TATE IDAHO 

DEPARl'MENf OF AGRICULTURE 

DfVJ[S][ON OF AGRICULTURAL RESOURCES 

C.L. "BUTCH" OTTER 

March 18, 2016 

Tawanda Maignan, Team Leader 

Emergency Response Team (7505P) 

USEPNOPP 

Document Processing Desk (EMEX) 

Room 84900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

Governor 

CELIA R. GOULD 

Director 

Re: Emergency use of sulfoxaflor, formulated as the product Transform SOWG (EPA Reg. 

No. 62179-625) for use on alfalfa grown for seed to control ofLygus Bug in Ada, 

Canyon, Owyhee and Payette counties in Idaho. 

1. Specific Request for a Section 18 Emergency Exemption from Registration for the use of 

Sulfoxaflor on Alfalfa Produced for Seed in Ada, Canyon, OWYhee, and Payette counties, Idaho. 

2. Contact Persons for all aspects: 

Dr. Jim Barbour, Professor, and Extension Specialist 

Department of Plant, Soil and Entomological Sciences 

University of Idaho 

Parma Research and Extension Center, 

29603 0 ofl Lane 

Parma, ID 83660-6590 

Tel: 208-722-67017 

Fax: 208-722-6708 

Email: jbarbour@uidaho.edu 

Dr. Doug Walsh 

, 

. 

Associate Entomologist!Environmental and Agrichemical Education Specialist 

WSU Prosser IAREC 

24106 N. Bunn Road 

Prosser, WA 99350-8694 

Phone: 509-786-9287 

Fax: 509-786-9370 

Email: dwalsh@wsu.edu 

' 

2270 Old Penitentiary Road • P.O. Box 790 • Boise, Idaho 83701 • (208) 332-8605 • Fax (208) 334-3547 • www.agri.idaho.gov 
3. Description of the Pesticide: 

Brand Name: Transfonn® 50 WG 

EPA Reg. No: 62179-625 

Active Ingredient: sulfoxaflor 

Percent of Active 50% 

Registrant: Dow AgroSciences, Zionsville, IN 

Sulfoxaflor is a sulfoximine insecticide that currently is registered (EPA Registration 

No.62719-625) under the trade name Transform® by Dow AgroSciences, Zionsville, IN. 

The sulfoximine class of insecticides is characterized by sulfoxaflor ([N-[methyloxido[l[ 

6-(tritluoromethyl)-3-pyridinyl]ethyl]-AA-sulfanylidene] cyanamide] and represents a new 

class of insecticides that exhibits a high degree of selective efficacy against a wide range 

of sap-feeding insects including plant bugs and aphids. Sulfoxaflor is an agonist at insect 

nicotinic acetylcholine receptors (nAChRs) and functions in a manner distinct from other 

insecticides that act at nAChRs. Sulfoxaflor also exhibits structure activity relationships 

that are different fi·om other nAChR agonists such as the neonicotinoids. Sulfoxaflor is a 

Classified by the Insecticide Resistance Action Committee in Resistance subgroup 4C and 

is the only member of that subgroup. 

The primary target insect for which this emergency request is being made for is Lygus 

bugs. Lygus bugs in alfalfa produced for seed consists of a mixed population of several 

insect species dominated by Lygus hesperus Knight (Heteroptera: Miridae) and Lygus 

elisus Carvalho. Lygus hesperus accounts for 80% to 90% of the lygus bugs found in 

alfalfa seed produced in southwest Idaho, eastern Oregon and Washington, with L. elisus 

and a few minor species accounting for the remaining 10% to 20% of the population. 

Lygus bugs exposed to lethal doses sulfoxaflor exhibit initial symptoms including 

tremors, antenna! waving, and leg extension and curling. Paralysis ensues and the Lygus 

bugs succumb to death. 

Pollinators are required for production of economically sustainable alfalfa seed yields, 

and represent a significant propmtion (20-3 0%) of the per acre costs of alfalfa seed 

production. The major pollinator of alfalfa seed in Idaho is the alfalfa leafcutter bee, 

Megachile rotunda/a Fabricius (Hymenoptera: Megachilidae). Significant numbers of the 

alkali bee Nomia melanderi Ckll. (Hymenoptera: Halictidae) are used in Washington and 

Nevada. ConculTently research has shown that once sulfoxaflor has dried on the leaf, it is 

not harmful to the alfalfa leafcutting bee, Megachile rotunda/a (Attachment #3) and the 
alkali bee, Nomia melanderi, the two key pollinators of alfalfa produced for seed in Idaho 

and Washington. 

4. Description of the Proposed Use: 

a) Sites to be treated: alfalfa seed fields in Ada, Canyon, Cassia, Franklin, 

Jerome, Oneida, Owyhee, Payette and Twin Falls Counties ofldaho. 

b) Method of Application: Ground 

c) Rate of application: Apply 1.5 to 2.75 oz. (0.047 to 0.086lb. a.i.) per acre per 

application. Ground application must be made in a minimum of 15 gallons of 

water per acre. 

d) Maximum Number of Applications: Two 

e) Total Acreage to be Treated: 12,000 acres 

f) Total Amount of Pesticide to be used: 4,125lbs. of Transform (2,062.5 lbs. 

a.i.). 

g) Use season: May 30,2014 through August 31,2014 

h) Harvest Dates: August 25 -October 1. 

i) Other Restrictions, User Precautions and Requirements: 

• Do not apply by ground within 25 feet, or by air within 150 feet, of lakes; 

reservoirs; rivers; permanent streams, marshes or natural ponds; estuaries 

and commercial fish farms. 

• Do not make applications less than 7 days apart. 

• Do not apply more than 5.5 oz. of Transform (0.172lbs. a.i. sulfoxa:flor) 

per acre per year. 

• Apply at night, after sunset and before sunrise, when bees are not actively 

foraging in fields of alfalfa produced for seed. 

j) A copy of the Section 18 label must be in the possession of the user at the 

time of application in Idaho. 

k) The Idaho State Dept. of Agriculture must be immediately informed of any 

adverse effects that may result from this use of Transfonn on alfalfa produced 

for seed. The number for ISDA is: (208) 332-8613. 

f) Follow all applicable restrictions, directions and precautions on the EPAregistered label for Transform (Attachment #2). 

5. Alternative Control Measures 

a. Registered Alternative Pesticides 

Flonicamid (Beleaf 50 SG Insecticide) and naled (Dibrom 8 Emulsive) 

have provided effective control of Lygus bugs in a blended tank mix 
during bloom for a residual of approximately 7 days. Naled is relatively 

toxic to pollinating bees if the bees are exposed to wet residues of naled. 

Hence the growers typically restrict themselves to applying this tank mix 

of flonicamid and naled during evenings when bees are not active and 

residues can dry overnight. In addition, Beleaf, is locally systemic 

(translaminar) in succulent foliage, but does not move well, and is thus 

less effective during the late bloom period as foliage begins senescing in 

mid to late June. Be leaf is limited to two applications per crop year 

making it a good early season control tool but is not feasible for later cycle 

applications. Beleaf(early) and Transform WG (late) will work well 

together in getting optimum Lygus Bug Control. 

Pyrethroids including alpha-cypermethrin, beta-cyfluthrin, bifenthrin, 

cyfluthrin, gamma-cyhalothrin, lambda-cyhalothrin, permethrin and zetacypermethrin have either a Section 3 registration on alfalfa or are 

registered on alfalfa produced for seed under a 24C Special Local Need 

registration. All of these pyrethroid insecticides can effectively control 

Lygus bugs but are extremely toxic to foraging bees and cannot be used 

for Lygus bug control during bloom. 

Organophosphates including chlorpyrifos, dimethoate, malathion, methyl 

parathion and oxydemeton methyl have either a Section 3 registration on 

alfalfa or are registered on alfalfa produced for seed under a 24C Special 

Local Need registration. All of these organophosphate insecticides can 

effectively control Lygus bugs but collectively are extremely toxic to 

foraging bees and cmmot be used for Lygus bug control during bloom. 

Carbamates including carbaryl, methomyl and formetanate hydrochloride 

are registered on forage alfalfa under Section 3 with direct labeling that 

restricts their use during bloom. All of these carbamate insecticides can 

effectively control Lygus bugs but are extremely toxic to foraging bees 

and cannot be used for Lygus bug control during bloom. 

Chiton inhibitors/ growth regulators. Novaluron (Rimon) can provide good 

control ofLygus, but is highly toxic to larvae of alfalfa leafcutting bees and 

other bees. Its use in alfalfa seed is advised only during the late bloom period 

after adult bees have laid eggs and provisioned larvae. Application during 

early bloom can results in 20% to 50% reduction of overwintering alfalfa 

leafcutting bees. 

Figure 1. Mean number(± sem)of brood cells produced and percentage live 

larvae for alfalfa leafcutting bees collected from alfalfa not treated with 

Rim on or treated with Rim on (12 oz. of Rim on per acre, June and July of 

2011) during early bloom (as soon as bees were actively flying) and three 

weeks later (late). Although total number of cell production was not 

significantly affected by Rimon, percentage live larvae was significantly 

lower for bees in fields treated early with Rimon compared to bees from 

fields treated three weeks later or from fields not treated with Rimon. 
Trt Brood cells Percentage live 

produced larvae 

Rimon early 777±65.1 a 21± 8.0 b 

Rimon late 797 ± 30.3 a 44 ± 6.4 a 

No Rimon 779 ± 50.5 a 39 ± 8.6 a 

b. Non chemical. 

Peristenus spp. A collective of 5 parasitic wasp species that is dominated 

by the species Peristenus howardi has been documented in several 

locations (most notably Parma, ID) as a parasite of Lygus bug populations. 

Unfortunately we have never observed levels of parasitism to exceed 15% 

in commercial seed production fields in Idaho and P. howardi does not 

provide effective control oflygus bugs in Idaho. 

6a. Efficacy of the proposed use: 

Table I. Mean± SEM number of small (instars 1-3: Table 1a) and large (instars 4 and 5: 

Table 1 b) lygus bug nymphs fi·om insecticide-treated plots of alfalfa grown for seed in 

Parma, ID in 2012. Insecticides were applied to four replicate 0.01 acre plots (22' by 22') 

on 6/25/2012 (single applications) or 6/25/2012 and 7112/2012 (two applications). Insect 

counts are the mean number of insects per three 180° sweep net samples taken per 

replicate plot prior to treatment and, 7, 14, 22 and 30 days after treatment. Treatments 

were analyzed by AN OVA df=27, P:S 0.05) and means from untreated control plots 

(UTC) separated from treated plots using Dunnett's procedure (P:S 0.05). 

Table 1a 

Rate Applications Davs after Treatment Trt (oz. product) I (14 day intervan 0 7 14 22 30 

UTC 10.0 ± 3,08 a 28.0 ± 3.81 a 29.0 ± 9.81 a 39.0 ± 9.35 a 30.5 ± 6.41 

Sulfoxaftor 1.5 1 7.8 + 3.25 a 7.3 ± 2.14 b 22.3 ± 2.59 a 37.5 + 8.07 a 28.5 ± 6.17 

Sulfoxaflor 1.5 2 16.3 + 4.73 a 7.8 + 1.03 b 22.3 ± 3.59 a 12.5 ± 7.24 b 12.0 + 5.40 

Sulfoxaflor 2.25 1 10.3 ± 2.78 a 8.0 ± 1.47 b 15.8 + 2.63 b 31.5 ± 5.27 a 41.5 + 6.24 

Su!foxaflor 2.25 2 9.5 + 1.71 a 2.8 + 0.75 b 14.0 ± 2.45 b 5.3 + 1.60 b 15.8 + 4.29 

a 

b 

b 

a 

b 

Beleaf SG 2.8 1 8.5 ± 2.90 a 4.5 + 1.55 b 10.8 + 2.14 b 24.8 ± 6.14 b 40.3 ± 10.76 a 

Beleaf SG 2.8 2 10.8 + 2.50 a 5.3 + 1.38 b 13.8 + 2.14 b 4.3 + 1.25 b 17.5 ± 0.65 b 

Warrior II 1.92 1 8.0 ± 3.37 a 1.0 + 0.00 b 5.8 + 1.65 b 17.0 ± 2.04 b 44.0 + 8.84 a 

Warrior II 1.92 2 15.3 ± 4.31 a 1.3 ± 0.95 b 4.3 + 1.49 b 5.8 + 1.93 b 20.8 + 7.33 b 

GF 2.75 2 14.0 ± 1.22 a 0.3 ± 0.25 b 9.3 ± 1.60 b 5.5 + 1.55 b 21.8 + 7.82 b 
Table lb 

Trt Rate Applications Days after Treatment 

(oz. product) (14 day interval) 0 7 14 22 30 

UTC 1.0 ± 0.71 a 2.5 ± 0.29 a 33.5 ± 2.50 -a 52.3 ± 7.35 a 64.3 + 11.61 a 

Sulfoxaflor 1.5 1 0.3 + 0.25 a 0.0 ± 0.00 b 3.8 + 1.03 b 41.3 ± 5.84 a 65.8 ± 14.04 a 

Sulfoxaflor 1.5 2 0.5 + 0.50 a 0.5 + 0.29 b 8.3 + 1.32 b 8.3 ± 3.97 b 13.3 + 5.95 a 

Sulfoxaflor 2.25 1 1.5 ± 0.29 a 0,0 ± 0.00 b 4.0 + 1.35 b 26.3 ± 5.36 b 49.8 ± 4.31 a 

Sulfoxaflor 2.25 2 0.3 + 0.25 a 0.0 + 0.00 b 4.5 ± 0.96 b 7.0 + 6.34 b 12.3 + 4.39 b 

BeleafSG 2.8 1 0.5 ± o.so a 1.0 ± 0.41 b 6.0 ± 0.71 b 21.3 ± 1.75 b 62.0 ± 14.16 a 

Beleaf SG 2.8 2 1.5 + 0.87 a 1.3 ± 0.75 b 9.5 + 0.89 b 8.8 ± 2.50 b 13.5 + 

Warrior II 1.92 1 1.0 + 0.41 a 0.0 ± 0.00 b 0.8 + 0.25 b 8.3 ± 1.75 b 44.0 + 

Warrior II 1.92 2 0.3 ± 0.25 a 0.0 + 0.00 b 1.5 + 0.64 b 3.0 + 0.58 b 31.8 ± 

GF 2.75 2 1.0 + 0.41 a 0.0 + 0.00 b 2.5 + 0.65 b 6.5 ± 1.19 b 16.0 + 

Table 2 Mean± SEM number of small (instars 1 l3) and large (instars 4 and 5) lygus bug 

nymphs from insecticide-treated plots of alfalfa grown for seed in Parma, ID in 2013. 

Insecticides were applied to four replicate 0.01 acre plots (22' by 22') in a three 

insecticide, bloom period rotation on 6/28/2013 (1st application), 7112/2013 (2"d 

application) and 7/16/2013 (3'd application). Insect counts are the mean number of 

insects per three 180° sweep net samples taken per replicate plot prior to treatment 14 

days after the final application. Treatments were analyzed by ANOV A df =27, P:S 0.05) 

and means from untreated control plots (UTC) separated using Student's LSD (P:S 0.05). 

2.75 

5.37 

8.41 

4.24 

Trt Rate Mean No. Lygus Bugs 14 days after Final Application 

(Insecticide rotation) (oz. Small Lygus Nymphs Large Lygus Nymphs 

product) (instars 1,2 and 3) (instars 4 and 5) 

UTC 15.4 ± 2.86 a 18.8 ± 4.59 

Be leaf, Assail, Transform 2.8, 2.3, 1.5 8.5 ± 1.11 b 9.4 ± 2.03 

Beleaf, Transform, Rimon 2.8, 1.5, 12.0 8.7 ± 1.46 b 9.4 ± 2.05 

Be leaf, Transform, Warrior 2.8,1.5, 1.9 9.6 + 1.80 b 16.3 + 4.82 

Transform, Beleaf, Rimon 1.5, 2.8, 12.0 6.6 + 1.03 b 5.3 + 1.26 

Power point slideshow: Efficacy of Sulfoxaflor for Control of Lygus Bugs in Alfalfa 

Seed, by Dr. J.D. Barbour, University ofldaho, Pmma Research and Extension Center 

(Attachment #3) 

6a. Pollinator safety of the proposed nse: 

Leafcutting and Alkali Bee Pesticide Safety Trials 

a 

be 

be 

ab 

c 

These tests, conducted in Parma ID 2005-2012 and Prosser WAin 2012 were designed to 

determine the residue hazard offour candidate: flonicamid (Beleaf), bifenthrin (Brigade 2 

EC), sulfloxaflor (Transform 2SC), and flupyradifurone (Sivanto ). The products were 

tested at registered or proposed label rates, as detailed in the table that follows. 

Tests were conducted with pesticides applied with a R&D C02 pressurized sprayer at a 

rate of26 gallons per acre using a hand-held boom. Products were applied to 0.01-acre 

plots of alfalfa being produced for seed. Field-weathered residual test exposures were 

replicated 5 times per candidate insecticide at 3 time intervals (1 hour, 8 hours, and 1 

b 

b 

b 

b 
day,) after the insecticides were applied. Samples consisting of approximately 400 em of 

foliage were taken from the upper 15 em of the plants and clipped to l-inch lengths and 

then placed into individual plastic Petri dish (15 em diameter) replicates, the tops and 

bottoms of which were separated by a wire screen (6.7 meshes/em) insert ( 45 em long 

and 5 em wide). 

Alkali bees were collected by hand individually from a screen mesh barrier. The bees 

were rendered unconscious with an application of C02 and then put in the Petri dish 

bioassay arena. Leafcutting bees were collected individually from a small screen barrier 

placed near a bee shelter. The leafcutting bees were similarly disabled with C02 for easier 

handling and placement in an individual Petri dish bioassay arena. Typically I 0 bees 

were placed in each arena, but some miscounts were made. Bees in cages were fed syrup 

(91: I ratio) in a wad of cotton (5 x 5 em) and held at 75 degrees F for mortality counts. 

Dr. Dan Mayer had concluded that materials or rates of materials that cause less than 

25% mortality with 2-hour residues likely can be applied during early morning with little 

or no hazard to bee populations and those that cause less than 25% mortality with 8-hour 

residues likely can be applied during late evening with little or no hazard. Evidence of 

mortality greater than 25% on residues greater than 24 hours in age should not be applied 

during bloom when bees are actively foraging. The mortality level at each residue age 

and for each bee species was corrected against the control mm1ality of bees placed in 

Petri dish bioassay arenas with alfalfa that was not treated with an insecticide. 

CONTROL MORTALITY 

.R!l~;idu~Age 

1 hr 2 9.8 

8 hr 6 6 

1 day 4 3.3 
*Mortality to acetamiprid recorded after 4 hours 

1 data for acetamiprid and flonicamid not collected after 24 hours 

Bifenthrin was used in these studies as a positive check for a pyrethroid insecticide 

known to be toxic to bees. Be leaf produced consistent results, similar to those from years 

past. We consider Be leaf safe to use during the bloom period when bees are actively 

foraging. Similarly we concluded that the candidate insecticides sulfloxaflor (Transform 

2 SC) at 3 oz per acre and flupyradifurone (Sivanto) the 7 and 14 oz. rate per acre are 

both safe for application in evenings or mornings. Based on both these products' efficacy 

against the major pests of alfalfa produced for seed and their safety to foraging bees, we 

continue work with the registrants to obtain the use of these insecticides on alfalfa 

produced for seed. 

See also Alfalfa leafcutting bee residual toxicity of Transform trials (Attaclunent #3). 

Important Note: Both the August 2013 EPA Staff Evaluation and Review Report for 

Sulfoxaflor: Application for approval to import or manufacture GF-2032 for release 

(ERMA200886) and the 24 March 2015 Health Canada Pest Management Regulatory 

Agency: Proposed Registration Decision for Sulfoxaflor (PRD2015-08) report that 

pollinator mortality risks were considered acceptable or lessened substantially when risk 

reduction measures included on the label are followed. 

7. Residue Information: 

Transform has established tolerances and is currently registered on barley, canola, cotton, 

root and tuber vegetables, potatoes, soybean, succulent, edible podded, and dry beans, 

triticale, and wheat. GLP residue trials have been conducted in-house by Dow 

AgroSciences and residues from the use pattern described in Section 4 of this document 

resulted in residue of 30 ppm. This residue information was submitted to the USEPA as 

part of the tolerance petition packet from Dow AgroSciences. 

Note: Idaho allows Special Local Needs registrations for nonfood and nonfeed use for 

Alfalfa grown for seed under Ru1es Governing Pesticide and Chemigation Use and 

Application, IDAPA 02.03 .03.800.01 (Attachment #4). 

Special Note: Transform WG received a Section 18 Emergency Exemption for control of 

Sugarcane Aphid in Sorghum in Texas in 2014 (File symbol14TX02). Idaho references 
this EPA file for any related and pertinent Section 18 information and requirements 

(Attachment #5). 

8. Risk Information: 

Alfalfa produced as a seed crop is grown in the irrigated regions of Southern Idaho. There 

are several river systems that run tluough the producing areas including the Snake, Boise, 

and Payette. Alfalfa grown as a seed crop is minimally irrigated during and after the 

bloom period and rainfall patterns are such that any chances of precipitation that would 

resnlt in agricultural runoff of storm or irrigation waters from fields of alfalfa produced 

for seed is highly unlikely 

9. Notification of Registrant: 

Dow AgroSciences has been notified of this request and supports it (Attachment #6). 

10. Notification of Other Agencies: 

The U.S. Fish & Wildlife Service Offices in Idaho and the Idaho Department Fish and 

Game have received copies ofthis request. Any comments received from any of the 

listed agencies will be forwarded to the US EPA. 

11. Enforcement Program: 

ISDA has adequate authority for enforcing provisions of Section 18 Emergency 

Exemptions and have been doing so for many years. We would be glad to answer 

any specific questions regarding our enforcement progran1. 

12. Progress Toward Registration: 

A complete Section 3 application is being prepared for submission to US EPA for the use 

of sulfoxaflor on alfalfa with a scheduled PRIA date of April 2015. 

B. REQUIREMENTS FOR SPECIFIC EXEMPTIONS BASED ON 

SIGNIFICANT ECONOMIC LOSS 

1. Pests to be Controlled 

Lygus bug (Lygus hesperus, L. elisus, and several other Lygus species) 

2. Discussion of the Emergency Situation 

The key direct pest of alfalfa produced for seed is the Lygus bug, Lygus hesperus and L. 

elisus. Lygus feeding on blossoms, seed, and seedpods can subsequently reduce seed 

yield at harvest by 7 5 to 1 00%. Unfortunately alfalfa bloom and peak pollinator activity 

coincide with Lygus bug population outbreaks. Alfalfa Seed Growers and their industry 

representatives (Attachment #7) need to be assured that they can balance pesticides 
applied for control of Lygus bugs while causing minimal harm to their valuable 

pollinators. Mitigation efforts in the past have included applying insecticides in the early 

morning or evening when bees are not foraging, allowing spray residues to dry by dawn 

when the bees forage and developing and registering soft chemistries that control Lygus 

with little hatm to bees. 

Drought conditions in the western US; particularly California but also in Idaho 

Counties (Attachment #8) has resulted in in a dramatic increase in the price of alfalfa 

as a forage crop prompting Pacific Northwest growers to increase their acreage. 

Consequently the acreage of forage alfalfa produced in proximity to fields of alfalfa 

produced for seed has increased. Drs. Doug Walsh and Tim Waters have documented 

through a transect trapping program that forage alfalfa is the key source of Lygus 

adults that migrate into fields of alfalfa produced for seed. Fields of alfalfa forage are 

cut and harvested on average 3 times per growing season. Adult L ygus are herded out 

of forage fields during these harvest events subsequently migrate in great abundance 

to fields of alfalfa produced for seed. 

Lygus is a generalist pest of many different crops and has a well-documented history 

of developing resistance to the insecticides applied for its control. 

3. Discussion of Significant Economic Loss (SEL ): 

Records of seed production (lbs.) in Idaho (source: Idaho Alfalfa & Clover Seed 

Commission) from 2006 through 2010. 

Ye•r•····· ... Prpdui;tiqh< ~~JV~S,te~·.·I·.··Vield···.· .. ·.·· 

·• .>.••·•· . ) . Jibs;) ( A~re~ < (lbs.p~racre) 

2006 10,050,000 15,000 670 

2007 10,350,000 15,000 690 

2008 8,520,000 12,000 710 

2009 8,140,000 11,000 740 

2010 8,160,000 8,500 960 

Ptrc_e~ 

(pe(c.wt) 

$1.35 

$1.49 

$2.00 

$2.07 

$1.99 

~~venue · 

(p~r~cre) ·•· 

$905 

$1,028 

$1,420 

$1,532 

$1,910 

Complete production statistics for 2011 to present are not available; however, the number 

of pounds of alfalfa seed produced in Idaho from 2011 through 2013 averaged 8,153, 

398.6lbs. (Idaho Alfalfa and Clover Seed Commission). Prices in 2013 were 

approximately $2.20/lb. Estimated average net revenue 2010-2013 in Idaho would be 

$17,934,477. 

In 2006, Hinman and Kugler estimated that costs associated with establishing a fall 

seeded alfalfa seed crop was$ 477.62 and that the operating expenses for alfalfa 

produced for seed was $1,126.86 in year I, $1,080.23 in year 2, and $1,074.97 in year 3 

(http://www.farm-mgmt.wsu.edn/PDF-docs/irrigated/eb2013e.pdf). They assumed that a 

grower had received a 3 year contract from the genetic provider they were increasing 

seed for. Amortizing planting the expenses over 3 years and averaging the tluee years of 

estimated cost of production this averages to $1,252.23 per acre per year. Production 
costs would be similar for Idaho. These 2006 estimates are certainly out of date most 

notably with the costs associated with pollination services provided by purchased alfalfa 

leafcutting bees that have increased substantially over the past several years. 

E E mergency xemp t' ton, T' 1er 1 A 1 . na ys1s, Id a o h 

With Without Change % 

Transform Transform Change 

Production 8,153, 397 6,527,717 1,625,680lbs 20% 

(lbs.) 

Price $2.2 $2.2 $2.2 

($/lb.) 

Revenue $17,934,477 $14,360,981 $3,576,495 20% 

Summary 

Due to the severe infestations and damage that has occurred in recent growing 

seasons from lygus bugs in alfalfa fields grown for seed, growers are requesting the 

emergency use of Transform WG (Sulfoxaflor). Idaho alfalfa has suffered from 

extreme drought conditions in recent years making it less vigorous and recuperate, 

and as a result more vulnerable to lygus bugs. Studies show Transform WG, when 

used in a pest control management plan along with Beleaf provides successfullygus 

bug control. Due to warranted concerns for pollinator safety by growers, uses of other 

products are not feasible in their Pollinator Protection Plans. Alfalfa Seed Growers 

are very concerned about protection for their pollinators and Transform WG, when 

used in accordance to the product label, is a good fit to reduce possible risks. 

Sulfoxaflor is classified in the Insecticide Resistance Action Committee's subgroup 

4C making it an ideal choice compared to other products like pyrethroids that have 

been used extensively in the past to the point that resistance is a documented concern 

now. As noted, this requested use of Transform WG on Alfalfa grown for seed is for 

non-food and non-feed purposes only so it will not enter into the food chain. 

Sincerely, 

George Robinson, Administrator 

Idaho State Dept of Agriculture 

Division of Agricultural Resources 

Office: (208) 332-8531 

Email: George.Robinson@agri.idaho.gov 
P.c.: 

Dr. Jim Barbour, U ofl Ext. 

Steve Foss, Washington State Depatiment of Agriculture 

Erik Johansen, Washington State Depmiment of Agriculture 

David Priebe, Oregon Depatiment of Agriculture 

Dr. Doug Walsh, WSU Ext. 

Ronda Himyck, University ofldaho 

Russ Holder, US F&W 

Jmney Thomas, Dow AgroSciences 

Roger Batt, ISPC 

Attachments 

1. Draft Section 18 label for use of Transform (EPA Reg. No. 62719-625) on alfalfa 

produced for seed. 

2. Section 3 Label for Transform 

3. Power Point Slides" Efficacy ofSulfoxaflor for Control ofLygus Bugs in Alfalfa 

Seed." 

4. IDAPA 02.03.03.800.01 

5. 2014 approved Section 18 for Transform WG in Texas 

6. Letter of suppmi from Dr. James Thomas, Dow AgroSciences 

7. Industry suppoti letters. 

8. U.S. Seasonal Drought Outlook and Idaho Emergency Designation.