UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Dr. Robert I. Rose 

Authorized Agent for: 

Phyllom, LLC 

922 San Leandro A venue, Suite F 

Mountain View, CA 94043 

Y o a 2013 OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Re: Bacillus thuringiensis subsp. galleriae strain SDS-502 fermentation solids, spores and 

insecticidal toxins in forested areas in Illinois, Minnesota, Pennsylvania, and Wisconsin 

Experimental Use Permit No.: 88347-EUP-1 

Decision No.: 460457 

Effective Dates: Immediately until August 31, 2014 (pesticide applications and associated 

activities, e.g., collection of field data) 

Quantity Authorized: 

For Year 2013- 1,600 pounds of formulated pesticide product, Phyllom boreGONEJTM 

biological insecticide (containing 1,224 pounds of active ingredient). 

For Year 2014-1,600 pounds of formulated pesticide product, Phyllom boreGONE(M 

biological insecticide (containing 1,224 pounds of active ingredient). 

Acres To Be Treated: 700 acres (for 2013) and 700 acres (for 2014) = 1,400 total acres 

Dear Dr. Rose: 

On the basis of the information furnished by the applicant, the subject Experimental Use Permit (EUP) 

under section 5 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is hereby issued for 

the pesticidal active ingredient, Bacillus thuringiensis subsp. galleriae strain SDS-502 fermentation 

solids, spores, and insecticidal toxins. The EUP, authorized only in the States of Illinois, Minnesota, 

Pennsylvania, and Wisconsin, will evaluate the experimental pesticide product's efficacy against the 

emerald ash borer (Agrilus planipennis) with aerial applications to particular forested areas within or 

near the City of Pittsburgh (Pennsylvania), Town of Utica (Illinois), City of Milwaukee (Wisconsin), 

City of La Crosse (Wisconsin and Minnesota), and City of Janesville (Wisconsin). Shipment and/or use 

under this permit are subject to the provisions of 40 C.F.R. Part 172. 

lntemet.Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper 
Dr. Robert I. Rose (Phyllom, LLC) 

EUP No.: 88347-EUP-1 

2 

Prior to shipment and/or use of this material, you must consult with the pesticide regulatory officials of 

the states in which your experimental program will be conducted and obtain a state permit or license if 

such is required. You are required to provide notice to the state pesticide regulatory agency at least 72 

hours prior to the application of this experimental use pesticide product. You are to notify the state lead 

agency of the states in which your experimental program will be conducted of the specific testing 

program (when, where, how much, etc.). EPA is also notifying the relevant EPA Regions by sending 

them copies of this EUP authorization letter. Issuance of this Federal permit does not negate the need for 

permission from individual states. Failure to obtain that permission may result in revocation or 

modification of the EUP. 

Based on the experimental program submitted, this product may be shipped for use under this EUP to 

the States of Illinois, Minnesota, Pennsylvania, and Wisconsin for the next experimental period, 

effective immediately until August 31, 2014. The acres and amounts permitted per state are as follows: 

POUNDS OF FORMULATED PRODUCT POUNDS OF ACTIVE INGREDIENT 

YEAR 2013 (Emerald Ash Borer Season 1) 

Illinois 200 400 306 

Penns lvania 200 300 229.5 

Minnesota 300 900 688.5 

Wisconsin 

700 1600 1,224 

YEAR 2014 Emerald Ash Borer Season 2 

Illinois 200 400 306 

Penns lvania 200 300 229.5 

Minnesota 300 900 688.5 

Wisconsin 

Prior to registration or amendment under FIFRA section 3, all data requirements must be satisfied (40 

C.F.R. Part 158, Subpart V). Reporting any adverse effects to EPA is also required. 

The label submitted in connection with the application for the EUP is acceptable, and a stamped, 

accepted copy is enclosed for your records. This label must be used for all shipments under this EUP 

and must be in possession of the user at the time of pesticide application. 

You must provide all cooperators with a copy of this EUP authorization letter prior to the initial 

pesticide application made in accordance with this EUP. 

You must provide a final report at the conclusion of the experiment. This final report should include all 

of the items set forth in 40 C.F.R. § 172.8(b)(2). 
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If you have any questions regarding this permit, please contact Ms. Jeannine Kausch by email 

(kausch.jeannine@epa.gov) or by phone (703-347-8920). 

Enclosure (1): 

Sincerely, 

atthews, Director 

Biopesticides and Pollution 

Prevention Division (7511P) 

Office of Pesticide Programs 

- Phyllom boreGONEr biological insecticide EUP EPA Stamped, Accepted Label 

cc: Fatima El-Abdaoui, EPA Region 3 (Pennsylvania) 

Terence Bonace and Seth Dibblee, EPA Region 5 (Illinois, Minnesota, and Wisconsin)