of existing natural enemies. c. Mass Production and Prolonged Storage: Outbreaks or potential outbreaks usually occur over extensive land areas, often exceeding one million acres. in order to be effective, the microbial agent must be applied over the entire area. Therefore, large quantities of the pathogen must be available to treat such areas. From the standpoint of efficient use of facilities and personnel, production should continue throughout the year and spores should be stockpiled. This then requires that the pathogen be capable of withstanding pro- longed storage without serious loss in viability. d . Adaptability to Efficient Low-Cost Application Techniques: Unlike intense agricultural areas where per acre gross returns are hundreds of dollars per year, the average gross returns on rangeland is less than $5.00 per year. For this reason land operators generally are reluctant to control grasshoppers on their entire holdings, even when done so under a cost-sharing arrangement with the state and Federal governments. Efficiency is increased and per acre costs are reduced when larger areas are treated that permit long swath runs (20 to 50 miles) and wide swath widths (500 to 2000 ft.) using Category A aircraft such as the Douglas DC-3, Lockheed P V- 1 , etc. Also, the pathogen must be in highly concentrated preparations that permit operationally efficient payloads. e. Suitable V iab i 1 ity: The diurnal temperatures of rangelands habitats may vary between 7 to 38° C during the time of year when grasshopper control programs are conducted. Ground temperatures might reach 50° C. Cloud cover usually is minimal, although evening thunderstorms are frequent. A pathogen might, therefore, be subjected to a variety of adverse climatic conditions and to intense solar radiations which it must tolerate (20) without serious loss in viability. Materials and techniques are available that could be applied to the pathogen to aid in preserving viability under such ad- verse conditions, but such materials and techniques add to the cost of the appli- cations. Such materials might increase infectivity and viability to the point that the added costs are offset so these procedures certainly should be studied. However, such studies often can be justified only after a definite control po- tential has been demonstrated, f . Potential Registration: Just as chemical insecticides are registered for use, microbial agents also will be registered for applied uses. In this country authority for registration rests with the Environmental Protection Agency (EPA) . EPA will establish the standards for safety, efficacy, allowable residues, etc., for all microbial agents. A pathogen then must exhibit characteristics that indicate probable success in satisfying the requirements for registration. Nosema locus tae Canning (1953) described Nosema locustae from a laboratory culture of the migratory locust, Locusta migrator ia mig ratorio ides , in England. Prior to that Steinhaus (1951) reported infections by an undescribed Nosema in grasshoppers sent to him by workers previously associated with our laboratory at Bozeman, Montana, and subsequent research established that this was Nosema locustae. In 1961, l initiated studies of pathogens of grasshoppers that subsequently led to the selection of Nosema locustae for our most determined effort at applied development. This decision was based on an evaluation of Nosema locustae and other known pathogens on the basis of the characteristics listed in the previous sect! on . a . V i rul ence : Nosema 1 ocustae infects the fat tissue of grasshoppers and in so doing de- prives them of their energy supplies. It is one of the least virulent pathogens (21) of grasshoppers. Canning (1962 a, b) observed variation in the infectivity of dif- ferent species of grasshoppers and reported difficulty in infecting adults. However, she observed increased mortality following inoculation of third instar nymphs of Locus ta migrator! a migratorioides . We have established that the LD^q at 25 days pos t inocul at ion of third instar nymphs of Mel anop lus sangu i n i pes or bi v i ttatus , which are economically important grasshoppers, is 5.5 x 10^ spores. Of the known specific grasshopper pathogens, including fungi, viruses, and other protozoa, only the amoebic protozoan and gregarines are less virulent (Henry, 1970). Recently we (Henry & Oma, 19^7 b) showed that Nosema locustae was much less virulent in grass- hoppers than the two other microsporidans, Nosema acr idophagous and N os ema cuneatum. The same study showed that virulence of Nosema locustae was enhanced when the grass- hoppers were subjected to added stresses such as crowding. Field tests have established that one billion spores per acre will cause about 50 percent reduction in the den- sities of grasshoppers within four weeks following application (Henry 1971, Henry et al. 1973, Henry and Oma, 197*» a), b. Host Range of Nosema locustae: Following her initial description of Nosema locustae. Canning (1962a) extended the host range to include the African locust, Schistocerca gregaria, and five species of grasshoppers from North American, including the economically important Mel anopl us sanguini pes, Melanopl us b i vi ttatus and Camnula pel lucida. More recently I (Henry, 1969) reported that 58 species of grasshoppers, a species of cricket, and a pygmy locust were susceptible to infection. This list included species that belonged to the three main traditional subfamilies of grasshoppers and included all economically important species. Recent studies have extended the host range to include additional species of grasshoppers and the Mormon cricket, Anabrus simplex. Laboratory studies have established that the eastern house cricket, Acheta domesticus, was not suscep- tible to infection. It appears that the host range includes most, if not all, species of grasshoppers, some species of crickets and other close relatives. (22) c . Mass Production and Prolonged Storage of Noseroa locustae: Canning (1962b) felt that the inability to mass produce spores outside the grass hoppers prohibited development of Nosema locustae for applied use. Hcwever, we have produced sufficient quantities of spores for all of our field tests, including a 46,000-acre pilot test, through laboratory cultures using the grasshopper Mel anopl us bivittatus . This species is relatively large and can tolerate extremely high spore concentrations. As reported previously, (Henry, 1971) each grasshopper produces in excess of one billion spores, and in more recent studies the average production was increased to more than two billion spores (or more than two acres of treatment) per grasshopper. Occasional concentrations of 2.0 x 10^° spores have been harvested from heavily Infected females and average productions of 8.0 x 109 spores per grasshopper appear possible. Therefore, mass production of spores in grasshoppers does indeed appear economically and physically possible. Some difficulty has been experienced in storing spores. Henry and Oma (1974a) showed that viability was reduced drastically after storage in water at - 10° C for one to three years or in cadavers at -10° C for one year. For this reason, the spores used in field tests have been produced within four months of application. However, preliminary studies on storage in liquid nitrogen have indicated that acceptable prolonged storage procedures can be devised. d . Adaptability of Nosema locustae to Low-Cost Application Techniques: As with most microbial agents, the infective stage of Nosema 1 ocus tae , the spore must be ingested by the grasshopper. For most field tests we have applied spores to wheat bran, which is then spread by aerial or ground equipment. The standard appli- cation rate (Henry et al . 1973) has been one billion spores on 1.5 1b wheat bran per acre. If it is applied with the predominant grasshoppers (usually Melanoplus san- gui n 1 pes ) are mostly third instar nymphs, this treatment kills about 50 percent of the grasshoppers within four weeks and causes sufficient infection (30 to 50 percent) (23) among survivors that reproduction is reduced or inhibited. In most instances, the initial reductions in densities will be sufficient to change the status of the in- festation from economic to noneconomic. There are some important disadvantages to using a bulky carrier like wheat bran for distributing Nosema locus tae, particularly in comparison to application in ultra- low-volume sprays. These include purchase price, treatment costs, handling expenses, and reduced payloads for airplanes. However, these disadvantages are more than off- set by advantages in the use of wheat bran. For example, recent field studies have established for chemical insecticide appl ications are poss ib 1 e w i th wheat bran which then reduces the per load application time. Also, we have established that complete coverage is not required in the application of Nosema locustae on wheat bran as is required for suitable control with insecticides. Therefore, retreatment of areas that were inadvertently missed is not necessary. Chemical insecticide applications are restricted to early morning hours when the temperatures are low and thermal cur- rents are not produced. Thermals are updrafts of warm air rising from the ground that cause loss of spray droplets through drying or increased drift. Thermals usually restrict aerial insecticide applications to one load per suitable day in western United States. In contrast, we have achieved excellent results in apply- ing wheat bran with spores throughout the day when temperatures and winds would prohibit spray applications. This allows for more efficient use of airplanes and crews, which lowers the cost of applications. Also, our studies have shown that ULV sprays with water require about ten times more spores than wheat bran appli- cations to achieve comparable results. The increased production cost of spores for ULV sprays greatly exceeds the costs Involved in using wheat bran, e. Viability of Nosema locustae in field applications: We have completed few studies on the effects of adverse climatic conditions on spores of Nosema locustae. Preliminary studies have shown that viability is decreased by temperatures over k0° C and by exposure to solar radiation for two or more hours. (24) Nevertheless, the field studies have established that sufficient viability is main- tained that the densities of grasshoppers are reduced and infections occur among survivors. We believe that the wheat bran provides some protection for the spores and we have observed that most of the bran is consumed by grasshoppers within two hours of application. Sf future results continue to justify studies on Nosema locustae, the development of techniques that maintain high spore viability would help increase efficiency and thereby reduce the cost of this pathogen. Nosema locustae persists in the field at least one year following experimental application (that is the limit of our testing) and it persists for a number of years in antural enzootic areas (Henry, 1972). We have found spores in the froth of egg pods and have observed that some nymphs from egg pods laid by infected females were infected. We suspect that young nymphs consume relatively large amounts of organic debris, including the cadavers of grasshoppers from the previous season, some of which possible contain spores of Nosema locustae. Apparently these are the principle means by which grasshoppers become infected by spores produced during the previous generat ion . f . Potential for Registration of Nosema locustae for General Use; At present no protozoan has been registered for general use against insect pests and, therefore, the criteria for registration and labeling have not been established. Certainly such criteria will include safety to non-target organisms, particularly warm-blooded animals, high efficacy, and development of sound bioassay techniques. Tests conducted to date indicated that Nosema locustae will not infect warm-blooded animals and that efficacy based on degree of infection is workable. Also, bioassays based on infectivity are sufficiently sensitive to detect changes in the infectivity of this pathogen. At this point the propect of registration of Nosema locustae against grasshoppers in encouraging. Prospects of Success As mentioned previously, all potential agents exhibit characteristics that might be useful in microbial control of grasshoppers. This raises the question of whether the selection of Nosema locus tae achieved our purpose of placing the maximum effort on developing the pathogen with the greatest potential for success. Our studies continue to show that Nosema 1 ocustae can be effective as an alternative method of controlling grasshoppers. We can reduce high densities of grasshoppers to tolerable levels within one month by disseminating spores of this pathogen. We can reduce re- production of grasshoppers which should reduce densities over a longer period. Yet, questions remain as to whether Nosema 1 ocustae will reduce the extent and frequencies of outbreaks, and whether the land operators will utilize this method for control of grasshoppers. In 1975 we initiated a large-scale pilot test from which we hope to derive answers to the 1 long-term control potential of Nosema locus tae. The initial results from the seasons of application indicate that continued development of Nosema 1 ocustae is jus- tified. However, this test will not be completed for at least three years so any fur- ther assessment of potential success would be premature. I feel it is extremely difficult to predict the public response to Nosema 1 ocustae as a method of grasshopper control. Many land operators have expressed the need for controls of this nature because they are concerned about the nonselect ive action of the chemicals presently used against grasshoppers and about the cost of these treat- ments. Certainly the cost of Nosema 1 ocustae must be sufficiently low to compensate for the slow reduction in densities. My personal view is that Nosema locus tae could be used most effectively by a group of cooperating landowners, possibly in conjunc- tion with governmental agencies, as the first line of defense against grasshoppers in an integrated program where chemical insecticides are used sparingly to reduce densities in restricted "hot spot" areas. If it were used in this way, S am con- fident that the use of Nosema locustaewill be accepted by the people involved and that grasshopper control will be realized. (26) Re fe fences Canning, E. U. 1953. A new microspor idian , Nosema locus tae n. sp., from the fat body of the African migratory locust, Locusta migratoria migrator ioides (R&F) . Parasitology A3, 287-290 „ Canning, E. U. 1962a. The life cycle of Nosema locus tae Canning in Locusta migratoria mi gratorioides (Reiche and Fairmaire), and its infectivity to other hosts. J. Insect Pathol . A, 237-24?. Canning, E. U. 1962b. The pathogenicity of Nosema locustae Canning, J. Insect Pathol. A, 248-256 . Henry, J. E. 1969 . Extension of the host range of Nosema locustae in Orthoptera. Ann. Ent. Soc. Am. 62, 452-53. Henry, J. E. 1970. Potential microbial control of grasshoppers and locusts. Proc. Snt. Study Conf. Current and Future Problems of Acridology. pp. 465“468. Henry, J. E. 1971. Experimental application of Nosema locustae for control of grass- hoppers. J. Invertebr. Pathol. 18, 389~39A . Henry, J. E. 1972. Ep i zoot iology of infections by Nosema locustae Canning (Micro- spor I da : Nosemat i dae) in grasshoppers. Acrida 1, 111-120. Henry, J. E, and Qma, E. A. 1974a. Effect of prolonged storage of spores on field applications of Nosema locustae (Microsporida: Nosematidae) against grasshoppers. J. invertebr. Pathol. 23, 37 1 "‘377- Hen ry , J. E. and Oma , E. A. 1974b. Effects of infections by Nosema locustae Canning, Nosema acridophagus Henry, and Nosema cuneatum Henry (Microsporida: Nosematidae) in Me Ian cp I us bivittatus (Say) (Orthoptera: Acrididae). Acrida 3, 223-231. Henry, J. E., Tiahrt, K., and Oma, E. A. 1973. Importance of timing, spore concen- trations, and spore carrier levels in application of Nosema locustae (Microsporida Nosematidae) for control of grasshoppers, J. Invertebr. Pathol. 21, 263-272. Mulkern, G. B., Pruess, K. P., Hagen, A. F., Cambell, J. B. , Knutson, H., and Lambley, J. J. D. 1969. Food habits and preferences of grassland grasshoppers of the north central Great Plains. N. Dak. State Univ. Agr. Sta. Bull . 481, 1 - 32 07) Steinhaus, E. A. 1951* Report on diagnosis of diseased insects 19^-1950. Hilgardia 20, 629-678, Steinhaus, E. A. 195^. The effects of disease on insect populations. 197-261 . H i Igard ia 9> (28) - John Henry, Ph.D . - Q: When you sprayed during the entire day, was there a difference in terms of if you sprayed in the morning. Would they feed during the day or would they feed at night or do they feed all the time? A: We did find a difference. We probably did lose some feeding activity, simply because when it gets that hot, the grasshoppers get up on to the vegetation, they are not feeding on the ground. In the morning, they will feed on the ground. There is a time factor that we are going to have to look into, but we do know that we can still infect them even at this time of day. Q: Because the material is being kept viable? A: I don't know if the material is being kept viable or if they actually are getting down to get it. We don’t have the data analyzed at this point, so that we can say that there was a difference between the time of day at this point. Generally speaking, I would say yes. Q: You say after the treatment, about 50 percent of the population are dead in four weeks and the remaining 50 percent will not live to reproduce? A: No, of the remaining 50 percent, about 30 to 50 percent of those are infected such that their reproduction is eliminated or is drastically reduced. In other words, we are cutting the reproduction. They will continue to die naturally, but at four weeks that is what we see. Q: Wouldn't it be more economically feasible to gather wild grasshoppers rather than rearing them? A: We have considered that and I don't think it would be efficient because of the bulk of material that we would have to run through in separation and clean up. In working with produdtion in the laboratory or rearing facilities, such as we have, we can collect only real heavily infected grasshoppers and from that our spore nutrition is already pretty clean. Q: You mentioned Nosema locus tae testing on several species of grasshoppers and also on field crickets and mormon crickets, has it been tested, at this time on roaches? A: Yes, we have tried roaches at Montana State eight or nine years ago and as I recall, well I know we didn't get anything out of it. I can't recall the particulars of the test, but I can say that roaches are not effected, but I don't have the solid data to back it up. Q, : Have you been constructing a public relations program to go along with this or what kind of public relations have you initiated, if any at all? A: The only public relations that we have initiated is dealing with the ranchers in our area. Generally, I think ranchers are ready for something like this, ranchers are definitely for the approach to grasshopper control. Most of the insecticide programs in the western United States in the past year, have been conducted on federally administered lands. BLM lands, Forest Service lands, Indian Service lands, primarily because it is difficult to get ranchers as a group, together in a control program. APHIS will not touch any program less than 5»0QQ acres maybe 10,000 acres, but they want large blocks in order to be effective, they have to have large blocks in order to do a reasonable job with Malathlon, in other words, they have to treat large areas. It is becoming increasingly difficult to sign up all ranchers in such an area for 2 8* various reasons. First of all, Malathion is not always effective. Secondly, the cost is getting quite high. This past year the cost has increased by a third. Mow, ft isn't very much really, the contract cost on a government program is about $1 per acre, which, in most states, Montana included, it is equally shared by federal government, state government and private individuals, so it only costs the private individual about $. 30/acre. When you are figuring the actual value or his overturn on that per acre is less than $5, which is a considerable amount. They are becoming increasingly hesitant about going into this type of program. We also know that Malathion does suspend in cotton and in other areas and does put us into a bind as far as requiring future spray programs. Where we have sprayed in the past, we shall spray again, we can predict that, whether it is because grasshoppers are there or because we have sprayed there before, I cannot say, but this has hap- pened before. So ranchers are looking for alternative methods or leaving grass- hoppers, but they are very much interested in something like Nosema locus tae, even though it does not get as dramatic results as the insecticides. To what degree is the Nosema self-perpetuating? They will stay in the population, we know, for one year. Will they reproduce more once within a population? Yes, definitely. The spore production goes up dramatically after we have applied the material. It will stay in the population at least one year, now this is the limit of our testing because I will not go out on small plots and consider this reliable. This Is certainly one of the reasons why we are on this large scale pilot test to be able to check this over a period of years. We are shooting for three years, we hope that this gets longer. 2& ADVANCEMENTS IN HERBICIDES - DRIFT CONTROL Pesticides contribute enormously to the quantity and quality of food, feed fiber, wildlife habitat and environmental quality. Our farmer now produces food for himself and over 50 others; we have the highest standard of living in the world and can help feed nations abroad by exporting not only our produce, but our technology. Part of this technology is the effective and safe use of the various pesticides needed in a wide variety of situations. All pesticides marketed in the United States are subject to very extensive and detailed testing for efficacy in the Intended use, toxicity of different types and potential impact on the environment. This process will take from five to ten years from discovery of activity to marketing for one crop use, and cost from ten to fifteen million dollars. Regulation of pesticide use by federal and state agencies is very extensive and continues to increase the cost. Some of this re- gulation seems warranted, however, to ensure proper care in application of these materials and prevent undesirable consequences from their misuse. The labels and other literature by pesticide marketers and several state and federal agencies provide information on the characteristics of these chemicals and instructions for their use. Proper application of these products to achieve the desired results without injury to property else where or the environment is important. Serious losses can be sustained because of crop or animal damage, illegal residues in produce or water, air or soil contamination. These problems can develop because of improper application of sprays or from vaporization of com- pounds afterward. Since I am familiar with herbicides and they provide a variety of characteristics to illustrate the problems and procedures of confining pesticides Presented by L. E. Warren, Ag-Organics Department, Research and Development, Dow Chemical U. S. A., Davis, California (29) to their target areas, my presentation will involve the volatility and drift of herbicides . Many different herbicides are applied by air or ground equipment to control weeds and wood plants in fields, forests, roadsides and right of ways. Some ap- plication methods can result in movement of small particles to offtarget areas as the spray falls. Depending on the nature of the herbicide and the amount that moves off the target area, the effect may be manifested in injury to plants or animals or possible illegal residues in plants, animals or water. In addition, loss of intended activity on the target area may result in inadequate control or require a greater quantity of herbicide to compensate for the loss. The movement of herbicides in the air to off-target sites can result also from vapors that may form after application of certain herbicide formulations. We should distinguish between the two sources (spray drift and vaporization) and eliminate or reduce the extent of both to acceptable minimums. We define spray DR I FT as that part of the spray that moves off the target in fine particles formed as the spray leaves the nozzle at the time of application, and falls out on adjacent property. VAPOR I ZATI ON is the escape of molecules of the herbicide by volatilization from the falling or fallen drops before or after reaching the target area. The volatilities of herbicide products can be deter- mined and formulations can be used that will prevent unacceptable vaporization. Some aspects of volatility will be discussed briefly. The amount of drift can be affected by many factors, some of which can be controlled or adjusted to by the applicator. The more important aspects of drift will be explored in greater de- tail. VOLATILITY The vaporization potential of a herbicide can be assessed by the vapor pres- sure in relation to air temperature. The vapor pressure of a formulation may be (30) different than that of the active ingredient. 2,A-D is an example of a herbicide that is formulated as inorganic or organic salts, both water and oil soluble, and as esters which are oil soluble and water emuls i viable. A quick review of these relationships may suffice to illustrate the problems of volatility. The chemical structure and reaction point of salts or alcohol radicals is shown in Fig 1. The vapor pressures of the salts of 2,4-D as well as phenoxy, benzoic or picolinic acid compounds are very low; bioassays in greenhouse and field studies have been estab- 1 ished the lack of offtarget effects from any vaporization of these salt forms (1). FIGURE 1 H 0 i i + 0-C-C-A * Cl *Amine or other salt cations **Alkyl alcohol attaches to make ester 2,4-D has been marketed as esters formed from two to eight carbon or carbon + oxygen alcohols. The esters with two to four carbons have the highest vapor pres- sures and significant amounts can volatilize at temperatures of 60°F. or higher. These short chain esters are called "High Volatile" (H.V.). The longer carbon chain esters are formed from six to eight carbon or carbon-oxygen alcohols and have significantly lower vapor pressures (2,3). See Table 1 from date by Jensen and Schal 1 (2) . Note the effect of temperature shown in Table 1; the figures for 25°C are representative of the temperatures under field conditions. The vapor pressure of the six to eight carbon chains are 1 /A to 1/2 those of the n-butyl ester, for example. The propylene glycol butyl ether ester (PGBE ester) of 2,A-D has about the same vapor pressure. Zimmerman et al . (1) showed by plant bioassays that the (31) low volatile esters all caused about the same response and that they were many times safer than the H.V. esters. Field and lab studies have confirmed that movement of these ester forms can occur, but that the hazard from the low volatile esters is slight TABLE 1 Vapor Pressures of 2,4-D Esters Ester Structure 25° mm Hg Temperature , 187° °C 250° ethy 1 -C-C .0011 18 150 C 8 2 -propyl -C-C .001 A 17 Ho n-buy 1 1 -c-c-c-c 9.2 88 c 1 4-heptyl -c-c-c-c-c-c 5.0 56 n-hepty 1 -c-c-c-c-c-c-c .0002 2.9 40 c 1 2-octy 1 -c-c-c-c-c-c-c 3.1 40 ethy 1-hexy 1 1 -c-c-c-c-c-c 2.9 37 --From Jensen and Schal 1 (2) if the surface temperature for the first few days remains below 95°F. High volatile forms can cause damage to susceptible plants outside the treated area, especially if large acreages are treated in a short period of time and day temperatures are above 60°F. Usually volatilization of ester forms will occur only for three to four days after application because of the ester chain hydrolyzes off leaving the acid radical on the plant or other surfaces. The vapor pressure of 2,4-D acid is about the same (32) as the low volatile esters, but the acid will react with plant constituents and should not vaporize appreciably even at high daytime temperatures in crop areas (40). DRIFT Herbicides often are applied in sprays with fixed wing aircraft or helicopters using a wide variety of systems. Spraying systems are becoming standardized because of more awareness of the problem and in some areas to conform to legal restrictions. Drift from ground applications varies in relation to nozzle types and pressures, spray patterns, and nature of the spray, but generally more drift occurs from aerial app 1 1 cations . Herbicides require certain coverage or drops per unit area of leaf surface for efficient phytotoxic effect; the coverage requirements vary with the individual her- bicide as well as adjuvants, such as oil or surfactants, that may be included in the spray. Several researchers (A, 5) have shown that effects of phenoxy herbicides on foliage increase up to a density of about 70 droplets per square inch; the size of the droplet can be microscopic. Very little increase in efficiency is realized with more coverage. Picloram, amitrol and dicamba are translocated very readily in plants and it is probably that fewer contacts per unit leaf area are required. We know that drift Is more likely to occur with finer droplets. Our objective as applicators is to use the volume rates and spray break-up that will provide adequate coverage for good weed or brush control with no detectable off-target drift. Assessing both the coverage needed and the drift hazard are very important. At times, reduced brush or weed control may have to be accepted or the application not made at all, depend- ing on the circumstances. Applications, both aerial and ground, have waited days or weeks for safer weather conditions to prevent off-target damage. The movement of fine spray particles off the target area, which we defined as "DRIFT", is dependent on a large number of influences; several are itemized for aerial applications in Table 2. Drift from ground applications is affected similarly, but usually to a lesser degree. (33) Off-target hazard is influenced by the type and form of the herbicide and the type of carrier as they affect the tendency to produce smaller droplets and increase active herbicide concentration on the drops. The hazard is related to the suscep- tibility of different plant species to small amounts of various herbicides. The spray carrier can be water, oil-water emulsions, invert emulsions, foam or thickened water. Akesson and Yates (8) have shown that introduction of oily addi- tives or surface tension reducing agents will result in small drops. Several 9 viscosity increasing agents and other spray modifiers to increase drop size, such as invert emulsions, hydroxyethy 1 cel 1 ulose, NORBAK ^ part i cul ati ng agent, Nalco- TABLE 2 Factors Affecting Drift of Aerially Applied Herbicides 1. Herbicide - Nature and Rate. 2. Nature of Carrier - Water, Oil/Water, Oil, etc. 3. Spray drop size spectrum, as affected by: a. Nozzle type, capacity and pressure. b. Nozzle orientation to airstream. c. Speed of aircraft. d. Viscosity of spray. A. Application conditions: a. Flight Path - level, rising, falling, or turning. b. Boom location in relation to the wing or rotor. c. Location of nozzles on the ship (boom) . d. Height of release of the spray. e. Wind speed and direction. f. Air Stability (vertical movement). g. Number of contiguous passes. h. Width of total spray pattern. m 5 . Distance and direction to problem areas. 6. Screening effect of barriers - trees, etc. 7. Turning Area and Technique Trol\ and foams, have been introduced to reduce drift. These will be discussed later. SPRAY DROP SIZE Spray drop sizes are measured as diameters in microns (jj) , but drops have a third dimension. These drop sizes are diameters of freely falling droplets and are only 1/3 to 1/5 the size of spots on collectors such as cards. Potts (9) has computed the number of droplets of different sizes produced by one gallon of spray and these are shown in Table 3* A droplet that has twice the diameter of another has eight times the volume or weight. The smaller droplet has about 1/2 the sur- face of the larger droplet and, therefore, requires about 1/16 the lifting force of air to remain aloft. These characteristics accentuate the drifting tendency of the smal ler droplets. Table 3 Size and Number of Droplets per Square Inch from One Gallon Liquid Uniformly over One Acre Droplet Diameter, Microns (p) * No. Droplets per Square Inch 25 80,625 50 9,22 4 100 1,16 4 150 347 200 142 300 43 1 ,000 1 * One micron (jj) = ab. 1/25,400". — From Potts (9) . Reg i stered trademark of Nalco Chemical Company, Oak Brook, Illinois. Droplet size is very important in drift; water droplets in various components of the atmosphere and their drifting potential are noted in Table 4 (7). Droplets in the size range of 20 - 30 p or smaller remain suspended (fog); in herbicide sprays, these droplets may be nearly invisible in the air. Of course, these as well as larger droplets, are subject to air movement. The larger droplets are moved less horizontally, but still may move considerable distances; note that 100 p droplets can move laterally 408 ft. in a three mph. wind while falling ten feet. Some applications to utility lines or forest sites are made 100 to 300 feet above the ground, which magnifies the drift potential greatly. Tabl e 4 Spray Droplet Size and Its Effect on Spray Drift Droplet Diameter Microns Type of Droplet No. of Drops per Sq. Inch from one ga 1 . Spray /Acre Time Requ i red to fa 1 1 10 ft. in Still Air Distance Droplet Will T ravel in Fal ling 10 ft. w i th 3 mph w ind 5 (to 30) Fog 9,000,000 66 min . 3 ml les 100 Mist 1,164 10 sec. 408 feet 500 Light Rain 9 1.5 sec. 7 feet 1000 Moderate Rain 1 1 sec. 4.7 feet — Adapted from Akesson and Yates (25) and K! ingman (7) The effect of a five mph crosswind on horizontal displacement of different size drops is shown graphically in Fig. 2 (10), assuming no change in size dur- ing fall. (36) FIGURE 2 Lateral Movement (ft.) 20 hO 60 80 100 120 Wind, 5 mph “■"From Seymour (10) Research has shown that there Is a rapid decrease in drift potential of drops as they increase from 20 to about 150 or 200 p . Thereafter, as the drops enlarge there is much less change in the drift potential. The critical size where this difference occurs Is larger with higher wind speeds, but lies in the range of 150 to 250 p for speeds of one to eight mph (11, 12); Fig. 3 shows this relationship. Drift is decreased greatly by increasing drop sizes to about 150 to 250 p, and much less after that. The size range from 200 to hOO jj allows adequate coverage with reasonable volume rates and is a good size to seek for spraying herbicide. (37) FIGURE 3 Relation of Spray Drop Size to Drift at Different Wind Speeds Drop Diameter, Microns --From Byrd (11) With water carriers, spray drop size may decrease during fall because of evaporation unless a non-evaporat ive film, such as oil, surrounds the drops. Smaller droplets falling into air of relative humidity less than about 80 per- cent may evaporate before hitting the target (13). Fig. k shows the effects of evaporation on water droplets 80 to 200 y in diameter falling through air with a 50 percent and 70 percent relative humidity with a one mph crosswind. Note that in air at 50 percent relative humidity, the 80 to 120 y drops disappeared with less than a seven foot drop; the smaller spray droplets dis- appear sooner. The herbicide in these drops will not fall out until picked up in falling rain. The 200 y drops may reach the ground, but will certainly be progressively smaller and more subject to drift. The droplets evaporate more slowly in 70 percent relative humidity and faster in lower relative (38) Fa 1 1 Distance, ft FIGURE A Effect of Relative Humidity on Lateral Movement of Spray Droplets in a One mph Wind Lateral Movement in One mph Wind, ft. _ — _ 70% Relative Humidity —Adapted from Seymour and Byrd (13) humidity. It is evident, then, that as water droplets fall through air with a water deficit (less than 100% RH) , they will be decreasing in size and will more more or less as indicated in Fig. A. Addition of oils or surfactants may reduce this eva- poration somewhat, but usually there will be some loss in water as they fall. (39) EFFECTS OF SPRAY SYSTEM CONDITIONS ON DROP SIZE As liquids are forced through orifices under pressure, they speed up. There usually is some turbulence in the nozzle or spray dispenser that exerts breakup forces on the liquid. As it leaves the nozzle, it may be directed into a fan or a hollow or solid cone pattern that creates added shear. The liquid extends into sheets--ei ther flat or circulai — or threads. These stressed liquids develop waves in the sheets or threads, and break up resulting in larger drops with many satellite droplets. The shear is caused by the pressure and turbulence, such as internal deflecting vanes to induce a cone or any diviation from a solid stream. Circular orifices without swirl plates produce the least disturbance and, therefore, larger drop sizes. Various size nozzles under different pressures change the average drop size, but the size range is still great. Certain devices have been developed to reduce the range of drop sizes, 2 3 2 such as the Microfoil boom, the Raindrop nozzle and Di rect-A-Spray . These will be discussed later. When a liquid is forced apart, it usually forms a large range of drop sizes. Most nozzles or spray devices produce a distribution of drop sizes, as indicated in Fig. 5. The pattern shown by the dashed lines (Fig. 5) would be close to ideal. Certain mechanical or electrical devices will produce fairly uniform drop sizes; the mean drop size of the spray must be increased so the amount in fine particles (less than 50 to 100 jj) will be below levels that may cause significant off-target effects. ^■Registered trademarks of Amchem Products, Inc., Ambler, Pennsylvania ^Registered trademark of Delavan Mfg. Co., West Des Moines, Iowa. (40) FIGURE 5 Typical Droplet Size Distribution from Spray Uozzles I 7 ttl) Because of the wide range of drop sizes in sprays, various methods are used to designate this factor. The one probably used most is a size at which half the spray volume is in drops above and half below this figure; it is called the "Volume Mean Diameter" (VMD) . This results in a much greater number of drops in the smaller half of the spray. Another term is the "Number Mean Diameter" (NMD), which indicates the size at which 1/2 the number of droplets produced is larger or smaller. If drop size counts are made for certain spray systems, the drift potential can be assessed by noting the percentage of spray in the size range below 100 to 150 /j, using a cumu- lative graph of the spray volume in the different size ranges, as indicated in Fig. 6 (15,33). FIGURE 6 «2) Drop sizes In sprays change significantly and inversely with pressures, as shown in Fig. 7 (34). Pressures in the range of 20 to 35 psi at the nozzle are usually ade- quate to produce the desired spray pattern and will result in much less drift then with higher pressure. Fig. 7 shows that there is less effect of pressure on drop s i ze w i th smaller size orifices. Tate and Janssen (16) found that the mean drop sizes of sprays from cone, fan or deflector nozzles were essentially the same If the fan or cone angles were the same. The drop size was almost directly proportional to the flow rate at equal pressures as plotted in Fig. 8. References to drop size determinations for various nozzles by Spraying Systems Co. (34) indicate that the wider angle fans or cones produce smaller droplets, as plotted in Fig. 9. Other data and experience show that a jet (round orifice) will produce the largest size drop for a given flow rate and pressure--due likely to the fact that there is less shear stress on the liquid. Also, certain noz- zles such as the Spraying Systems Low Pressure (LP) nozzles, can produce a good pat- tern at pressures from 10 to 20 psi. Spraying Systems type TG and GG solid cone (full jet) nozzles produce larger drops than fan or hollow cone nozzles with equal core or fan angles, flow rates and pressures (34), as shown in Fig 10. The Raindrop nozzle recently introduced by Delavan Mfg. Co. apparently reduces the range of particle size by providing a chamber outside the metering orifice to in- duce coalescence of the small drops. Field tests are progressing now; data from manufacturer's tests indicate that drift can be reduced In ground applications by this means without sacrificing much in coverage. Foam nozzles are special aspirators with fans, jets or other patterns that are used with certain foaming agents that incorporate air to expand the spray volume 4 to 600% (18). Drift of foam sprays will be discussed in the section under"Adj uvants" . The microfoil boom (Amchem Co.) uses a large number of holow needles projecting back from a small air foil boom mounted on a helicopter. These tubes produce few m FIGURE 7 ✓ I* f . V fine drops and the air stream moving around the air foil helps coalesce them. It is FIGURE 8 Droplet Size vs. Nozzle Flow Rate 210 200 L. Proc. Am. Soc. Agri. Engineers. 15. COUTS, H. H. AND W. E. YATES. 1965. Analysis of Spray Droplet Distribution f rom Agr i cul tural Aircraft. Paper No. 65-157, Proc. Am. Soc. Agri. Eng i neers 16. TATE, R. W. AND L. F. JANSSEN. 1966. Droplet Size Data for Agricultural Spray Nozzles. Trans. Am. Soc. Agri. Engineers, 9 (3) 17. ISLER, D. A. AND J. B. CARLTON. 1964. The Effect of Mechanical Factors on Atomization of Oil Base Aerial Sprays. Proc. Am. Soc. Agri. Engineers, Paper No. 64-608. (62) 18. GRATKOWSKI , H. J. AND R. E. STEWART. 1973. Aerial Spray Adjuvants for HerbicSdal Drift Control. U.S.D.A. Forest Service Tech. Rpt. PNW-3. 19. LANING, E. R. AND T. W. HOLMSEN. 1969. Minimizing Spray Drift of Her- bicides. Industrial Vegetation Management 1 (2) : 2 -5 • 20. BYRD, B. C. AND K. G. SEYMOUR. 1964. Wind Tunnel Studies of Thickened and Particulate Sprays. Paper No. 64-609D, Proc. Am. Soc. Agri. Eng i neers . 21. YATES, W. E., N . B. AKESSON AND D. E. BAYER. 1 97^. Effects of Spray Adjuvants on Drift Hazards. Paper No. 74-1008, Proc. Am. Soc. Agri. Eng i neers . 22. MOORE, A. D. 1967* Aircraft in Forest Insect Control. Proc. Aerial Applicators1 Short Course. 23. YATES, W. E., N. B. AKESSON AND R. BRAZELTON. I967. Basic Factors Related to Distribution Patterns from Agricultural Aircraft. Proc. Western Reg. Pesticide Chem. Applicators Short Course, II: C1-3I. 24. WARREN, L. E. 1973. Pattern Studies with Jet Nozzles on a Helicopter. Unpublished data, The Dow Chemical Company, Davis, Calif. 25. AKESSON, N. B. AND W. E. YATES. 1964. Problems Relating to Application of Agricultural Chemicals and Resulting Drift Residues. Ann. Rev. Entom , , 9. 26. ASHFORD, R. 1974. Herbicide Efficacy and Drop Size. Proc., Canadian Weed Committee, 28th Annual Meeting, pp. 32 - 33 . 27. GROVER, R. 1974. Reducing Droplet Drift From Existing Farm Sprayers. Proc. Can. Weed Comm., 28th Ann. Mtg., pp. 18-19. 28. MAYBANK, J. AND K. Y0SH1DA. 1973* Droplet Deposition and Drift from Herbicide Sprays - Analysis of the 1973 Ground-Rig Trials. Saskatch- ewan (Canada) Res. Council, Physics Oiv., pp. 73 ~ 7 6 . 29. BODE, L. E.» B. J. BUTLER AND C. E. GOERING. 1975. Effect of Spray Thickener, Nozzle Type and Nozzle Pressure on Spray Drift and Re- covery. Paper No. 75-1065, Proc. Am. Soc. Agri. Engineers. 30. YATES, W. E. 1975. Drift Reduction Techniques for Aerial Spray Applications. Proc. 27th Ann. 111. Custom Spray School. 31. WSLCE, S. E., N. B. AKESSON, W. E. YATES, P. CHRISTENSEN, R. E. COWDEN, D. C. HUDSON AND G. I. WEIGHT. 1974. Drop Size Control and Aircraft Spray Equipment. Agri. Aviation, Inti. Aviation Ctr., 16(1) : 7~ 1 6 . 32. AKESSON, N. B., R. FOSSE. 1 960 . Invert Emulsions Reduce Unwanted Drift. Agrichemical West, 31(6). 33. SPRAYING SYSTEMS CO. 1967. Graph - Particle Size vs. Volume Percentage for 15° Flat Spray Nozzles, Drwg. 12135-7* (G3) 34. IBID. 1966. Graph - Spray Particle Size vs. Pressure, 15° Flat Spray Nozzles, Drwg. 11825“!’. 35. WARREN, L. W. , W. E. YATES AND S. R. RADOSEVICH. J975. Control of Drift from Helicopter Applications of TORDON 101 Mixture and Tri- clopyr with Nalco-Trol. Unpublished data, the Dow Chemical Company and University of California, Davis, California. 36. FEDERAL REGISTER. 1974. No. 121.1225. Adjuvants for Pesticide Use Dilutions (Sodium acrylate and acrylamide co-polymer (Nalco-Trol) Vol. 39, No. 241, December 13, 1974. 37* BOUSE, L. F. AND R. E. LEERSKQV. 1973* Drift Comparisons of Low Expansion Foams and Conventional Sprays. Weed Sc i . 21 (5) :405~408. 38. THE R. L. WILSON COMPANY. . Wilsco Foamspray Data Sheet. 39. LAUCKE , J. E. 1974. Application of Paraquat and Diquat by Air. Chev- ron Chemical Co., p. 13* 40. HAMAKER, J. W. 1975. Vapor Pressures of 2,4-D Acid and its Esters. (Private communication). The Dow Chemical Company, Walnut Creek, Cal i forn ia. (64) DILEMMA FOR DISPOSAL OF HERBICIDE ORANGE In 1962 vegetation control systems using herbicides were Introduced by the military into the Southeast Asia Conflict. Their use was to remove dense vegetation along highways, canals, lines of communication, and around base perimeter camps; thereby reducing enemy ambush. The herbicide formulation of choice was an equal mixture of the n-butyl esters of 2,4-D and 2,4,5-T. This formulation was labelled Orange because of the orange band around the centers of the 55~ga11on drums in which It was transported. Although severe criticism of the defoliation program was voiced as early as 1964, St was five years later before the program (Operation Ranch Hand) was suspended by the Department of Defense. Initial criticism was directed at Orange as a chemical warfare agent used against crops and the environment of South Vietnam. However, the termination of the program was not based on the above criticism but rather on reports by South Vietnamese newspapers of an increased occurrence of birth defects during June and July I969 from areas defoliated with Orange Herbicide. These reports elic- ited far-reaching reactions from governmental agencies, segments of the scientific commun i ty , lay groups concerned with environmental problems, and from the cormiuni- cat ion media. Government sponsored panels of experts, special commissions established by scientific organizations, hearings before subcommittees of the U. S. Congress, and Conferences attended by representatives from industry, government, and universities examined available data and were not able to provide a generally acceptable answer to the central question of whether 2,4, 5-T as produced and used constituted a risk for human pregnancy. In mid-October 1969, a report was released to the press of the findings of a study by Bionet ics Research Laboratories, Litton Industries Incorporated. The report documented the presence of defective offsprings from mice and rats treated during Presented by Captain Alvin L. Young, Ph.D., Associate Professor of Physiology, De- partment of Chemistry and Physiology, United States Air Force Academy, Colorado (65) early pregnancy with large doses of 2,4,5_T. It was subsequently announced on October 29, 1969, that a series of coordinated actions were being taken by several governmental agencies to restrict the use of the herbicide 2,4,5"T. Additional animal experiments performed early in 1970 confirmed that pregnant mice did deliver some malformed off- spring. The question then was one of whether or to what extent, such animal date could be extrapolated to man. On April 14, 1970, the Secretary of Health, Education and Wel- fare (HEW) advised the Secretary of Agriculture that: "In spite of these uncertainties, the Surgeon General feels that a prudent course of action must be based on the decision that exposure to this herbicide may present an imminent hazard to women of child-bearing age." Accordingly, on the following day, the Secretaries of Agriculture, HE V/ , and Inte- rior jointly announced the suspension of 2,4,5-T for "all uses around the home, recrea- tion areas, and similar sites" and "in all uses on crops intended for human consumption.1 Immediately thereafter, the Department of Defense suspended the use of Orange Herbicide in South Vietnam. The suspension of the use of Orange Herbicide left the Department of Defense with 1.5 million gallons in Vietnam and 860,000 gallons at the Naval Construction Battalion Center, Gulfport, Mississippi. In September 1971, the Secretary of Defense directed the Joint Chiefs of Staff to dispose of the surplus inventories of herbicide in both the Continental United States and Vietnam. The Air Force was assigned the responsi- bility of finding a disposal method(s) that was (were) ecologically safe and econom- ically feas ible. In April 1972, the 1.5 mi 1 1 ion gal 1 on s of herb i c ide in V ietnam was placed in 55~gal Ion drums and transported to Johnston Island, Pacific Ocean. The total Orange Herbicide inventory was 2.3 million gallons stored in approximately 40,000 55-gallon drums. Thus, not only is there herbicide to be disposed but also the drums. The initial method proposed for disposal was incineration at a commercial facility in the United States. The details of this proposed course of action were documented in a draft environmental statement which was filed with the Council on Environmental Quality and the Public in January 19/2. The draft statement discussed the studies that were being accomplished, but not completed when the statement was filed. Based on the fact that studies were still in progress and the interest evidenced in comments received on the draft statement, the Air Force decided to conduct additional studies on incineration as well as additional investigations of alternative disposal methods. In April 1972, the Air Force Logistics Command (AFLC) began an indepth invest i- gation into the feasibility of use, Incineration, soli biodegradation, fact ionat ion , chi or inolys is and reprocessing as major disposal options. Data to be collected on each method included the parameters of time, cost, and effectiveness of the disposal process. In addition, the physical, biological, managerial and soc ial -pel S t i cal fac- tors for potential sites of disposal were to be assessed. Reports of progress and/or problems encountered were periodically presented to an Ad hoc Committee on the DIs- posal of Herbicide Orange of the Air Force Scientific Advisory Board. Other disposal options reviewed and discussed with the Ad hoc committee were return of the herbicide to the manufacturer, deep well disposal, burial in an underground nuclear cavity, s sludge burial, microbial reduction, and no disposal action. The last option was to be selected only if the other options were not ecologically acceptable, technology not sufficiently developed for their employment, if excessive capital investment was required, if unacceptable time delay was imminant, or If the socio-political opposi- tion prevented any course of action. The option of “no action" would mean that Orange would be placed into seal storage tanks for permanent storage at both Johnston Island, and Gulfport, Mississippi. In the formulation of an environmental impact statement on the disposal of Orange the following description of action for each option was prepared. 1 . Use Orange herbicide is not an Environmental Protection Agency (EP A) registered pesticide and cannot be domestically used or sold. The Orange Herbicide stock to be (67) disposed represents a resource of considerable monetary value (a recent estimate is $80 - 100 million). Orange Herbicide has a potential use on Federal lands as well as on privately owned lands; however, any use would require registration. The prudent disposition of Orange Herbicide for use on privately owned or governmental ly owned lands may have a tremendous impact on increasing the availability of certain natural resources, e.g., rangelands and forests. Undesirable weed and brush species are widespread in every region of the United States. Their combined impact on rangelands and production of commercial timber is enormous. Approximately half of the total land area of the United States is used f for pasture and grazing purposes, and weeds and brush are a problem on nearly all these forage lands. Economic losses from weeds on forage lands are virtually incal- culable and include low yield of forage and animal products per unit area, reduced livestock gains, and livestock poisoning. Although herbaceous weeds are found on all rangelands in the United States and result in forage losses, brush is the pri- mary problem. Various brush species dominate an estimated 320 million acres of rangelands. More than 80% of 107 million acres of grazing land in Texas alone is infested to some extent with brush. Once establ ished,wwood plants such as mesquite (Prosopis spp.), juniper (J un jperus spp . ) , oak (Quercus spp.), and sagebrush (A rte- mi s 1 a spp . ) cannot be eliminated by good grazing practices alone. Measures must be taken to convert brush dominated rangeland to more productive types of vegetation. Brush control and striking improvements in the grazing capacity of rangeland may be obtained most economically by low-rate and low-volume applications of phenoxy herbi- cides . Commercial forest land in the United States is estimated at 509 million acres. Although much of this land is not under any form of planned management for production of forest products, management for an increased productivity will soon become essen- tial to meet the needs of the United States population. It is estimated that the total area of forest lands supporting important amounts of undesirable vegetation is approximately 300 million acres, or a land area potential! commercial timberland equal to roughly the combined areas of Texas, California, and Washington. There are some 4.7 million acres of commercial forest land in western Oregon and Washington on which the land is occupied by vegetation whose presence precludes reestablishment of conifers. Much of the area is in the highest productivity class for growth of forest products. Concepts of selective brush control have been developed for reforestation with the aid of commercial formulations of 2,4-D and 2,4,5“T. There are presently some 100,000 acres being treated each year with various formulations of these materials, all as the low-volatile esters. Success has been good, especially In operations on the s lower -grow i ng brush species. Thus, the purpose for using herbicide Orange on rangelands and reforestation would be to reduce the amount of undesirable vegetation that dominates in selected regions of the United States because of past disturbances and improper grazing and/ or timber practices. Wi th the use of herbicide Orange, a more diversified and de- sirable variety of plant species would become established. This In turn would have a substantial impact on increasing productivity of these regions. The environmental impact of using herbicide Orange for chemical brush control will vary from region to region and whether it is for range or forest use. However, regardless of the region of use, or for rangeland or reforestation, critical assess- ments of effects on vegetation, wildlife, domestic livestock, soil microorganism, aquatic life, rangeland or forest waters, and man must be evaluated. 2. RETURN TO MANUFACTURERS in March 1972, seven manufacturers of herbicide Orange were contacted re- garding the possibility of chemically reprocessing Orange Herb ic ide whereby all impurities, including dioxin, would be estracted or destroyed. Results from all manufacturers were essentially the same; i.e., they did not feel that they were (GO) capable of reprocessing the product without extensive investment in equipment and/or development of new processes. Lead time for this type of action would require in excess of 18 months before large scale reprocessing could begin. As a result of EPA's action on June 2b, 197** to cancel the hearings on the possible further restric- tion of 2,^,5-T, the manufacturers were again contacted (August 197*0 via letter to determine if their position may have changed. Manufacturers again indicated that they did not want to reprocess Orange. 3. DEEP ( INJECTION) WELL DISPOSAL This process would involve injection of the herbicide into a deep subsurface formation. The well hole down into the formation would be lined with casing which has been cemented into place to prevent fluids from rising to the surface outside the casing to a permeable geologic formation. The herbicide drums would be emptied into tanks or vats on the surface where the Orange Herbicide would be diluted and then pumped down the tubing to the permeable formation. The packer tool prevents fluid from returning to the surface inside the casing and impermeable upper and lower for- mations adjacent to the permeable formation restrict verticle movement. This process has not been approved by state agencies, or the EPA, as deep well injection is not considered environmentally safe or desirable disposal method for waste materials. The policy is to oppose all storage or disposal of wastes in deep wells without strict controls and a clear demonstration that such disposal will not: a) interfe re w i th present or potential use of subsurface water supplies, b) contaminate interconnected surface waters, or c) otherwise damage the environment. Little concrete information in available on what degradation of the Orange would occur at the depths, temperatures, and pressures encountered in deep wells. This coupled with the possibility of subsur- face disturbances at a later date which might allow Orange to migrate into formations leading to water supplies or other valuable formations, has prevented any of the firms interested in disposing of Orange in deep wells from obtaining state or Federal permits. 4. BURIAL IN UNDERGROUND NUCLEAR TEST CAVITIES The Atomic Energy Commission was contacted regarding the possibility of dls- posing of the Orange by burying it in an earth cavity formed during underground nuclear testing. They advised that a major research, development, and experimentation effort would be required to prove the practicality of this alternative. In view of the time required for this effort, it is not considered a feasible alternative. 5. SLUDGE BURIAL This technique offered definite promise, but there was a lack of interest and qualified industries to undertake the necessary preliminary investigations. This process involves one concept of destroying the Orange through bacterial action. The proposal envisioned constructing trenches in geologically suited formations on iso- lated government land. The type of formations picked for the trenches would preclude vertical and lateral movement of the orange and would then be surrounded by secondary sewage plant sludge, which would provide a growth medium for the bacteria. The tops of the drums would then be mounded with dirt fill and aggragate. Depending upon the type of bacteria selected to decompose the Orange, vents might be required. This process is not considered acceptable because of the time to completely destroy the herbicide is quite lengthy, possibly as long as 10 to 25 years, and because a sys- tem of monitoring would be required throughout this time period. The earth covering would require maintenance and additional time might also be required to develop a strain of bacteria that would tolerate high concentrations of Orange. 6. MICROBIAL REDUCTION This process involves the biological degradation of the herbicide through fermentation. It requires the development of a microorganism to "feed" on the herbicide. From the literature, it seems apparent that microorganisms have developed unbelievable capabilities for handling organic compounds. However, two factors severely complicate the biological degradation of this refractive material: 1) its insolubility in water and 2) its chemical structure (specifically the number (71) and position of chlorine atoms attached to the aromatic ring). Many investigators have showed that 2,4-D is rapidly decomposed in the soils and that high concentra- tions have no depreciable effect on the soil population of bacteria, fungi, and act inomycetes . The presistence of 2,4,5~T is usually two or three times longer than 2,4-D and very few microorganisms have been identified as having the ability to break down the 2,4,5-T molecules. Data are available that indicate that mixtures of 2,4,5-T are more rapidly degraded than are single compounds. Very little work has been done on the microbial degradation of TCDD; however, initial data indicate that it is de- gradable, but with an estimated half life of one year (as a single compound). The environmental impact of a microbial reducat ion method is dependent upon the fate of TCDD in a biological treatment facility. It must be established that no TCDD is remaining in the effluent, or a problem of enormous consequences can occur. Thus far no data are available on the fate of TCDD in a biological reduction system. All other aspects of such an alternative can be controlled and minimized to an acceptable level. Monitoring methodology and a failsafe system would be required. Until more data are developed the particular environmental aspects cannot be evaluated. More specific information concerning the process, size of facility, land acreage required, and effluent parameters are needed. 7. FRACTIONATION Fractionation is the process of converting Orange into its acid ingredients by means of distillation. This would separate the normal butyl esters of 2,A-D and 2,4,5-T and its contaminant TCDD. the 2,4-D would be reformulated for commercial use. TCDD would then be destroyed by chemical, biological or incineration techniques. Actual distillation efficiencies theoretically could approach 90-95%* One investiga- tor stated that any TCDD residue could be destroyed by splitting the ether bonds of the molecule. In the process of fractionation, the dioxin would be isolated or destroyed. A small scale study was funded, but the results were inconclusive. (72) Fractionation is not acceptable because: a) the fate of the dioxin has not been demon- strated, b) in the process, 3% of the Orange processed could not be accounted for, c) standards to control and monitor vapor and fluid emmissions into the environment have not been identified. 8. SOIL BIODEGRADATION Soil biodegradation is a soil incorporation technique based on the premise that high concentrations of the Orange Herbicide and the contaminant TCDD will be degraded to Innocuous products by the combined action of soil microorganisms and soil chemical hydrolysis. The rationale for soil incorporation of herbicide as an ecolo- gically-safe disposal method comes from pertinent laboratory and field studies. It seems apparent from laboratory studies that microorganisms have developed extensive capabilities for handling organic compounds. Moreover, most organisms seem to have a latent ability for decompos it ion of halogenated hydrocarbons. However, the amount of active herbicide applied to soil may diminish by means other than biological decomposition; e.g., chemical degradation, absorption, volatilization, leaching, and photodecompos i t ion . Until recently there was very little information concerning the breakdown of 2,A-D or 2,4,5-T in a soil incorporation site. However, field experiments on the use of soil incorporation as a method of disposing of massive quantities (approximately 1-1/A mil- lion gallons) of 2, A-D and waste by-products has been carried on in eastern Oregon. A trenching technique was employed to simulate subsurface injection. A concentration of 500 Ib/A 2,A~D (plus waste) was placed at a depth of 10 inches (5-inch bands on two- foot centers). With this placement the actual concentration of herbicide within these bands was approximately 1250 ppm. Samples taken between trenches and in soil profile segments from the surface down through the point of application indicated minimal vertical and horizontal movement of the herbicide (or phenolic waste) from the site of initial deposition. Results from this experiment indicated little differences in rates of degradation in the trenched plots or a surface application of 500 1 b/A : 95% (73) degradation in 540 days. Our project group at the United States Air Force Academy has studied the persis- tence and movement of herbicide Orange and TCDD following soil incorporation at rates of 1,000, 2,000, and 4,000 pounds active ingredient 2,4-D and 2,4,5_T/acre (lb ai/A) in a remote site in western Utah. The precent loss of herbicide over a 330 day sam- pling period was 78.2%, 75*2% and 60.8% for the 1,000, 2,000 and 4,000 lb ai/A plots, respectively. The calculated half-life or herbicide Orange in alkaline (pH=8.1) desert soils was approximately 150 days at these massive rates. Data on soil penetration indicated that less than 3*7% of the herbicide w as found at depths greater than 18 inches 282 days after soil incorporation of 4,000 lb ai/Z. Preliminary data based on levels of TCDD in the formulation (3*7 ppm) and those encountered in the soil profile 265 days following soil incorporation suggested that under these environmental conditions that half-life of TCDD was 88 days. Our USAF Academy team also established biodegradation plots in Garden City, Kansas and Elgin AFD, Florida. Data from these i ncorporat ion studies are in agreement with the Utah plots: degradation of 2,4-D, 2,4, 5“T and TCDD when applied at massive rates, rapidly occurs and movement of the herbicide in fact is minimal. It is important that the criteria for selection of a site for soil biodegradation include certain physical, biological, and managerial factors. (1) Physical Factors: From the standpoint of just physical consideration, the soil incorporation technique provides an array of alternatives as to the selec- tion of site. In general: (a) A minimum of 2,000 acres must be available. (b) The site must be remote. It cannot be adjacent to land currently in agronomic production. (c) The land must have a low-use potential, i.e., it should be nerginal land. Moreover, the land should not be considered land that will be significantly productive in the foreseeable future. (d) Water resources must be sufficiently far away so as not to be contaminated. (e) The topography of the land must be relatively flat with a uniform surface. (f) The texture of the soil should be sandy-loam or s i 1 ty-1 oam w i th a pH of approximately 8.0. (g) The area should not be characterized by rock outcrops or areas of marked deflation or dunes. The area should also have minimal surface erosion. (h) Data should be available on subsurface geology and hydrology. (2) Biological Factors: The vegetation that characterizes the particular site must be uniform with a ground cover of at least 10 - 1 5% . Such a plant community will provide the organic matter and microclimate that supports the growth and mainte- nance of microflora (e.g. , fungi and bacteria). Ideally, the vegetation should be low-growing shrubs, forbs and grasses to facilitate the incorporation equipment. (3) Management Factors: The management factors that will influence the selection of the site are: (a) The requirement for established all weather roadbeds to and within the disposal site. (b) The distance to the disposal site from an off-loading station (e.g., rail to truck). (c) The requirement for security of the disposal site. (d) Availability of personnel facilities. (e) Adequate storage space at the disposal site. A subsurface injection system would be used to incorporate the herbicide into the soil at a depth of six to ten inches. The injection would be done by using a conventional agricultural subsoiler, drawn by a heavy industrial tractor. The sub- soiler would consist of a verticle blade on which a chisel, or foot, is mounted at an angle of approximately 15° from horizontal. A piece of metal tubing will be attached to the blade (and terminating at the base of the chisel) in such a manner that a piece of hose from the injection pump could be inserted to permit disposi- tion of the herbicide immediately behind the chisel. The equipment, with eight injectors (shanks), should be calibrated to apply 4000 Ib/A of Orange. The eight shanks should be on 20-inch centers. During the process of application the over- lying vegetative structures will be damaged. To prevent the loss of soil moisture and to reseal the soil (thus minimizing volatility and damage from wind) a soil compactor (cul t ipacker) will be required and a drought resistant, salt tolerant grass will be planted. (75) The environmental impact of soil biodegradation would be expressed in two major areas; the most significant of which is the denial of a 1,000 - 2,000 acre tract of land for reclamation or recreation use for a three to five year period during bio- degradation. The proposed site would require continuous monitoring during the life- time of the project. Also occurring will be damage and/or kill of the overlying vegetative structure in the immediate disposal area, drastic alteration of the soil structure, and disturbance and/or temporary destruction of local ecosystems. Ad- herence to the above site criteria and incorporation method will optimize the soil biodegradation procedure and minimize adverse environmental impact. 9. CHL0RI N0LYSIS From the theoretical engineering point of view, chi or inoly sis offers an efficient, controlled, and safe method for disposal of the herbicide, as well as other hydrocarbon formulations. Chi or inol ys i s is a process that breaks down the molecule and adds a chlorine molecule to produce carbon tetrachloride, phosgene, and anhydrous hydrogen chloride, all of which have established commercial value. Ch lor i nol ys is as a means to dispose of Orange Herbicide was evaluated over a period of almost two years. In July of 1972, discussions and co rrespondence w i th the Environmental Protection Agency (EPA) committed the Air Force to pursue the testing and research program necessary to determine the feasibility of converting Orange to salable products by chlor inolys is. In September 1972, a Memorandum of Agreement between the EPA and the Air Force was initiated. The objective of the agreement was the development of a laboratory program to evaluate the practicality of the application of chlor inol ys is for the disposal of Orange. The investigation was also to determine the extent of destruction of the impurity dioxin. The infor- mation and data obtained in this research was to be utilized by the Air Force to determine whether the proposed concept could be applied and used to dispose of Orange and by the Environmental Protection Agency to determine if it could contri- bute toward solving the disposal problems of the petrochemical industry. It was agreed that the EPA would manage the research and provide a report containing all data collected, together with conclusions and recommendations. The Air Force agreed to fund the effort in the amount of $35,000. An additional $10,000 was provided for analysis of dioxin. Three drums of Orange containging 14 ppm dioxin (analysis by Dow Chemical Company) were provided by the Air Force. The EPA report, “Study of Feasibility of Herbicide Orange Ch lor i nol ys is" (EPA- 600/2-74-006, July 1974), covering only the work of Diamond Shamrock Company was delivered on October 2, 1974. The report covered the results of bench scale tests and concluded, based on these bench scale tests, that ch lor inol y s i s under the proper conditions effectively converts Orange Herbicide and its TCDD contaminant to carbon tetrachloride, carbonyl chloride and hydrogen chloride. Destruction of the TCDD was complete, and preliminary toxicology tests of the recovered carbon tetrachloride on rabbits showed no evidence of TCDD contamination. The report also contained cost estimates which included credit for the sale of chemicals from 25 ton/day plant. The cost in the worst case was shown to be $11 million and in the best $4 million. Owing to the uncertainties associated with developing this technique to a full scale plant capable of processing 2.3 million gallons of Orange in a timely and economical manner. Partial or total chi or inolys is was not selected as the method of disposal even though it is satisfactory from an environmental point of view. 10. INCINERATION AT SEA One of the most viable options for the destruction of Orange Herbicide is via incineration on a ship at sea. Since September 1972, a ship the “Volcanus" (registered in Rotterdam, Netherlands) has been equipped to carry certain hazardous liquid chemical cargoes from northern European ports and approved by participating countries to incinerate the waste cargo in prescribed areas of the North Sea. Additionally, U. S. Companies have suggested shipboard incineration and have indicated a willingness to investigate it. The ship is a double hulled and double bottom tanker with an overall length of (77) 33 1.4 feet, a beam of 47.2 feet and a draft of 22.9 feet. Her construction complies with the latest Inter-Governmental Maritime Consultative Organization (IMCO) regula- tions of bulk carriage of dangerous chemicals at sea. Because of her size, the vessel is able to operate and continuously man the incineration process. Two diesel engines drive the single propeller to give service cruising speeds of 10 to 13 knots. The vessle's cargo tank capacity of 3,503 cubic meters (CBM) (925,493 gallons) is divided into 15 cargo tanks ranging in volume from 115 cbm to 574 cbm. Hone of these tanks are in contact with the vessel's hull and/or bottom. The engine room is separated from the cargo tanks by double bulkheads, the pump room and generator room being situated in between. The incineration system consists of two combustion chambers installed right aft of the upper deck. Each of the bricklined incinerators has a maximum outer diameter of 5.50 meters (m) , and inside diameter of 4.80 m and a total height, including the stack, of 10.45 m. The volume of each conbustion chamber is calculated to be 87.9 cmb. Each chamber has three burners with rotating cup fuel injection systems which provide vortex turbulence and distribution of fuel feed throughout the whole chamber. Incineration could be conducted in a designated area 50 to 60 miles clear of normal shipping lanes and on the open tropical sea downwind cf Johnston Island. Gas or diesel oil would be used to bring the chambers to the required combustion tempera- ture, normally 1 400°C (2552°F) ; the maximum operating temperature is reported as 1650°C. Only when the required temperature is reached would the feed pumps allow waste to enter the combustion chambers. Waste feed flow and air would be carefully controlled to insure complete combustion. Once the required temperature was obtained, the chambers would be fed solely by the undiluted Orange. The Orange could be pumped to each of two chambers at a rate of 10 to 12 toms per hour for a total daily pump rate of about 576 tons. Therefore, about 22 to 26 days of continuous incineration would be required to burn the entire Orange stock (2.3 million gallons). The vessel's capacity of about 925,000 gallons of Orange would require three voyages; 925,00 gal- lons of Orange would be burned during each of the first two voyages, and the remain- ing 380,00 gallons of Orange plus any solvents used in drum cleaning would be burned during the third voyage. The data accumulated, together with theoretical considerations and applied thermochemistry, clearly Indicate that the production of incomplete combustion pro- ducts can be minimized to insignificant levels. Destruction, efficiencies of 99.9% or better appear feasible for this incinerator project. This would result in a total discharge of 0.05 pounds or less of TCDD via the exhaust streams over the duration of the project. (The average concentration of TCDD in the herbicide is about 2 mg/kg and the total amount of TCDD In the entire Orange stock Is approximately 50 pounds). The corrpiercial incinerator test program indicates that if any TCDD were present in the exhaust stream, it analytically nondetectabl e. Incineration would convert the Orange herbicide to its combustion products of carbon dioxide, hydrogen chloride, and water which will be released to the atmosphere. In addition, a relatively small amount of elemental carbon and carbon monoxide would be generated in the incineration process and discharged to the atmosphere. With proper concern for the environment In which such incineration would take place, incineration is an environmentally safe method of disposal of Orange Herbicide. Ecological monitoring is neither required nor feasible for the following reasons: a) the ship will complete the project within a month and always be moving and operating over a large area of the open tropical sea; and b) the predicted impact will be very minimal and transient for this incineration option. A dispersion zone model utilizing "worst case" analyses techniques was used to estimate mass concentrations of unburned Orange and Hydrogen chloride in the air and water environment in the vicinity of the discharge, and a meteorological model was applied to predict the atmospheric concen- tration of unburned Orange and hydrogen chloride at sea level downwind of the discharge location. Predicted results from these models revealed that there would be no sig- nificant environmental impact upon either the air or ocean environment. 11. INCINERATION ON JOHNSTON ISLAND If incineration at sea is not approved by EPA (e.g., if a permit for incin- eration at sea were not approved) than an alternate incineration option would be the construction of an incinerator facility on Johnston Island. Incineration on Johnston Island would require a higher efficiency owing to the ecology of the Atoll. (A com- plete ecological survey was conducted of Johnston Island by the Smithsonian Institution in order to document the areas of concern). The facility on Johnston Island would probably be designed to incinerate about 206 drums of herbicide per day. At this rate, approximately 200 burn days would be required to incinerate all 2.3 million gallons of the Orange stock. Thermal decomposition research using differential thermal analysis was conducted to determine the temperatures required for complete combustion of Orange Herbicide and a test program was conducted in a commercial incinerator to document the feasibility of destroying undiluted Orange Herbicide by means of combustion. Particular emphasis was placed on the ability to destroy the low quantity of TCDD (low miligram per kilo- gram concentration, rng/kg) present in the herbicide. Extensive sampling, utilizing time-weighted and concentration techniques, was conducted to evaluate the unscrubbed combustion gases, the scrubbing liquid used to cool and scrub the combustion gases, scrubbed effluent gasses, and any solid residues deposited in the system. Program objectives were outlined to determine, among other things, engineering data relative to controlling and monitoring the incineration process, the composition of the com- bustion products, and the toxicity of discharged scrubber water to several aquatic organ i sms . For a system operating at combustion chamber temperatures of 2**00-2800°F ; dwell time equal to or greater than 0.1** seconds, fuel to air mass ratio of about 0.1; and (SO) excess air greater than 30%, it can be stated that: a) combustion gas and scrubbed -3 effluent gases are free to undetectable levels. (^Q .20x10 wg/1 for each compound) of herbicide esters, acids, and TCDD; b) about 10% of the carbon dioxide and greater than 39.9% of both the hydrogen chloride and carbon particulates are removed from the combustion gases via an alkaline scrubber; c) combustion pyrolyzates are unchlori- nated hydrocarbons whose total concentrations average less than 0.50 jug/ 1 ; d) alkali scrubbing removes a small fraction of the pyrolyzates from the combustion gases, and with gaseous condensation in presence of chlorine, converts some of the pyrolyzates into chlorinated hydrol yzates ; e) total unchlorinated pyrolyzates average less than 13*0 pg/1 and total chlorinated hydrolyzates average less than 3.0 /ug/1 in the spent scrubber water; f) carbon particulates contain no detectable levels of any type of hydrocarbon and the mass of these particulates was less than 0.5% of the carbon in the herbicide, g) carbon dioxide, carbon monoxide, and heat of combustion gases are not environmentally significant; and h) dispersions of scrubbed effluent gases into the atmosphere have no effect on tomato plant bioassays and attest to the lack of phytotoxicity of the gases. 12. INCINERATION IN THE CONTINENTAL UNITED STATES (CONUS) ROCKY MOUNTAIN ARSENAL, COLORADO An incineration system has been constructed, installed, and operated at the U. S. Army Rocky Mountain Arsenel (RMA) in Colorado which, by technical inves- tigation, appears to be capable of incinerating the Orange in an environmentally safe manner. The RMA incinerator is used to destroy mustard agend and many of the problems associated with the incineration of mustard and Orange are similar. The problems arise from the similarity between mustard and Orange as regards certain physical and chemical properties and environmental impact. These problems include: fuel conditioning, high temperature incineration, acceptable effluents, real time monitoring and drum disposal. The problems are handled at RMA; but, the facility is necessarily of considerable value, and the waste feed rate of^2 gallons per minute (gpm) requires considerable time to incinerate a given quantity of material. The information below regarding the RMA facility has not been reviewed by the U. S. Army, nor has any action been taken to contract the RMA facility for Orange incinera- tion. Incineration of 2.3 million gallons would require approximately 27 months. The RMA system can operate at> 2,000°F with a stay time of two to six seconds. Al- though no actual Orange incineration data is available, it is felt that such opera- ting conditions will adequately destroy the herbicide and. TCDD. In addition a caustic scrubber installed on the system will provide additional treatment of the combustion gas. The elimination of the liquid discharge, the slow rate of incineration, the combustion gas treatment, the monitoring systems installed, and the drum cleaning capability make this option extremely attractive. Based on technical and environmental considerations, incineration in the CONUS in units such as the RMA facility could be safely accomplished. Unfortunately incin- eration units of sufficient capacity are located near centers of populations and industry, and these areas are already marginally acceptable from a polution viewpoint because of presently occurring degrees of air pollution. Furthermore, local and state governments are generally opposed to the importation of waste for disposal within their areas of jurisdiction. For the above reasons, incineration in the CONUS is not considered a viable alternative. 13. REPROCESSING Reprocessing of Herbicide Orange would convert it into commercial products (n-butyl esters of 2,A-D and 2,A,5~T) containing acceptable levels of TCDD. The process would differentially destroy the TCDD or concentrate it into a readily dis- posable waste. To date (September 1975) three chemical companies have submitted process descriptions in support of bids to reprocess the herbicide. The basic pro- cesses proposed all basically attempt to selectively separate the valuable components of Herbicide Orange from the TCDD contaminant. Classical chemical methods, i.e., solvent extraction, distillation or absorption, would be employed to concentrate the YCDD . The TCDD impurity would then be disposed of by incineration. The process descriptions have been evaluated by EPA and the Army Environmental Hygene Agency. The processes appear promising with respect of 2,4-D and 2,4,5“T recovery as well as satisfactory destruction of the dioxin contaminant. However, sufficient proces- sing questions have been raised (e.g., disposal of dioxin wastes and in-process destruction) to warrant a mandate for pilot studies (up to 150 gallon capacity). The objectives of the pilot study would include: (1) confirmation of process claims, (2) determination of impact of scale-up unit on process efficiencies, (3) evaluation of dioxin destruction and disposal, (4) estimation of possible dioxin contamination of the environment. The Scientific Advisory Board's Ad hoc Committee on Disposal of Herbicide Orange met for a final assessment of all research data and a discussion of options in March 1974. Rough estimates for the cost of each major viable option were presented. TREATMENT ESTIMATED COST ($ MILLION) Complete incineration 3.657 Complete Biodegradation 2.235 Fractionation and incineration 4.031 Fractionation and Biodegradation 2.754 Complete Ch 1 or i no lys i s 11.462 Fractionation and Chlor i nolys is 9.033 Reprocess i ng/Hemogenous Mixing/Sale 2.153 Although these data suggested that the reprocessing option was most viable, there were no assurances given by EPA that once selected, registration of appro- priate inventory would follow. The use option (as Orange Herbicide) was not con- sidered in the final analysis for two reasons (1) no registration existed for the n-butyl ester of 2,4-D and 2,4,5-T and (2) the market for a n-butyl ester formula- tion was thought to be minimal. Moreover, field tests with Orange Herbicide in western Oregon in 1973 drew an unusually and controversial reaction from the public. Newspapers in the area (and throughout the Country) generally carried a very derogitory view of the use of this chemical (as Orange) in reforestation programs. Biodegradation of tiie herbicide in an isolated area in western Utah appeared feasible. However, newspaper coverage in the Fall of 1 373 > also made this option “politically" sensitive. The suggestion in the newspapers that the Air Force was seeking a site to “dump" 2.3 million gallons of toxic surplus herbicide from Vietnam made the selection of an appropriate location impossible. For similar reasons, the incineration of Orange within the Continental United States (CONUS) appeared unrealis- tic. The obvious option was considered to be incineration outside the COHUS. Since some of the European Countries had used specially designed shi ps for incineration at sea, this option was considered the “most likely to succeed". As a consequence, the Environmental Health Laboratory at Kelly AF3, Texas, was tasked with preparing an environmental impact statement for the incineration of herbicide Orange. The final statement “Disposition of Orange Herbicide by Incineration" was released in November 197**. Destruction of Herbicide Orange is pending final evaluation of reprocessing and a review of the status of 2,4, 5-T Herbicide by the Environmental Protection Agency. If the latter two actions are negative, then the Air Force will seek a permit for ocean incineration of Orange. Destruction of the herbicide by incineration could begin in the Spring of 19/6. It is ironic that such large quantity of herbicide, so widely used in the United States, and so critical in World Agriculture, will be destroyed because it was used in a highly controversial military conflict. When given the option of whether to use it for the benefit of mankind or destroy it as a symbol of protest against war and the abuse of our environment, the American public has choosen the latter. A PLAN FOR DETERMINING WASTE PESTICIDE DISPOSAL PRACTICES IN EPA REGION VIII The disposal of unwanted pesticides and used pesticide containers has been a problem for some time. Murray^ reported approximately 130 million containers were used for agricultural pesticides with another 100 million aerosols for home use. A study conducted in Mississippi described unused pesticide and pesticide container disposal practices. Specifically, 21 .So of unused pesticides remained in storage, 2b. 2% were buried, 15.6% were applied to the soil surface, 11.0% went to a city dump and the remaining 21.9% were either burned, returned to the dealer, disposed in a sanitary landfill or city sewage system. The pesticide containers were either disposed of by burial, 18.4%; delivered to the city dump, 16.6%; retained by owner, 15.3%; sold, 11.4% or burned, 10.5%. The remaining containers, 25.8%, were either crushed, formed trash piles, or returned to the dealers. 2 Fox and Delvo sampled 8,500 United States farmers to collect information on pesticide containers associated with crop roduction. The study revealed that the predominant method of disposal was burning, 49.2%, followed by private dumps, 18.9%. Eleven percent of the pesticide containers were retained. The remaining containers, 31.3% were disposed of in commercial dumps, buried, returned to dealer, left where sprayer was filled, left in the field, or disposed of in some unspecified manner. 3 Pratt reported an Interdepartmental Task Force on Pesticide Container Disposal was instituted to deal with used pesticide containers in California. Results of a collection program initiated by the Task Force showed only partial success, as only 39% of the agricultural districts participated with 22,000 containers being collected. The proper disposal of pesticide containers is essential to assure a minimum hazard to man and the environment. Disposing of pesticide containers in open dumps Presented by Gary J. Mihlan, Research Associate, Institute of Rural Environmental Health, Colorado Epidemiologic Pesticide Studies Center, Colorado State University, Fort Collins, Colorado or fields may pose a threat to public health. Gehlbach and Williams** documented three poisoning cases resulting from improperly disposed pesticide containers. Pro- per disposal methods must be employed. Realization of the pesticide disposal problem has been gradual, but progress is being made. Private industry along with local state and federal governmental agencies are working to assure that safe disposal of pesticides and used pesticides containers i s accomp 1 ished. Enabling legislation for the establishment of disposal procedures was published in the Federal Environmental Pesticide Control Act of 1972^ Section IS of the Act required the Administrator of the Environmental Protection Agency to ''establish pro- cedures and regulations for the disposal or storage of packages and containers of pesticides and for the disposal or storage of excess amounts of such pesticides, and accept at convenient locations for safe disposal of pesticide the registration of which is cancelled..." Subsequently, on May 1, 197V guidelines were published in the Federal Register^. The May 1, 197^ guidelines dealt with disposal methods for various pesticide types as well as used pesticides containers. The October 15, 197^+ Federal Register in part amended the May 1, 197^* federal guidelines, such that several disposal methods were not considered acceptable.'7 These methods included open dumping, open burning, water dumping, deep well injection, and other methods which would contami- nate food or feed supplies. The remaining disposal methods of incineration, buried in a specially designated landfill, soil injection, and storage are acceptable. The problem was not simply one of disposal, but disposal in an environmentally safe man- ner . Considering the published guidelines of May l, 197V and October 1, 197V the Environmental Protection Agency has no specific disposal system for pes t i c i de wastes in most states within Region VIII (Colorado, Utah, Wyoming, ilorth Dakota, South Dakota, Montana). Table I lists general ground disposal facilities by state. Much variation exists between states concerning the quality and quantity of these poten- tial pesticide disposal sites. v/ithin the Region the State of Montana in conjunction with the Environmental Protection Agency is cooperating to conduct a pesticide disposal demonstration study dealing with container and waste pesticide management. In the Region as a whole, no indication of the need for pesticide and pesticide container disposal is evident. The disposal problem must be defined in order to develop a safe disposal system. Information specifying the type, quantity, and location of unwanted or excess pesticides and numbers of used pesticide containers requiring disposal must be determined before a functional disposal program can be developed. The EPA in Region VIII has subsequently contracted with the Colorado Epidemio- logical Pesticide Study Center at Colorado State University to determine the current status of pesticide disposal in the Region. The objective of the study is to deter- mine and describe the disposal practices in EPA Region VI I S by obtaining an assessment of the quantities, types, and locations of such pesticide products requiring disposal. Since the disposal practices of commercial applicators, pesticide formulators, govern- mental agencies, and rural, suburban, and urban users would differ considerably the study was developed in four parts. I . Comme r c i a 1 A pp 1 i ca to rs_ The commercial applicators studied are ground applicators, aerial applicators and structural applicatbrs (pest control operators). Due to the large number of applicators in the Region (Table II), not all are contacted in each state. A 20 % randomly selected sample is chosen. Upon identification and selection of the commercial applicators a questionnaire form is developed. The form is designed to obtain information on the types, quantities, and locations of unwanted or excess pesticides requiring disposal. Information con- cerning numbers, types, and locations of used pesticide containers is also questioned. The questionnaire is divided into three parts (refer to Appendix). Part A lists personal information and is used to locate the geographical area where disposal is (37) needed. Information obtained on quantities of pesticides applied, number and types of application equipment, and number of employees is used only for stratification. Part B deals with unwanted or waste pesticides. This is concerned with those pesticides that are no longer used, those that have been only partially used, or those that have become contaminated or otherwise made useless. Pesticides involved in spills are also included. Methods of disposal and storage and handling practices a re quest ioned . Part C of the questionnaire deals with the disposal of used pesticide containers. The numbers and types of containers, along with storage and handling practice infor- mation is requested. In each part questions are designed to allow for standard interpretation by all respondents. Questionnaire forms are mailed to the applicators. A cover letter is included explaining the study and a metered return envelope is provided. Upon mailing the questionnaire a three week period is allowed for response. After the three week period persons who do not return the forms are sent follow-up letters to request co- operation in the study. In the following weeks respondents and non-respondents are subsamp 1 ed . The subsample of respondents are presonally interviewed to serve as quality con- trol. Questionnaire forms which have been previously submitted by the respondent are used. The personal interview involves reviewing the questionnaire to determine the accuracy of information given and the ability of the respondent to correctly interpret each question. Approximately k0% of the respondents are interviewed for quality con- trol. The subsample of non-respondents is initiated to assure an adequate sample size for the study. Data received from respondents is biased in some respects. Respondents, perhaps are more conscientious or knowledgeable of proper disposal practices. IJon- respondents, therefore, are also subsampled and personally interviewed. Approximately 20% of the non-respondents are contacted. II. Pesticide Formulators Pesticide formal ators in the Region are studied. The sampling scheme is basically the same as described for commercial applicators. Due to the large numbers of formu- lators in the Region (Table I!) only a 20% randomly selected sample is studied. A questionnaire form is developed to obtain pesticide disposal information. The questionnaire designed for pesticide formulators is essentially the same as for the commercial applicators. Minor alterations are instituted to design questions relevant to the pesticide formulator industry. As described in Section I Commercial Applicators, the questionnaire is divided into three parts; Personal Information, Unwanted or Waste Pesticides, and Used Pesticide Containers. Questionnaire forms are mailed to the sample. A cover letter and a metered return envelope is provided. A three week response period is allowed. After this time persons who do not respond are sent follow-up letters encouraging response. After two weeks respondents and non-respondents are subsampled and personally inter- v i ewed . 111. Mosquito Abatement Districts and Governmental Agencies Mosquito Abatement Districts within Colorado and Utah are studied. Governmental agencies are contacted only within Colorado. Three state governmental agencies are studied. These agencies include the Colorado Division of Wildlife, Colorado Weed and and Pest Control Districts, and the Colorado Department of Highways. Three federal governmental agencies studied include the U. S. Forest Service, Bureau of Reclamation, and Bureau of Land Management. The questionnaire form used is similar to that described in Section I Commercial Applicators. The form consists of three parts; Personal Invormation, Unwanted or Waste Pesticides and Used Pesticide Containers. Questionnaires are mailed with three weeks allowed for response. After this time a follow-up letter is mailed to non- respondents encouraging response. Few non- respondents are anticipated from the Districts and governmental agencies. (X) If there are non-respondents these are personally interviewed. I V • Rural , Suburban and Urban Users Ideally to conduct the study, a listing of all rural, suburban, and urban users for each state is desirable. Since this is not possible at present, only one area is studied, Larimer County, Colorado. A sample of 50 rural users, 50 suburban users, and 50 urban users are selected. The procedure employed involves personal interview- i ng of each user . The questionnaire used to conduct personal interviews is similar to that de- scribed in Section I, Commercial Applicators. Disposal practices for the rural, suburban, and urban users will differ considerably from commercial applicators. The questions are designed for multiple responses. Common household disposal prac- tices are included in the questionnaire. After obtaining information from respondents and personal interviews of non- respondents, data is transferred to forms for computer coding and subsequent analysis. Conclusions can be formed concerning pesticide disposal practices and quantities and types of pesticides and used containers requiring disposal. Disposal methods and storage and handling practices for unwanted pesticides are presented as a percentage employed. Pesticides requiring disposal are presented as mean quantities per appli- cator. The disposal and storage method for used pesticide containers and container rinsing practices are given as percentages, .lumbers and types of used containers requiring disposal are given as a mean number per applicator. In this manner an accurate description of pesticide disposal practices can be presented. Results may then be extrapolated to the total population in the Region. Presently the study has obtained some of the date from the users and handlers. Information from the ground, aerial, and structural applicators, pesticide fornulators, mosquito abatement districts, and governmental agencies has been obtained. The rural, suburban and urban applicators have as yet not been contacts. Preliminary results of the study show a 1 5% response from the sample of appli- cators and formulators in all states except Montana. Montana has yet to be contacted. A lQO/o response is anticipated from the mosquito abatement districts and local state and federal governmental agencies. If there is non-response, the districts or agencies will be personally contacted to obtain information. Data from ground, aerial and structural applicators and pesticide formulators indicate very few unwanted pesticides within the Region requiring disposal. Specifi- cally, 2642 liters (700 gallons) and 953 kg (2100 pounds) of pesticides were listed as requiring disposal. 'This was from a total of five app 1 i cators/formul ators . The largest area of concern is with used pesticide containers requiring diposal . In this case approximately 39,000 used containers were listed by respondents as stored or disposed of in the last year. The data given is preliminary. There exists much variability between appl icators/formul ators concerning numbers of containers and quantities of unv/anted pesticides requiring disposal. The remainder of the study is anticipated to require nine months for completion. A final report will be submitted to the Environmental Protection Agency, Region VIII, Denver ,• Co lorado . The study will be available to state agencies for referral in developing individual state pesticide disposal facilities. The study has incorporated a broad cross-section of the pesticide users and handle within the Region. Not only have the commercial applicators been sampled but rural, suburban, and urban users, as well as governmental agencies. From such a diverse population the pesticide disposal needs and practices can be evaluated. Current dis- posal practices utilized can be determined as well as quantities, types, numbers, and locations of pesticide products requiring disposal. This information will provide a data base for future development of a pesticide disposal system. TABLE I HUMBER OF DISPOSAL SITES BY STATE WITH I N E.P.A. REGION VIII Colorado Utah Wyoming North Dakota South Dakota 255 land disposal sites Greater than 200 landfills and dumps 5** open dumps, 31 modified sanitary landfills 10 sanitary landfills, 402 dumps 400 landfill sites, 85~90% are considered open dump 65 landfill sites, 64 non-landfill or dump sites Montana TABLE I I NUMBER OF PESTICIDE APPLICATORS AND FORMULATORS IN E.P.A. REGION VIS! Aer i a 1 App 1 i ca tors 710 Ground Applicators 766 Structural Appl icators 150 Pesticide Formulators 1 kk TOTAL 1770 REFERENCES 1. Murray, W.S., The Navy Disease Vector Ecology and Control Center, Pesticide Storage and Disposal, The Seminar on Environmental Ecology and Pesticides, May 25~27, 1371, Naval Air Station, Alameda, California. 2. Fox, Austin S. and Delvo, Herman W., Federal Working Group on Pest Management, Pesticide Containers Associated With Crop Production, Proceedings of the National Converence on Pesticide Containers, New Orleans, Louisiana, Nov. 28-30, 1972, Washington, D.C., U.S. Government Printing Office, December 1972. 3. Pratt, Robert M., California Collection, Transportation and Disposal Systems, Proceedings of the Region VIII Pesticide Disposal Conference, U.S. Environmen- tal Protection Agency, Denver, Colorado, April b, 5, and 6, 1973, PP . 65”9^. b. Gehlbach, Stephen H., Williams, Wilton A., Pesticide Containers, Their Contri- bution to Poisoning, Arch. Environ. Health, Vol . 30:49~50, 1375* 5. Federal Environmental Pesticide Control Act of 1972, Public Law 92-518, 92nd Congress, Oct. 21, 1972. 6. Regulations for Acceptance and Recommended Procedures for Disposal and Storage, Federal Register, Vol. 39, No. 85, Part IV, p. 1523b, Wednesday, May 1, 197^. 7. Proposed Regulations for Prohibition of Certain Acts Regarding Disposal and Storage, Federal Register, Vol. 39, p. 38867, Tuesday, Oct. 15, 137^. . . ■ APPi^IX ■ . . . . r n COLORADO STATE UNIVERSITY PESTICIDE DISPOSAL SURVEY QUESTIONNAIRE Ground, Aerial and Structural Applicators A. Personal Information Name _________ Company Address __ Number of Employees ___ _ ___ Number and types of application equipment Give an approximation of quantities of pesticides applied within the last year, lbs gallons d. Unwanted or Waste Pesticides 1. Do you ever store or d ispose of unwanted pesticides? Yes No If no, proceed to Part C. 2. Check the method or methods used to dispose of unwanted pesticides. Please list the three main methods, having (1) as the most frequently used. I nc i nerat Son *Publ ic Dump P r i vate Dump Hoi d ing Pond Sewer Ex: (1) **San i tary Landfill ***Modified Sanitary Landfill Collection and Storage Spread on Ground (2 ) Return to Vendor Other (specify) earthen cover. (3) Open dumping of refuse with no Managed refuse site with a daily cover of earth. Weekly cover of earth over refuse. 3. List the type, amount, and EPA registration number of unwanted pesticides disposed or stored in the last year. Also list the condition of containers in which the unwanted pesticides are in. Amount EPA registration ^Container Pesticide Name (lbs. or gal.) number Condition Ex.: Kel thane 200 lbs. 707-66-AA Good '^Container conditions - Good - sealed tight, no visible dents or other physical damage. Fair - loose seal, slight dents or scratches. Poor - not sealed, dented, rusty, or leaky 4. Indicate the type, size, and numbers of containers unwanted pesticides are stored in prior to disposal. a . Metal : 1 gallon __ 5 ga 1 Ions 20 to 30 gal lons_ 50 to 55 gal Ions b. Glass: 1 gallon _____ c. Paper: 4 to 5 pounds ______ 20 to 25 pounds __ d . Plastic: 1 ga 1 Ion 5 gal Ions e. Other types of containers (s Less than 1 pint 1 quart 1 gal ion ______ 5 g'al Ions _______ 29 to 30 gallons 50 to 55 gal Ions 20 to 25 pounds 50 pounds and over Other (specify) Other (specify) 50 pounds and over Other (specify) ify) Less than 3 pounds 4 to 5 pounds 20 to 25 pounds 50 pounds and over Other (specify) 5. List the area in which unwanted or waste pesticides are most frequently stored prior to disposal . Secured area, enclosure __ Inside building _____ Open Area (field) Other (specify) 6. Are containers which are used to store unwanted pesticides labelled according to their contents? Always Sometimes Never Don't Know No response 7. Are stored unwanted pesticides mixed together or maintained in separate containers by pest icide type? Always Mixed Sometimes Mixed Sometimes Separated Always Separated Don't Know No Response (97) C . Used Pesticide Containers 1. Check the method or methods used to dispose of unwanted pesticide containers. Please list the three main methods in order of use, having (1) as the most frequently used. Returned to dealer Lx.: (1) **San i tary Landf i 1 1 Inc inerat i on ***Modified Sanitary Landfill Buried (2) Retained and reused *Public Dump Recycled as scrap steel Sold to private individuals Other (specify) * Open dumping of refuse with no earthen cover. ** Managed refuse site with a daily cover of earth. *** Weekly cover of earth over refuse. 2. This question deals with the number, size, and types of used pesticide containers stored or disposed of in the last year. Please estimate the number of containers stored or disposed of in the provided size categories for each type of container listed. Fill in either the weight or volume. If there are no containers in any type of size category, please fill in "0". a. Metal containers: 1 qal Ion 5 gal Ions 29 to 30 gallons 50 to 55 gallons b. Glass containers: 1 gallon c. Paper containers: 4 to 5 pounds _ 20 to 25 pounds _____ d. Plastic containers: 1 gallon 5 gal Ions e. Other types of containers (speci Less than 1 pint 1 quart __ 1 gallon 5 gallons __ 20 to 39 gallons _____ 50 to 55 gal Ions 3. Are containers rinsed out prior to di question 5* Always rinsed Sometimes rinsed 4. 20 to 25 pounds 50 pounds and over Other (spec i fy) Other (specify) 50 pounds and over Other (specify) Other (specify) Less than 3 pounds 4 to 5 pounds 20 to 25 pounds 50 pounds and over Other (specify) posal? If never rinsed, proceed to Never rinsed Don't know Please check the method or methods which most closely describe how the rinse is disposed of. Indicate the top two methods used, having (1) as the most frequently used. n. cont . Buried in a sanitary landfill Poured down sewer Pun onto ground Run into waterway Reused as pesticide dilutent Other (spec i f y) ___________ ________ 5. List the area in which pesticide containers are most frequently stored prior to d i sposal . Secured area, enclosure ______ Inside of building Open area (field) Other (specify) 6. Do you use a central collection point for disposal of pesticide containers? Yes No 7. At the present time do you have any disposal problems requiring immediate attention? Yes , No If yes, what? Leaky containers Chemical changes (separation) Excessive amount of pesticide Other 8. Comments: POLITICAL FACTORS IN ANIMAL DAMAGE CONTROL Most of you here are perhaps well aware of the kinds of problems caused by animal depredations and that vertebrate animals, particularly the carnivores, seem to generate the greatest degree of interest and emotion. Most people seem either to support or oppose the concept and programs dealing with predator control. Few seem to be indifferent or to have no opinion. The effects of political and administrative influence on direction and effec- tiveness cf such programs are often thought to be clear and obvious. In reality, such influences and results are usually complex and often obscure. Any attempt to analyse, document and thoroughly discuss such cause-effect patterns would require an immense amount of time and voluminous writing. Perhaps, therefore, a relatively simple discussion of trends, programs and the cancellation process for the three major chemicals employed in predator control may serve to illustrate a rather com- plex pattern. Animal damage control has always been an essential element in protection of human interest. No country, including this one, could have progressed from a primitive stage without such practices and control has been employed in the United States since the first European settlers arrived. Indian history records some similar act i v i t ies . Early in this century professional rodent and predator control was initiated by the U.S. Department cf Agriculture (USDA) Bureau of Biological Survey on federal lands for protection of agricultural interests. It grew during the first World War in the interest of providing essential food and fiber for a nation at war. It con- tinued under USDA direction until 1939 when the program was transferred to the Department of Interior (USDl) and became the Branch of Predator and Rodent Control Presented by Dale A. Wade, Extension Wildlife Specialist, University of California (100) (PARC) but with little change in responsibilities. Its purposes remained primarily those of protecting agricultural crops, animal and human health, forest and range, wildlife and other resources. It continued with these duties and programs for 26 years . Following recommendations of the Leopold Committee (1964), in 1965 PARC was given a new name, Division of Wildlife Services (Dl/S) with increased duties in wildlife enhancement and management. These have continued to the present time with a greater emphasis on enhancement and a lesser emphasis on damage control. Prior to 1915, animal damage control had primarily been the responsibility of individuals, producer groups, counties or states, with additional effort by munici- palities and public health agencies. Growing federal involvement by USDA, USDI , and public health agencies has occurred since that time. Concern for human health and safety, cleanliness of human food, public utilities, aircraft safety and other fac- tors have dictated more extensive and intensive state and federal involvement for several decades. Gradually, various cooperative arrangements have evolved between federal, state, county and municipal agencies. Producer and other interest groups have often been a part of such programs. Several types of programs exist, from professional federal, state or county activities, to Extension predator control, or completely independent efforts. In most localities, professional control is augmented by individual effort, producer groups and sport hunters. Bounty programs still exist in some areas al- though they appear to be losing their appeal. In general, they seem to be considered expensive, wasteful, ineffective and often abused. This seems particularly true 'where highly intelligent problem animals exist and continue to cause depredations. Until recently, USDI-DWS had contracts with state and county agencies in 16 of the 17 western states. Kansas was the exception. Some USDI officials have repeatedly expressed a desire to return these program responsibilities to the states. Since 1972, several bills have been introduced in Congress in attempts to accomplish this change. Federal funding to supplement state efforts has been proposed in most of these in the attempt to secure congressional and local support. In most of these bills, however, some reservation of authority to direct or control the extent of damage control and methods to be employed by the states has been reserved to USDI. For different reasons, therefore, agricultural and environmental groups have occasionally found themselves aligned in opposing similar bills. Usually, this has meant opposition to state-controlled programs by environmental groups because they foresee a loss of their influence if state programs are more responsive than USD! to agricultural concerns. In contract, agricultural groups have often opposed these bills because they felt that proposed restrictions on control methods were too severe. As a result, no federal bill has become law, although the states of South Dakota, Colorado and Washington have adopted state control programs in the past two years. Thus, there appears to be at least a partial return toward more state and local responsibility in such programs, although far greater restrictions by federal regu- lations and policy have been imposed and options in control are largely limited to mechanical control methods. Methods employed in predator control may include exclusion by fences, some repellent techniques, close herding of livestock, guard dogs and lethal mechanical or chemical techniques. Lethal chemicals have been severely restricted since 1972, however. Repellent techniques have shown little but short term benefits and effec- tive reproductive inhibitors have not been developed. Taste aversive agents and collars containing toxic chemicals are being evaluated but are not proven effective methods. There has been a great deal of political and administrative pressure recently to adopt the toxic collar, however. Suggestions for control methods and sources of program funding are many and varied, including those denying that a problem exists and insisting that damage (1J2) control is not needed. Others prefer a return to the so-called "balance of nature" in the belief that this would provide an immediate and painless solution. Opposition to predator control is at least partially due to the tremendous shift of population to metropolitan areas during this century. More than 90 percent of Americans now reside in urban centers, some removed by several generations from an interest in or concern for the agricultural sector. The majority of antagonism to damage control is centered in urban areas. Among the reasons often cited are opposition to hunting, trapping, firearms, killing of animals, multiple use of public lands and abuse of land by agriculture interests. Others are a disbelief that damage occurs, or that it is a problem of any magnitude, and often a belief that "management" would solve any problem that does exist. Occasionally, the belief that man is vegetarian by nature and should niether kill animals nor eat meat is given. These beliefs and support by environmental groups, primarily from urban areas, have led to extensive continued efforts to prohibit animal damage control methods and programs. Such efforts are evident in current restrictions and in bills introduced by state and federal legislators to further restrict chemicals and mechanical control methods, including traps and firearms. Numerous bills to abolish control programs have also been proposed. It has become increasingly apparent that a much greater degree of public understanding and knowledge of the need for control is essential. Factual information and education programs are obviously the only solution if effective control programs are to continue. Opposition to predator control programs, particularly to the use of chemicals, increased in the decade prior to 1972. The Leopold Report (1964) increased and focused attention on these activities and opposition became highly critical with reports of eagle deaths due to shooting and chemicals in 1970-71 in the mountain states. These were apparently major factors in appointment of the Cain Committee (103) in 1J71 to review predator control in the western states and in cancellation of the major chemicals used in control programs. Somewhat unique in the Leopold Report (1364) and the Cain Report (19/1) were the differing conclusions, even though there had been no basic change in the livestock industry, the predation problem, the extent of the control programs, the chemicals employed, and the area and techniques for application of control methods. Sn addition, both committee chairmen served on the other committee. The Leopold Committee concluded that the steel trap is one of the most damaging control methods in the sense of its being nonselective and that much unnecessary kil- 1 ing of wildlife in the western United States has resulted from the use of such traps in coyote control. St is further stated that when properly applied, 1 080 (sodium monof 1 uoroacetate) meat baits are effective and humane in control of coyotes with very little damaging effect on other wildlife. The Cain Committee did not agree. It stated that the use of chemicals is likely to be inhumane and nonselective and recommended that landowners be trained in the use of steel traps as a major method of coyote control . Ostensibly, the decisions to cancel predator control chemicals and subsequent orders and actions by the President and agency administrators were based on the Cain Report. This report was released to the public following Executive Order, No. 11643, issued by President Nixon on February 8, 1972. Evidence has gradually accumulated since then, however, indicating that other administrative and political influences were major factors. Some review of chronology is necessary at this point. The Cain Committee was appointed in early 1971 and apparently began its review in late July under contract to the president's Council on Environmental Quality (CEQ.) and USDI. The contract supposedly required completion of the report by October 30, 1972, allowing approximately three months for data gathering, review, and writing of the report. Apparently the report was completed by November and first printed in December 1971 > although there are statements of record that was not printed un- t i 1 January 1972. (i)4) On July 9, 1971 > at Estes Park, Colorado, USDI Secretary Morton included the following statements regarding the Cain Committee and its findings in his address to the National Wildlife Federation Conservation Summit. "Well before the Jackson Canyon eagle kill last month, I agreed to cooperate w i th the Council on Environmental Quality to initiate a complete review of predator control activities to identify problem areas and seek their resolution. This study team will be composed of seven non-governmental professionals recognized for their expertise in the wildlife field... The task Force has been charged with the responsibility of examining all aspects of the issue, including poisoning carried on by the private sector and state and local government as well. They have been instructed to examine with care the economics of national insurance programs as a possible alternate to predator control and to recommend any changes which may be needed in our present administration of this program. Let me add that I absolutely guarantee that the findings of these experts will be given a full hearing and review by wool growers and cattlemen, as well as wildlife interests. The study already has received funding from Interior and the Council on Environmental Quality, and I personally pledge that performance will follow program so that our imperiled predators will not perish in a sea of platitudes." Although public hearings were "absolutely guaranteed," none were held. The Cain Committee Chairman stated on March 14, 1972, in Mexico City in a panel dis- cussion that "1 should say that we first considered public hearings. We decided, hcwever, that there simply was not enough time to hold public hearings, to gather testimony, and to digest it and because of the slowness of the hearing process." One is forced to wonder why there was such a shortage of time. During this same panel discussion in response to a question regarding public hearings not being held, USDI Assistant Secretary Reed stated: "I would be delighted to give you the answer. I think it is about time that it came right out onto the surface and everybody knew. We all understand the political truths of life. The President received the recommendation sent by the chairman of the Committee to the Secretary of the Interior, and said: 'It's about time I got a recommendation like that and I intend to act upon it. However, I think that it is of such national interest that I reserve it as my right to give it in the Environmental Message which is scheduled for February 8th. There will be no disclosure of the report nor your recommendations to me until that time.'" If Secretary Reed was accurate in quoting the President, there would appear to have been prior decisions made with regard to cancellation of these chemicals. That this was the case appears to be supported by a stipulation filed in the U.S. District Court for the District of Columbia, apparently late in 1971* in relation to two civil actions filed in that court early in 1971. The relation of the stipulation to the civil actions appears to be as follows: Civil Action 564-71 was filed with the Court on March 16, 1971* The action filed by Counsel for the Defenders of Wildlife and the Sierra Club against USDS and individuals within the Department contained a series of allegations that USDI activities in damage control were damaging to wildlife including endangered species, particularly with regard to chemicals used in damage control. The action requested an injunction prohibiting USDI from conducting control activities alleged to be seriously affecting certain wildlife species. A second Civil Action, No. 775~7l, was filed in this Court on April 14, 1971, by the Humane Society of the United States and its California branch against USDI and these same individuals. This complaint contained a series of allegations with regard to the use of predacides and requested a permanent injunction to prohibit USDI from conducting such control activities. The related stipulation was apparently filed in late 1971 with the District Court and contains the following information. STIPULATION FILED UNDER SEAL Defendents by their attorneys, have requested that plaintiffs not pursue, before February 15, 1972, their motions for permanent and/or preliminary injunctions, and have repre- sented to them as follows: 1. That the draft of a study under the direction of Dr. Stanley A. Cain will be finalized and published in early January 1972; and 2. That as a result of recommendations contained in 006) the Cain study and other considerations defendants presently intend to make major changes in policies and programs relating to the existing animal damage control program no w conducted by them, and publicly to announce these changes on or before February 15, 1972; and 3. That defendants will need, following publication of the Cain report, additional time, to February 15, 1972, to finalize such plans; and 4. That defendants intend to conclude the present predator control program insofar as killing by poison is concerned, except that defendants intend to continue bird and rodent control programs and animal control research; and 5. That after the changes in pol icy and programs have been publicly announced, defendants intend to implement such policies and programs as soon thereafter as is practicably possible; and 6. Nothing herein shall be used by any party as an admission or as a statement against interest by any party. As a result of the foregoing representations plaintiffs agree not to pursue on or before February 15, 1972, their motions for permanent and/or preliminary injunctions and further agree not to pursue, on or before February 15, 1972, other motions or discovery in connection with their lawsuits. In the event that plaintiffs thereafter reactivate their lawsuits, defendants agree to forego any contention that plaintiffs are foreclosed from relief on account of the delay. This stipulation shall remain in earner and sealed until this litigation is concluded. (.107) The stipulation was signed by counsel for plaintiffs in both civil actions and was apparently sealed until July 1972. Disposition of these two Civil Actions apparently was as follows: a stipulation of dismissal of Civil Action 564-71 was filed with the Court in March 1972 stating that "It is hereby stipulated and agreed that the above case is dismissed without prejudice." In May 1972, a similar document dismissing Civil Action 775“7! was filed with the Court. Both documents were signed by counsel for plaintiffs and defendents. On February 8, 1972, Executive Order No. 11643, prohibiting use of the major u? predacides on federal land and by federal employees was issued by the White House. It provided for emergency use of these chemicals only if in each specific case the head of the agency involved provided written justification for use following consul- tation with the Secretaries of Interior, Agriculture and Health Education and Welfare and the Administrator of EPA. Additional criteria for emergency use were an essential need for protection of human health and safety, or wildlife species, or "prevention of substantial irretrievable damage to nationally significant natural resources." On February 10, 1972, USDI issued a news release indicating that it had ceased to formulate, distribute or use these chemicals for predator control on federal lands and had ceased to use any toxic chemicals with secondary effects in control of rodents, birds, or other species. Only mechanical methods were authorized for use by USDI per- sonnel and chemicals were removed from field use as rapidly as weather conditions permi t ted . On March 9, 1972, the EPA Administrator issued orders cancelling and suspending these chemicals (sodium cyanide, strychnine and sodium monof 1 uoroacetate) for use in predator control. In that order (PR notice 72-2) the Administrator expressed the agency's commitment to review the status of registration for these three chemicals for use in predator and rodent control in rangeland areas. He indicated that "this \ commitment grew out of grave concern surfaced by the reported deaths of some 20 eagles killed by the misuse of thallium sulfate." Since this compound had not been an operational USDI professional control tool for some 15 years, the "misuse" pre- sumably would have been by non-professionals. Perhaps the interest in reviewing the professional use of chemicals was wholly desirable. It is difficult, however, to see any direct relationship between correct professional use of the three major chemicals and illegal non-professional use of a completely different compound. In addition, the EPA Administrator cited the Cain report and "a detailed petition submitted to this Agency by several distinguished conservation groups urging that the registration of these compounds be cancelled and suspended immediately." It appears, therefore, that political and administrative influences were significant in the cancellation process. During the same period and continuing into late 1973, testimony by EPA and USDI administrators at congressional hearings for review of predator control policy and related matters repeatedly emphasized that chemicals were not needed in such programs since other alternatives such as mechnical methods and livestock management practices were effective and adequate. Testimony, speaches and news releases by administrators also indicated that losses to predators were likely exaggerated and were not as severe or serious as livestock interests considered them to be. Many individuals in live- stock production and operational predator control programs disagreed substantially with some of these premises, but had little effect on Agency or administrative pol i cy . It appears, therefore, that there are some aspects of the cancellation process for these chemicals which at the least are somewhat unique. In addition to the con- duct and dismissal of the civil actions against USDI mentioned earlier, there are others which might be considered. Comparison of the use and cancellation of these chemicals with DDT points to some major differences. The predacides were used largely in the 17 western states in contrast to DDT which was used nationwide. The amount of DDT used annually exceeded the amount of (IQS) the predacides used by several thousand fold. DDT has shown adverse effects on several nontarget wildlife species whereas the professional use of the predacides has not shown sucii effects. DD7 was cancelled following extensive public hearings over an extended period whereas no hearings were held prior to cancellation of the predacides. The predacides were cancelled for professional use without prior know- ledge by the affected industry and largely due to illegal use of a different compound by non-professionals. Of all the chemicals registered for control of plant and animal species, only those used for predator control were cancelled by executive order. In the President's message to Congress, August 1972, the restrictions on DDT and tne predacides were cited as significant contributions of his Administration to protection of the environment; 1372 was a presidential election year and from the revelations of Watergate one is led, inescapably, to wonder what effect election concerns had on earlier administrative decisions which were widely supported by environmental groups. Despite earlier insistence that chemical methods were not needed for predator control, USD1 requested and was granted emergency use of the l\~b^ sodium cyanide device by EPA in May 137^ for protection of sheep and goats where mechanical controls alone were found inadequate. A US D 1 report on the use of that device for the period from June through October 137^ indicated that in some areas and under some conditions mechanical controls were ineffective and that combined mechanical and chemical preda- tor controls were necessary to prevent or reduce severe livestock losses. Experimental permits for the device were also granted by EPA to several western states in 137^ to determine if it was effective in reduction of losses. US D I has since requested EPA to allow registration and full operational use of the M -hk. A hearing on that request for registration and others from several states was held by EPA in August 1975 and apparently registration will be allowed. It appears, therefore, that political and and administrative influences were significant in altering predator control methods (210) and programs, first by removing the chemicals and secondly by attempting to bring at least one of them back into operation. Of additional significance was the notice of intent by the EPA to hold hearings in regard to cancellation of these chemicals for rodent control filed in June 1373* “Informal hearings" were announced and held in September and October 1373 at Washing- ton, D.C., Denver, Colorado, Dallas, Texas and Sacramento, California. All interested parties were invited to produce relevant evidence. The cancellation notice was with- drawn in December 1973 with the following statement as part of the withdrawal: “Based upon both the informal hearings and the Agency revi ew, EPA has concluded that sufficient valid scientific and economic data do not exist at this time to justify the continuation of the procedures begun by the June 19, 1973 Mot ice. Accordingly, I hereby withdraw the Notice of Intent to hold a hearing and thereby withdraw the proceedings initiated by that Notice." The significance of this statement is that far more hard scientific data existed with regard to rodent damage and chemical rodent control than existed on predator damage and chemical control. Therefore, if insufficient evidence existed for can- cellation of these chemicals as rodent i cides , it is difficult to assume that evidence existed for cancellation of them as predacides. It seems apparent that a suit brought by the state of Wyoming and other plaintiffs against the EPA and other defendants in regard to cancellation of the predacides was a factor leading to review of the Executive Order (11643) and agency policies. On June 12, 1975, the District Court in Cheyenne, Wyoming, granted the state a temporary in- junction setting aside the EPA order which cancelled and suspended registration of these chemicals. The Court also ruled that the EPA was required by its own regulations to follow due process by allowing the livestock interests to be heard and that it must file an environmental impact statement relative to t lie cancellation of these chemicals. That ruling is now under appear by the EPA. A new Executive Order, No. 11870, was issued by President Ford on July 18, 1375* It replaced Order No. 11643, but with few real changes. Section 1(3) adds constraints on devices and additional concerns for individual animals which were not included in ,io. 11643 and is, therefore, more restrictive than the earlier Order if strictly interpreted. Section 3(c) allows the head of an agency to authorize the use of sodium cyanide on an experimental basis to control predator or bird damage to 1 i ve- sted; on federal lands or in federal programs for no more than one year. Environ- mental groups appear to feel that except for Section 3(c), there are greater restrictions on use of chemicals than existed in Order 1 1 643 . There appears in reality to be very little real change from Order 11643 since the emergency permit authorized US D I to use the IT-44 in protection of livestock, except on federal lands. Insofar as experimental use is concerned, there appears to be no obvious advantage on federal lands since similar conditions forresearch can readily be found on private or state lands. There is the possibility of different methods of application, i.e.: the toxic collar, which can be used experimentally by USDI under Order 11870. USD ! has applied for registration of this device, a toxic collar fitted to the neck of sacrificial sheep, to provide a somewhat different approach as indicated in the following com- ments from Sc iences, August 1, 1975: “The Council on Environmental Quality ( CEti) has announced that the government will permit new experimental use of sodium cyanide to kill coyotes that attack sheep. The latest decision is a modi- fication of a 1972 executive order that bans predator poisoning on public lands except under emergency conditions. Coyotes are responsibly for the death of 3 to 5 percent of sheep herds in the West (25 percent in some areas), said CEQ head Russell Peterson. Shepherds find the losses hard to bear, since the sheep industry has been steadily declining since the 1940's. The simplicity and restraint that characterizes the new idea perhaps explains why it wasn't thought of before. Most coyotes don't like eating sheep (rabbits are their staple), but few love them, and will attack again and again. They prefer lambs, preferably tethered, and they attack by lunging at the neck. So a poisonous collar - necklace of sodium cyanide capsules — has been devised. A few iambs will be tethered at the edge of their herd and fitted with the collar. A passing coyote with an eye for sheep will leap at at the animal's neck, his teeth will puncture a cyanide pellet, the poison will squirt in his mouth , and violal he will drop dead . Peterson says tests in large pens show that this works, and further- more, the lamb generally escapes unharmed. The project has virtues ecologically not only because of its selectivity but because carrion CU2) eaters happening upon the dead coyote will not be poisoned by eating the flesh. Peterson, in answer to a question, said it was possible the technique could have an adversive conditioning effect on whole populations of coyotes--one day, perhaps, breeding an anti sheep attitude into the subconscious of the race, as it were. Defenders of Wildlife, a Washington group that fought for the 1972 poison ban, has criticized the recent action on the grounds that it opens loopholes for indiscriminate poisoning programs to resume. The government argues that relaxing the order to allow experimental programs will permit development of more effective and environmentally sound means of predator damage control." CEQ. appears to have had, and still to have, substantial influence on administrative decisions related to the predacides and appears to be pushing heavily for adoption of the collar as a totally new concept. However, neither the concept or the collar are really new, but came from suggestions of control personnel in field operations and are several years old. Reasons they were not adopted are several, but included are these: physical limitations in applying these to animals weighing from 6 to 150 pounds or more and logistic problems of application, including the number of sheep that must carry collars, or placement of the few sacrificial sheep into suitable locations to intercept the coyotes. Equally as great are the limitations due to intelligence and behavior of the coyote species. However desirable that the toxic collar may be, it is questionable that it will be effective as the major method of coyote control. Experimentally, the toxic collar should be extremely interesting to test and, hopefully, will be at least partially effective. It does seem, however, that wide- spread application would provide a logistics problem to stagger the imagination, particularly where coyotes are traveling long distances to kill, where their travel routes and direction are unknown, and where they fail to see the attraction of tethered lambs compared to those running free. These factors appear to carry little weight in CEQ. if the report in Sc ience is accurate and there remains little doubt that political and administrative factors continue to function; 1976 is also an election year. Political and administrative actions normally occur in response to the interest, mTi activity and size of pressure groups. In numbers, the rural population is distinctly outweighed. The 1973 census revealed that k.S> percent (9,^72,000) of the total U. 5. population (210,036,000) were farm residents. The total number of U. S. farms reported in 1975 was 2,819,000, of which 1^6,200 were involved in the sheep industry. If one assumes that the rural population is evenly distributed across these farms, approxi- mately 5-2 percent of rural residents were involved in sheep production in 1975, less than one-fourth of one percent (0.23 percent) of the entire U. S. population. St is not surprizing, therefore, that agriculture, particularly sheep producers, has rela- tively little influence 00 political and administrative decisions. The livestock industry has been further hampered by a lack of unified, clear, consistent opinions, policies and objectives on the predator issue. Individual violations of lav/s and regulations, including the use of toxic chemicals, have also contributed to a loss of influence and to increased opposition in all aspects of animal damage control. The extension of opposition to include other wildlife manage- ment practices, particularly hunting and trapping, has occurred. In many instances, a lack of understanding of carrying capacities and population dynamics seems to be coupled with a belief that ,:the balance of nature*' is all that is needed. Particularly critical has been opposition to animal control on public lands, accompanied by growing opposition to multiple use of such areas for hunting, grazing and other purposes. The beneficial effects of hunting to protection of habitat by preventing overuse by game animals and damage to adjacent agricultural crops 3s often not recognized. Without question, overuse of land by game animals as well as livestock contributes to loss of vegetation, decreased water retention and erosion. However, moderate grazing by livestock increases forage by reducing w i 1 dfi res , by suppressing some plant species and stimulating regrowth of others. Grazing, therefore, is not necessarily undesirable. This depends on the intensity of use and moderate use can benefit wildlife in many areas. Private agricultural land is at least as important to wildlife as public land by nvi) providing habitat the year around for many species and critical habitat, particu- larly in the winter, for such species as deer and elk. Thus, the importance of agricultural land to wildlife as well as food production suggests that economic survival of producers is essential. Given the opposition to control programs and the influence of opposition groups, it is not unusual that "panaceas" such as repellents, aversive agents and "livestock management" are so appealing to legislators and administrators. From any point of view an effective non lethal method which offered both the relief sought by producers and acceptance by opposition groups would be ideal and highly attractive politically. However, all methods are subject to limitations imposed by physical, biological and climatic factors. From current knowledge of predator biology, behavior, intelligence and adaptability, it is evident that a wide range of options and flexibility in appli- cation are essential to solving individual problems. Livestock management, repellents, predator-proof fencing and other nonlethal methods may be useful in many situations but they cannot be effective under all conditions. Theoretical approaches to "solve" the predator issue have often been directed with little prior knowledge or consideration of limiting factors and many "simple solutions" have been offered. The difficulty in application has been the lack of simple problems to which they apply. A quote attributed to P. A. M. Dirac, Nobel Laureate, seems particularly appro- priate: "St is also a good rule not to put overmuch confidence in the observational results that are put forward until they have been confirmed by theory." It often appears that this philosophy has been applied with little restraint in administrative approaches to animal damage control over the past several years. It would seem even more valid to apply the inverse, that confidence in theory can only be supported by confirmation in fact. It is possible that additional new control techniques such as specific attractants (115) and reproductive inhibitors may be developed. Such methods could provide alternatives for management of damaging species and may offer one of the best options for non lethal control in the future. It is highly unlikely, however, that nonlethal methods can ever provide all necessary control in the immense variety of habitat types, climatic conditions and damage situations that are known to exist. Management of predator populat ions w i 1 1 be necessary and political reality suggests that this too must be recognized . (116) Refe rences Audobon Leader. 1975. Vol . 16(1*0:1. July 25- Allen, D.L., Chairman. 1972. Report of the Committee on North American Wildlife Policy. Transactions: North American Wildlife Conference 33:152-181. Cain, S.A., J.A. Kadlec, D.L. Allen, R.A. Cooley, M.rl. Hornocker, and F.H. V/agner. 1971. Predator Control - 1971. Report to the Council on Environmental Quality and the Department of the Interior by the Advisory Committee on Predator Control. University of Michigan Press. Ann Arbor. 207p. Cain, S.A. 1966. Statement before the Fisheries and Wildlife Subcommittee of the House Committee on Merchant Marine and Fisheries. Hearing, Predatory Animal Control Policies. February 2, 1 966 . 13 p . (mimeo.). Colorado Department of Agriculture, 1975. Colorado Agricultural Statistics Colorado Crop and Livestock Reporting Service, Bulletin. July 1975. Connolly, G. and W.M. Longhurst. 1975. The effects of control on coyote populations: a simulation model. University of California Experiment Station. Bulletin, (in press). Conservation News. 1975. Predator control and the sodium cyanide collar. Vol. **0(16):2-4. Council for Agricultural Sciences and Technology. 1975. Multiple use of public lands in the seventeen western states. Report No. ^5. Department of Agronomy, Iowa State University. Ames. 50010. 1 3p • (Mimeo.). Council on Environmental Quality. 1972. Printing Office. Washington, D.C. Council on Environmental Quality, 1973- Printing Office. Washington, D.C. Council on Environmental Quality. 197*4* Pr Fitting Office. Washington, D.C. Court Records. 1971 “72. United StateS Environmental Protection Agency. 1972. Notice 12-1. 6p. (mimeo.). March Third Annual Report. U.S. Government ^50p. Fourth Annual Report. U.S. Government *49 8p . Fifth Annual Report. U. S. Government 597p. District Court. District of Columbia. Pesticides Regulations Division PR 9, 1972. (in re use of December *4, 1 973* Environmental Protection Agency. 1973* FIFRA Docket No. 2 9 ^ . certain rodent icides.) Notice of Withdrawal of Proceedings. 3 p . (mimeo) Howard, W.E. 197*4. The biology of predator control. Add i son-Wes ley Module in Biology, No. 11. Cummings Publishing Company. Menlo Park, California. 48p. Kncwlton, F.F. 1972. Preliminary interpretation of coyote population mechanics with some management implications. Journal of Wildlife Management 38(2): 369-382. (117) Knowlton, F.F. 1973. Using population mechanics in management schemes. Proceedings. Great Plains Wildlife Damage Control Workshop. Kansas State University. Manhattan. December 10-12, 1973. PP • 11-16. Leopold, A.S., S.A. Cain, D.M. Cottam, I.N. Gabrielson, and T.L. Kimball. 1964. Predator and rodent control in the United States. Transactions: North American Wildlife Conference 29:27-49. Marsh, F.M. 1975. National Woold Grower 65(8) :4. August 1975. Morton, R.C.B. 1971. Remarks at the National Wildlife Conservation Summit. Estes Park, Colorado. July 9, 1971, 5p • (mimeo). Poole D.A., L.M. Talbot, A. 5. Leopold and N.P. Reed. 1972. Special panel: results and implementation of the Council on Environmental Quality - Department of Interior predator control study. Transactions: North American Wildlife Conference 27:395-409. Presidential Documents. 1972. Executive Order 11643. Federal Register 37(27): 2875-6. February 8, 1972. Presidential Documents. 1975* Executive Order 1 1 870 . Federal Register 40(140:30611-13. July 22, 1975. Ruch, J.B. 1973. Long range objectives of the federal government in coyote management. Proceedings: Great Plains Wildlife Damage Control Workshop. Kansas State University. Manhattan. December 10-12, 1973* Pp. 1-4. Sciences. 1975. CEQ. relaxes stand on predator poisoning - biter beware. Vo 1 . 189 (4200) : 361 . August 1, 1975. Science Hews. 1975 Lee Talbot: an ecologist for all seasons. Vol . 107 ( lb) : 260 . April 1 9, 1975. United States Department of Agriculture. 1974. Number of farms and land in farms. Annual report. Statistical Reporting Service. December 30, 1974. United States Department of Agriculture. 1975. Annual cattle inventory. Statistical Reporting Service. February 3, 1975. United States Department of Agriculture. 1974. Annual hog inventory. Statistical Reporting Service. December 3, 1974. United States Department of Agriculture. 1975. Annual sheep and goat inventory. Statistical Reporting Service. January 28, 1975. U.S. Congress, House of Representatives. 1973. Predatory animals. Hearings, Subcommittee on Fisheries, Wildlife Conservation and the Environment. Ninety-Third Congress, First Session. March 1 9 -2 0 , 1973* Serial No. 93“ 2 397p . U.S. Congress, House of Representatives. 1973* Predator control. Hearings Committee on Agriculture. Ninety-Third Congress, First Session. September 18, 20 and 21 , 1973. Serial No. 93-DD. 35 4p . (118) (US) U.S. Congress, Senate. 1972. Predator control and related problems. Hearings, Subcommittee on Agriculture, Environmental and Consumer Protection. June 2-3, 1971* Ninety-Second Congress, First Session. 220p . U.S. Congress, Senate. 1972. Predator control and related problems. Hearings, Subcommittee on Agriculture, Environmental and Consumer Protection. December 1A-20, 1971. Ninety-second Congress, Second Session. 668p. U.S. Congress, Senate. 1973* Predator control. Hearings, Subcommittee on the Environment. Ninety-Third Congress, First Session. March 2 7“ 7S > May 10, 1973. Serial No. 93-28 . 5l4p. U. S. Department of Interior. 1986. Fish, Wildlife and Pesticides. U.S. Government Printing Office. Bulletin. 12p. U.S. Department of interior. 1972. Interior, CEQ, release Advisory Committee study report on predator control. News release. 2p. (mimeo.) February 8, 1972. U.S. Department of interior. 197^. M-44 Efficacy Data. A report on emergency use of the M-44 cyanide ejector for canid damage control. June 1 - October 1, 197^. Up. (mimeo.). U.S. Department of Interior. 1972. Use of poisons halted by Interior in animal damage control program. News release. 2p. (Mimeo.). February 10, 1972. Wade, D.A. 1973* An assessment of the coyote problem in the Great Plains states. Proceedings: Great Plains Wildlife Damage Control Workshop. Kansas State University. Manhattan. December 10-12, 1973. pp.5~10. CUD) CONTROL OF NOXIOUS PLANTS THROUGH THE APPLICATION OF REST ROTATION GRAZING MANAGEMENT Today, I am going to discuss a natural method of controlling noxious or weed plants. This method involves manipulation of livestock in such a manner to provide desirable plants the opportunity to out compete undesirable plants; and ultimately increase the quality and quantity of desirable vegetation on Montana rangelands. First of all, before 1 become too deeply entrenched in my topic, S want to make it clear that this discussion is directed solely at control of noxious plants on na- tive rangelands. Noxious plant control on farm lands, hay meadows, and irrigated pastures are beyond the scope of this paper. Also, if I make an inference that a particular plant is noxious, I am only referring to its successional position rela- tive to a specific range site. Philosophically, the Bureau is guided by one major axiom in its noxious plant control program, ranges in good condition with vigorous stands of high quality vege- tation have fewer noxious plants than overgrazed ranges in poor condition. A recent study conducted in Montana by SCS, documents numerous cases of resource deterioration by overgrazing. The results collected from about 80 range sites indicate that exces- sive quantities of big sagebrush, annual grasses, and undesirable forbs have invaded and significantly reduced the productive potential of such sites. (Slide) Compara- tive compositional data, for grazed site versus nongrazed site near Helmville, Montana, shows that rough fescue (Festuca scabrella) occupies 78 percent of the vegetative composition on the ungrazed site and big sagebrush (Artemis i a tr i dentata) is almost absent. Nearly the reverse is true on the adjacent grazed site. (Slide) Over- grazed ranges stripped bare of protective desirable perennial vegetation offer an ideal environment for invasion of undesirable vegetation. Heavy continuous grazing Presented by Harry R. Cosgriffe, Range Conservationist, Bureau of Land Management, B i 1 1 i ngs , Montana increases undesirable plants and decreases tall grasses. Tall grasses with healthy vigorous root systems will effectively control the establishment and spread of un- desirable vegetation; and eventually undesirable plants are diminshed to their natural successional position. The Bureau favors natural control techniques, i .e. , specified livestock grazing treatments over cultural treatments. This strategy is necessary and logical, especially when one considers that BLM is responsible for management of surface resources over 3. 3 million acres in Montana, North Dakota, and South Dakota. The success or failure of our program will directly affect an additional 3-7 million acres of adjacent, inter- mingled private and State land. This enormous land area consists of a heterogeneous mix of soil and vegetative types and rough, broken lands that simply are not suited to cultural treatments. Most weed control strategies today, are oriented toward cultural control, but little attention is given to good livestock management before, during, or after the treatment is applied. Thus, the symptom is treated, rather than the factor directly responsible for the problem, whether it be the result of improper livestock grazing, or other man-caused land disturbances. Before mechanical or herbicidal treatments are applied, the ability of the land to respond to good grazing management technique must not be underestimated. The control of noxious plants by manipulating class of livestock in combination with prescribed grazing treatments has been recommended and tested by various investi- gators at home and abroad. Turner (1969) in a three-year study in western Oregon found that utilization of Medusahead (Taenutherum asperum) infested ranges by sheep in early-late spring grazing treatments reduced Medusahead and allowed perennial grass species to become dominant. In a search of literature. Huss (1972) found that researchers in central Africa indicated goats might be more effective for controlling brush than herbicides and reported efforts to control brush by goats in Texas and Mexico 021) was successful providing the goats were rotated between pastures. (Slides) Rest rotation grazing on the Leo Petrie federal range allotment north of Turner, Montana, improved the vigor and condition of silver sagebrush (Artemis ia cana) . Prior to initiation of the grazing system, continuous grazing by sheep maintained the plants in low vigor. Baker (Personnel Communication) found in a study conducted in Montana that early spring grazing of leafy spurge by sheep reduced the rate of spread, and prevented seed production; and concluded that early sheep grazing in combination with herbicide applications was an effective control method. Biological control of noxious vegetation offers great potential, especially if it is correlated with grazing management. In some areas, the introduction of host specific insects has proved a worthwhile tool. Baker and Anderson (197*0 are experi- menting with leafy spurge hawkmoth to control leafy spurge. The moth Calophasia is being tested on Dalmatian toadflax in Idaho, Wyoming and Wash ington . The moth Agroga We bsteri attacks big sagebrush viciously; and it has the capability to effectively control dense monotypic stands of sagebrush. In developing a strategy for controlling noxious plants, BLM is faced with two s i tuat ions : 1. Controlling established stands of noxious plants, and 2. Prevention of the spread of existing stands and establishment of new infestat ions . Conceptually, we approach each of these situations similarly. First, intensive livestock grazing management is advocated which involves the systematic rotation of livestock over a period of years to al low important perennial plants to regain vigor, produce seed and allow seedlings to become established. (Slide) In each allotment designated for intensive grazing management, the resource manager must select a key plant to manage for. Selection of the key plant is based on certain characteristics (122) and qualities, such as, the plant provides excellent soil protection, perennial fibrorous or rhizomatous root system, generally reproduces from seed, and possesses a tall growth stature which offers it a competitive advantage over undesirable plants. Specific grazing treatments are designed to meet the growth needs of the key plant. By recognizing the various growth stages, i.e., leaf stages, flower stalk showing, flowering and seed ripe, the resource manager can predict the degree of root develop- ment and carbohydrate storage. The relationship between growth stage, root development and carbohydrate storage for Ida fescue (Festuca idahoens is) is illustrated in Figure 1. The principles presented apply to other grasses, forbs, and shrubs, but of course, the growth stages and physiology differ from plant to plant. Sn Montana's area of jurisdiction, a variety of grazing formulas are in operation. The number of treatments in each formula is dependent upon the amount of rest the re- source manager decides is necessary for key plants to recover vigor, allow seed to ripen, allow seedling to establish and provide for lay-down of litter. Examples of grazing formulas that have proved particularly successful over the years are illustrated be low . 1. (Slide) Nichols Coulee RCA - This allotment is located about 70 miles south of Malta, Montana, in the Missouri River Breaks. The allotment encompasses 88,000 acres. Two pastures are located in the C.M. Russell Wildlife Range and two outside. Square Butte RCA is located about 50 miles southwest of Malta near the Little Rocky Mountains. There are about 10,000 acres in the grazing system. The allotment is divided into four equal pastures. The grazing formulas for each allotment are compared in Figure 2. (123) 00 75 50 25 0 0 25 50 75 100 FIGURE 1 START OF GROWTH Seed ripe G KEENNESS FI ower ing / / / 1 T. \ • \ * F 1 owe r i S how tal ks ng J / 1 f f i \ » \ YIELD x/— / / / / . 1 HE \ \ GHT \ ft MO IS CONT EURE ENT / x / / / / ✓ s f SHOO' ’ GROWTH \ \ 1 / i ■ 1 / / (124) COMPARISON OF NICHOLS COULEE AND SQUARE BUTTE GRAZING FORMULAS NICHOLS COULEE RCA TREATMENT ApRIL JUNE JULY 20 SEPT EMBER NOVEMBER 30 A GRAZE 0 1 1 .GRAZE C * I 1 * GRAZE D I REST FOR ESTABLISHMENT! OF REPRODUCTION PO PO cz rn m JO c /> CO —i CO -1 O rt cz c < CO — 1 — — . m o — - rn o o cp > po — 1 JO m s — CO "O rt m < TREATMENT APRIL SQUARE BUTTE RCA JUNE JULY 1 AUG. 1 SEPT. OCT. 30 A REST GRAZE RfST GRAZE B . j _ ■ GRAZE C. REST FOR ESTABLISHMENT OF ^PRODUCTION D “ ADDITIONAL REST FOR ESTABLISHMENT OF REPRO. , GRAZE REST — i pa pa m c: m m Z2Z TO CO * CO CP CO — | O rt o CZ ~n < CO ~n — 1 o -. m po — - m CO o CP m > < > H — PO CO m CTO — — o O ~o po m Figure 2. A pasture is necessary for each treatment in the grazing formula, thus four pastures are required to implement each formula. In four years, pasture will receive a prescribed sequence of the aforementioned grazing treatments. This sequence of treatment is referred to as one grazing cycle . (END OF SEASON 2. (Slide) To facilitate operation of the grazing system, the rancher is pro- vided a diagram of pasture moves over time as illustrated in Figure 3. Year 1967 PASTURE 1 PASTURE 2 July 25 (c) ~June 1 . (B) 'jv PASTURE b Pasture 3 Rest (D) April LA} Year 1968 PASTURE 1 PASTURE 2 Res t August 5 (a) t (c) PASTURE b Pasture 3 -» h -> April 1 June 10 (A) ( B) i Year 1969 x Year 1370 PASTURE 1 PASTURE 2 PASTURE 1 jl. PASTURE 2 \ April 1 Rest May 28 April t (A) (D) a (b) (A) 4 PASTURE b PASTURE 3 Pasture b PASTURE 3 June 6 August 1 July 20 Rest (B) (c)c (c) (D) Figure 3. The rancher follows the arrows. The date varies for treatment from year to year based on the phenology of the key plant. (120 The progress of the grazing system is monitored for one grazing cycle, generally four to five years. If our studies indicate that noxious plants are continuing to spread, then herbicidal or mechanical treatments are employed. However, if an especially aggressive species, such as leafy spurge is creating a serious problem, cultural and grazing treatments are applied simultaneously. The BLM in cooperation with ranchers, State of Montana, SCS, Forest Service, and Fish and Wildlife Service has implemented 2hb grazing systems on two million acres of National Resource Lands and one million acres private and State lands in the last ten years . Significant resource improvement is documented on grazing systems that have been operational for five to ten years. Resource improvement is monitored and documented by means of permanent photo stations. Photo stations are established on key sites as determined by professional resource managers. A permanent 3 ft. x 3 ft. plot is established, and over-plot (close-up) and general view photographs are taken. Quan- titative data is also gathered and recorded on the 3 ft. x 3 ft. plot. Repeat close- up and general view photographs are retaken annually through the first grazing cycle. After the first cycle, photographs are generally retaken at the same time of the year and grazing treatment on a particular pasture received when the study was established. (BLM Manual 1 369) . Over the years, BLM has catalogued many repeat photographs that show significant resource improvement (s 1 i de sequence Stellar Creek Allotment). A series of slides was presented showing significant improvement in plant composition by comparing original close-up or general view slides to repeat photographs, simultaneously. Undesirable plants that appear to be highly susceptible to grazing treatments designed to favor desirable vegetation are Broom snakeweed (Gu? tierrez ia sarothrae), Fringed sagewort (Artemis ia f r ig i da) , Gumweed (Grindelia squarrose), and wild 1 icor ice , (G1 ycy rrh iza lepidota) . Studies indicate aforementioned plants are reduced appreciably and in some cases eliminated entirely in three to five years. Highly competitive noxious plants, such as, Big sagebrush (Artemisia tridentata), (127) Cocflebur (Xa nth Sum strumarium), Prickly pear cactus (Opuntia polycantha), cheatgrass (Bromus tectorum), and Japanese brome (B . japonicus) show a stronger resistance to grazing treatments. Where these species are established, it takes from five to ten years before noticeable improvement in plant composition occurs. The rate and degree of recovery is highly dependent upon site condition. Soil type and degree of soil loss are the major determining factors that regulate vegetation compositional changes. Thus, on sites where severe degradation has occurred change from undesirable to desirable plants is a long slow process. Over the long run desirable plants will gain the competitive advantage by reducing seedling establishment and survival of undesirables, provided grazing treatments are designed to meet the growth needs of des i rabl e p lants . As supported by our studies, desirable plants exhibiting the capacity to control noxious plants are listed below. Des i rable 'Western wheatgrass (Ag ropy ron smi th i i ) Green needlegrass (Stipa v i r idula) Nutall saltbush (Atriplex nuttal 1 i i) V/e stern wheatgrass Green needlegrass Rough fescue (Festuca scabrel la) B 1 uebunch wheatgrass (Ag ropy ron spicatum) Yellow sweet clover (Me 1 1 lotus officinale) Undes i rabl e Cheatgrass £ Japanese brome Broom snakeweed Fringed sagewort Gumweed Prickly pear cactus Big sagebrush Alkali cordgrass ( Spa r t fnag r ac flTs ) Wild licorice Prairie cordgrass TSpartina pectinata) Cocklebur Canada Wi Idrye (Elymus canadensis) Western wheatgrass CONCLUSION Application of sound grazing management principles on three million acres over the past ten years leads us to conclude that properly stocked grazing management systems are a powerful tool for controlling noxious plant species. In order to speed (123) up the control process brought about by grazing management a relatively unexplored opportunity for manipulating class of livestock and introduction of biological con- trols, such as insects, offers infinite potential for natural control of noxious species. In order for cultural control programs on native ranges to be ecologically and economically successful, such programs must be subordinate and supportive in nature to good grazing management technique. (129) LITERATURE CITED 1. Turner, Robert B. 1969. Vegetation Changes on Medusahead Dominated Western Oregon Foothill Range Following Spring Sheep Grazing and Mowing. Proceeding Range Weed Research Meeting and Field Tours - Nevada - California: page 9. 2. Baker, L.O. Personnel Communication, September 10, 1975. Control of Leafy Spurge by Chemical and Non -Chemical Means. Montana State University, Bozeman, Montana. 3. Ross , Robert L . 1973* Soi 1 and Vegetation I nventory of Mear-P r is t i ne S i tes in Montana. USDA, Soil Conservation Service, Bozeman, Montana. 55 pp. 4. Huss, Donald L. 1972. “Goat Response to Use of Shrubs as Forage" adapted from v/ i 1 dl and Shrubs - Their Biology and Utilization, USDA Forest Service Technical Report SNT-1 I n termoun ta in Forest and Range Experiment Station, Ogden, Utah. 5. Baker, L. and N. Anderson, 1 974. Leafy Spurge Hawkmoth in NOW, MSO - College of Agriculture, Bozeman, Montana, pp . 3-5. 6. rlormay, A.L. and Talbot, M.W. 1961. “Rest-Rotation Grazing - A New Management System for Perennial Bunchgrass Ranges/' U.S. Dept. Agr. Prod. Res. Rep. 51, 43 p . , i 1 1 us . 7 . Troughton, Arthur. 1957* “The Underground Organs of Herbage Grasses." Common- wealth Agr. Bureax, Bucks, England, Bull, 44, 163 p.> 111 us . 8. Bureau of Land Management Manual 4412. 22C, Release 4-34 dated 7/14/69. (130) REMARKS BY HURLON RAY EPA 2,4,5-T In April 1970, the U S Department of Agriculture, Interior and Health, Education and V/elfare, and the Surgeon General jointly declared all 2,4,5_T used in lakes, ponds and ditchbanks, and liquid formulations for use around homes and recreation areas to oe an imminent hazard; USDA suspended these uses and the Department of Defense simul- taneously suspended all military uses of 2,4,5“T pending completion of further studies. Food uses were canceled except for use on rice which was appealed by the manufacturer. Following this Agency's creation we continued this policy. These actions were a re- sult of the President's Science Advisor's announcement that scientific experiments indicated that the herbicide caused such teratogenic effects as cleft palate and systic kidney in test animals. 2,4,5-T is now used only to control weed and brush growth on rice, rangelands, forests, and along rights of way, and contains in it a contaminant known as tdtra- Dioxin, which has some known evidence of causing birth defects in test animals. Sn June 1974, the Agency canceled the 2,4, 5”T hearings requested by manufacturers due to inadequate analytic methodology, a euphemism meaning there was no data from which to draw conclusions. The past year the Agency has been constructing a system to gather and analyze the nedessary data about dioxin, and its possible environmental effects . The monitoring plan, started in March of this year, consists of two parts: 1) short monitoring plan, examining a collection of beef samples from rangelands of known treatment with 2,4,5“T. Approximately one-third of these samples have been tested, and all 125 samples should be completed by October 1975. 2) Additional areas of research activities to be implemented pending funding. These studies in- Presented by Hurlon Ray, EPA, Office of Pesticides, to the Annual Meeting of the Pesticide Users Association, Helena, Montana (131) elude monitoring studies of rights of ways, fish and wildlife, rice, persistency, combustion, and toxicity, and is expected to cost in the neighborhood of $1.2 million. The EPA will and based on that re-opening of the have a preliminary recommendation for the Administrator soon, recommendation the Administrator will make a decision on the hearings on 2,4,5~T, and other pesticides containing dioxin. / -i —f/~\ \ SECTION FIVE, EXPERIMENTAL USE PERMITS Section 5, of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), permits to anyone who applies to the Administrator issuance of a permit in order to accumulate information necessary to register a pest ic ide when it is determined that the applicant needs such a permit. Also, the Administrator may: 1) if it is used on a food or feed, establish a temporary tolerance level for residues of the pesticide before issuing the expenimen tal use permit; 2) supervise use of the permit; 3) specify the types of study; and 4) grant to the States the right to grant experimental use permits. In Section 5 regulations, published last April 30th, application requirements are spelled out which permit, we believe, the necessary room to promote the desire for research, while providing necessary environmental controls; these permits are issued only after extensive review of comments from interested parties. Additionally, a pesticide that is already registered for one product does not need to receive an experimental use permit if it wishes to test it on another pro- duct . (IS) HERBICIDE ORANGE I believe a brief explanation of the Agency's delays in disposing of Herbicide Orange is in order. As you may know, in accord with Section 19(a) of the amended Federal Insecticide, Fungicide, and Rodenticide Act (FI FRA) the Administrator of the Environmental Protec- tion Agency is required to establish procedures and regulations for the disposal or storage of pesticides, and excess amounts of such pesticides. Initial regulations under this section were published in the Federal Register on May 1, 197^, and additional rule making is now under final deliberation within the Agency. In essence this policy states: “Before destroying a pesticide examine the use- ful values it has that are not damaging to the environment." The EPA is now considering two primary methods for handling the disposal of Herbicide Orange: destruction and reprocessing. EPA believes reprocessing is worthy of additional serious consideration, and may well be preferred to destruction. Reprocessing would involve the chemical break- down of the herbicide, and, if current estimates prove correct, could return quantities of herbicide to normal channels of trade which are at least as pure as products cur- rently being manufactured. The EPA has already received bids from manufactueres interested in examining the possibility of reprocessing. I emphasize, however, that all options are still in the exploratory phase, and because of the public concern about Herbicide Orange, no final decision will be made without opportunity for full public participation. HERBICIDE ORANGE The recovery of useful value from pesticides in a disposal situation must be determined to be unfeasible before destruction can be considered. The possibility of recovering useful herbicidal value from the 2,A-D and 2,4,5“T components of Herbicide Orange with the concurrent destruction of the contaminant dioxin appear promising. Therefore, this avenue must be fully explored before a decision on destruction can be determined. With respect to destruction by incineration at sea, the EPA feels satisfied that there is little likelihood of release of unburned Herbicide Orange ( and its contaminant, known as Dioxin) into the environment. With waste of a similar chemical nature, but of lower caloric content, destruction efficiencies of up to 99.99 percent have been achieved, and never less than 99*0 percent. EPA is presently reviewing the Air Force's application to use the Dutch ship Vulcanus for at-sea incinerations. STRYCHNINE Strychnine is now permitted to be used in Wyoming against rabid skunks under Section 18, Specific Exemption. EPA is now considering registering st rychn i ne w i th the Center for Disease Control, which has applied for such registration at our urging. The Agency is of the opinion that the CDC is experienced in controlling disease vec- tores, and their decision-making would save time in emergency situations. This is in no way removing our own Agency from regulating the use of this pesticide, or releasing the Agency from regulatory responsibilities. /T7r"\ m-M The ft-kk is a mechanical device used to eject sodium cyanide into the mouth of canids when they activate it, after being attracted to it by a bait. It was developed in response to a need to replace the explosive shell of the Coyote Getter. Frederick N. Dennistoun, Administrative Law Judge, for the Environmental Protection Agency, issued a recommendat ion on August 29, 1575 to permit registration of the device with appropriate restrictions determined to be sound and under supervision of the U.S. Fish and Wildlife Service. Objections were made by environmental groups, including the respected National Audobon Society and Sierra Club, mainly concerning harm to non-target animals. However, Judge Dennistoun found the evidence showed the con- d itions of use of the M- 44 as embodied in actual practice under the experimental use permits avoid most of these dangers. He highlighted this point by citing the Fish and Wildlife Service statistics from Montana between July l, 197^ and June 30, 1975, showing a total of 603 coyotes, 1^8 foxes (the target animals) and 23 skunks, 6 raccoons, k dogs and 1 badger killed by the M-44. Here the target animals account for 96 percent of the species taken. Administrator Train is to issue final decision Wednesday . (137) CHANGES IN FI FRA There have been two substantial changes in the law passed by the House Agriculture Committee: review of Agency decisions by the Secretary of Agriculture and self-certifica- tion. These amendments will go to the floors of the House and Seriate for a final vote within the coming weeks, along with the rest of FI FRA. The Agency is new analyzing the amendments to FI FRA which requires review of Agency decisions by the Secretary of Agriculture, and the Aamin i strator is expected to announce his position on the proposed legislation within the week. As for self- certification, the Agency is opposed to the amendment which would allow any private applicator to use dangerous, restricted-use pesticides simply by saying he or she was competent to apply them, without having to demonstrate any knowledge of ability. On its face I believe it is obvious that this proposal would weaken the purpose of FI FRA, to protect the environment and people from the uncontrolled introduction of dangerous chemicals. 058) EPA recognizes the necessity and value of pesticides for the adequate production of food and fiber and for the preservation of human health. It is for this very reason that we issue numerous experimental use permits for pesticide research and ultimately responsibility under the provisions of the Federal Insecticide, Fungicide, and Rodent- icide Act (FIFRA) to regulate pesticides in order to ensure that they are used safely and without hazard to man or the quality of the environment. EPA is authorized under the Act to regulate the marketing of pesticides and to require that such products be registered with this Agency on the basis of proven effectiveness and safety to humans, livestock, wildlife, and the environment. Should scientific evidence developed after a product's registration challenge its safety or efficacy, EPA is authorized to can- cel or, in cases of more immediate hazard, suspend the product's registration. Out of the total of about 30,000 registered pesticides products containing over 1,200 registered pesticides chemicals, only three major active chemical ingredients-- ODT, aldrin and dieldrin-- have finally been canceled by EPA since its inception in IQ 7 0. in addition, chlordane and heptachlor are presently undergoing both cancella- tion and suspension actions. We believe this record shows that the Agency has administered its responsibilities under the FIFRA in an even-handed manner, acting neither precipitously nor recklessly. It is important to note, that the three can- cellations were effected on the basis of substantial evidence of harm to human health and the environment. We thus do not feel that we have acted precipitously in exercising our cancellation authority. I would also like to state that both costs and substitutes have been among EPA's foremost considerations in our major cancellation actions to date, and are matters which receive this Agency's continuing attention. Understandable concern has been expressed in the past, for example, that a cancellation or suspension action could remove necessary pesticide tools from the farmer without leaving him with an acceptable substitute. The Substitute Chemicals Program was thus initiated under Public Law 9 3“ 1 35 to "provide research and testing of substitute chemicals." The major objective of this program is to determine the suitability of substitute chemicals which now or in the future may act as replacements for those uses, both nnjor and minor, of pesticides that have been canceled, suspended, or are in litigation or under internal review for potential unreasonable adverse effects on man and the environment. The legislative intent of the Program is to prevent 1) the removal of pesticides from the market when there are no effective substitutes and 2) the substition of pesticides which, in fact, have the potential for effecting more environmental harm than the canceled or suspended use. Under the Substitute Chemicals Program, each potential alternative pesticide chemical is reviewed considering all applicable scientific factors, including chemistry, toxicology, pharmacology, environmental fate and movement, and in consideration of socio-economic factors usch as use patterns and cost/benefit analyses. Through this review, the Agency thoroughly studies all relevant implications of potential regulatory activity, from the standpoint of both the pesticide user and the ecology in general. We attempt to ensure that safe and effective alternative pesticides are registered and available when and where they are needed as substitutes for canceled or suspended uses . This year, the Agency was completed seven substitute chemical reviews. Some of these chemicals may be used as alternatives to DDT, and may also in the future be called upon to act as substitutes for other canceled substances. Reviews of numerous chemicals as substitutes for al dr in/d iel dr i n and chlordane/heptach lor are also currently underway, and are expected to be completed within the next year. Substantial progress is being made in the area of research into substitute chemicals. Prior to EPA's cancellation of DDT and al dr in/d iel dr in , and its issuance of Notice of Intent to cancel and suspend chlordane/heptachlor , the Agency made certain that alternative chemicals were registered for all the discontinued uses, and care- fully considered the cost implications of these actions. In the Administrator's DL)T Order, for example, a full discussion of the substitute chemicals registered for all uses of DDT, and the costs associated with use of tnese substitutes, appears on pages 13371- 72 and further discussion continues through the remainder of the document. The Federal Register package on al drin/dielarin, contains extensive discussion of both substitute materials and the cost impact of suspension. Further comments supporting EPA's position regarding cost and alternatives are included in the U.S. Court of Appeals decision upholding the Agency's suspension of al dr i n/d i e 1 dr in (a copy of which is also enclosed). EPA's more recent Notice of Intent to suspend chlordane/heptachlor con- tains a description of the Agency's position regarding the two factors of cost impact and registered substitutes. The Agency has also prepared a comprehensive report on the economic impact of the proposed chlordane/heptachlor suspension, and this analysis should be released shortly. 1 believe that these materials substantially illustrate EPA's consistent efforts to give due consideration to both the cost impact and the existence of registered alternative products, in initiating administrative proceedings against widely used agricultural chemicals. I would also like to mention the Agency's position on availability of alternative chemicals, as is discussed on page 3^57 of the Notice of Intent to suspend chlordane/ heptachlor product registrations. The applicable law does not require that the Agency staff, as part of its affirmative case, offer recommendations of substitutes or pro- vide evidence that alternatives registered are actually obtainable, efficacious or available at reasonable prices. The Agency is required only to present evidence that alternatives are registered for the uses in question. The burden of demonstrating that the alternatives are not actually obtainable, are not efficacious or are not available at reasonable prices remains on the proponents of continued registration of the pesticides under review in a cancellation or sustension proceeding. Thus, the Agency has upheld its legal obligations in the major administrative proceedings to date by ensuring that alternative chemicals are registered for the appropriate uses. v/hile both registered alternatives and economic impacts are important considera- t i on s , I believe that the most important consideration of all, which has been the b asis for each of our administrative actlons--is, the preser vation of human health and environmental quality. In order to cancel or suspend a pesticide product's re- gistration, EPA must have substantial scientific evidence indicating that the chemical in question "causes unreasonable adverse effects on the environment," or posses "an imminent hazard" to man or the environment. The cases against continued use of DDT, al dr i n/d i el dr in , and chlordane/heptachlo r are well documented and supported by hard scientific data. See pages 1 3 370“ 71 of the DDT Order, which contains a discussion of the risks, in terms of health effects and environmental properties, posed by con- tinued use of DDT. At the time of its cancellation, DDT was recognized as "a non- specific chemical that kills both target and nontarget species..." It was cited as an uncontrollable durable chemical that persists in aquatic and terrestrial en- vironments, collects in the food chain, and is passed up to higher forms of aquatic and terrestrial life. The persistence and biomagnification of DDT in the food chain were seen as clear causes for concern, given the long-range effects of DDT in man and the environment. Cancer research experts at that time indicated that the tumorigenic results of tests conducted with DDT to date were indicators of carcino- genicity, and that DDT should be considered a potential carcinogen. At that time, it was also recognized that DDT causes damage to certain wildlife species, particularly avian and aquatic populations. I would like to refer to item 26 on page 37252 and surrounding discussion in the al drin/dieldrin suspension package, as well as to pages 372^5“5’3 (Conclusions, 1. - IV.), and to pages 37 267_ 70 (11. The issue of Carcinogenicity of Aldr in/Di el dr in) , which contain a full discussion of the evidence presented indicating that aldrin/ dieldrin pose a high risk of causing cancer in man. Page 3^56 (Additional Cancer Evidence) and the remainder of the enclosed chi ordane/heptach lor suspension Notice contains additional discussion of t he cancer risks posed by these substances. 1 believe this material thoroughly documents the hazards to human health and environmental well being posed by al dr in/d i e 1 dr i n and ch 1o rdane/heptachl or . EPA's administrative actions against pesticide product registrations are ini- tiated on the basis of scientific data, but are finalized upon a complete weigh S ng of the risks and benefits which can be expected from continuing use of the material in question. Extensive risk-benefit discussions appear in the enclosed material on DDT, al d r in/di el dr in and chlordane/heptachlor. In the first two cases, determination was finally reached that the risks of continued use of DDT and al dr in/d iel dr in out- weighed the benefits they afforded. As the U.S. Court of Appeals stated in its re- view of EPA's al dr in/d iel dr in suspension, “the statute places a heavy burden on any administrative officer to explain the basis for his decision to permit the continued use of a chemical known to produce cancer in experimental animals." The cancer risk posed by these pesticides has been found to outweigh almost all of their benefits. You may be interested to know that EPA recently submitted a report to congress on DDT. The study concluded that DDT residues in the food supply, human tissues and in the environment have declined in recent years, especially since the 1972 cancel- lation. It showed that risks are declining, alternative pesticides are available, and economic impacts have been nominal since our 1972 action. For most crops, in- cluding cotton, production has been maintained. However costs have increased in some cases. In reviewing studies conducted since 1972, the report found that DDT should still be considered a potential human cancer agent; that DDT is stored in human fatty tissue, wildlife and fish; that DDT is toxic to fish and birds and interferes with the reporduction of some species; and that DDT persists in soil and water for years. Finally, I would like to assure you that EPA is vitally concerned, in all its m) policy and regulatory decisions, with maintaining a balance between effective pest control and environmental quality. Our programs are mandated by Congressional statute, and can be revised at the discretion of the Congress at any time they cons i or appropriate. EPA must consider the issues of human carcinogenicity, wil preservation, and overall environmental integrity, in judging the Agency's regulatory actions. EPA believes in the legacy of sound, health, plentiful and world environment for future generations. der necessary dl i f e s pecies pest icide national - Hurl on Ray - l: Did you hear Alvin Young's talk yesterday about the disposal of agent orange? A: No, I did not. Are you aquainted with the problems that the Air Force has had of disposing of agent orange? A: Yes, I am. J: What comments do you have? A: Agent orange, the recovery of useful valuable pesticide in a disposal situation must be determined to be unfeasible before destruction can be considered. The possibility of recovering useful herbicide of 2,4-D and 2,4, 5~T components of herbicide orange with the concurrent destruction of contaminant dioxin, appear promising, therefore, this avenue must be fully explored before a decision can be made on destruction of 2,4-D and 2,4, 5“T. With respect to destruction by incineration at sea, the Environmental Protection Agency feels satisfied that there is little likelihood of release of unburned herbicide orange or its contaminant, dioxin, into the environment. With a waste of similar chemical nature, but a lower caloric content, destruction efficiency of up to 33.33% have been achieved and never less than 99.0%. ERA is presently reviewing the Air Force's application to burn orange at sea and we expect to make a statement on that about next week. Q: Monitoring program for dioxin is a short-term sample program which consists of the beef and what was the long-term monitoring program or is there one currently in operation? A: The long-term one is to look at gestation periods, still births, other kinds of things that may happen to the animal itself, there may not be one, there might not be a long-term program. Q.: Oh, so 1 see, the long-term-program really will depend upon what the beef sampling program finds? A: Yes. What they're doing in Oklahoma, as most of you know, most of Oklahoma since 1953 has had a lot of applications in 2,4,5"T. They picked some ranches there and this wasn't easy to do either, to find a rancher who'd let us makr a cow that was sprayed with 2,4, 5_T last spring and follow that cow to market and all the way to the processing plant and take a sample. Many of the ranchers just don't like to have EPA guys on their farm or ranch and maybe j ust i f i abl y so. It was not easy to get the 125 samples, but they were collected, they were froze im- mediately, and were sent to laboratories in Salt Lake City, Midland Michigan, our labs in the south and a fourth lab as a control. I say again the results should be out, we should have a decision by Thanksgiving whether or not Mr. Train wants to open up the hearings again on 2,4,5“T or whether some other adverse action will be taken. Q.: Being as you are so concerned about DDT being a carcinogenic, why isn't tobacco taken off the market? WiA A: My wife asks me that every night. Q.: It's the same difference, I mean it's dangerous, tobacco has been proven more dangerous than DDT ever thought of being, but EPA hasn't done anything with it. I think it's politics myself. A: I disagree with that. I think that DDT has proven to . . . V/e 11, we know what DDT can do. Q.: I don't see any information that shows this. Where is the statistical infor- mation at? A: For DDT? Q.: Yes A: It's in the Federal Register. Q: Why has it never been put out to the public? A: The Federal Reg 1 ster is publ ic property. It's in all public libraries, all state offices, all Federal offices and all county offices. has DDT been shown to be carcinogenic to human beings? A: I'm not going to argue about that fact. Mow about alcohol? Q.: Has Mr. Train made any decision regarding sodium cyanide and the M-44? A: I think this afternoon you have a speaker on the subject, I'll leave it to him. Q: About your administrative law, has Mr. Train made a decision? A: He will make it today. Today is Wednesday isn't it? On strychnine, it's been used on rabid skunks under Section IS in Wyomi ng and also, I don't know whether Montana has applied or not. They've issued a permit to Wvoming to use strych- nine. The Communicable Disease Center in Atlanta, Georgia has applied for a permit for strychnine and I believe EPA is going to authorize that one. I think the Agency is going about these requests at a reasonable, sensible, professional manner, based on information that they have. Q.: May I ask a question about strychnine? CDC in Atlanta and the state of Montana have applications for registration in. We just received our application back, denied. But in the Federal Register of September 12, 1 375, both CDC and Montana applications are discussed there in regard that they are going to allow everybody to comment and maybe they will hold hearings to possibly change the 72-2 order to allow for registration consideration. In other words, the same process as sodium cyanide. Is that what you foresee? A: Yes, that's what I see. Q.: In other words, this is a longevity paper work process again, with attornies and everything wrapped up in trying to get a job done, what do we do in the interim? A: Be patient, every process back there is a long drawn out legal process and when Train said he has asked f o r a committee to study ways and means to improve the decision making process in the office of pesticides, he means that. 1 ■■/I ru I just want to comment about one of these proposed amendments for the information of the people in this room. For self-certification, under Montana's Pesticide Act, we cannot self-cert ify private applicators, they will still be' certified by written examination not by signing a register as proposed. Even if this amendment is adopt- ed by Congress, that will not change state law within Montana and our law requires a certification of private applicators by written exam. This will not change other states who have already implemented certain provisions such as Mew York, etc. A: The three of the $5,000,000 that we transferred to the extension service to develop the manual, the training, etc., etc., that job is just about completed. If this amendment passes, a lot of money is going down the drain, and Minnesota won't buy it either and neither will Texas, ! don't know about Wyoming. Q: Let me ask a question that I think that's pretty important and that is the cancer policy of EPA. I think this creates a lot of confusion in the minds of a lot of people, simply because they have gone away from the use of the carcinogenic term to the oncogenic term and I think this is creating a situation that we are not going to be able to live with. Can you comment on that policy? A: You are one of the several professionals that has asked that question. This is another item that Russ has met on about eleven days ago, is our cancer policy, within EPA. Me expects to announce a cancer determination policy within, I would say two weeks, of a way to go about it. It will be somewhat different, 1 think, than the way we have done St before. l: it's going to stall any pesticide development, 1 am sure until it's cleared up. Because no company is going to invest millions of dollars to find out somewhere down the road he can create a tumor by overfeeding the product to the test animal that is especially subceptible to that particular situation anyway. A: This is the first time I really ever had a chance to watch Russ produce. I'm impressed with his desire to learn more about the effects of pesticides on people and the environment. I think in the next two months you are going to see some changes, I think, you are going to see a different way of doing business in the office of pesticides. If it doesn't happen, 1 think Congress is going to do some- thing about it. 4 ; EFFECTS OF SAGEBRUSH CONTROL Oil WILDLIFE AND ECOSYSTEM COMPONENTS - RESULTS OF A TEN YEAR STUDY INTRODUCTION Plant communities containing sagebrush are common and often a dominating aspect of Montana's prairies and mountain foothills. Sagebrush ecosystems are necessary for the very survival of some wildlife species and important to many others. Because of its broad distribution and general importance to wildlife (Q.uimby 1 966 ) it was not surprising that game managers were among the first to express their concern about the chemical war being waged against sagebrush. By the early 1 96O ' s the practice of treating sagebrush rangelands to eridicate sagebrush and increase grass and 1 ivestock production was becoming widespread and the potential negative impact on Montana's wildlife resource was significant. Public land managers were also becoming aware of and concerned about the increasing demands for multiple use of public lands. In 1365 concern was broad-based, culminating in the initiation of a joint, ten year commitment by the Montana Department of Fish and Game and the Bureau of Land Management to study the ecology of sagebrush control. All field work for this ten year project has now been completed and final reports are in preparation. Vast quantities of data were gathered and have been reported in more than 2,000 pages of annual progress reports, popular and technical articles, conference and workshop presentations, etc. The primary objective of the project was to determine the effects, if any, on certain non-target ecosystem components of a control program aimed at reducing or eliminating sagebrush from central Montana rangelands. Ecosystems are complicated Presented by Eugene 0. Allen, Chief, Research Section, Montana Department of Fish and Game, Bozeman, Montana and often delicate structures and it is very difficult to determine the role played by a major component such as sagebrush. Yet, to recognize the full impact of sage- brush removal, myriad sagebrush-ecosystem component relationships must not only be unveiled, but understood. Many of these relationships can be observed and measured directly; others can only be surmised through subtle and intuitive deduction. There- fore, proper evaluation of sagebrush control dictated a variety of ecological studies of associated ecosystem components. During the course of this project, data evaluation was complicated by an omni- present factor - the grazing of domestic livestock. Sagebrush control is often the first of several events associated with the refinement or altering of an existing grazing management system, including: water developments, fences, changes in graz- ing seasons and intensities of use, etc. In this study, the presence and impact of grazing animals often seriously influenced the data gathered and their subsequent anal ys is-somet imes actually overriding and masking the effects of sagebrush control i tse If. With these factors as background, I would like to briefly outline the nature of the study and summarize the major findings. DESCRIPTION OF THE STUDY AREA Most work was conducted in the Yellow V/ater Triangle which lies in east-central Montana between U. S. Highway 87 and Montana Highways 200 and 244 and between the towns of Winnett and Grassrange; some studies were conducted in a smaller area in the Missouri Breaks north of the Yellow Water Triangle. Jorgensen (1974) described in detail the physiography, geology and soils, climate and vegetation of the study area . METHODS Five areas were selected for treatment and intensive study (Table 1). Treatments were applied to Yellow Water Triangle study areas in 1968 wii i 1 e the Missouri Breaks area was treated in 1972. Chemical treatments were with G/;0 2,4-D and included total and partial kill blocks ana 100 foot wide strips, mechanical treatments included con- tour furrowing and i nterseed ing . Percent kill of sagebrush on total kill blocks and strips were approximately 95 while percent kill on partial kill blocks averaged 59 and ranged from 0-30 for partial kill strips. Table 1. Spray Treatment Data. Area Treatment When Treated Amount Trea ted Percent dead sagebrush after treatmen t ^ Winnett Total kill June 1368 hoO acres 95+ Strip spray 400 acres^ 95+ King Total ki 1 1 June 1363 229 acres 99+ S i bbert Partial kill J une 1968 253 acres h5 1 verson Partial ki 11 June 1963 31 7 acres 59 Strip spray 320 acres^ 0-90 rl i ssour i Breaks Total kill May 1372 320 acres 99+ *0n the basis of canopy coverage of dead vsT live sagebrush. Determined ^one year after treatment. The total area including the 100 foot wide leave strips A wide variety of methods and techniques were necessary to collect data during the many project phases; they have been reported in detail in the ten annual progress reports (see Literature Cited). RESULTS Soil Two parameters of soil were evaluated with respect to chemical and mechanical treatments: soil erosion and soil moisture. Three hundred erosion disks were installed on the Winnett, King and Iverson study area. Comparisons of soil erosion were made between sprayed and unsprayed sites, between mechanically treated and control sites, and between sites protected from grazing and unprotected sites. Steepness of slope was the most important factor contributing to soil erosion; however, no difference in rate of soil erosion was detected between any treated and untreated plot; this was true both inside and outside exclosures (Jorgensen 197*0. Effects of treatments on soil moisture were evaluated using the gypsum block method and is described in detail in Jorgensen (1975). Results indicate that total kill spray did not significantly effect the degree of soil moisture recharge following spring snowmelt and heavy rainstorms. Killing of sagebrush apparently did not affect rate of water penetration into this type of soil (thebo clay). The first two years following treatment, moisture withdrawal was greater on the unsprayed site compared to the sprayed site at all depths except four feet; the third year the rate of withdrawal was greater on the unsprayed site at all depths. Total kill spraying did not affect the amount of snow accumulation during the years of study, but on wind-blown ranges snow accumulation and resultant soil mois- ture recharge could decrease as the dead sagebrush snags break down. On the partial kill spray study area, soil moisture recharge was greater at the 36" and A8“ depth on the treated sites than on the untreated. However, no significant differences in moisture withdrawal resulting from partial kill spray were detected on any site in any year. It is unclear why the effects of partial kill were different from those of total kill. In this study, no increases in soil moisture following mechanical treatments were detected. The effectiveness of contour furrowing in improving soil moisture is dependent upon the decrease of runoff. During the study period, little or no runoff was observed in the control area. VEGETATION Following treatments vegetation was measured with respect to canopy coverage (CC), dry matter production, foliage height, species composition and succulence; (MS) results were reported by Jorgensen, 1975. Differences in effects of partial kill compared to total kill spray were ones of degree, with effects of partial kill less pronounced or persistent than those of total kill. Fo rbs One of the greatest effects of total kill spray was the large reduction in CC of forbs . Total CC was reduced to about 1A that of the controls immediately after treatment and had only recovered to approximately 1/2 the controls five years post- treatment. Most forbs were reduced following total kill spray, but subsequent rates of recovery varied between species. Six years post-treatment, CC of fringed sage (ARFR) on treated areas was equal to or greater than controls, while vetch (V1AM) showed little or no recovery. Dry matter production of vetch was about five times less on sprayed plots while production of fringed sage was three times greater. Yellow sweetclover (MEOF) is highly susceptible to 2,^-D damage, but apparently re- covers rapidly. In the Missouri Breaks study area, sweetclover was virtually absent on the sprayed site one year following treatment as compared to its abundance on surrounding unsprayed sites; one year later the situation was reversed. Three forbs were analyzed for succulence six years post -treatment . No signifi- cant differences were noted for dandelion (TAOF); succulence of fringed sage and vetch was significantly less on the sprayed plots than on the controls. Gras s Increased dry matter production of Western wheatgrass (AGSM) was evident one year following total kill spray treatment, ranging from 1.13 to 3.16 times that of the controls. In the Artemi s ia-Agropyron type where bluebunch wheatgrass was the dominant grass, its production was 2.0 to 3.36 times higher on sprayed plots. Pro- duction of ooth grasses continued to be 2.0 to 3.0 times greater six years post- treatment. Other grasses, as a group, had a higher yield immediately after spraying averaging 1.6 times that of control; three years post-treatment, however, their pro- duction on sprayed plots was equal to or less than the controls. Mechanical Treatments Total CC of the vegetation community was significantly decreased following mechanical treatment while amount of bare yround increased; both changes persisted five years post -treatment . Treatmen t- induced increase in bare ground was attributed to sharp decreases in CC of blue grama (bOGR), lichens and clubmoss (SEDt). One year following treatment, CC of grass was significantly lower on the treated plots, but eventually increased to about the same as the controls. Most of the in- crease in CC of grass was attributed to western wheatgrass, but its increase was apparently only enough to offset decreases experienced by blue grama and needle-and- thread (STC02) . Canopy coverage of forbs and shrubs (mainly big sagebrush) were unaffected by mechanical treatment. Succulence of fringed sage and vetch was significantly lower on the contour furrowed plots than on the controls six years post- 1 rea trnen t ; dandelion was not affected. SAGE GROUSE Habitat requirements of sage grouse are well documented, and game bioloyists have long recognized the close tie between sage grouse and their sagebrush environ- ment. Because sagebrush control may not have an immediate noticeable affect on sage grouse (depending on size of area treated in relation to total habitat available), it was difficult to evaluate the effect of small (less than 500 acres) scattered (3 areas in 171 >000 acres) control sites in our study. Movements and habitat use of individuals and groups of birds were determined, but translating these data into population consequences required a certain amount of inference as well as direct observation . Direct Observation Dropping counts - Dropping counts were made along 257 permanently located transects on four study areas for five years (3 pre- and 2 pos t-t rea tment) (Pyrah 1372) . Re- sults indicated a 32 to 88 percent reduction in sage grouse use in the total kill (130) block and strip spray areas, respectively; mechanical treatments resulted in a 36 percent decline. block partial kill declined slightly the first year, but in two more years was back to pre-treatment levels while use of partial kill strips doubled, because sage grouse populations during this time more than doubled in this general area, effects of partial kill may have caused a decline in the block and no effect in the strip treatments, respectively. Strutting ground counts - Between Ij63 and 1 363 counts from grounds adjacent to treat- ment areas declined slightly (6 percent) while other grounds in the Triangle doubled and tripled in cock counts (ave. 264 percent). A 31 percent loss of habitat (sprayed) adjacent to the north Yellow Water strutting ground was apparently responsible for a 63 percent decline in the number of strutting males over a two year period. 1 nf erence Data on sage grouse habitat relationships were obtained from observations of 73 radio-marked birds. Food habits were determined by examination of 426 crops collected during all seasons . Breed ino Habitat Wallestad and Schladweiler (1374) reported 80 percent of locations of breeding cocks away from strutting grounds occurred in sagebrush stands with a canopy coverage of 20 to 30 percent. No cocks were observed in areas having less than 10 percent CC of sagebrush. All 41 sage grouse nests located by V/allestad and Pyrah (1974) occurred under sagebrush plants and were located in stands of sagebrush averaging 23 percent CC. They found that successful nests nad significantly greater sagebrush cover within 24 inches of the nest, within a 100 sq. ft. plot around the nest and were located in stands of sagebrush with a higher average CC than those of unsuccessful nests. D rood Hab i ta t Brood habitat was largely determined by the availability of succulent vegetation (Peterson 1970). Broods used sagebrush areas early in summer and then shifted to bottomland types as uplands dessicated. In fall, as green forbs dried, sage grouse shifted back to sagebrush types for food and cover. Sagebrush canopy measured at brood sites averaged \k percent for June, 12 percent for July, 10 percent for August and 21 percent for September (Wallestad 1971). Fall and Winter Habitat Seven ty -e ight percent of 151 fall and winter locations of sage grouse recorded by Wallestad (1972) occurred in sagebrush stands that exceeded 20 percent CC. Eng and Schladweiler (1972) reported 82 percent of 60 winter locations occurred in stands of sagebrush that exceeded 20 percent CC. They described sage grouse winter- ing areas as being large expanses of sagebrush (20 percent and greater CC) on land having little if any slope. When snow depth exceeded 12 inches sage grouse were restricted to taller sagebrush stands on about 1700 acres, or only seven percent of the range available to them in a normal winter (Wallestad 1973). Food Hab ? ts Sagebrush comprised 62 percent of all foods consumed by adult sage grouse durin the year and in winter (December - February) sagebrush was the only item eaten (Wallestad et al . 1975). Only through the months of June - September did sagebrush make up less than 60 percent of the diet by volume. Peterson (1970) reported that sagebrush became an important part of the diet of juvenile sage grouse when they were 12 weeks of age. Depending upon the size of area treated and the type of treatment, effects of sagebrush control on sage grouse can apparently range from no noticeable effects to near extinction. Most sagebrush control projects are aimed at dense stands of sage- brush in excess of 20 percent CC. Stands of this density comprise the sage grouse wintering-nest ing complex, and the potential for a severe negative impact is great. Those treatments doing the least damage to the sagebrush stand likewise affected sage grouse the least and the duration of the adverse effect was shortest. Studies indicated that strip spraying was a desirable alternative to block spraying and that (152) partial kill was superior to total kill. An tel ope As with sage grouse, a certain amount of inference must be employed when attempt- ing to evaluate the full impact of sagebrush control on antelope populations. Eleven separate studies of antelope food habits in central and eastern Montana indicate that big sagebrush is the most important winter food and occurs in the year-around diet more than any other item (Couey 13**6, Cole 1356, Cole and Wilkins 1952, Martinka 19&7, Wentland 1S6S, Bayless 1570, Campbell 1970, Roberts 19/0, Becker 1371, Freeman 1971, and Knapp 1975). Some of these studies also found forbs to be the primary spring- early summer food when available. A study of 35 antelope fawn bedding sites in central Montana indicated an importance of sagebrush in the selection of bedding s i tes (Py rah 1 37*0 . Total Kill Spray Antelope avoided total kill spray area, resulting in a corresponding increase in densities on the untreated portions of summer and winter ranges - they did not expand or establish new Sumner or winter range areas. Total kill spray adversely affected antelope food and cover requirements by nearly eliminating sagebrush and by reducing the amount of forbs and changing their composition. The non-use of total kill spray areas has not changed seven years post- treatment. Partial Kill Spray Vegetation changes resulting from partial kill spray were not as damaging to antelope food and cover plants as was achieved with total kill. While antelope avoided sprayed areas the first years following treatment, observations five years post-treatmen t indicated suitable conditions for antelope had been restored, but possibly not to pre-t reatment levels. As with total kill, antelope densities increased on the untreated portions of their range - they did not establish new summer or winter range areas. (153) Mechanical Treatments Contour furrowing had a severe adverse impact on antelope, causing them to make little use of the area in the seven years since treatment. Because this treatment resulted in few vegetation changes, avoidance by antelope was probably related to security and difficulty for escape caused by the uneven ground. As with spray treat- ments, antelope densities increased with no expansion of traditional summer or winter ranges . Antelope use of interseeded areas following treatment was near normal. The two most damaging treatments to antelope (total kill spray and contour fur- rowing) were both used on the King study area. This area was part of the home range of antelope herd II. Doe band I I -A was most directly influenced by the treatments and experienced significantly lower fawn production after treatment than the rest of heard II and was sub-standard to the Yellow Water Triangle as a whole (Pyrah 1975). This decline in production was apparently an inverse density dependent response caused by antelope non-use of treated areas and the subsequent increase in densities in the remaining untreated portion of their traditional range. As with the sage grouse, partial strip, partial block, total kill and contour furrowing treatments had increasing adverse effects on antelope use of treated areas. Mule Deer Reduction of big sagebrush and forbs following t reatmen t w i th 2,4-D has been v/e 1 1 documented. Mackie (1970) reported that big sagebrush formed an important part of the Missouri Breaks mule deer diet during winter and spring and that forbs were significant during all seasons. This study was initiated on the Missouri Breaks study area in 1970 to investigate the effects of total kill spray on mule deer range use patterns. Range use patterns were determined by pellet group counts pre- and post- treatment and was reported by Becker and Wallestad (197*0. 054) Range use patterns of mule deer changed significantly following treatment. Pre treatment pellet counts in 1970 and 1972 indicated similar use of both portions of the study area (Table 2). One year following treatment, 95 percent of the control sample plots contained pellet groups while only 5 percent of the sample points In the treated area contained pellet groups. In the control, mean pellet groups per sample point increased from 0.50 and 0.45 p re- treatmen t to 2.15 post-treatment; in the treated area, mean groups decreased from 0.43 and 0.71 to 0.10, respectively. Mack ie (1970) described eight different habitat types in the Missouri River Breaks and reported the A r tern 1 s i a -A g ropy ron type to be important to mule deer during winter when sagebrush was the most important food. Results of this study, in con- junction with the findings of Mackie, indicate that large-scale alterations of this habitat type would significantly lower the area's potential for supporting mule deer and could result in a population decline. (155) TABLE 2. OCCURRENCE OF MULE DEER PELLET GROUPS BY YEARS AND TREATMENT TYPES. P re- 1 reatment Post-treatment Treatment Types 1370 1372 1373 , x 1 Control (20) % Sample points with fecal groups 35.0 25.0 55.0 Total No. fecal groups 10 3 43 Mean No. fecal groups per sampl e point 0,50 0.45 2.35 Total Kill (21 ) 1 % Sample points with fecal groups 28.6 38. 1 -t- co Total No. fecal groups 10 15 2 Mean No. fecal groups per sample point 0.48 0.71 0.10 Differences in use 2 between treatments Tm.: r--.-: — rr rr: — N.S. N.S. S i g. 1 « wn W I V » V VI I I tj— • # W V« I » I V/Vf ■ tE ^A t=test used to test the difference of the means at the \% level. N.S. = Not significant, S i g . = Significant. Small Mammals Studies were initiated in 1 366 to determine the effects of partial kill block spray (Iverson study area) and total kill block and strip spray (Winnett study area) treatments on small mammal populations. Results have been reported by Cada (1968), Tschache (1970) and Reichelt (197*0. The most conmonly captured small mammal was the dear mouse (Permyscus maniculatus) 10 other species were represented. Because of normal fluctuations In population levels, numbers of deer mice can be compared within years, but not between years. The 1973 trapping series produced much higher numbers of deer mice than any of the previous four trapping studies (Table 3). The population density may actually have been greater or an "apparent" greater density may have been due to the different method of handling the trapped mice (Reichelt 197*+). No differences in mouse densities were noted one year following treatment. After five years, however, deer mice had been nearly eliminated from the total kill area. While an increase in deer mouse density was indicated in the strip spray area, most (57 or 72) mice were caught in the live sagebrush strips. There reductions were probably in response to changes in vegetation composition which were most dramatic in total kill plots. Reduction in deer mouse numbers were not compensated for by subsequent increases in numbers of other species. The apparent increase in the strip apray area may have been the result of increased "edge effect." Since the deer mouse is an important component in the food chain of other animals, the overall importance of its reduction may not be easily or immediately recognized. 057) TABLE 3. NUMBER OF DEER MICE CAPTURED. ** ■|P re 1966 -treatment 1967 9 Pos t- t rea tmen t 1368z 19692 1973 Iverson Study Area Part ial Kill 13. 93 6.5 33.0 9.3 69.0 Control 11.2 2.3 31 .2 9.4 66 . 0 Winnett Study Area Control 13.0 5.6 23.3 10.2 27.0 Total Kill 15.3 3.4 25.6 10.3 6.0* Strip Spray 8.4 6 . 0 0 CM 5 .6 72.0* ^Significant difference (P * 0.013) from catch 1 on Control Plot. ^Cada (I368). TTschache ( 1 370) . ^Individuals per 18.6 acres. Non -game Birds Studies on the effects of sagebrush control on small, non-game birds were initiated in 1966 and results have been reported by Feist (1968), Best (1970) and Reichelt (197*0* Partial kill block spray was evaluated on the Inverson study area and total kill block and strip spray was evaluated on the Winnett study area. Eight different species of small birds were observed; Brewer's and vesper sparrows were the most abundant and composed nearly 90 percent of all birds observed prior to treatment (Table 4). One year following treatment, total birds observed on the total kill block spray had declined and by five years post- treatmen t had declined to approxi- mately one-half that of the control. This reduction in total birds was attributed to the reduction and near elimination one and five years pos t-t reatmen t, respectively, of the brewer's sparrow. Total kill block spray was apparently the only treatment detrimental to small bird populations and the Brewer's sparrow appeared to be the only species adversely effected. TABLE 4. NON -GAME BIRDS OBSERVED DURING FIVE BREEDING SEASONS. IVERSON STUDY AREA 19661_ 19671 9 Control Plot 1 968 19692 1373 Brewer's sparrow 50(55) 5 44(64) “wrcfr ' h\ (ioJ TSTW Vesper sparrow 2M27) 23(33) 20(29) 14(21) 12(29) 0 ther 16(18) 2( 3) 6( 8) 13(19) 14(33) Total 90(100) 69(100) 70(100) 68(100) 42(100) Part ial Kill Plot Brewer's sparrow 55(61) 23(62) 34(60) 31(50) 17(43) Vesper sparrow 24(27) 16(34) 21(36) 26(42) 11(28) Other 11(12) 2 ( 4) 2( 4) 5( 8) 12(29) Total 90(100) 47(100) 57(100) 62(100) 40(100) WINNETT STUDY AREA Control Plot Brewer's sparrow 40(43) 56(59) 39(53) 39(54) 33(56) Vesper 1 spa rrow 46 ( A3) 29(31) 27(37) 23(32) 12(20) Other 7( 8) 9(10) 7(10) 10(14) 14(22) Total 93(100) 94(100) 73(100) 72(100) 59(100) Strip Spray Plot Brewer's sparrow 46(55) 41(69) 38(56) 34(56) 29(50) Vesper sparrow 34(41) 16(27) 26(37)q 22(36) 14(24) Other 4( 4) 2( 4) 6( 7) 5( 8) 15(26) Tota 1 84(100) 59(100) 70(100) 61 (100) 58(100) Tota 1 Kill Plot Brewer's sparrow 15(28) 38(54) 27(45) 11(27) K 3)* Vesper sparrow 35(64) 29(40) 29(48) 24(59) 16(55) Other 4( 8) 4( 6) 4( 7) 6(14) 12(42) Total 54(100) 71(100) 60(100) 41 (100) 29(100)* Tei st ( 1 968) . 2Best (1970). * 1 nd ividual s per 40 acre plot (Percent 0 f total plot observations) . *S ign i f icant ly different (P 0.05) from count on Control PI ! ot. The Brewer's sparrow nests above the ground and Best (1370) concluded that the reason for its decline one year post-treatment was due to a reduction of suitable nesting cover. He stated that it compensated for the lack of protective foliage by selecting larger, more heavily branched dead shrubs. As sagebrush skeletons (153) deteriorate, an area would become increasingly unsuitable for nesting by Brewer's sparrow . The vesper sparrow nests on the ground, usually under the protection of sage- brush or another brush; it appeared to be less affected as long as there was some protection provided by the dead sagebrush skeleton. The vesper sparrow population may also decline as the dead sagebrush deteriorates. GRASSHOPPERS Effects of total kill spray and mechanical treatments on grasshoppers was studied by Hewitt and Rees (197*0 on the Winnett and King study areas during 1969-1971* They concluded (from Table 5): 1) Spraying for sagebrush control with 2,4-D did not result in a large reduc- tion in the density of grasshoppers. Some species such as Psol oessa del i catul a de 1 icatu la were consistently less abundant on treated areas; other species such as Arphia conspersa and Arphia pseudon ietana were more abundant. 2) Plots which were contour furrowed and interseeded provided an unfavorable habitat for most grasshopper species present, including all the economically impor- tant species indicated in Table 5, except the migratory grasshopper. Grasshopper density was less during all three years of sampling on treated plots. The greatest differences were found on contour furrowed plots, but these differences appeared to decrease with time. One species, Psoloessa delicatula delicatula, was much less abundant on these treated plots, but other species, such as Arphia conspersa and Tr ime rotrop i s g rac S 1 i s sord i da, were more abundant. 3) Probably both increases and decreases in preferred food plants of grass- hoppers that resulted from treatments influenced the abundance of grasshoppers. However, abundance on treated and untreated plots could only be related to food plants in a general way. It also appeared that mechanical treatments were more detrimental to grass- hoppers that winter as nymphs compared to those hatching from eggs in the spring. (161) TABLE 5. THE PERCENTAGE CHANGE IN GRASSHOPPER SPECIES OVER A 3~YEAR PERIOD DUE TO RANGELAND RENOVATION TREATMENTS.1 Spec i es^ W 2, innett 4-D King Fu rrowed King 1. Aeropedellus clavatus (Thomas) - 32.5 + vn 0 0 - 20.0 2. *Ageneotett ix deorum (Scudder) - 41.2 + 4.5 - 78.3 3. Arphia conspersa (Scudder) + 40.0 +100.0 4" 66.7 A. A. pseudon i etana (Thomas) + 76-3 + 1 Co . 0 + 40.0 5. *Encoptol ophus sordidus costal is (Scudder) - 6. 8 + GO.O - 100.0 • 6. *Eritettix simplex tricarinatus (Thomas) - 74.4 +181 .8 - 61.5 7. Melanoplus gladstoni (Scudder) - 75.0 + 57.1 - 25.0 8. *M. infantilis (Scudder) + 55.6 - 20.3 - 70.3 9. *M. sanguinipes (F.) - 3.8 - 14.0 + 28.6 10. *0 pe i a obscura (Thomas) + 33.3 + 73.1 - 31 .3 11. *Ph 1 ibost roma quadrimaculatum (Thomas) + — 64.7 — 50.0 12. Psoloessa del icatula delicatuia (Scudder) + 6.7 - 23.1 - 8S.7 13* Trachy rhachys kiowa (Thomas) +125.0 - C5 .6 - 55.5 14. Trimerotropi s campestris - 74. 5 - 87.5 - 62.5 (McNeil 0 15. T. gracilis sordida ('Talker) - 50.0 + 75.0 + 75.0 16. Xanthippus corallipes tuckelli (itebard) 43.2 + 50.0 - 10.5 Miscellaneous species - Ou. 1 + 11 .5 - 57.8 Total ' 22.3 12.o 60 .5 + and refers to percent increase and decrease due to treatment. * Economically important species on rangeland. V jl‘»w *.-/ LIVESTOCK As was previously mentioned, livestock grazing was a significant influence through- out trie stud/, data were gatiiered to determine cattle food and range use habits and to nelp evaluate data gatiiered from other phases of the study. These data are currently ueing analyzed and some general conclusions can ue drawn (Pyrah 1^75). Forbs and shrubs occasionally appeared to be preferred forage. Yellow sweet clover was used exclusively when it was available, and greasewood and silver sage- brusn was used late summer and early fall after grasses had desiccated. Food abundance or plant composition do not appear to be trie most important factors governing how cattle wi 1 1 use a pasture. Factors which nay be more important are water source, fence placement and social tradition. Cattle did not always appear to avoid areas simply Decause of the presence of sagebrush, nor did use of an area appear to increase simply because sagebrush had been removed. On strip sprayed areas no difference in use could be detected between the sprayed and unsprayed strips. On the total kill block spray, data were conflicting because of new fences and w'ater sources and disruption of traditional use patterns. On the King Study Area it was indicated that contour fur raving vias less desirable than total kill. Tuere was evidence this choice may have been related to greater forb abundance and/or composition on interseeded areas. Further data analysis may help clarify cattle range relationships and help put in proper perspective tneir role in tne ecology of other ecosystem components. DISCUSSION The sudden death of a major dominant species in a plant community sets off a chain of events that ultimately effects every component of the ecosystem. Some of these events are well understood, some are suspected, to exist, but probably many are unknown. Host studies following herbicide and mechanical treatments have Leen empirical in nature, measuring the gross changes in vegetation, but not attempting to determine the underlying intermediate events responsible for these changes. Until the basic chain of events following treatments are understood, results of studies in one habitat type cannot be safely extrapolated to others. The prime objective of sagebrush control programs is to increase grass and live- stock production. Results of such programs are viewed as beneficial or detrimental depending on how changes effect various facets of human society. Seldom are changes evaluated as to what is '‘good11 or "bad1' for the plant community itself. Sagebrush is a climax plant in many of the prairie habitat types; as such, it must be considered "good" for the plant community. Upon killing the sagebrush, a number of unanswered questions come to mind: 1. After spraying, most ecosystem nutrients are tied up in grass. V/ha t is tne long range effect on soil fertility and forage production of an increased rate of grass removal by livestock grazing? 2. The death of sagebrush plants results in a less of snow-stopping capacity of ranges in windy areas. ’.Jill this reduce 'the amount of moisture entering the soil on an annual basis, thereby reducing forage production? 3. The shading effect of sagebrush is removed. 7 ill the higher soil temperature cause more rapid evaporation and increased mortality of grass and forb seedlings? h. Do plant communities with deep-rooted plants make more efficient use of moisture and nutrients? Will the elimination of deep-rooted plants cause some moisture and nutrients to be lost to the system? 3. Soil under sagebrush plants appears to be more friable than between plants. Will the removal of sagebrush, with continued heavy grazing, ultimately result in a decline in overall soil permeability? One important question concerning 'wildlife comes to mind. -'hat are the long range effects of the loss of traditional range use habits and patterns? In game management it is practically axiomatic tnat wild animals are presently utilizing tae oest iiabitat resourees available to them and that any change from the present would probably be to a less desirable situation. f n ■■ • \ Ubt; The assumptions underlying the objective of greater crass and livestock production should also be questioned: cattle do not necessarily prefer grass during all seasons, and just because an area is treated is no assurance tiiat cattle will convert the addi~ tional grass into pounds of red meat! w'tiile this study did net answer all the questions, results did suggest t ha t partial kill strip spray in small e locks would l.e a fair compromise for sagebrush rangelands scneduled for chemical conversion. rv"~\ (165) LITERATURE CITED Dayless, S. 1367- Winter ranqe use of pronghorn antelope in central Montana. (Fed. Aid in Wildl. Restoration Proj. W-38-R) . II. S. thesis, Montana State University, Bozeman. 65pp. Seeker, B.W. 1371. Pronghorn-cattle range use and food habits relationships in an enclose^ sagebrush control area (Job Prog. Rept., Fed. Aid in Wildl. Rest., Proj. W-105~R~7). M.S. thesis, Montana State University, 3ozeman . 37pp. decker, B.W. and Richard Wallestad. 1374. Effects of chemical Sagebrush Control on mule deer in the Missouri River breaks, Montana. In: Pyrah, D. and henry Jorgensen. Ecology of Sagebrush Control. Job Prog. Rep., Proj. No. W-l 05~R“5.. Mont. Dept, of Fish & Game. 123pp. Best, L.S. 1370. Effects of ecological changes induced by various sagebrush control techniques on non-game birds. (Fed. Aid in Wildl. Restoration, Proj. W-105-R-5) . M.S. thesis, Montana State University, Bozeman. 74pp. Cada, J.D. 1968. Populations of small mammals in central Montana with special reference to tentative sagebrush control sites. (Fed. Aid in Wildl. Res- toration, Proj. W-105-R). M.S. thesis, Montana State University, Bozeman. 52 pp. Campbell, R. B. 1370. Pronghorn, sheep and cattle range relationships in Carter County, Montana. M.S. thesis, Montana State University, Bozeman. 37pp. Cole, G.F. 1356. The pronghorn antelope -- its ranee use and food habits in central Montana with special reference to alfalfa. Montana Fish and Game Dept, and Montana Agri. Expt . Sta. Tech. Bull. No. 516. 63pp. and B. T. Wilkins. 1358. The pronghorn antelope -- Its range use and food .habits in central Montana with special reference to wheat. Mont. Fish and Game Dept. Tec.i. ^ull. ho. 2. 35pp. Couey, F.li. 1346. Antelope foods in southeastern Montana. i. / i 1 d 1 . Ucrnt. 10(4) :367. Eng, R.L. and P. Schl adwei 1 er . 1375. Sage grouse winter movements and habitat use in central Montana. J. /ildl. Manage. 36(1). 141 146. Feist, F.G. 1368. Breeding bird populations in relation to proposed sagebrush control in central Montana. (Fed. AiJ in Wildl. Resotration, Proj. W-105-R). !,.S. thesis, Montana State University, Bozeman. 33pp. Freeman, J.S. 1371. Pronghorn range use and relation to livestock in southeastern Montana. M.S. tiiesis, Mont. State Univ. , Bozeman. 45pp. iiewitt, G.3. and N.E. Rees. 13/4. Abundance of grasshoppers in relation to range- land renovation practices. Jour. Range Mgt. 27(2) : 1 36- 1 60. Jorgensen, ii.t. 13/4. Vegetation typing of the Yellow Water Triangle. In. Pyrah D. and henry Jorgensen. Ecology of Sagebrush Control. Joa Prog. Rep., Proj. .