Talking Points for NAAA Member Use in Drafting Personal Comments
On EPA’s Draft Spray Drift Guidance
Environmental Protection Agency
Office of Pesticide Programs (OPP)
OPP Docket
EPA Docket Center (28221T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001
RE:
Guidance Documents for Consideration of Spray Drift in Pesticide Risk Assessment
Docket ID: [EPA-HQ-OPP-2013-0676]
[Send a letter using your own words to describe your business. Use your company logo]
1. [My experience]: I have been in the aerial application business for many years and take pride in the quality
of the work I do. I have _________ years and ______ hours of agricultural aerial application experience. In a
typical season, I will treat ________ acres. My applications are typically in the states of _______, ________
and _______ and I treat the following crops: __________________. In addition to crop pests, in a typical
year I’m also involved in the control of pest control for (public health), (ranching) and (forestry). I treat large
areas when timing matters most to my customers and their need to control pests, often when fields are too
wet, too remote, or otherwise inaccessible for ground applications.
2. [Proper planning and aircraft set-up]: Best practices that minimize spray drift are a critical part of my
business. My day starts with a check of my aircraft set-up, including nozzle choice, nozzle angle and
alignment on the boom, and checking my application equipment. Loading of the spray tank mix is a critical
step. I verify product label requirements and treatment conditions of the application agreement we have with
our customers, review maps of the fields to be treated, and identify the environmental and safety criteria that
will come into play during the treatments. I verify the weather report and schedule my applications during the
hours of the day when wind and turbulence is expected to be minimal. All of this occurs before we take off
for the aerial application job.
3. [Careful application]: When I arrive at the application site, it’s important to circle the field and verify the
accuracy of pre-flight information, locate the up-wind edge of the field, determine wind speed and direction,
and adjust for swath offset. I use vegetable-oil smoke trails, GPS and on-board meteorological equipment.
Working from the upwind side of the field and using advanced techniques such as half-boom shut off and
slowing near field edges, I minimize the production of fine droplets and limit the need for a downwind buffer.
4. [Participate in continuing education programs and aircraft calibration clinics]: I participate in Operation
S.A.F.E. (Self-Regulating Application and Flight Efficiency) fly-in clinics to evaluate my aircraft set-up,
nozzle selection and calibration, boom adjustment, and application efficiency. In fact, I recently attended a
clinic on _________ to calibrate my aircraft. The clinic analysts verify spray pattern, droplet size, and
calibrate the aircraft performance. Many pilots are experienced in the use of USDA-ARS spray-nozzle
models and AgDISP to assist in routine adjustments of their aircraft as part of pre-flight planning to minimize
drift. USDA-ARS scientists and university extension specialists are readily available to assist in pilot efforts
to determine effects on drift and deposition efficiency of potential aircraft setup changes. These models allow
assessment of many variables that can affect drift, such as nozzle selection, spray pressure, nozzle angle,
boom length versus wingspan, swath adjustment, adjuvants and tank mix variables, ground speed, release
height, and other factors.
I also participate in spray drift reduction training such as the EPA supported Professional Aerial Applicators’
Support System (PAASS) program offered by the National Agricultural Aviation Research and Education
Foundation. PAASS improves my understanding of the causes of spray drift and introduces me to cutting
edge technologies and techniques to mitigate drift and make more effective aerial applications. In addition,
NAAA’s annual meeting agenda routinely includes technical sessions by academics, government experts, and
consultants on drift-reduction planning and best practices.
5.
[EPA’s DRT Program should come first]: Effective DRTs and application methods minimize spray drift.
Before EPA implements policies and no-spray buffer requirements, EPA should implement its DRT Program
to support continued DRT development and DRT use in product labels. Product labels should give pilots the
flexibility to adjust application methods for the conditions experienced on a particular day at a particular site.
Canada’s application regulatory program works well that way; the U.S. program would too.
I take great pride in what I do in treating my farmers’ crops. I am also very concerned about the environment. If I
don’t take care of both I will be out of business. I have years of experience in caring for both and know my
aircraft, my pilots, how to use my application equipment and read meteorological conditions to ensure I keep
applied product on the target field.
Thank you for considering my comments.
Sincerely,
NAME
OPERATION
CITY, STATE