# 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: Emergencyuse ofsulfoxaflor, formulated as theproductTransform SOWG (EPA Reg. No. 62179-625) for use onalfalfa grownfor seed to control ofLygus Bug inAda, Canyon, Owyhee andPayette counties inIdaho.
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 ofPlant, Soil and Entomological Sciences University ofIdaho ParmaResearch and Extension Center, 29603 

### 0 oflLane Parma, ID 83660-6590 Tel: 208-722-67017 Fax: 208-722-6708 Email: jbarbour@uidaho.edu

Dr. DougWalsh , 

# .

Associate Entomologist!Environmental and Agrichemical Education Specialist WSU ProsserIAREC 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.gov3. Description ofthe Pesticide: BrandName: Transfonn® 50WG EPAReg. No: 62179-625 Active Ingredient: sulfoxaflor Percent ofActive 50% Registrant: DowAgroSciences, Zionsville, IN
Sulfoxaflor is a sulfoximine insecticide that currently is registered (EPA Registration No.62719-625) underthe trade name Transform® by Dow AgroSciences, Zionsville, IN.

The sulfoximine class ofinsecticides is characterized by sulfoxaflor ([N-[methyloxido[l[ 6-(tritluoromethyl)-3-pyridinyl]ethyl]-AA-sulfanylidene] cyanamide] and represents a new class ofinsecticides that exhibits a high degree ofselective efficacy against a wide range ofsap-feeding insects including plantbugs and aphids. Sulfoxaflor is an agonist at insect nicotinic acetylcholine receptors (nAChRs) and functions in a manner distinct from other insecticides that act atnAChRs. 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 ofthat subgroup.

The primarytarget insect for whichthis emergency request is being made for is Lygus bugs. Lygus bugs in alfalfa produced for seed consists ofa mixed population ofseveral insect species dominated by Lygus hesperus Knight (Heteroptera: Miridae) andLygus elisus Carvalho. Lygushesperus accounts for 80% to 90% ofthe 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% ofthe population. Lygus bugs exposedto 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 ofeconomically sustainable alfalfa seed yields, and represent a significantpropmtion (20-30%) ofthe per acre costs ofalfalfa seed production. The major pollinator ofalfalfa seed in Idaho is the alfalfa leafcutter bee, Megachile rotunda/a Fabricius (Hymenoptera: Megachilidae). Significant numbers ofthe alkali beeNomia melanderi Ckll. (Hymenoptera: Halictidae) are used in Washington and Nevada. ConculTently researchhas shown that once sulfoxaflor has dried onthe leaf, it is notharmful to the alfalfa leafcutting bee, Megachile rotunda/a (Attachment #3) and thealkali bee, Nomia melanderi, the two key pollinators ofalfalfaproducedfor seedin Idaho and Washington.


### 4. Description ofthe Proposed Use: a) Sites to be treated: alfalfa seed fields in Ada, Canyon, Cassia, Franklin, Jerome, Oneida, Owyhee, Payette and TwinFalls Counties ofldaho. b) Method ofApplication: Ground c) Rate ofapplication: 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) MaximumNumber ofApplications: Two e) Total Acreage to be Treated: 12,000 acres f) Total Amount ofPesticide to be used: 4,125lbs. ofTransform (2,062.5 lbs. a.i.). g) Use season: May 30,2014through 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, oflakes; reservoirs; rivers; permanent streams, marshes or natural ponds; estuaries and commercialfish farms.

• Do not make applications less than 7 days apart.

• Do not apply more than 5.5 oz. ofTransform (0.172lbs. a.i. sulfoxa:flor) per acre peryear.

• Apply at night, after sunset and before sunrise, when bees are not actively foraging in fields ofalfalfa produced for seed. j) A copy ofthe Section 18 label mustbe inthe possession ofthe user atthe time ofapplication inIdaho. k) The Idaho State Dept. ofAgriculture must be immediately informed ofany adverse effects that mayresult from this use ofTransfonn on alfalfa produced for seed. The number for ISDA is: (208) 332-8613. f) Follow all applicable restrictions, directions andprecautions on the EPAregistered label for Transform (Attachment #2).



### 5. Alternative Control Measures

a. Registered Alternative Pesticides Flonicamid (Beleaf50 SG Insecticide) and naled (Dibrom 8 Emulsive) have provided effective control ofLygus bugs in a blended tank mixduring bloom for a residual ofapproximately 7 days. Naledis relatively toxicto pollinating bees ifthe bees are exposed to wet residues ofnaled. Hencethe growers typically restrict themselves to applying this tankmix offlonicamid and naled during evenings whenbees are not active and residues can dry overnight. In addition, Beleaf, is locally systemic (translaminar) in succulent foliage, but does notmove well, and is thus less effective during the late bloomperiod as foliage begins senescing in midto late June. Be leafis limitedto two applications per crop year makingit a good early season control tool butis notfeasible for later cycle applications. Beleaf(early) and Transform WG (late) will work well together in getting optimumLygus 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 onalfalfaproduced for seed under a 24C Special Local Need registration. All ofthese pyrethroid insecticides caneffectively control Lygus bugs but are extremelytoxic to foraging bees and cannotbe used for Lygus bug control during bloom. Organophosphates including chlorpyrifos, dimethoate, malathion, methyl parathion and oxydemetonmethyl have either a Section 3 registration on alfalfa or are registered on alfalfa produced for seed under a 24C Special LocalNeedregistration. All ofthese organophosphateinsecticides can effectively control Lygus bugs but collectively are extremely toxic to foraging bees and cmmot be usedfor Lygus bug control during bloom. Carbamates including carbaryl, methomyl and formetanate hydrochloride
are registered onforage alfalfa under Section 3 with direct labeling that restricts their use during bloom. All ofthese carbamate insecticides can effectively control Lygus bugs but are extremely toxic to foraging bees and cannot be usedfor Lygus bug control during bloom. Chiton inhibitors/ growth regulators. Novaluron (Rimon) canprovide good control ofLygus, but is highly toxic to larvae ofalfalfa leafcutting bees and other bees. Its use in alfalfa seed is advised only during the late bloomperiod after adult bees have laid eggs and provisioned larvae. Application during early bloom can results in 20% to 50% reduction ofoverwintering alfalfa leafcutting bees. Figure 1. Mean number(± sem)ofbrood cells produced andpercentage live larvae for alfalfa leafcutting bees collected from alfalfa not treated with Rimon ortreated with Rimon (12 oz. ofRimon 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 ofcell 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 of5 parasitic wasp species that is dominated by the species Peristenus howardihas beendocumented in several locations (most notably Parma, ID) as a parasite ofLygus bug populations. Unfortunately wehave never observed levels ofparasitismto exceed 15% in commercial seedproductionfields in Idaho and P. howardi does not provide effective control oflygusbugs inIdaho. 

### 6a. Efficacy ofthe proposed use: Table 

### I. Mean± SEM number ofsmall (instars 1-3: Table 1a) and large (instars 4 and 5: Table 1 b) lygus bug nymphs fi·om insecticide-treatedplots ofalfalfa grown for seedin Parma, ID in2012. 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 ofinsects perthree 180° sweep net samples taken per replicate plotpriorto treatment and, 7, 14, 22 and 30 days aftertreatment. Treatments
were analyzed byANOVA

### df=27, P:S 0.05) and means from untreated control plots (UTC) separated from treated plots using Dunnett'sprocedure (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 BeleafSG 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 BeleafSG 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 bTable 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 BeleafSG 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 ofsmall (instars 1 l3) and large (instars 4 and 5) lygus bug nymphs from insecticide-treatedplots ofalfalfa grown for seedinParma, ID in 2013. Insecticides were applied to four replicate 0.01 acre plots (22' by22') ina three insecticide, bloomperiodrotation on 6/28/2013 (1st application), 7112/2013 (2"d application) and 7/16/2013 (3'd application). Insect counts are the meannumber of insects perthree 180° sweep net samples takenperreplicate plotpriorto treatment 14 days after the final application. Treatments were analyzed byANOVA df =27, P:S 0.05) and means from untreated control plots (UTC) separatedusing Student's LSD (P:S 0.05). 2.75 5.37 8.41 4.24

Trt Rate Mean No. Lygus Bugs 14days 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 ofSulfoxaflorfor Control ofLygus Bugs in Alfalfa Seed, by Dr. J.D. Barbour, University ofldaho, PmmaResearch and Extension Center (Attachment#3)


### 6a. Pollinator safety ofthe proposed nse: Leafcutting and Alkali Bee Pesticide Safety Trials a be be ab
c

These tests, conducted in ParmaID 2005-2012 and Prosser WAin2012 were designed to determine theresidue hazard offour candidate: flonicamid (Beleaf), bifenthrin (Brigade 2 EC), sulfloxaflor (Transform 2SC), and flupyradifurone (Sivanto). The products were tested atregistered or proposed label rates, as detailed in the table that follows.

Tests were conducted withpesticides 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 ofalfalfa beingproduced 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 bday,) after the insecticides were applied. Samples consisting ofapproximately 400 em of foliage were taken from the upper 15 em ofthe plants and clipped to l-inch lengths and then placed into individual plastic Petri dish (15 em diameter) replicates, thetops and bottoms ofwhich were separated by a wire screen (6.7 meshes/em) insert (45 em long and 5 em wide).
Alkali bees were collectedbyhand individually from a screen mesh barrier. The bees
were rendered unconscious with an application ofC02 and then put in the Petri dish bioassay arena. Leafcutting bees were collected individually from a small screenbarrier placed near abee shelter. The leafcuttingbees were similarly disabled with C02for easier handling and placement in an individual Petri dish bioassay arena. Typically I0 bees
were placed in each arena, but some miscounts were made. Bees incages were fed syrup (91: I ratio) in a wad ofcotton (5 x 5 em) and held at 75 degrees F for mortality counts.
Dr. DanMayerhad concluded that materials or rates ofmaterials that cause less than 25% mortality with 2-hour residues likely canbe applied during early morning with little
orno hazardto bee populations and those that cause less than 25% mortality with 8-hour residues likely canbe applied during late evening withlittle orno 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 eachresidue age and for each bee species was corrected against the control mm1ality ofbees placed in Petri dishbioassay arenas with alfalfathat was not treated with aninsecticide.

CONTROL MORTALITY

**.R!l~;idu~Age** 1 hr 2 9.8 8 hr 6 6 1 day 4 3.3*Mortalityto acetamipridrecorded after 4 hours 1 datafor acetamiprid and flonicamid not collected after 24 hours

Bifenthrin was used inthese studies as a positive check for a pyrethroid insecticide known to be toxic to bees. Be leafproduced consistent results, similar to those from years past. We consider Be leafsafe to use during the bloomperiod whenbees 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 ormornings. Based onboth these products' efficacy against the major pests ofalfalfaproduced for seed and their safetyto foraging bees, we continue work with the registrants to obtain the use ofthese insecticides on alfalfa produced for seed.

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

### Important Note: Both the August 2013 EPA StaffEvaluation and Review Report for Sulfoxaflor: Application for approval to import or manufacture GF-2032 for release (ERMA200886) and the 24 March 2015 Health Canada PestManagementRegulatory Agency: Proposed Registration Decisionfor Sulfoxaflor (PRD2015-08) reportthat pollinator mortalityrisks were considered acceptable or lessened substantially when risk reduction measures included onthe label are followed.



### 7. Residue Information: Transformhas established tolerances and is currentlyregistered on barley, canola, cotton, root and tuber vegetables, potatoes, soybean, succulent, ediblepodded, and drybeans, triticale, and wheat. GLP residue trials have been conducted in-houseby Dow AgroSciences and residues from the use pattern described in Section4 ofthis document resulted in residue of30 ppm. This residue information was submitted to the USEPA as part ofthe tolerance petitionpacket from DowAgroSciences.

Note: Idaho allows Special Local Needs registrations for nonfood and nonfeed use for Alfalfa grown for seedunder Ru1es Governing Pesticide and ChemigationUse and Application, IDAPA 02.03 .03.800.01 (Attachment#4). Special Note: Transform WGreceived a Section 18 Emergency Exemptionfor control of Sugarcane Aphid in Sorghum in Texas in2014 (File symbol14TX02). Idaho referencesthis EPAfile for any related and pertinent Section 18 information and requirements (Attachment#5).

8. RiskInformation: Alfalfa produced as a seed crop is growninthe irrigated regions ofSouthern Idaho. There
are several river systems thatrun tluough theproducing 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 suchthat any chances ofprecipitationthat would resnlt in agricultural runoffofstorm or irrigation waters from fields ofalfalfaproduced for seed is highly unlikely

9. Notification ofRegistrant: Dow AgroSciences has been notified ofthis request and supports it (Attachment #6).

10. Notification ofOther Agencies: The U.S. Fish & Wildlife Service Offices in Idaho and the Idaho Department Fish and Game have received copies ofthisrequest. Any comments received from any ofthe listed agencies will be forwarded to the US EPA.

11. Enforcement Program: ISDAhas adequate authority for enforcing provisions ofSection 18 Emergency Exemptions and have been doing so for many years. We would be glad to answer any specific questions regarding our enforcementprogran1.

12. Progress Toward Registration: A complete Section 3 application is being prepared for submissionto US EPA for the use ofsulfoxaflor on alfalfa with a scheduled PRIA date ofApril 

### 2015.

B. REQUIREMENTS FOR SPECIFIC EXEMPTIONS BASED ON SIGNIFICANT ECONOMIC LOSS 1. Pests to be Controlled Lygus bug (Lygus hesperus, L. elisus, andseveral otherLygus species)

2. Discussion ofthe Emergency Situation The key direct pest ofalfalfaproduced for seed is the Lygus bug,Lygus hesperus andL. elisus. Lygus feeding onblossoms, seed, and seedpods can subsequentlyreduce seed yield at harvest by 7 5 to 

### 1 00%. Unfortunately alfalfabloom and peakpollinator activity coincide with Lygus bugpopulation outbreaks. Alfalfa Seed Growers and their industry representatives (Attachment#7) need to be assuredthat they canbalance pesticidesapplied for control ofLygus bugs while causing minimal harmto their valuable pollinators. Mitigation efforts inthepasthave included applying insecticides in the early morning or evening when bees are not foraging, allowing spray residues to dry by dawn whenthe bees forage and developing and registering soft chemistries that control Lygus with little hatm to bees. Drought conditions inthe western US; particularly Californiabut also in Idaho Counties (Attachment #8) has resulted in in a dramatic increase inthe price ofalfalfa
as a forage crop prompting Pacific Northwest growers to increase their acreage. Consequently the acreage offorage alfalfaproduced inproximity to fields ofalfalfa produced for seed has increased. Drs. Doug Walsh and Tim Waters have documented through a transect trappingprogram that forage alfalfa is thekey source ofLygus adults that migrate into fields ofalfalfaproduced for seed. Fields ofalfalfa forage are cut and harvested on average 3 times per growing season. Adult Lygus are herded out offorage fields during these harvest events subsequently migrate in great abundance to fields ofalfalfaproducedfor seed. Lygus is a generalist pest ofmany different crops and has a well-documented history ofdeveloping resistance to the insecticides applied for its control.



### 3. Discussion ofSignificant Economic Loss (SEL): Records ofseed production (lbs.) inIdaho (source: Idaho Alfalfa & Clover Seed Commission) from 2006 through 2010. 

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### (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 Completeproduction statistics for 2011 to present are not available; however, the number ofpounds ofalfalfa seedproduced inIdaho 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 netrevenue 2010-2013 in Idaho wouldbe $17,934,477.

In 2006, Hinman and Kugler estimated that costs associated with establishing a fall seeded alfalfa seed crop was$ 477.62 and thatthe operating expenses for alfalfa producedfor 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 contractfrom the genetic provider they were increasing seed for. Amortizing plantingthe expenses over 3 years and averaging the tluee years of estimated cost ofproductionthis averages to $1,252.23 per acre per year. Productioncosts would be similarfor Idaho. These 2006 estimates are certainly out ofdate 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 

### t' T' 1 A 1 . Id h

mergency xemp ton, 1er na ys1s, a o 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 ofTransform WG (Sulfoxaflor). Idaho alfalfa has suffered from extreme drought conditions inrecent years making it less vigorous and recuperate, and as a result more vulnerable to lygus bugs. Studies showTransform WG, when used in a pest control management plan along with Beleafprovides successfullygus bug control. Dueto warranted concerns for pollinator safety by growers, uses ofother products are not feasible intheir Pollinator Protection Plans. Alfalfa Seed Growers
are very concerned about protectionfor their pollinators and Transform WG, when used in accordance to the productlabel, 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 otherproducts like pyrethroids that have been used extensively in the pastto the pointthatresistance is a documented concern now. As noted, this requested use ofTransform WG onAlfalfa grown for seed is for non-food and non-feedpurposes only so it will not enter into the food chain. Sincerely,

George Robinson, Administrator Idaho State Dept ofAgriculture Division ofAgricultural Resources Office: (208) 332-8531 Email: George.Robinson@agri.idaho.govP.c.: Dr. Jim Barbour, U oflExt. Steve Foss, Washington State Depatiment ofAgriculture Erik Johansen, Washington State Depmiment ofAgriculture David Priebe, Oregon Depatiment ofAgriculture Dr. Doug Walsh, WSUExt. Ronda Himyck, University ofldaho Russ Holder, US F&W Jmney Thomas, DowAgroSciences Roger Batt, ISPC
Attachments 1. Draft Section 18 label for use ofTransform (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 TransformWG in Texas 6. Letter ofsuppmi from Dr. James Thomas, DowAgroSciences 7. Industry suppoti letters. 8. U.S. Seasonal Drought Outlook and Idaho Emergency Designation.