APPLICATION PLAN FOR THE AERIAL SPRAYING OF PLANT PROTECTION

APPLICATION PLAN FOR THE AERIAL SPRAYING OF PLANT PROTECTION
PRODUCTS (DOTHISTROMA (RED BAND) NEEDLE BLIGHT CONTROL WITH
COPPER OXYCHLORIDE OR CUPROUS OXIDE) IN SCOTLAND
Applicant name and address:
Date: [APPLICANT TO ADD]
Dear Sir/Madam
REQUEST FOR APPROVAL OF APPLICATION PLAN TO AERIALLY SPRAY
PLANT PROTECTION PRODUCTS; AND REQUEST FOR PERMISSION TO
AERIALLY SPRAY IN ACCORDANCE WITH THAT APPLICATION PLAN
(SUBJECT TO IT GAINING APPROVAL)
I seek approval of the Application Plan below, to aerially apply plant protection
products to land at the locations detailed in the Appendix/ces to this letter.
APPLICATION PLAN
I will ensure that spray jobs are conducted in accordance with the following conditions:

The product to be applied shall be Cuprokylt (MAPP 00604), containing the
active substance copper oxychloride, authorised under NANUM 1447 of 2013.

Operators carrying out the aerial spraying will hold specified training
certificates. The certificate number(s) is/are: [APPLICANT TO ADD].

The Civil Aviation Authority Certificate Number(s) for the aircraft undertaking
the spray is/are: [APPLICANT TO ADD].

A combination of the best available technology and spraying technique will be
used to minimise drift from the target (pine needles) to the forest floor and other
non-target areas.

GPS equipment will be used to identify spray areas and record the spraying
activity. The width of the boom, ie the distance between the outer atomisers,
will not exceed 80% of the rotor diameter of the aircraft. Microair rotary
atomisers will be used to produce a spray with VMD of 65 µm. Vanes and flow
rates will be calibrated prior to, and monitored during, the spray operation.
Flow meters will be used and if possible the atomiser rotation monitored during
application (if this is not possible spraying will only take place when the
calculated airspeed is achieved).

Spraying will be done in the maximum acceptable windspeed commensurate
with flight safety at a height of 4-6 metres above the canopy. Higher wind
speeds increase turbulence, keeping droplets suspended in the canopy for
longer. Spraying is not acceptable in windspeeds at release height above 10
Chemicals Regulation Directorate – Protecting the health of people and the environment
knots, because of the increased risk of off target drift. Spraying will also be
done when the wind is blowing away from any sensitive areas.
I will ensure that the landowner is aware of, and ensures that spray jobs are
conducted in accordance with, the following conditions:

Appropriate measures are put in place to forewarn members of the public in
good time where areas are to be treated (for example, the use of robust and
legible warning signs at an appropriate distance);

That spraying to protected areas is done in accordance with the terms of any
existing nature conservation consent or management agreement which
specifically covers aerial spraying. Spraying shall comply with any additional
conditions identified by HSE as necessary and attached to any Permit issued
following consideration of this Application Plan;

Measures necessary to comply with the Water Framework Directive and to
protect drinking water are applied.

All surface water bodies, wells, boreholes and springs will be protected by a
minimum 100 metre no-spray zone.

Scottish Water and the relevant local authority shall be consulted at the same
time as submission of the Application Plan. Where they have stipulated
additional mitigation measures these shall be put in place. Scottish Water also
to be notified prior to spraying in the cases of concern to them.

Avoid copper build-up in the environment through faulty equipment. (Excessive
copper is toxic to livestock).

All pipe-work on the tank/aircraft must be examined to make sure that it is in
good condition and does not leak.

Assess levels of copper before and after spraying in the soil and vegetation, in
the spray area and up to 100m from edges of sprayed area.

Aircraft operators must have experience at flying between 4 and 6 metres
above the trees and be able to recognise when excessive turbulence (caused
by increasing wind speeds) results in unsafe aircraft operation.
I will ensure that the pilot is aware of, and ensures that spray jobs are conducted in
accordance with, the following conditions:

Aircraft are maintained at a:
-
Height of not less than 200 feet from ground level when flying over an
occupied building and its curtilage;
-
Horizontal distance of 60m from any occupied building and its curtilage,
children’s playground, sports ground, or building containing livestock. This
may be reduced to 30m with the express written consent of the occupier;
and/or
-
Height of not less than 250 feet above ground level over any motorway and
not less than 100 feet above ground level over any public highway. This
restriction does not apply if the motorway or public highway has been
closed.
2

Spraying outside a protected (nature conservation) area will have a 100m
precautionary buffer zone along the boundary of the protected site, unless
advised otherwise as a result of HSE’s consideration of this Application Plan.
SUPPORTING DECLARATION
In support of the above Application Plan, I declare that:

The following range of alternative methods of control have been considered
and deemed inappropriate:
- Hand spraying is unsuitable due to the size and extent of the area to be
sprayed (5ha). The heights of mature pine trees are too great to apply
fungicide by hand; aerial application is the only way to effectively spray all
foliage.
AND/OR
- Aerial application offers advantages in terms of minimising risks to human
health due to the sloping or uneven terrain in remote locations, which make it
unsuitable for land-based application. The topography would significantly
increase the risks to operators which are associated with handling of the
equipment, handling and storage of chemicals and washing of equipment;
- Aerial spraying of copper oxychloride and cuprous oxide fungicides on mature
pine species to reduce impact of dothistroma (red band) needle blight has been
very effective in other countries, eg New Zealand.

The information contained herein is true and reflects my best understanding of
the circumstances relating to these spray jobs at this time;

I will advise HSE of any circumstances which may necessitate the review,
withdrawal or amendment of the Application Plan or spray jobs permitted under
it, in the event that I obtain approval of this Application Plan and permission for
those spray jobs from HSE.
I understand that it is an offence to:

make a false declaration for the purposes of obtaining a permit to apply plant
protection products from an aircraft;

undertake an aerial application which does not comply with an approved
application plan or any permits granted under it.
Yours faithfully
3
Appendix A
Land neither in nor within 500m of a protected area
Applicant
Ref
County
Map refs
Provisional date and time
Amount to be applied
(kg)
4
Appendix B
Land covered by SEARs clearance
Applicant
Ref
County
Map refs
Provisional date and time
Amount to be applied
(kg)
5
Appendix C
Land covered by a Rural Development Contract or Management Agreement referring to bracken control
Applicant
Ref
County
Map refs
Provisional
date and
time
Amount to be applied
SSSI only
SSSI & Natura
site
Natura site
only
(kg)
Tick (√ ) one of these boxes only
6
Appendix D
Land not covered by a Rural Development Contract or Management Agreement referring to bracken control
Applicant
Ref
County
Map refs
Provisional
date and
time
Amount to be applied
SSSI only
SSSI & Natura
site
Natura site
only
(kg)
Tick (√ ) one of these boxes only
7