July 20, 2012
Office of Pesticide Programs (OPP)
Regulatory Public Docket (7502P)
Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460-0001
Re: Document ID: EPA-HQ-OPP-2012-0365-0001
The North Dakota Stockmen's Association is an 83-year-old trade organization representing nearly 3,000 cattle ranchers in North Dakota. Prairie dog management has been a priority issue for the North Dakota Stockmen's
Association for decades.
Thank you for this opportunity to comment on the proposed amended labeling for Rozol Prairie Dog Bait.
Black-tailed prairie dogs negatively impact North Dakota rangelands, destroying grasses and leaving soil vulnerable to erosion and weed invasion. The animals also can host vectors that carry diseases threatening to humans nd other mammals. Obviously, rangelands serve as the foundation of our livestock operations and our businesses. That¹s why cattle ranchers need effective management tools to control prairie dog populations, which have > grown in the recent past and continue to be a challenge as we, as range managers, balance for a healthy and diverse ecosystem.
Rozol is one of the most effective tools amongst the limited options cattle ranchers have to use in controlling prairie dog populations. Without safe, effective, affordable tools, prairie dog populations will either go unchecked and their range-destroying impacts will be exacerbated or cattle ranchers and other landowners will have to resort to more dangerous options for prairie dog control, such as propane or anhydrous ammonia techniques.
We have reviewed the proposed label language and find the label instructions, including those for carcass searches and collection, to be reasonable and acceptable for livestock producers. We do urge the Environmental Protection Agency, however, to consider expanding the approved application method to include mechanical application of Rozol Prairie Dog Bait, in addition to the manual hand application that is currently suggested. While hand application may be acceptable in small, newly established towns, many prairie dog towns cover many, many acres and hand application only would be difficult to accomplish in an efficient manner. We believe that allowing mechanical application, wherein the product could be applied by sticking a tube down the prairie dog burrow from an All-Terrain Vehicle or another device, would minimize the time burden of application without any negative environmental effects.
Please consideration these comments as you make the final decision regarding the Rozol label. North Dakota cattlemen and cattlewomen are eager for this product to be reinstated so they can use it to control prairie dogs this season.
Thank you for this opportunity to comment.
Julie Schaff Ellingson
Executive Vice President
North Dakota Stockmen's Association
407 S 2nd St., Bismarck, ND 58504