tion with EBIs allows at least 10-day intervals between 

 fungicide applications, which is at least 3 days longer 

 than with any other fungicide. This program substan- 

 tially reduces the overall fungicide load in an orchard. 



It should be obvious why IPM growers, consult- 

 ants, and researchers are distressed at the loss, at least 

 temporarily of EBDCs. Without the EBDCs, we can 

 confidently predict that overall fungicide use will in- 

 crease in New England in 1990. Miticide use will also 

 increase. The irony of the situation appears even more 

 acute when we consider that the most important IPM 

 use of EBDCs occurs before bloom, before fruit forma- 

 tion, and therefore before any possibility of residue 

 being deposited on the harvested crop. A related article 

 in this issue indicates that EBDC residue is probably 

 not a problem when applications are made early in the 

 season. 



For these reasons, regaining some apple uses for 

 the EBDCs is most desirable. The EBDC fungicides 

 provide several specific and important management 

 options in apple IPM. Specifically, they can be used 

 with oil, allowing mite biocontrol. They also allow the 

 EBIs to be used in so-called "extended interval" pro- 

 grams, which reduce the amount of fungicide per sea- 

 son. They allow extended intervals during the sum- 

 mer. In reality, the only effective, broad-spectrum 

 fungicide left for apples is captan, in spite of its limi- 

 tations. 



We hope that two points have emerged from this 

 work: 



1. Present regulatory efforts to reduce risks from 

 fungicides aim at the identification and elimination of 

 "bad actors," or the individual compounds that appear 

 likeliest to endanger human health. This narrow 

 approach will frustrate real-world efforts to reduce 



fungicide use, because it limits growers' ability to ex- 

 ploit the subtle but important differences between 

 similar compounds. When the benefits of a compound 

 are considered, its value in reducing the use of other 

 compounds and the overall ecological effect of such re- 

 ductions should be part of the consideration. Con- 

 versely, how the removal of compounds may increase 

 the overall use of similar fungicides, or even other 

 pesticides, should be considered. Regulators must look 

 more closely at how the use of each compound relates 

 to the use of all pesticides. The effect of the loss of the 

 EBDCs on New England apple IPM sharpens these 

 points painfully. 



2. Growers and researchers must put themselves in a 

 better position to inform regulators about the various 

 compounds that come under regulatory scrutiny. The 

 apple industry must perform a use-pattern survey 

 similar to the preliminary study also presented in this 

 issue, but covering the complete range of compounds 

 and apple ecosystems. Such a study, combined with 

 data on residue, disease damage, and arthropod dam- 

 age, would greatly expand our own knowledge of our 

 chemical use, while enabling us to provide EPA with 

 the sort of information the agency needs to regulate 

 wisely. 



We growers and agricultural researchers can, by 

 studying our own work, contribute sound information 

 to the regulatory process. If we do, we are likely to be 

 able to retain the use of some valuable tools. We might 

 yet defend our use of EBDCs successfully, if we are 

 quick and willing to accept or even propose stricter 

 limitations on their use. We must stop reacting after 

 the rules are written and start helping to write the 

 rules. 



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Fruit Notes, Winter, 1990 



21 



