Title: John W
Author: FSDefaultUser
Company: USDA Forest Service

John W. Taylor, Jr.
IPM Specialist
Forest Health Protection
State and Private Forestry
Southern Region
Suite 862 S
1720 Peachtree St, NW
Atlanta, GA 30309
404-347-2718-office
404-909-0270-cell
404-347-1880-fax
jwtaylor@fs.fed.us

We have some concerns with the EPA's proposed label 
changes for the Sevin XLR label, particularly the "bee caution" portion. 
Our concern is that if the label on the XLR product is changed to the same 
wording used on the other carbaryl labels, as  EPA intends to, all 
forestry uses, including poplar/cottonwood plantation treatments in the 
Midwest and bark beetle treatments in the Western US, will be excluded 
since the wording will prohibit applications when "bees are visiting the 
treatment area", as opposed to "foraging in the treatment areas" as on the 
current XLR label, at any time weeds are flowering. The term "visiting" is 
so general that I would not be comfortable recommending Sevin XLR for use 
on any forestry sites since technically the applicator could be in 
violation if bees (of any genera or species, not just the honeybee) could 
be found on the treatment site when flowers are present (which could be 
virtually any season in parts of the South and West). Since carbaryl is 
the only product presently labeled and efficacious for bark beetles on 
forest sites in the western US,  and is the primary control for Cottonwood 
Leaf Beetle in poplar/cottonwood plantations in the South and Midwest, we 
are very concerned about this change. Implementation of the proposed 
wording will essentially, in my opinion at least, remove Sevin XLR as a 
tool for managing forest insect pests when any blooming plant is present 
on the treatment site.