### 1 Section 18 Application

– S ulfoxaflor (Transform WG Insecticide )

Tennessee Cotton

Submitted by the Tennessee Department of Agriculture

Type of Exemption

- Tennessee Section 18; Specific Exemption Request; April 4, 2016 . This is an application for a specific exemption to authorize the use of Sulfoxaflor (Transform WG Insecticide EPA Reg. No. 62719

- 625) to control tarnished plant bug in cotton.

(1) Identity of contact persons

.

(i) Tennessee Department of Agriculture

John Ew ell, Product Registration and Insurance Supervisor Regulatory Services, Tennessee Department of Agriculture Ellington Agricultural Center

, P.O. Box 40627 Nashville, TN 37204
Office: (615) 837

- 5340

Fax: (615) 837

- 5335
Email: john.ewell@tn.gov

Kathy Booker, Pesticide Administrator Regulatory Services, Tennessee Department of Agriculture Ellington Agricultural Center

, P.O. Box 40627 Nashville, TN 37204
Office: (615) 837

- 5133

Fax: (615) 837

- 5335
Email: kathy.booker@TN.gov

(ii) University and r egistrants contact s :

Scott D. Stewart, Professor and IPM Coordinator Department of Entomology & Plant Pathology
West Tennessee Research and Education Center 605 Airways Blvd
Jackson , TN 38301
Office: 731

- 425

- 4709
Cell: 731

- 267

- 6085
Email: sdstewart@utk.edu

Tami Jones

- Jefferson U.S. Regulatory Leader

, U.S. Regulatory & Government Affairs

– Crop Protection Dow AgroSciences
9330 Zionsville Road Indianapolis IN, 46268
Tel: ( 317 ) 337

- 3574
Email: tjjonesjefferson@dow.com

### 2 Jamey Thomas US Regulatory Manager Dow AgroSciences
9330 Zionsville Road Indianapolis, IN. 46268
Office: (317) 337

- 4138
Email: jdthomas@dow.com

(2) Description of the pesticide.

Common chemical name (active ingredient): Sulfoxaflor
Brand name: Transform WG (EPA Reg. No. 62719

- 625 )
Formulation: 50WP
Manufacture r: Dow AgroSciences

(A) A co nfidential statement of formula.

A confidential statement of f ormula has been previously submitted to EPA with the Section 3 registration package for Transform WG (GF2372, active ingredient sulfoxaflor). Transform WG is
a WDG formulation of the active ingredient sulfoxaflor.

(B) Complete labeling to be used in connection with the proposed exemption use.

The proposed label is included in this submission as Attachment A

.

(3) Description of the proposed use . The application shall identify all of the foll owing:

(i) Sites to be treated, including their locations within the State:

The insecticide will be restricted to use on cotton fields within the state of Tennessee for the purpose of controlling the tarnished plant bug, Lygus lineolaris (Palisot de Beauv ois). Historically, almost all cotton has been produced in the counties of Dyer, Lauderdale, Shelby, Tipton, Carroll, Chester, Crockett, Fayette, Gibson, Hardeman, Haywood, Henderson, McNairy, Madison, Giles and Lincoln ( Attachment B

, USDA NASS 20 14 County Estimates for Tennessee, http://www.nass.usda.gov/Statistics_by_State/Tennessee/Publications/County_Estimates/Cott on14_TN.pdf ).

(ii) The method of appl ication:

Foliar ly applied by air or ground

(iii) The rate of application in terms of active ingredient and product:

1.5

- 2. 25 oz product/acre (0.047

- 0.0 71 lb AI /acre). Annual use will not exceed 0. 266 lbs active ingredient per acre (8.5 oz product/acre)

.

(iv) The maximum number of applications:

### 3 Four applications per acre per year

(v) The total acreage or other appropriate unit proposed to be treated:

The National Cotton Council’s annual Cotton Planting Intentions survey estimates that Tennessee
will plant 193,000 acres in 2016 , and if realized, this would be up 25% from 2015. However, current economics and grower comments indicate this number could increase to ≈ 2 25,000 in

201 6

. Tennessee has the potential need to treat 168,750 acres (7 5 % ) of this acreage with sulfoxaflor for control of tarnished plant bug. This assessment is based on estimates of the IPM Extension Specialist (Stewart) , agricultural extension a gents, and selected consultants that 50

- 7 5 % of these acres could experience serious Lygus infestations requiring three or more applications of insecticide , and it is these situations where Transform WG is most needed

. During recent years, three or more ap plications specifically targeting tarnished plant bug are needed on a majority of the acres (e.g., Fig. 1).

Figure 1. Survey results from 2014 (bottom) and 2015 (top) of independent crop consultants in West Tennessee showing individual respons es and the average (Avg.) number of foliar Consultant Identifier

Consultant Identifier

### 4 insecticide applications made per acre and the number specifically targeting tarnished plant bug (TPB)

.

(vi) The total amount of pesticide proposed to be used in terms of both active ingredient and product:

Tarn ished plant bug, Lygus lineolaris (Palisot de Beauvois)

, infestations may caus e economic
losses o n all acres , but emergency use will be restricted to 168,750 acres in Tennessee during

201 6

. No more than four applications, and likely two or less, would be required to reduce the

im pact of this pest

. Seasonal use restrictions prohibit more than four applications and 8.5 oz of total product use per acre (0.266 lb ai/acre). Thus, the maximum amount of insecticide that c ould
be applied is 89,648 lb formulated product or 44,824 lb active ingredient

.

(vii) All applicable restrictions and requirements concerning the proposed use which may not appear on labeling:

Refer to the Transform® WG container label for first aid, precautionary statements, directions for

us e and conditions of sale and warranty information. It is a violation of federal law to use this product in a manner that is inconsistent with all applicable label directions, restrictions and precautions found in the container label and this supplemental l abel. Both the container label and this supplemental section 18 quarantine exemption label must be in the possession of the user at the time of application.

Applicable restrictions and requirements concerning the proposed use and the qualifications of app licators using Transform® WG are as follows:

• Pre

- harvest Interval: Do not apply within 14 d ay s of harvest.

• Minimum Treatment Interval: Do not make applications less than 5 d ays apart.

• Do not make more than four applications per acre per season.

• Do not ma ke more than two applications during the bloom period.

• Do not apply more than a total of 8.5 oz. of Transform WG (0.266 lb AI of sulfoxaflor) per

acre per year.

• Label must include a pollinator advisory statement including but not limited to the following:

o If known apiaries are within one mile of cotton fields intended for treatment, applications should be made within three hours of sunset during the flowering period.

o Prior to use of Transform WG, growers and the beekeepers hosted on their farm are
advised t o implement cooperative standards as drafted in the Tennessee Pollinator
Conservation Plan

.

• Before Transform WG can be used tarnished plant bug densities must reach or exceed thresholds published in UT Extension’s Insect Control Recommendations for Cotton, PB

1768 ( Stewart and McClure 2016) where populations are equal to or exceed t han 1 5 insects per 100 s weeps or 3 per 5 row f ee t on a drop cloth.

(viii) The duration of the proposed use:

June

- September of the 201 6 cotton growing season

### 5 (ix) Earliest possible harvest dates:

September 1 5 , 201 6

(4) Alternative methods of control. The application shall contain: (i) A detailed explanation of why the pesticide(s) currently registered for the particular use proposed in the application is not available in adequate supplies and/or effective to the degree n eeded to control the

emergency.

In secticide Resistance: Pyrethroids Presently, numerous insecticides are recommended against tarnished plant bug, but varying levels of resistance has been documented to nearly every class of these compounds among
Midsouthern (Arkansas, Louisiana, Mississipp i, Tennessee) populations of this insect. Populations have demonstrated resistance to pyrethroids (Snodgrass 1996, Snodgrass and Scott 2000) since
the mid

- 1990 s. Currently, none of the pyrethroids are recommended for tarnished plant bug
control in the Ten nessee because resistance to this class has become widespread and field experiments show poor control

. A summary of all trials conducted at the Delta Research and Extension Center in Stoneville Mississippi from 2004 to 2010 revealed that control with the

p yrethroids ranged from 0 to 47% control. In general, bifenthrin (ex. Brigade) showed better activity against plant bugs than other pyrethroids, but control was still less than adequate (Figure

2 ). In Tennessee, data from multiple insecticide efficacy tri als are published on the internet at http://www.utextension.utk.edu/fieldCrops/MultiState/MultiState.htm

. In recent years, these trials show applications of synthetic pyrethroids provide less than 30% control of tarnished plant bugs , which is inadequate against even moderate populations . Please see examples in figu res 2
and 3 or refer to other data published online.

Figure 2. An experiment done in Tennessee during 2014 showing inadequate control of tarnished plant bugs with pyrethroid insecticides including DoubleTake (bifenthrin + diflubenzuron)

, Mustang Max, and Hero. It also shows the inadequacy of other ins ecticide classes such (e.g.,

### 6 Athena, Carbine, Brigadier ). Ratings are shown for 5 and 6 days after the first and second application, respectively (α = 0.05).

Figure 3

. Yield data from a season long cotton experiment performed in w est Tennessee during 2010 against tarnished plant bug and stink bug infestation on Bt cotton ( Madison Co. ). Data do not include sulfoxaflor but show the relative inactivity of Brigade (bifenthrin), Carbine (flonicamid), Trimax Pro (imidacloprid) and Intruder (acetamiprid); resulting in a statically significant yield loss ranging from 19

- 29% after five applications of each compound (P < 0.05).

Use rate is indicated on the x

- axis (oz product/acre except acephate which is lb ai/acre ).

Insecticide Resistance : Organophosphates and Carbamates

More recently, resistance has been documented to several organophosphates (Snodgrass and Gore 2007, Snodgrass et al. 2009 ). Acephate has been the most widely used and effective insecticide for control of plant bugs in cotton but efficacy continues to decrease i n much of the
Mid

- South

. For the purpose of measuring tarnished plant bug resistance to organophosphates, acephate has been used in bioassays to represent the entire class because it is the most utilized for field control. For the most part, populations t hat show greater than 3

- fold levels of resistance to acephate also have high levels of resistance to dicrotophos ( Fig

. 4 ). Figure 4 shows the resistance ratios ( gray bars) for Baythroid (pyrethroid), Bidrin (OP), Orthene (OP), and Vydate CL

V (carba mate ) for tarnished plant bugs. This particular population shows high levels of cross resistance to all classes of insecticides evaluated. The black bars show percent mortality of tarnished plant bugs caged on cotton plants sprayed with field use rates of ea ch of the insecticides. In all cases except Vydate, the highest labeled rate was used. None of the insecticides provided greater than 48% mortality at field use rates. Additionally, preliminary research suggests that there are multiple mechanisms of res istance to the OP’s. There appears to be populations with target site insensitivity and metabolic resistance. Most of the plant bug populations across the Mississippi River Delta express target site insensitivity, which confers cross
resistance to the ot her organophosphates and carbamates. Populations that only have metabolic resistance do not always exhibit cross resistance with other insecticides and the cross resistancePounds / Acre 

## Lint

500 600 700 800 900 1000 1100 1200 1300 1400 1500

a a a a a a ab bc bc bc c d

### 7 appears to be linked to the specific enzymes involved. Although not tested, a simi lar situation likely exists in Tennessee. Vydate had sometimes perform adequately in Tennessee at rates at or above 12 oz/acre (e.g., Fig. 3 ), but other times provides inadequate control when used by itself or as a tank mix partner at reduced rates , similar as to reported in other states

. R egardless, DuPont
has reported a serious breakdown at the plant where Vydate is manufacture d , and it appears this
insecticide will only be available in limited quantities during 2016.

In the Mid

- South, field efficacy with both acephate and dicrotophos has declined in recent years. Table 1 provides a summary of results from insecticide screening trials conducted by Mississippi State University personnel at various locations across the Mississippi Delta from 2005 through 2010. In 2005, acephate and dicroto phos provided 84.0 and 79.3 percent control, respectively. By 2010, control declined to 45.8 and 28.2 percent control, respectively, for these insecticides. Similar results were seen for yield losses attributed to tarnished plant bugs over that same time period (Table 1). In West Tennessee, resistance monitoring efforts (Table 2) also indicate the presence of resistance to organophosphate insecticides (i.e., acephate or methamidophos) in 9 of 16 populations collected during 2006

- 2011. Although some OP in secticides such as dicrotophos and acephate still provide adequate control in some circumstances, the level of control is declining and label restrictions and resistance management guidelines limit their utility. Tank mixing with
other modes of action is typically recommended to achieve adequate control when severe infestations of tarnished plant bug are encountered.

Figure 4 . Resistance ratios and control of Lygus with multiple classes of insecticides (AR, LA and MS Delta).

With these levels of contr ol, growers commonly experience field control failures with all of the organophosphates currently labeled for tarnished plant bug control in most d elta environments of the Mississippi River and adjacent counties

. In W est Tennessee , organophosphates are usu ally applied in a tank mix with another class of insecticide. 18

7 3.6 3.6 4.8 0 25 44 39 48

20

8



### 0 10 20 30 40 50 60 70 80 90 100

Baythroid (2.6) Bidrin (0.5) Orthene (0.5) Orthene (1.0) Vydate (0.33) UTC RR Percent Mortality 

### Percent/RR

### 8 Table 1. Average (Standard Error) percent control and yield for Acephate and Dicrotophos from trials conducted in Stoneville, MS from 2005 to 2010 and percent yield reductions compared to

200 5. Acephate Dicrotophos

Year %
Control Yield (Lint/A) % Yield
Reductio

n % Control Yield (Lint/A) % Yield
Reduction

2005 84.0 (5.0) 1342 (47.4)

--- 79.3 (5.8) 1374 (78.6)

--- 2006 81.7 (3.8) 1213 (131.3) 9.6 83.3 (3.5) 1149 (129.8) 16

2007 83.5 (3.7) NA NA 86.0 (2.6)

--- --- 2008 71.6 (2.7) 946 (60.5) 29.5 67.0 (3.1) 936 (93.4) 31.9

2009 55.8 (5.7) 676 (92.6) 49.7

--- --- --- 2010 45.8 (2.3) 984 26.6 28.2 (4.3) 970 (77.0) 29.4

P <0.01 <0.01 <0.01 <0.01

Table 2. Summary of acephate or Monitor (methamidophos) resistance assays for Lygus collected
from west Tennessee. Bolded numbers indicate populations that exceeded predefined resistance threshold (< 75% mortality with a discriminating dose of methamidophos or an LC50 val ue for acephate > 7.5).

Year Collection Site (County) Discriminating Dose (% Mortality) LC50 u g Methamidophos Acephate

2006 Haywood* 86

--- Lauderdale* 90

--- Madison* 98
Gibson* 98

--- Crockett 60 4.92 Dyer 86

2007 Haywood* 72 7.22
Lak e* 88

--- Madison* 68 9.62 Dyer 96 10.53
Crockett 90 4.89 Tipton 88 10.64

2008 Crockett

--- 11.03
Madison

--- 7.82 Tipton

--- 9.43

2011 Madison

--- 10.0


### * Spring or early summer samples (other samples were made late summer).

Insecticide Resistance: Neonicotinoids The neonicotinoid class of insecticides is recommended for both tarnished plant bug control in

Tennessee . The insecticides in this class have historically only shown marginal control of tarnished plant bug following first flower when the most serious Lygus infestations typically occur

. This has

### 9 especially true of acetamiprid and imidacloprid (e.g ., Fig. 3 )

. Acetamiprid (Intruder or Strafer ) is rarely tested because its performance is generally too poor to be considered for tarnis hed plant bug control. Very little acetamiprid is used except as a tank mix partner when aphid infestations are also present.

Among the neonicotinoids, t hiamethoxam (Centric) is more active insecticide against tarnished plant bug

. However, t he Universit y of Tennessee ’s insect management guidelines for cotton (PB1768, http://www.utcrops.com/cotton/cotton_insects/pubs/PB1768

- Cotton.20pdf ) does not recommend using this cla ss of ch emistry after first flower as part of an ove rall resistance management plan, and because alternative insecticides or tank mixes often provide better
control

. This resistance management plan also suggest s avoiding the use of premixed insecticides

t hat also contain a neonicotinoid component (e.g., Endigo and Leverage). Seasonal use rate restrictions prevent more than 2

- 3 applications of thiamethoxam, either as Centric or as the premix Endigo formulation

. Table 3 and Figure 5 d emonstrate the poor performance of imidacloprid ( Trimax Pro, Couraze 4F or Admire Pro) and bifenthrin (Brigade)

. Table 5 also shows the relatively superior performance of sulfoxaflor (Transform) that is often observed

.

Endigo is a premix of thiamethoxam and lambda

- cyhal othrin and, prior to 2012

, was a top performing insecticide (e.g., Figure 3). There are now unpublished reports of resistance to thiamethoxam in some populations of tarnished plant bug 

### ( source: USDA ARS in Stoneville, MS)

. Data collected in Tennessee als o shows decreased efficacy of Centric or Endigo (e.g., Table 3 ).

Table 3

. An efficacy trial done in Tennessee during 2015 demonstrating the poor performance of Centric (thiamethoxam) and Strafer (acetamiprid). Note that Transform, Ort hene + Diamond, and
Transform + Diamond were the top yielding treatments in this test.

Formulation Appl

1 Strafer 70 % 3 oz wt/a ABC 2.5 bcd 5.8 bcd 24.5 ab 12.0 b 1432 cd

2 Strafer 70 % 3.5 oz wt/a ABC 1.8 cd 10.0 bc 12.0 cd 12.3 b 1466 a-d

3 Strafer 70 % 3 oz wt/a ABC 3.3 bc 5.3 cd 7.5 d 4.8 c-f 1616 abc

Diamond 0.8 lb/gal 6 fl oz/a ABC

4 Centric 40 % 2 oz wt/a ABC 4.3 b 7.8 bcd 26.5 ab 9.3 bc 1457 bcd

5 Centric 40 % 2 oz wt/a ABC 2.0 cd 7.5 bcd 15.5 bc 5.8 bcd 1597 abc

Diamond 0.8 lb/gal 6 fl oz/a ABC

6 Orthene 90 % 1 lb/a ABC 2.3 bcd 5.8 bcd 7.8 d 2.5 f 1593 abc

7 Orthene 90 % 1 lb/a ABC 1.0 d 6.0 bcd 8.3 d 2.3 ef 1736 ab

Diamond 0.8 lb/gal 6 fl oz/a ABC

8 Bidrin XP II 5 lb/gal 12 fl oz/a ABC 3.1 bcd 11.5 ab 10.8 cd 4.5 b-e 1512 a-d

9 Bidrin XP II 5 lb/gal 12 fl oz/a ABC 2.5 bcd 10.8 abc 9.5 cd 2.3 def 1680 abc

Diamond 0.8 lb/gal 6 fl oz/a ABC

10 Transform 50 % 1.75 oz wt/a ABC 1.8 cd 2.0 d 10.0 cd 2.0 def 1742 a

11 Transform 50 % 1.75 oz wt/a ABC 1.0 d 5.5 cd 9.0 cd 3.5 c-f 1696 abc

Diamond 0.8 lb/gal 6 fl oz/a ABC

12 Untreated A 7.5 a 16.5 a 28.0 a 31.5 a 1279 d
Means followed by same letter do not significantly differ (P=.05, LSD) Total TPB Lint (lbs/a) Total TPB Description Total TPB Total TPB

8/3/2015 10/12/2015 Rating Date 7/13/2015 7/20/2015 7/27/2015

Treatment Rate 6 DA-B 6 DA-C Trt-Eval Interval 5 DA-A 12 DA-A

### 10 Other Insecticides and A dditional Information
There are curre ntly only two other insecticide classes labeled for tarnished plant bug control. The first is flonicamid (Carbine)

, a pyridine cabo xamide. Although this insecticide does show activity against tarnished plant bugs and provides good control of western tarnished plant bug ( Lygus hesperus ), results hav e not been promising in the Mid

- South ( F ig. 5, Table 4 )

. Its primary use has been cases where cotton aphids are the primary target, as cotton aphids in Tennessee are now

resistant to neon icotinoid insecticides. Carbine ofte n provides only 50

- 60% control of Lygus or less

. Please refer to other e xample s of efficacy trials in Tennessee with C arbine a nd other previously discussed insecticide classes ( linked below). http://www.utcrops.com/MultiState/Trials/2014/tpb

- FMC%20General%20Cotton.pdf http: //www.utcrops.com/MultiState/Trials/2014/tpb

- Intruder%20Summary.pdf http://www.utcrops.com/MultiState/Trials/2013/FMC

- Athena

- tpb.pdf http://www.utcrops.com/MultiState/Trials/2013/FMC

- General

- TPB.pdf http://www.utcrops.com/MultiState/Trials/2012/TPB%20SkyR aider%20Cotton.pdf http://www.utcrops.com/MultiState/Trials/2012/TPB

- Athena

- Crooks.pdf

Figure 5

. Numbers of Lygus per 10 r ow feet following and 6 and 5 days following a first and second application , respectively . Data show how alternative treatments, including Diamond and Carbine, equal to competitive standards (Tennessee, 2010).

The data below shows the results for an experiment conducted in St oneville, MS in 2009. The data show the number of nymphs 5 days after the second application of each insecticide in an overall control program. A total of 7 insecticide applications were made to the entire field. Five of those applications were blanket ap plications applied across the entire field. Carbine did not reduce tarnished plant bug densities below that observed in the non

- treated control (Table 6 ). 0 2 4 6 8 10 12 14 16 18 20

6 DAT1 5 DAT2

### 11 Table 4

. Results from an experiment conducted in Stoneville, MS in 2009 on tarnished plant bug

.

Tr eatment Rate Nymph/5 ft.

Centric 2 oz/A 12.6 B
Bidrin 8 fl oz/A 9.4 B Acephate 0.75 lb AI /A 5.9 B
Carbine 2.8 oz/A 22.1 A

Non

- treated 24.3 A

The other insecticide is novaluron (Diamond), an insect growth regulator. Because novaluron is an insect g rowth regulator, it only controls the immature stages of tarnished plant bug and has no activity against adults. Field testing of this insecticide generally showed variable results in terms of tarnished plant bug control. In a trial co nducted in Sunflower county, MS in 2006, large
blocks of cotton on a growers farm were treated with Bidrin at 0.5 lb ai/A, Orthene at 1.0 lb ai/A, Orthene at 1.0 lb ai/A + Diamond at 0.04 lb ai /A, Bidrin at 0.5 lb ai/A + Diamond at 0.04 lb ai/A, and Diamond at 0.06 lb ai/A. Tr eatments were applied by ground with a high clearance sprayer and all treatments were replicated 4 times. The treatments were applied to an established population and pre

- treatment counts averaged 22.6 nymphs per 5 row ft. Two applications were
made 7 da ys apart. Seven days after the second application, tarnished plant bug densities in all of the treatments remained well above the action threshold of 3 bugs per 5 row ft, ranging from 7.2 for Orthene (1.0 lb ai/A) + Diamond (0.04 lb ai/A) to 15.6 nymphs per 5 row ft for Diamond alone (0.06 lb ai/A). Similar results were observed in other trials and by consultants and growers for the first few years that Diamond was commercially available. Other research has shown that Diamond is not very effective on la rge nymphs. In an experiment conducted in Stoneville, MS in 2007, fifth instar nymphs were exposed to cotton plants treated with a range of field use rates in a spray chamber. The nymphs were allowed to feed on the treated plants until they molted into
adu lts or died (Table 5 ). The percentage of nymphs that molted into the adult stage ranged from 47.8 at the highest labeled rate to 83.3 at the lowest rate tested. This combined with the rapid growth rate of tarnished plant bug makes timing of the application critical. Adverse weather conditions (rain, high wind, etc.) are common and can delay applications up to a week. In that time frame, susceptible stages of nymphs (1 st

- 3 rd Instars) have time to develop to less susceptible
stages.

Table 5 . Impact of Diamond insecticide (novaluron) on late instar tarnished plant bug nymphs in a controlled experiment in Stoneville, MS.

Treatment Rate Percent Adults

UTC

--- 96.7 A
Diamond 2 83.3 AB
Diamond 4 60.0 BC
Diamond 6 58.5 C
Diamond 9 69.7 BC
Diamond 12 47.8 C

Over the last several years, we have discovered better ways to use Diamond in an overall Lygus
management program. Research in the Mid

- S outh has shown that early preventative applications can help reduce the impact of tarnished plant bugs in cotton. Howev er, the timing of these

### 12 applications is critical and must target the egg s and early instar stage s . The difficulty in using eggs as a trigger is that tarnished plant bugs insert their eggs into plant tissue and are not visible in the
field. This combined wi th the difficulty in controlling late instar nymphs makes managing this pest with Diamond extremely difficult. Using Diamond preventatively in Tennessee, where the intensity and timing of Lygus infestations and timings varies considerably poses a real chal lenge. Treating large acreage where Lygus populations may not develop into severe infestations can lead to unnecessary insecticide applications. Additionally, control with Diamond against established infestations is typically less than adequate unless tw o applications are made or tank mixed with
other insecticides

. Like adult plant bugs, Diamond has no activity on adult stink bugs a nd this is
another reason it generally requires co

- application with other insec ticides. Fu r ther , Diamond is
hard on beneficial insect populations and often flares populations of aphids and spider mites ( e.g., Fig. 6 ). Of course, the same is also true of other altern ative insecticides, especially when repeatedly sprayed ( e.g., Fig. 7 ).

Figure 6

. Aphid “flaring” data from a season long cotton experiment performed in West Tennessee during 2010 against tarnished plant bug and stink bug infestation s on Bt cotton (Madison Co.). Data show how some competitive standards for tarnished plant bug control such as Vydate (oxamyl), Diamond (novaluron) and synthetic pyrethroids (e.g., Brigade) worsen ed infestations of secondary pests. Aphid infestations wer e ranked from 1 (low) to 4 (very high), P <

0.05. Use rate is indicated on the x

- axis (oz product/acre). 0.0 0.5 1.0 1.5 2.0 2.5 3.0 

### Aphid Rating, 1

- 4

a a b a a a a a a c c b

### 13 0 10 20 30 40 50 60 70 80 90

4 2 1 1 0
No. Applications (Bidrin or Orthene) Percent infested plants (7/25)

d c cd b a

0 2 4 6 8 10 12

3 1 0 0
No. Applications (Centric or Trimax) Mite hits per 600 row ft (6/26)

6/18 a

b b b 

### Early season Late season

Figure 7

. Spider mite “flaring” data from a study evaluating treatment threshold s for tarnished plant bug in West Tennessee during 2 007 (Lauderdale Co.) . Data show how some competitive
standards including neonicotinoids used early season ( Centric and imidacloprid such as Trimax, Admire Pro, etc. ) or organophosphates used during the flowering period ( Bidrin and Orthene )

,
worsen ed in fes tations of secondary pests. Insecticides were rotated as indicated where more than one application was made.

In some areas of the Mid

- South , tarnished plant bug infestations have reached outbreak levels and become uncontrollable. In Tennessee during 201 4 and 2015

, some consultants recommended an average of four or more insecticide applications per acre for tarnished plant bug (Fig. 1 ), and

s ome fields received as many as eight applications for this pest

. Current trends with insecticide
resistance and la ck of effective alternative technologies will allow problems with tarnished plant bug management to intensify. Chemical control options that provide consistent efficacy are not
available or have significant negative repercussions . Effective Lygus control is a serious, unmet
need for Midsouthern cotton growers and one that requires immediate and urgent action. This has now become an emergency situation.

These results have shown that regardless of the registered insecticide, tarnished plant bug populations in th e Mid

- South have become significantly more difficult to control using common
recommended i nsecticides (Lorenz et al. 2009, Moore et al. 2010). As a result, the numbers of applications and use rates needed to control Lygus have increased. With a nove l mode of action and chemical class, sulfoxaflor will successfully control both susceptible and insecticide

- resistant populations of tarnished plant bug, thereby improving the overall cotton IPM system. This is a tremendous economic opportunity for cotton growers, and more environmentally

- friendly alternative to the sustained frequency of the currently used products. T able 6 shows a study conducted in the Mississippi Delta where all of the currently registered classes of insecticides were
used in an overal l management progr am. In this trial, a total of seven applications were made. Each of the insecticides being tested were applied four times, but no more than two times in a row. Ratings of tarnished plant bug control were made after the underlined treat ments. These data show that none of the treatment programs provided consistent control of tarnished plant bugs over the entire season. As a result, yields for all of the spray programs were very low

### 14 compared to state averages in 2010. This experiment sho ws that an overall tarnished plant bug program is not feasible or economical for producers with the few insecticide classes tha t are currently labeled in the Mid

- South

.

Table 6 . Evaluation of tarnished plant bug management programs in the Mississippi Del ta in 2010.

Treatment 5 DAT 1
% Control 13 DAT 1
% Contro l 7 DAT 2
% Control 14 DAT 2
% Control 7 DAT 3
% Control 7 DAT 4
% Control Lint Yield

Vydate 0.33 lb fb Centric 2.5 oz
fb
Orthene 0.75 lb fb
Orthene 0.75 lb fb
Diamond 6 oz fb
Orthene 0.75 lb fb

Ort hene 0.75 lb 69 54 50 0 57 0 549

Vydate 0.33 lb fb Centric 2.5 oz
fb
Diamond 9 oz fb
Diamond 9 oz fb
Orthene 0.75 lb fb
Diamond 9 oz fb
Diamond 9 oz 60 72 0 31 62 73 482

Vydate 0.33 lb fb Centric 2.5 oz
fb
Bidrin 6 oz fb
Bidrin 6 oz fb
Diamond 6 oz fb
Bidrin 6 oz fb
Bidrin 6 oz 53 36 0 0 38 0 343

Vydate 0.33 lb fb Centric 2.5 oz
fb Vydate 10 oz fb Vydate 10 oz fb
Diamond 6 oz fb Vydate 10 oz fb Vydate 10 oz 31 0 75 0 72 0 343

Vydate 0.33 lb fb Centric 2.5 oz
fb
Centric 2 oz fb
Centric 2 oz fb

Diamo nd 6 oz fb
Centric 2 oz fb

Centric 2 oz 21 16 0 0 72 0 405

Vydate 0.33 lb fb Centric 2.5 oz
fb Endigo 5 oz fb Endigo 5 oz fb
Diamond 6 oz fb Endigo 5 oz fb Endigo 5 oz 19 12 0 0 26 67 567

Vydate 0.33 lb fb Centric 2.5 oz
fb
Trimax Pro 1.5 oz fb

Trima x Pro 1.5 oz fb
Diamond 6 oz fb
Trimax Pro 1.5 oz fb

Trimax Pro 1.5 oz 0 0 0 0 31 23 358

### 15 Vydate 0.33 lb fb Centric 2.5 oz
fb
Carbine 2.5 oz fb
Carbine 2.5 oz fb
Diamond 6 oz fb
Carbine 2.5 oz fb
Carbine 2.5 oz 0 40 0 0 18 0 405

Vydate 0.33 lb fb Centric 2.5 oz
fb Leverage 360 3.2 oz fb Leverage 360 3.2 oz fb
Diamond 6 oz fb Leverage 360 3.2 oz fb Leverage 360 3.2 oz 0 0 0 0 15 0 397

Vydate 0.33 lb fb Centric 2.5 oz
fb
Intruder 1.1 oz fb
Intruder 1.1 oz fb
Diamond 6 oz fb
Intruder 1.1 oz fb
Intruder 1. 1 oz 0 12 0 0 42 0 372

Vydate 0.33 lb fb Centric 2.5 oz
fb Brigade 5.12 oz fb Brigade 5.12 oz fb
Diamond 6 oz fb Brigade 5.12 oz fb Brigade 5.12 oz 0 24 0 17 38 0 312

Check NA NA NA NA NA NA 225 *Ratings start after 4 th application

(ii) A detailed e xplanation of why alternative practices, if available, either would not provide adequate control or would not be economically or environmentally feasible.

Several IPM strategies are recommended for controlling tarnished plant bug in cotton (Gore et al.

20 08 ). Non

- chemical tactics include area

- wide control of non

- crop alternate hosts. Proper
selection of early

- maturing varieties and managing the optimum planting period are being used to produce a rapid fruiting and early maturing crop; thereby reducing the time the crop is

su s ce p tibl e to this pest. Careful timing of insecticide application s based on revised spray action thresholds are used to precisely target populations before they reach outbreak levels. All of these practices are currently in place and are being used by cotton producers. However, these strategies only serve to suppress populations and are not effective as stand

- alone practices. Effective chemical control practices are still necessary to provide tarnished plant bug management in cotton. As highlighted above the current situation in Tennessee has produced severe economic burdens on cotton producers. The Midsouthern states have experienced greater reductions in cotton acres compared to other cotton producing regions of the country. The recent
increase in cost of tarnished plant bug control is an important reason for this decrease in cotton

acres

.

Currently, tarnished plant bugs have widespread resistance to the pyrethroids,

organo p hosphates, and carbamates. In the case of the organopho sphates, resistance is partially dominant. A recent study by Snodgrass and Gore showed that because the trait is not recessive,

### 16 resistance levels do not decline during the winter. Also, relevant genetics data suggests that gene flow can occur between popu lations that are up to approximately 10 miles apart. These factors have contributed to the rapid spread of resistance in much of the Mid

- South . Also, this makes predicting where the resistance levels will be highest from year to year extremely difficult. The widespread resistance to pyrethroids, organophosphates, and carbamates renders these insecticides nearly useless for economical cotton production. Over the last ten years, field use
rates have more than doubled and control has continued to decline. Th is has put a tremendous amount of pressure on the neonicotinoid class. Of that class, thiamethoxam is the most effective for tarnished plant bug control. Consequently, 1

- 4 preflower applications in cotton may target both tarnished plant bugs and cotton a phids. Centric (thiamethoxam) has been the insecticide of choice in this situation because it provides better control of the whole pest complex than other neonicotinoids at that time of the year. The most common rate used at that time of year is 2 oz
form ulated product per acre (0.05 lbs ai/A) . The maximum seasonal use rate for Centric is 5.0 oz (0.125 lb ai thiamethoxam). Therefore, two applications of Centric at 2 oz/A (0.05 lbs ai per acre per application) during the pre

- flowering period does not leav e enough active ingredient for later applications of either Centric or Endigo (thiamethoxam + lambda

- cyhalothrin). As already mentioned, recent evidence now shows decreased efficacy of Centric on tarnished plant bug. The only other labeled insecticides av ailable are Carbine (flonicamid) and Diamond (novaluron). As previously described, Carbine is not a reliable control option for Lygus in the Midsouthern states

. Diamond is the only other insecticide available for late season tarnished plant bug control. Diamond is an insect growth regulator that only controls the immature stages. Therefore, Diamond applications are exclusively used with another class of chemistry to control adults. Also, application timing is critical with this insecticide and applicatio ns are often sprayed too late to provide the most effective levels of control. Thus , the use of Transform WG will be important for alleviating some of the economic hardships that cotton growers in Tennessee are currently experiencing

.

As expected and pre viously mentioned, the excessive use of some products for tarnished plant bug are now beginning to induce additional pest problems (spider mites and cotton aphids) in

some areas . T here is a strong correlation between the number of applications targeting t arnished plant bugs and other pests such as cotton aphids and /or spider mites ( Fig s

. 6

, 7 and 8 ). Problems
with th ese secondary pests have subsided this past 3

- 4 years , much to the credit of using
Transform i n IPM program. The loss of Transform is of great concern to produc ers and pest management practitioners. Organophosphate, carbamate and pyrethroid insecticides can impact natural beneficial arthropod populations and flare secondary insects. Acephate is commonly used for Lyg us control and can flare aphids, mites , and bol lworm populations . Pyrethroid insecticides
often flare aphids and mites, as well. By using s ulfoxaflor , we expect a reduction in the use of

some insecticides, especially ace phate, dicrotophos, and oxamyl. The ecological and toxicological profile of sulfo xaflor is considered to be more favorable than the ecological and toxicological profiles of these insecticides. D ata indicates that sulfoxaflor is not likely to flare aphids and mites. Therefore, the use of Transform will and has provided significant econ omic benefits for cotton growers in Tennessee. Furthermore, the use of Transform since 2012 has replaced products that are well known to be more toxic to honeybees therefore increasing the overall safety to honey bees and likely other pollinators (Zhu et a l. 2015 )

### 17 Figure 8

. Correlations between Lygus applications and applications for other pests (Mississippi).

(5) Effectiveness of proposed use. The application shall contain data, a discussion of field trials, or other evidence which provide the basis for the conclusion that the proposed pesticide treatment will be effective in dealing with the emergency

.

Sulfoxaflor ( Transform WG TM ) has been evaluated in laboratory and field trials for the past several

years. R ecent publication s by Babcock et al. ( 2010 ) and Zhu et al. (201 1 ) clearly define the biology and biochemistry of s ulfoxaflor and demonstrate a novel mode of action against sap feeding insects including those in the order H e teroptera . Insects in the genus Lygus are included in this
order. Sulfo xaflor

- induced mortality was similar between insecticide

- resistant and insecticide

susceptible strains of several Homoptera and Heteroptera. No cross

- resistance was detected to sulfoxaflor in populations expressing resistance to a br oad range of modes of action. These research projects support a novel mode of action for sulfoxaflor including those insecticides with similar chemical structures (neonicotinoids).

Data from s everal field trials in Tennessee and elsewhere demonstrate the excellent efficacy of
sulfoxaflor (T ransform ) relative to the best alternative insecticide s ( Figs. 9 and 10

, Table s 3 , 7, and

7 )

. Other examples are published online at http://www.utcrops.com/MultiState/MultiState.htm

. In all tests including sulfoxaflor , this product has pro vided excellent control either as good as or better than the best alternative treatment (typically acephate at the highest labeled rates). D ata from other areas of the MidSouth highlight the value of Transfo rm in preserving yield when used in combination or rotation with alternative treatments (e.g., Table s 9 ). 0 0.2 0.4 0.6 0.8

1 1.2 1.4 1.6 1.8

2

1 3.1 5.2 4.9 3.2 7.5 5.5 6.5 6 Spider Mites

Cotton Aphid Mite/Aphid Applications

Lygus Applications r = 0.9634

r = 0.8401

### 1 8 Figure 9 . Numbers of Lygus per 10 row feet

, showing the relative efficacy of sulfoxaflor vs. competitive standards, Tennessee, 2011.

Figure 1 0 . Numbers of Lygus per 10 row feet

, showing the relative efficacy of sulfoxaflor vs. competitive standards, Tennessee, 2010.

Table 7 . Standard efficacy test comparing Transform to standard insecticides in the Mississippi
Delta in 2010.

Treatment Seasonal Mean TPB Adults and Nymphs

Transform 0.045 lb + Bifenthrin 4.27 oz 13.3 e 0 2 4 6 8 10 12 14 16

Transform

1.5 oz Transform

2.25 oz Bidrin

8 oz Acephate 90S

17.8 oz Endigo

5 oz Untreated Plant bugs 6 DAA

Plant bugs 14 DAA

0 5 10 15 20 25 30 35 4 DAT1 4 DAT2 8 DAT2

0.25“ of rain 1.25 hours after application 1

### 19 Transform 0.067 lb 14.0 de
Transform 0.067 lb + Bifenthrin 4.27 oz 16.8 de Endigo 0.08 27.5 bc
Bidrin 0.05 lb 35.0 b
Orthene 1 lb 23.0 cd
Untreated 135.8 a

P = 0.0001

Table 8

. Standard efficacy test comparing Transform to standard insecticides in the Mississippi
Delta in 2009.

2009 Transform Efficacy Test Compared to Common Standards for Tarnished Plant Bug
Product Seasonal Mean TPB Adults and Nymphs

Tr ansform 0.067 lb 8.5 d
Orthene 1 lb 16.3 c
Bifenthrin 6.4 oz 20.3 c

Centric 2.5 oz 33.5 c
Bidrin 0.05 lb 35.0 b
Transform 0.067 lb + Bifenthrin 6.4 oz 8.0 d
Untreated 82.0 a

P = 0.0001

Table 9 . Percent control and yields from a tarnished plant bug program trial conducted in Wayside, MS in 2010.

Treatment Seasonal Mean

No. Lygus Seasonal Mean Lygus % Control Lint Yield

Transform 0.045 lb fb Transform
0.045 lb fb
Orthene 1 lb fb
Transform 0.045 fb
Transform 0.045 46.8 c 84 a 1266 a

Transform 0.067 lb fb Transform
0.067 lb fb
Orthene 1 lb fb
Transform 0.067 lb fb Transform

0.067 42.1 c 85 a 1267 a

Orthene 0.5 lb +
Diamond 9 oz fb
Bidrin 0.5 lb fb Endigo 0.08 lb fb
Orthene 0.75 lb +
Karate 0.04 lb fb
Orthene 1.0 lb 128.3 b 56 b 1019 b

Untreat ed Check 292.3 a NA 664 c

1 Means followed by the same letter are not significantly different (P<0.05).

### 20 Although natural enemy populations provide little benefit for tarnished plant bug management,

a lte rnative insecticides targeting plant bug s reduce natural enemy populations and “flare” other pests such as twospotted spider mite or cotton aphid. A study conducted in Stoneville, MS in 2013 compared overall management programs. Th e treatments included cotton grown with all classes except neonicotinoids or sulfoxaflor, all classes except sulfoxaflor, and all available classes. Overall, 1

- 2 applications were needed for twospotted spider mite in the treatments where
sulfoxaflor was not used ( Fig

. 1 1 ). Additionally, the treatments that did not include sulfoxaflor each needed to be sprayed separately for cotton aphid . A portion of this is due to sulfoxaflor control of cotton aphids, but preservation of beneficial insec ts also contributed. In summary, the use of sulfoxaflor for tarnished plant bug management can reduce the number of insecticide applications targeting other pests because of the lower toxicity to beneficial arthropods. Overall, yields and economic returns were greater where all classes of insecticides were included.

Figure 11

. Impact of insecticide use programs for tarnished plant bug management on the number of insecticide sprays for twospotted spider mite and cotton aphid.

Fro m 2014 to 2015 a graduate student at Mississippi State University conducted a study comparing the tarnished plant bug IPM program to a standard approach at multiple planting dates Hills and Delta regions of Mississippi. In the IPM approach, sulfoxaflor was a standard component of the insecticide use strategy. It was also occasionally used in the standard approach when aphids were also present. Overall, the IPM program resulted in greater yields, fewer insecticide applications, and greater economic returns c ompared to the standard approach (Fig. 1 2 ).

### 21 Figure 12 . Economic returns for a tarnished plant bug IPM program compared to a Standard approach i n Mississippi averaged across 2014 and 2015. The BMP treatments included sulfox aflor as a foundation of the overall IPM program. It was occasionally used in the standard approach mainly to manage cotton aphid.

Sulfoxaflor (DAS test code GF

- 2372, proposed trade name Transform TM ) has been evaluated in laboratory and field trials for t he past several years. Recent publi cations by Babcock et al. (2010 ) and Zhu et al. (2010) clearly define the biology and biochemistry of sulfoxaflor and demonstrate a novel mode of action against sap feeding insects including those in the order Heteropter a. Insects in the genus Lygus are included in this order. Sulfoxaflor

- induced mortality was similar between susceptible and insecticide

- resistant strains of several Homoptera and Heteroptera. No

cross

- resistance was detected to sulfoxaflor in populations expressing resistance to a broad range of modes of action. These research projects support a novel mode of action for sulfoxaflor including those insecticides with similar chemical structures (neonicotinoids).

All available data indicates that s ulfox aflor is an excellent tool for managing tarnished plant bug
infestations in Tennessee and Midsouthern cotton IPM programs by improving efficacy, reducing input costs, and increasing yields. This compound has a selective spectrum of activity, has not
shown a propensity to flare other pest s, can be used as a rotational or tank

- mix partner with other chemistries, and has demonstrated value against insect icide

- resistant populations. It is likely that sulfoxaflor will be the backbone of chemical control strateg ies for tarnished plant bug and is critically needed in this emergency situation.

(6) Discussion of residues for food uses. If the proposed use is expected to result in residues of the pesticide in or on food, the application shall list the food likely t o contain such residues and shall contain an estimate of the maximum amount of the residue likely to result from the proposed use, together with the information on which such estimates are based.

Acute Assessment Food consumption information from the USDA 1994

- 1996 and 1998 Nationwide Continuing Surveys of Food Intake by Individuals (CSFII) and maximum residues from field trials rather than
tolerance

- level residue estimates were used. It was assumed that 100% of crops covered by the registration request ar e treated and maximum residue levels from field trials were used.

### 22 Drinking water. Two scenarios were modeled, use of sulfoxaflor on non

- aquatic row and orchard crops and use of sulfoxaflor on watercress. For the non

- aquatic crop scenario, based on the

Pest icide Root Zone Model/Exposure Analysis Modeling System (PRZM/EXAMS) and Screening Concentration in Ground Water (SCI

- GROW) models, the estimated drinking water concentrations (EDWCs) of sulfoxaflor for acute exposures are 26.4 ppb for surface water and

69 .2 ppb for ground water. For chronic exposures, EDWCs are 13.5 ppb for surface water and 69.2 ppb for ground water. For chronic exposures for cancer assessments, EDWCs are 9.3 ppb for surface water and 69.2 ppb for ground water. For the watercress scenario , the EDWCs for surface water are 91.3 ppb after one application, 182.5 ppb after two applications and 273.8 ppb after three applications.

Dietary risk estimates using both sets of EDWCs are below levels of concern. The non

- aquatic

crop EDWCs are more rep resentative of the expected exposure profile for the majority of the population. Also, water concentration values are adjusted to take into account the source of the water; the relative amounts of parent sulfoxaflor, X11719474, and X11519540; and the relat ive liver toxicity of the metabolites as compared to the parent compound.

For acute dietary risk assessment of the general population, the groundwater EDWC is greater than the surface water EDWC and was used in the assessment. The residue profile in

groun dwater is 60.9 ppb X11719474 and 8.3 ppb X11519540 (totaling 69.2 ppb). Parent sulfoxaflor does not occur in groundwater. The regulatory toxicological endpoint is based on neurotoxicity.

For acute dietary risk assessment of females 13

- 49, the regulatory e ndpoint is attributable only to the parent compound; therefore, the surface water EDWC of 9.4 ppb was used for this

assessment.

A tolerance of 0.3 ppm for sulfoxaflor on grain sorghum has been established. There is no expectation of residues of sulfoxafl or and its metabolites in animal commodities as a result of the proposed use on sorghum. Thus, animal feeding studies are not needed, and tolerances need not be established for meat, milk, poultry, and eggs.

Drinking water exposures are the driver in the d ietary assessment accounting for 100% of the exposures. Exposures through food (sorghum grain and syrup) are zero.

The acute dietary exposure from food and water to sulfoxaflor is 16% of the aPAD for children 1

- 2 years old and females 13

- 49 years old, the population groups receiving the greatest exposure.

Chronic Assessment The same refinements as those used for the acute exposure assessment were used, with two exceptions: (1) average residue levels from crop field trials were used rather than maximum
valu es and (2) average residues from feeding studies, rather than maximum values, were used to derive residue estimates for livestock commodities. It was assumed that 100% of crops are treated and average residue levels from field trials were used.

For chronic dietary risk assessment, the toxicological endpoint is liver effects, for which it is possible to account for the relative toxicities of X11719474 and X11519540 as compared to

### 23 sulfoxaflor. The groundwater EDWC is greater than the surface water EDWC. The r esidue profile in groundwater is 60.9 ppb X11719474 and 8.3 ppb X11519540. Adjusting for the relative toxicity results in 18.3 ppb equivalents of X11719474 and 83 ppb X11519540 (totaling 101.3 ppb). The adjusted groundwater EDWC is greater than the surface water EDWC (9.3 ppb) and was used to assess the chronic dietary exposure scenario.

The maximum dietary residue intake via consumption of sorghum commodities would be only a small portion of the RfD (<0.001%) and therefore, should not cause any additional risk to humans via chronic dietary exposure. Consumption of sorghum by sensitive sub

- populations
such as children and non

- nursing infants is essentially zero. Thus, the risk of these subpopulations to chronic dietary exposure to sulfoxaflor used on grain sorghum would be insignificant.

The major contributor to the risk was water (100%). There was no contribution from grain sorghum to the dietary exposure. All other populations under the chronic assessment show risk
estimates that are below levels of conce rn.

Chronic exposure to sulfoxaflor from food and water is 18% of the cPAD for infants, the population group receiving the greatest exposure. There are no residential uses for sulfoxaflor.

Short

- term risk. Because there is no short

- term residential exposu re and chronic dietary exposure has already been assessed, no further assessment of short

- term risk is necessary, the chronic dietary risk assessment for evaluating short

- term risk for sulfoxaflor is sufficient.

Intermediate

- term risk. Intermediate

- term ri sk is assessed based on intermediate

- term residential exposure plus chronic dietary exposure. Because there is no residential exposure and chronic dietary exposure has already been assessed, no further assessment of intermediate

term risk is necessary.

Cum ulative effects. Sulfoxaflor does not share a common mechanism of toxicity with any other substances, and does not produce a toxic metabolite produced by other substances. Thus, sulfoxaflor does not have a common mechanism of toxicity with other substances

.

Cancer. A nonlinear RfD approach is appropriate for assessing cancer risk to sulfoxaflor. This approach will account for all chronic toxicity, including carcinogenicity that could result from exposure to sulfoxaflor. Chronic dietary risk estimates are b elow levels of concern; therefore,
cancer risk is also below levels of concern.

There is a reasonable certainty that no harm will result to the general population, or to infants and children from aggregate exposure to sulfoxaflor as used in this emergency exemption
request.

The above content (Expected Residues for Food Uses ) was prepared by Michael Hare, Ph.D., Texas Department of Agriculture.

(7) Discussion of risk information

### 24 Human Health ( Toxicological Profile )
Sulfoxaflor is a member of a new class of insecticides, the sulfoximines. It is an activator of the nicotinic acetylcholine receptor (nAChR) in insects and, to a lesser degree, mammals. The nervous system and liver are the target organs, resulting in developmental toxicity and hepatotoxicity.

De velopmental toxicity was observed in rats only. Sulfoxaflor produced skeletal abnormalities likely resulting from skeletal muscle contraction due to activation of the skeletal muscle nAChR in utero. Contraction of the diaphragm, also related to skeletal mu scle nAChR activation, prevented normal breathing in neonates and increased mortality. The skeletal abnormalities occurred at high doses while decreased neonatal survival occurred at slightly lower levels.

Sulfoxaflor and its major metabolites produced li ver weight and enzyme changes, and tumors in subchronic, chronic and short

- term studies. Hepatotoxicity occurred at lower doses in long

- term studies compared to short

- term studies.

Reproductive effects included an increase in Leydig cell tumors which were not treatment related due to the lack of dose response, the lack of statistical significance for the combined tumors, and the high background rates for this tumor type in F344 rats. The primary effects on male reproductive organs are secondary to the loss of normal testicular function due to the size of the Leydig Cell adenomas. The secondary effects to the male reproductive organs are also not treatment related. It appears that rats are uniquely sensitive to these developmental effects and are unlikely to be relevant to humans.

Clinical indications of neurotoxicity were observed at the highest dose tested in the acute neurotoxicity study in rats. Decreased motor activity was also observed in the mid

- and high

- dose groups. Since the neurotoxicity was obser ved only at a very high dose and many of the effects are not consistent with the perturbation of the nicotinic receptor system, it is unlikely that these
effects are due to activation of the nAChR.

Tumors have been observed in rat and mouse studies. In ra ts, there were significant increases in hepatocellular adenomas in the high

- dose males. In mice, there were significant increases in hepatocellular adenomas and carcinomas in high dose males. In female mice, there was an increase in carcinomas at the high dose. Liver tumors in mice were treatment

- related. Leydig cell tumors were also observed in the high

- dose group of male rats, but were not related to treatment. There was also a significant increase in preputial gland tumors in male rats in the high

- dose g roup. Given that the liver tumors are produced by a non

- linear mechanism, the Leydig cell tumors were

not treatment

- related, and the preputial gland tumors only occurred at the high dose in one sex of one species, the evidence of carcinogenicity was weak.

Ecological Toxicity Sulfoxaflor (N

- [methyloxido[1

- [6

- (trifluoromethyl)

- 3

- pyridinyl]ethyl]

- lambda 4

- sulfanylidene]) is a new variety of insecticide as a member of the sulfoxamine subclass of neonicotinoid insecticides. It is considered an agonist of the n icotinic acetylcholine receptor and exhibits excitatory responses including tremors, followed by paralysis and mortality in target insects. Sulfoxaflor consists of two diastereomers in a ratio of approximately 50:50 with each diastereomer consisting of two enantiomers. Sulfoxaflor is systemically distributed in plants when applied. The chemical acts through both contact action and ingestion and provides both rapid knockdown (symptoms are typically observed within 1

- 2 hours of application) and residual cont rol (generally provides from

### 25 7 to 21 days of residual control). Incident reports submitted to EPA since approximately 1994 have been tracked via the Incident Data System. Over the 2012 growing season, a Section 18 emergency use was granted for application of sulfoxaflor to cotton in four states (MS, LA, AR, TN). No incident reports have been received in association with the use of sulfoxaflor in this situation.

Sulfoxaflor is classified as practically non

- toxic on an acute exposure basis, with 96

- h LC 50 v alues of >400 mg a.i./L for all three freshwater fish species tested (bluegill, rainbow trout, and common carp). Mortality was 5% or less at the highest test treatments in each of these studies. Treatment

related sublethal effects included discoloration at the highest treatment concentration (100% of fish at 400 mg a.i./L for bluegill) and fish swimming on the bottom (1 fish at 400 mg a.i./L for rainbow trout). No other treatment

- related sublethal effects were reported. For an estuarine/marine sheepshead mi nnow, sulfoxaflor was also practically non

- toxic with an LC 50 of 288 mg a.i./L. Sublethal effects included loss of equilibrium or lying on the bottom of aquaria at 200 and 400 mg a.i./L. The primary degradate of sulfoxaflor is also classified as practicall y non

toxic to rainbow trout on an acute exposure basis (96

- h LC 50 >500 mg a.i./L).

Adverse effects from chronic exposure to sulfoxaflor were examined with two fish species (fathead minnow and sheepshead minnow) during early life stage toxicity tests. For fathead minnow, the 30

- d NOAEC is 5 mg a.i./L based on a 30% reduction in mean fish weight relative to controls at the next highest concentration (LOAEC=10 mg a.i./L). No statistically significant and/or

treatment

- related effects were reported for hatchin g success, fry survival and length. For sheepshead minnow, the 30

- d NOAEC is 1.3 mg a.i./L based on a statistically significant reduction in mean length (3% relative to controls) at 2.5 mg a.i./L. No statistically significant and/or

treatment

- related effec ts were reported for hatching success, fry survival and mean weight.

The acute toxicity of sulfoxaflor was evaluated for one freshwater invertebrate species, the water flea and two saltwater species (mysid shrimp and Eastern oyster). For the water flea, t he 48

- h EC 50 is >400 mg a.i./L, the highest concentration tested. For Eastern oyster, new shell growth was significantly reduced at 120 mg a.i./L (75% reduction relative to control). The 96

- h EC 50 for shell growth is 93 mg a.i./L. No mortality occurred at any test concentration. Mysid shrimp are the most acutely sensitive invertebrate species tested with sulfoxaflor based on water column only exposures, with a 96

- h LC 50 of 0.67 mg a.i./L. The primary degradate of sulfoxaflor is also classified as practicall y non

- toxic to the water flea (EC 50 >240 mg a.i./L).

The chronic effects of sulfoxaflor to the water flea were determined in a semi

- static system over a period of 21 days to nominal concentrations of 6.25, 12.5, 25, 50 and 100 mg a.i./L. Adult mortality, reproduction rate (number of young), length of the surviving adults, and days to first brood were used to determine the toxicity endpoints. No treatment

- related effects on adult mortality or adult length were observed. The reproduction rate and days to fir st brood were significantly (p<0.05) different in the 100 mg a.i./L test group (40% reduction in mean number of offspring; 35% increase in time to first brood). No significant effects were observed on survival, growth or reproduction at the lower test conc entrations. The 21

- day NOAEC and LOAEC were determined to be 50 and 100 mg a.i./L, respectively.

The chronic effects of sulfoxaflor to mysid shrimp were determined in a flow

- through system over a period of 28 days to nominal concentrations of 0.063, 0.13, 0.25, 0.50 and 1.0 mg a.i./L. Mortality of parent (F 0 ) and first generation (F 1 ), reproduction rate of F 0 (number of young), length of the surviving F 0 and F 1 , and days to first brood by F 0 were used to determine the toxicity

### 26 endpoints. Complete F 0 mortal ity (100%) was observed at the highest test concentration of 1.0 mg a.i./L within 7 days; no treatment

- related effects on F 0 /F 1 mortality, F 0 reproduction rate, or

F 0 /F 1 length were observed at the lower test concentrations. The 28

- day NOAEC and LOAEC were determined to be 0.11 mg and 0.25 mg a.i./L, respectively.

Sulfoxaflor exhibited relatively low toxicity to aquatic non

- vascular plants. The most sensitive aquatic nonvascular plant is the freshwater diatom with a 96

- h EC 50 of 81.2 mg a.i./L. Similarly, sulfoxaflor was not toxic to the freshwater vascular aquatic plant, Lemna gibba , up to the limit amount, as indicated by a 7

- d EC 50 for frond count, dry weight and growth rate of >100 mg a.i./L with no significant adverse effects on these endpoints observ ed at any treatment concentration.

Based on an acute oral LD 50 of 676 mg a.i./kg bw for bobwhite quail, sulfoxaflor is considered slightly toxic to birds on an acute oral exposure basis. On a subacute, dietary exposure basis,
sulfoxaflor is classified as practically nontoxic to birds, with 5

- d LC 50 values of >5620 mg/kg

- diet for mallard ducks and bobwhite quail. The NOAEL from these studies is 5620 mg/kg

- diet as no treatment related mortality of sublethal effects were observed at any treatment. Similarly, the primary degradate is classified as practically nontoxic to birds on an acute oral exposure basis with

a LD 50 of >2250 mg a.i./kg bw. In two chronic, avian reproductive toxicity studies, the 20

- week NOAELs ranged from 200 mg/kg

- diet (mallard, highest c oncentration tested) to 1000 mg/kg

- diet (bobwhite quail, highest concentration tested). No treatment

- related adverse effects were observed at any test treatment in these studies.

For bees, sulfoxaflor is classified as very highly toxic with acute oral and contact LD 50 values of 0.05 and 0.13 μg a.i./bee, respectively, for adult honey bees. For larvae, a 7

- d oral LD 50 of >0.2 μg a.i./bee was determined (45% mortality occurred at the highest treatment of 0.2 μg a.i./bee). The primary metabolite of sulfoxaflor is practica lly non

- toxic to the honey bee. This lack of toxicity is consistent with the cyano

- substituted neonicotinoids where similar cleavage of the cyanide group appears to eliminate their insecticidal activity. The acute oral toxicity of sulfoxaflor to adult
bumb le bees ( Bombus terrestris ) is similar to the honey bee; whereas its acute contact toxicity is
about 20X less toxic for the bumble bee. Sulfoxaflor did not demonstrate substantial residual toxicity to honey bees exposed via treated and aged alfalfa (i.e., mortality was <15% at maximum application rates).

At the application rates used (3

- 67% of US maximum), the direct effects of sulfoxaflor on adult forager bee mortality, flight activity and the occurrence of behavioral abnormalities is relatively
short

- li ved, lasting 3 days or less. Direct effects are considered those that result directly from interception of spray droplets or dermal contact with foliar residues. The direct effect of sulfoxaflor on these measures at the maximum application rate in the US i s presently not known. When compared to control hives, the effect of sulfoxaflor on honey bee colony strength when applied at 3

- 32% of the US maximum proposed rate was not apparent in most cases. When compared to hives prior to pesticide application, sulfo xaflor applied to cotton foliage up to the maximum rate proposed in the US resulted in no discernible decline in mean colony strength by 17 days after the first application. Longer

- term results were not available from this study nor were
concurrent control s included. For managed bees, the primary exposure routes of concern include direct contact with spray droplets, dermal contact with foliar residues, and ingestion through consumption of contaminated pollen, nectar and associated processed food provisions . Exposure of hive bees via contaminated wax is also possible. Exposure of bees through contaminated

### 27 drinking water is not expected to be nearly as important as exposure through direct contact or pollen and nectar.

In summary, sulfoxaflor is slightly toxi c to practically non

- toxic to fish and freshwater water aquatic invertebrates on an acute exposure basis. It is also practically non

- toxic to aquatic plants (vascular and non

- vascular). Sulfoxaflor is highly toxic to saltwater invertebrates on an acute

exp osure basis. The high toxicity of sulfoxaflor to mysid shrimp and benthic aquatic insects relative to the water flea is consistent with the toxicity profile of other insecticides with similar MOAs. For birds and mammals, sulfoxaflor is classified as moder ately toxic to practically non

toxic on an acute exposure basis. The threshold for chronic toxicity (NOAEL) to birds is 200 ppm and that for mammals is 100 ppm in the diet. Sulfoxaflor did not exhibit deleterious effects to terrestrial plants at or above i ts proposed maximum application rates.

For bees, sulfoxaflor is classified as very highly toxic. However, if this insecticide is strictly used as directed on the Section 18 supplemental label, no significant adverse effects are expected to

Louisiana wi ldlife. Of course, standard precautions to avoid drift and runoff to waterways of the state are warranted. As stated on the Section 3 label, risk to managed bees and native pollinators from contact with pesticide spray or residues can be minimized when a pplications are made before 7 am or after 7 pm or when the temperature is below 55 ◦ F at the site of application.

Environmental Fate Sulfoxaflor is a systemic insecticide which displays translaminar movement when applied to foliage. Movement of sulfoxaflor within the plant follows the direction of water transport within the plant (i.e., xylem mobile) as indicated by phosphor translocation studies in several plants. Sulfoxaflor is characterized by a water solubility ranging from 550 to 1,380 ppm. Sulfoxaflor has a low potential for volatilization from dry and wet surfaces (vapor pressure= 1.9 x 10

- 8 torr and Henry’s Law constant= 1.2 x 10

- 11 atm m 3 mole

- 1 , respectively at 25 °C). Partitioning coefficient of sulfoxaflor from octanol to water (K ow @ 20 C & pH 7 = 6; Log K ow = 0.802) suggests low potential for bioaccumulation. No fish bioconcentration study was provided due to the low K ow , but sulfoxaflor is not expected to bioaccumulate in aquatic systems. Furthermore, sulfoxaflor is not expected to partition int o the sediment due to low K oc (7

- 74 mL/g).

Registrants tests indicate that hydrolysis, and both aqueous and soil photolysis are not expected to be important in sulfoxaflor dissipation in the natural environment. In a hydrolysis study, the parent was shown to be stable in acidic/neutral/alkaline sterilized aqueous buffered solutions (pH values of 5, 7 and 9). In addition, parent chemical as well as its major degradate, were shown to degrade relatively slowly by aqueous photolysis in sterile and natural pond water (t 1⁄2 = 261 to >1,000 days). Furthermore, sulfoxaflor was stable to photolysis on soil surfaces. Sulfoxaflor is expected to biodegrade rapidly in aerobic soil (half

- lives <1 day). Under aerobic aquatic conditions, biodegradation proceeded at a more mo derate rate with half

- lives ranging from 37 to 88 days. Under anaerobic soil conditions, the parent compound was metabolized with half

- lives of 113 to 120 days while under anaerobic aquatic conditions the chemical was more persistent
with half

- lives of 10 3 to 382 days. In contrast to its short

- lived parent, the major degradate is expected to be more persistent than its parent in aerobic/anaerobic aquatic systems and some aerobic soils. In other soils, less persistence is expected due to mineralization to CO 2 or the formation of other minor degradates.

### 28 In field studies, sulfoxaflor has shown similar vulnerability to aerobic bio

- degradation in nine out of ten terrestrial field dissipation studies on bare

- ground/cropped plots (half

- lives were <2 days

in nine cropped/bare soils in CA, FL, ND, ON and TX and was 8 days in one bare ground soil in TX). The chemical can be characterized by very high to high mobility (Kf oc ranged from 11

- 72 mL g

- 1 ). Rapid soil degradation is expected to limit chemical amounts that may potentially leach and contaminate ground water. Contamination of groundwater by sulfoxaflor will only be expected when excessive rain occurs within a short period (few days) of multiple applications in vulnerable sandy soils. Contamination of surface w ater by sulfoxaflor is expected to be mainly related to drift and very little due to run

- off. This is because drifted sulfoxaflor that reaches aquatic systems is expected to persist while that reaching the soil system is expected to degrade quickly with sl ight
chance for it to run

- off.

When sulfoxaflor is applied foliar on growing crops it is intercepted by the crop canopy. Data presented above appear to indicate that sulfoxaflor enters the plant and is incorporated in the plant foliage with only limited d egradation. It appears that this is the main source of the insecticide sulfoxaflor that would kill sap sucking insects. This is because washed

- off sulfoxaflor, that reaches the soil system, is expected to degrade.

In summary, sulfoxaflor has a low potenti al for volatilization from dry and wet surfaces. This chemical is characterized by a relatively higher water solubility. Partitioning coefficient of sulfoxaflor from octanol to water suggests low potential for bioaccumulation in aquatic organisms
such as f ish. Sulfoxaflor is resistant to hydrolysis and photolysis but transforms quickly in soils. In contrast, sulfoxaflor reaching aquatic systems by drift is expected to degrade rather slowly. Partitioning of sulfoxaflor to air is not expected to be importan t due to the low vapor pressure and Henry’s Law constant for sulfoxaflor. Exposure in surface water results from the drifted parent compound, and only minor amounts are expected to run

- off only when rainfall and/or irrigation immediately follow application . The use of this insecticide is not expected to adversely impact Louisiana ecosystems when used according to the Section 18 label. Of course, caution is needed to prevent exposure to water systems because of toxicity issues to aquatic invertebrates. As stated on the Section 3 label, this product should never be applied directly to water, to areas where surface water is present or to intertidal areas below the mean water mark. Also, the label includes the statement “Do not contaminate water when disposi ng of equipment rinsate.”

Endangered Species A list of the endangered species present in this application was obtained from the US Fish and
Wildlife Service website ( Attachment C ). None of these species are expected to be impacted by applications of sul foxaflor to control plant bugs, due to very low toxicity to these organisms and/or the fact that they do not occur in the Tennessee cotton ecosystem. This product does adversely affect insects, including bees, and aquatic invertebrates, but the limited ex posure to these species should not negatively affect endangered and threatened species when all applications label precautions are followed and preformed.

Resulting Environment from Sulfoxaflor U se Tennessee’s farmscape should experience a reduction in t he number of insecticide applications
used to control tarnished plant bug. This reduction will be even more important considering that many of those replaced applications will be for organophosphate or carbamate insecticides

. The availability of sulfoxaf lor on cotton will directly reduce alternative sprays for the target pest, but

### 29 also reduc e the probability of flaring secondary pests such as spider mites and aphids . This can further reduce the number of total insecticide applications on cotton.

The abov e content ( Discussion of Risk Information ) was, for the most part, prepared by Michael Hare, Ph.D. (Human Health Effects) , David Villarreal, Ph.D. (Ecological Effects), and David Villarreal, Ph.D. (Environmental Fate), all with the Texas Department of Agri culture.

( 8) Coordination with other affe cted State or Federal agencies.

The Tennessee Wildlife Resource Agency will receive a copy of this request. Any comments
received will be forwarded to the U.S. EPA.

(9) Notification/support of registrant.

Dow AgroSciences has been notified of this agency’s intent regarding this application and has provided a letter of support ( Attachment D ) . They also provided t he copy of a proposed section 18 label with directions for use of this product if this emergency exemption is approved

.

(10) Description o f proposed enforcement program.

The Tennessee Department of Agriculture (TDA) has adequate authorities for enforcing provisions of Section 18 emergency exemptions. TDA will require Dow AgroSciences to prepare Section 18 labeling that complies with TDA and EPA requirements for this emergency use, if approved, to ensure that product distributed for the exemption is properly labeled.

(11) Repeated uses.

This is the second time that the TDA has request ed as applied for this specific exemption. A section 18 was previously granted in Tennessee during 2012

.

(b) Information req uired for a specific exemption.

(1) The scientific and common n ame of the pest or pest complex :

Lygus lineolaris (Palisot de Beauvoi s) , tarnished plant bug

(2) A discussion of the events which brough t about the emergency condition:

Tarnished plant bug has become the number one pest in Tennessee. Prior to the mid 1990’s

, tarnished plant bugs were generally controlled by insecticides directed at other pests during the flowering period of cotton; therefore, economic damage from tarnished plant bugs during flowering was relatively uncommon. However, with > 9 0% of Midsouthern (Arkansas, Louisiana, Mississippi, Tennessee) cotton now bein g planted to transgenic cotton expressing one or more
toxins derived from Bacillus thuringiensis (Bt) ( Wil liams 2008 ) and the eradication of the boll weevil, Anthonomus grandis grandis Boheman (Coleoptera: Curculionidae), many of the foliar applications for other pests during flowering have been eliminated. An increase in federal conservation/wetlands reserv e programs, wide scale adoption of conservation tillage systems,

### 30 and increased diversity of the summer farmscape have created a more favorable environment enhancing populations of tarnished plant bug s

. The region has also experienced a significant
reducti on in cotton acres . Cotton serves as a sink crop for tarnished plant bugs, and there is a n increasingly clear inverse correlation between cotton acres and infestation levels of tarnished plant bugs

. The consequence of th ese change s is that tarnished plant bug ha s become the
dominant

, season long pest across this region d uring the last decade

. Because of higher

p opulations which persist longer during the season, c ontrol costs and crop losses associated with tarnished plant bugs have increased substantially

. Prior to 2004, fewer than two applications per

season were typically directed towards this pest

. However, applications for tarnished plant bug have been increasing steadily, with private consultants reporting the need to treat for plant bugs

an average of 4

- 7 times per season with individual fields being sprayed eight or more times ( Fig.

1 )

. Insecticide ap plications for secondary pests, specifically spider mites and aphids

, w ere also on
the r ise. Notably , applications for these secondary p ests have decreased once Transform WG
became widely used , and yields have increased despite the increasing pest pressure (Tables 10 and 11) . These statistics do not fully account for all applications which are, at least in part, targeting tarnished plant bug because b ollwor m and stink bug applications often include tank mixes with the goal of targeting a pest complex that includes plant bug s

.

In addition, an increase in the frequency of chemical control strategies for this pest has intensified
selection for resistance. Sno dgrass and Gore (2007) has reported resistan c e to a number of OP’s

, carbamates, and pyrethroids. Producers were relying heavily on neonicotinoids (thiamethoxam, imidacloprid), but now some populations are showing reduced sensitivity to those products. In

a ddition, the actual seasonal AI/acre of neonicotinoids further restricts product availability. In order to obtain some level of population management, there has been an increase in use rates to the highest labeled dose s

. Tarnished plant bug management in m any Midsouthern fields has degraded to a point where the only option to reduce yield impacts is the co

- application of
insecticides with different modes of action. As referenced by Luckmann and Metcalf (1982) on the stages of crop protection, cotton produ cers and pest management practitioners are in crisis phase with tarnished plant bug. The subsequent step is that of the disaster phase which would result in a collapse of the existing pest management system for cotton grown in the Mid

- South

. Exacerbating t he current situation are poor commodity prices for 2016 and substantially
increased control costs for herbicide

- tolerant weeds. Budgets are tight , and even small improvements in yields or reduced control costs for plant bugs might make the difference
betwe en a profitable year and a net loss for farmers

. Tennessee growers are facing an economic crisis, partly due to the tarnished plant bug because control costs and yield loss have nearly tripled in the last decade. The most expensive insecticide is the one t hat does not work, and losing Transform WG has impose d a substantial economic burden on Tennessee farmers.

3) A discussion of the anticipated risks to endangered or threatened species, beneficial organisms, or the environment that would be remedied by the pr oposed use of the pesticide;

See above discussion. Sulfoxaflor is expected to replace alternative products that are used at higher rates and represent greater risk to the environment and beneficial organisms. See
Attachment C ( Tennessee Endangered an d Threatened Species List 201 5 )

.

(4) A discussion of the anticipated significant economic loss, together with data and other information supporting the discussion that addresses one or more of the following, as appropriate:

### 31 (i) Yield or utilized yield reason ably anticipated in the absence of the emergency and expected losses in quantity due to the emergency; (ii) The information in paragraph (b) (4) (i) of this section plus prices reasonably anticipated in the absence of the emergency and changes in prices and/or production costs due to the

emergency; (iii) The information in paragraph (b) (4) (ii) of this section plus operating costs reasonably anticipated in the absence of the emergency;

The information below demonstrates the substantial economic impact that plant bug s are having in the Mid

- South and Tennessee. These data also demonstrate that since Transform has become available for use in cotton, producers have benefited greatly both in terms of revenue and increased yield protection. Furthermore, during the four ye ar period that Transform has been used, there have been no reports of bee kills associated with this product. Many growers in regions with only moderate resistance levels have also benefitted from the safety toward beneficial insect populations in the fiel d. Overall, Transform has become one of the foundation products in our IPM cotton program.

Table 10

. Foliar insecticide costs, yield loss, and the total costs (costs + loss) of managing tarnished plant bug in Tennessee over the past 12 season

. Control co sts for tarnished plant bugs has nearly tripled in the last decade. These data represent averages across all of Tennessee, and thus, dilute the impact observed in some areas or fields that are more affected by tarnished plant bug.

Year Yield Foliar Costs % Yield Cost + Loss ($/acre) Loss ($/acre)

2012

- 2015 928 $31.09 3.20 $52

2008

- 2011 848 $14.79 2.01 $27

2004

- 2007 777 $12.22 0.93 $18
% Change 19.4 154.4 244.1 188.9 *Assumes gross $0.70/lb lint value (includes equities and seed check)

.

Tab le 1 1

. Yield, yield loss es, and the number of insecticide applications for plant bug (PB) and also for secondary pests (e.g., spider mites and cotton aphids ) in the Midsouth and Tennessee. In
recent years, y ield loss es caused by plant bugs have almost do ubled despite more insecticide applications

. Note that since Transform WG was introduced (2012), average yields have increased in the region by over 20% and in Tennessee by about 10%. Also applications and yield loss caused by spider mites and aphids hav e decreased during this same time frame.

Sources : Cotton Insect Losses, http://www.entomology.msstate.edu/resources/cottoncrop.asp

### 32 NASS Yields, http://www.nass.usda.gov/Statistics_by_State/Tennessee/

It is relatively easy to project that the loss of T ransform WG f or Tennessee cotton producers could
result in increased crops losses and m ore and less effective pesticide applications for plant bu gs and secondary pests that could exceed 20% of their net revenue , this i n an economic environment
where commodity prices already make profitability questionable (and this is true of other major row crops including corn and soybean).

(iv) Any other information explaining the economic consequences of the emergency.

Summary of the Current Situation Facing West Tennessee Producers: Te nnessee producers are spraying more than ever f or tarnished plant bugs . Growers in Tennessee can expect similar or higher pest populations during the 2016 season. The absence of new products to manage tarnished plant bug has serio usly impaired the economic viability of cotton across in parts of

Tennessee and much of the Mid

- South . Use of currently available products is not economically and environmentally sustainable. Resistance to pyrethroid insecticides, some organophosphates,

a nd now neonicotinoids have left Tennessee with essentially f ew alternative insecticides to control plant bugs

. A s previously discussed, r esistance and resistance management, the likelihood
of flarin g secondary pests, label restrictions , and other factors limit the utility of these products. Because sulfoxaflor (Transform WG) is a novel mode of action with no known resistance, it will greatly enhance the producer’s ability to manage tarnished plant bu gs. Prior to the label being revoked, Transform WG sulfoxaflor had become part of a holistic IPM program for cotton growers.

References used to support previous statements and Section 18 request:

Babcock, J. M, C. B. Gerwick, J. X. Huang, M. R. Loso, G. E. Nakamura, S. P. Nolting, R. B. Rogers, T. C. Sparks, J. D. Thomas, G. B. Watson and Y. Zhu. 2010. Biological Characterization of Sulfoxaflor, a Novel Insecticide. Pest Mgmt. Sci. 67: 328

- 334

.

Copes, J. T., G. L. Snodgrass, J. Sharp, B. R. Leonard, D. R . Ring, and D. Blouin. 2010. Acephate resistance is widespread in Louisiana tarnished plant bug populations. La. Agric. 53: 14

- 15.

Gore, J., G. Andrews, J. Robbins, A. Catchot, F. Musser, J. Smith, G. Snodgrass, R. Jackson, C. Abel, D. Dodds, G. Lorenz, S. Akin, G. Studebaker, R. Leonard, R. Bagwell, S. Stewart, and K. Tindall. 2008. Strategies for managing tarnished plant bugs in cotton. Miss. State Univ. White Paper Recommendations Report, 4 pp.

, released April 2008.

Lorenz, G, T. Barber, S. D. Stewar t, A. Catchot, J. Gore and D. Cook. 2009. Evolving pest management in cotton. Proc. Beltwide Cotton Conf. 1395.

Luckmann W. H. and R. L. Metcalf. 1982. Why pest management, pp. 1

- 33? In R. Metcalf and W.
Luckmann eds. Introduction to Pest Management

. John Wiley and Sons, New York, NY.

Moore, J. L., J. H. Temple, J. T. Hardke, K. Emfinger, P. P. Price, J. T. Copes, J. W. Sharpe, E. Burris
and K. A. Fontenot. 2010. Proc. Beltwide Cotton Conf. 817

- 819.

Sharp, J. W., J. T. Copes, B. R. Leonard, E. Burris, P. P. Price, J. H. Temple and J. T. Hardke. 2010. Can we rely on any single insecticide for season long tarnished plant bug control in Louisiana

### 33 cotton

, p. 1170. In Proceedings, 2010 Beltwide Cotton Conferences, National Cotton Council, Memphis, T N.

Snodgrass, G. L. 1996. Insecticide resistance in field populations of the tarnished plant bug (Heteroptera: Miridae) in cotton in the Mississippi Delta. J. Econ. Entomol. 89: 783

- 790.

Snodgrass, G. L. and W. P. Scott. 2000. Seasonal changes in py rethroid resistance in tarnished plant bug (Heteroptera: Miridae) populations during a three

- year period in the delta area of Arkansas, Louisiana, and Mississippi. J. Econ. Entomol. 93: 441

- 446.

Snodgrass, G. L. and J. Gore. 2007. Status of insecticide re sistance for the tarnished plant bug, pp.

56

- 59. In Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis, TN.

Snodgrass, G. L., J. Gore, C. A. Abel, and R. Jackson. 2008. Predicting field control of tarnished plant bug (Heteroptera: Mirida e) populations with pyrethroid insecticides by use of glass

- vial bioassays. Southwestern Entomologist 33: 181

- 189.

Snodgrass, G. L., C. A. Abel, R. E. Jackson, and J. Gore. 2008. A Bioassay for Determining Resistance Levels in Tarnished Plant Bug Populati ons to Neonicotinoid Insecticides. Southwestern Entomologist 33: 173

- 180.

Stewart, S. and A. McClure. 2016 . Insect control recommendations for field crops. University of Tennessee Extension, PB 1768, http://www.utcrops.com/cotton/cotton_insects/InsectBook.htm

.

Williams, M. R. 2008. Cotton insect losses. In Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis, TN. (but also available at http://www.entomology.msstate.edu/resources/cottoncrop.asp ).

Williams, M. R. 2004

- 201 4 . Cotton insect losses

. In Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis , TN. (but also available at http://www.entomology.msstate.edu/20resources/cottoncrop.asp ).

Willrich

- Siebert, M., L.C Walton, R.B. Lassiter, R.A. Haygood, J.D. Thomas, and J.S. R ichburg. 2010. Performance of Dow AgroSciences’ Sulfoxaflor insecticides against tarnished plant bug, Lygus lineolaris, in Mid

- South cotton, pp. 1204.

. In Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis, TN.

Zhu, Y., J. Adamczyk, T. R inderer, J. Yao, R. Danka, R. Luttrell, and J. Gore. 2015. Spray toxicity and risk potential of 42 commonly used formulations of row crop pesticides to adult honey bees (Hymenoptera: Apidae). J. Econ. Entomol. 108:2640

- 2647.

Zhu, Y., M. R. Loso, G. B. Watson, T. C. Sparks, R. B. Rogers, J. X. Huang, C. B. Gerwick, J. M. Babcock, D. Kelley, V. B. Hegde, B. M. Nugent, J. M. Renga, I. Denholm, K. Gorman, G. DeBoer, J. Hasler, T. Meade, and J. D. Thomas. 2011 . D iscovery and Characterization of Sulfoxaflor : A Novel Sap

- Feeding Insecticide. J. Agric. Food Chem. 59(7): 2950

- 2957.