### DEPAR'I'MENf OJF' AGRJICUJL'I'URE DllVllSllON OJF' AGRJlClJJL'I'URAL RESOURCES

March 15,2016

Tawanda Maignan, Team Leader Emergency Response Team (7505P) USEPA/OPP Document Processing Desk (EMEX) Room S4900, One Potomac Yard 2777 S. Crystal Drive Arlington, VA 22202 C.L. "BUTCH"' OTTER Governor CELIA R. GOULD Director

Re: Emergency use ofpyridate, formulated as the product ToughHerbicide (Not currently registered in the U.S.) for use on mint to control broadleafweeds, inparticularRedroot Pigweed, Armaranthus retroflexus andKochia, Kochia scoparia inAda, Canyon, Elmore, Gem, Owyhee, Payette and Washington counties in Idaho.
A. Summary ofGeneral Information
1. Type ofExemption: Specific
2. Contact Persons:
Steve Salisbury (Teclmical) Mint Industry Research Council PO Box4059 Salem, OR97302-1059 Phone: 503-551-3747 Email: steve@pacificagresources.com
Dr. DonMorishita (Scientific) University ofIdaho Kimberly Research & Ext. Center 3793 North 3600 East Kimberly, ID 83341-5076 Phone:208-423-4691 Email: don@uidaho.edu

2270 Old Penitentiary Road • P.O. Box 790 • Boise, Idaho 83701 • (208) 332-8605 • Fax (208) 334-3547 • www.agri.idaho.govRoger Batt (Economics) Idaho Mint Commission 55 SW 5th Ave. #100 Meridian, ID 83642 Phone 208-888-0988 Email: Roger@amgidaho.com
Liesbeth Bosman (Registrant) Belchim Crop Protection, Inc. Techno1ogie1aan 7 1840 Londerzeel Belgium Phone: +32 (0) 473 86 52 33 Email: Liesbeth.Bosman@Belchim.com

3. Description ofPesticide Active Ingredient: Pyridate
Trade Name: Tough Herbicide SEC, not currently registered inU.S.
Formulation: Emulsifiable concentrate formulated at 55.8% (5.0 lb. ai. pergal.) and 44.2% inert ingredients. Registrant/Manufacturer: Belchim Crop Protection is aBelgium-based company (EPA Co. No. 91746). The U.S. distributor is Engage Agro USA Corp.
4. Description ofProposed Use

a. Sites to be Treated There isjust over 18,000 acres ofmint grown inIdaho. It is estimated that approximately 9,000 (50%) ofthis acreage will needto betreated with Tough. The mint production areas are located in southwest Idaho counties ofAda, Canyon, Elmore, Gem, Owyhee, Payette and Washington. There is also some production in the southcentral county ofTwin Falls. The soils ofthese mint growing counties are generally productive, deep, and fertile in agricultural areas where a diversity ofcrops are also grown. b. Method ofApplication The herbicide will be applied by ground-driven spray equipment by licensed applicators according to the proposed Section 3 product label and Section 18 label. Toughmay not be applied by aerial methods, or through any type ofirrigation system and prohibitions on these types ofapplications are included on the Section 18 label.

c. Rate ofApplication A maximum of.9375lb. active ingredientper acre (24 ounces ofproductper acre) in 20-40 gallons ofwater per acre will be applied during the growing season.d. MaximumNumber ofApplications A maximum oftwo applications ofTough per growing season may be made, ifnecessary, with a minimum of 14 days between applications. Applications maybe made between April 1 and December 31, 2016. No applications may be made within 49 days ofharvest.

e. Total Acreage to be Treated Itis estimated that approximately 9,000 acres (50% oftotal Idaho acreage) will need to be treated with Tough.
f. Total pesticide to be used An estimated 3,375 gallons (16,875lbs ofa.i.) ofherbicide are expected to be applied. 9,000acre * 24 fl.oz. * 2 applications= 3,375 gal. offormulated product. 3,375 gal* 5lb a.i./ gal= 16,875lbs ofactive ingredient.

g. Use season We are requesting application beginning April 1through December 31, 2016. A fall application after harvest maybe necessary ifconditions promotingweed growth occur. No applications will be made within 49 days ofharvest.
h. Harvest Dates The majority ofpeppermint acreage is harvested once in August. However, some peppermint growers are double cutting their crop. Double-cut mint is harvestedtwice during the growing year, once in June and again in late August or early September. Spearmint is harvested twice during the growing season, once in the middle ofJune and again inthe middle ofAugust.
i. Other Restrictions, User Precautions, and Requirements Federal and supplemental labels address reentry and worker protection, environmental hazards and restrictions (see attached label). Treated fields or forage from treated fields may not be used for livestock feed or grazing. Tough will not be applied through any type ofirrigation system or by air. To protect endangered freshwater invertebrate species, Tough will not be applied within 100 yards ofany freshwater spring.
5. Alternative Methods ofControl

a. Registered Post-Emergent Herbicide Alternatives
1. Bentazon (Basagran)- Provides inconsistent (partial) post-emergence control of Kochia. Does not control pigweed. Weeds emerging after application are not controlled.
2. Bromoxynil (Maestro)

- Phytotoxic to actively growing mint. Cannot be applied above 70 degrees F to actively growing mint. Only gives partial control ofKochiaand Pigweed seedlings. Kochia and Pigweed seeds germinate (multiple flushes) throughout the growing season.3. Clethodim (Select Max)- Grass weed control only.
4. Clopryalid (Stinger)- For spot treatment, post emergence control ofbroadleafweeds (canada thistle, dandelion). Destroys mint which comes in contact withthe herbicide. Does not control Kochia or Pigweed
5. MCPB (Thistrol)- Can only be applied early post-emergent to weeds and to dormant or small/newly emergedmint. Itis limitedto pmtial control ofCanadathistle and field bindweed. Does cause crop injury and loss ofoil yield.
6. Quizalifop (Assure II)- Grass weed control only.
7. Sethoxydim (Poast Plus)

- Grass weed control only.
8. Terbacil (Sinbar)- Does not control Kochia and Pigweed has developed resistant biotypes, due to years ofcontinuous use. It is not effective on weeds that have grown beyond the seedling stage. Carmot be used when rotating from mint into other crops the following year, due to soil persistence m1d crop rotational restriction. Cannot be used on sandy, loamy sands, or soils with less than 

### 1% organic matter without crop injury.
b. Other alternatives Mechanical weed control methods such as tillage are not feasible orpracticed in actively growing mint due to the destruction ofthe crop. Tillage in mint at any time also spreads the disease Verticillium Wilt, a fungal pathogen in mint which is spread bythe movement of soil and debris. Tillage also spreads the rhizomes and stolons ofperennial weeds. Hand rogueing is cost prohibitive and does not provide season long control ofweeds as weed seeds continue to germinate in the soil throughout growing season. In addition, the labor needed for hand weeding is not available inmost mint growing regions. Crop rotation is practiced when feasible, butmintis aperennial crop andis leftinproductionfor 3to 5years, or longer. Research on biological control methods is currently being conducted, but as ofto date no effective methods have been developed.

c. On-going research for chemical alternatives The mint industry has placed a high priority onfinding altematives to pyridate for post-emergence broadleafweed control. The industry has diligently invested several hundred thousands ofdollars ofresearch funds over the past decade towm·d this effort. Numerous pre-emergent and post-emergent herbicides have beentested and evaluated with little or no success. Pre-emergence herbicides evaluated include pendamethalin, terbacil, saflufenacil, sulfentrazone, flumioxazin, oxyfluorfen, pyroxasulfone and both oxyfluorfen and flumioxazin impregnated on fertilizer. Post-emergence herbicides that have beentested include bentazon, terbacil, bromoxynil, bicyclopyrone, mesotrione, tembotrione, topramezone, fluroxypyr, MCPB, and carfentrazone. These herbicides are either too injurious to the mint or do not adequately control the pigweed. A letter from Dr. Rick Boydston, USDA-ARS, summarizes mint herbicide research since 2006.In summary, despite extensive effmis, the mint industry has not been able to successfully find an adequate replacement for pyridate (Tough herbicide) to providepost-emergence weed control, without causing significant injury to the mint crop. Therefore, weed control remains anurgent situation challenging the ability to produce high quality mint oil.

In additionto the urgency ofthe situation, it is important to note that post-emergence broadleafweed control has recently developed into a non-routine situation due to the increased demand for double-cut production acreage. Many acres have beenforced to double-cut productionto meet recent global regulatory and market demands. Fmiher description ofthis non-routine situation is discussed in SectionB Pmi 2 (Description ofthe Emergency Condition) ofthis request.
6. Efficacy ofthe Proposed Use Results ofefficacy and comparative field trials are attached. However, trial data in Idaho is limited. Therefore, a letter ofsupport fi·om Dr. Rick Boydston, USDA-ARS, inProsser, W A is attached (Attach#6) to help explainthe benefits and usability ofTough inmint production. Dr. Boydston has been instrumental inweed controlresearch in mintproduction for nearly three decades. Additionally, Dr. DonMorishita, Superintendent and Extension Professor at the University ofIdaho-Kimberly Research and Extension Center, is available for comment on weed control in mint production. Tough selectively controls annual weeds in mint without causing significant crop injury. Risks to rotational crops are minimized due to the shorthalf-life and low soilpersistence leadingto
no residual impact to subsequent crops. Tough is the only known broadleafherbicidethat can provide post-emergent control ofweeds without impacting crop yield.
7. Residue Information Residue trials for mint were conductedby the IR-4 Program in 1994. Applications made in accordance withthe requested provisions are not expected to result inresidues ofpyridate and its metabolites in excess of0.2 ppm for peppermint and spearmint tops. These tolerances have been established by theEPA and are recorded under CFR 180.462 (see Attach#7). Secondm-y residues inmeat, poultry, and eggs m·e not expected to result.
8. RiskInformation On May 3, 2000 the EPA established tolerances of0.2 ppm for residues ofpyridate and its metabolites in/onpeppermint and spearmint tops (see Attach #8). Information regarding py:ridate toxicology and aggregate exposure canbe found inthe finaltule published inthe Federal Register May 3, 2000, volume 65, number 86, pages 25647-25652.

a. Human Health Tough herbicide poses little potential risks to humans, domestic animals, wildlife, and the environment. The acute oral LD50 for male rats is> 5,000 mg/kg. The active ingredient has a low dermal irritation potential and a low inhalation hazard. Acute dermal LD50 for rabbits is> 2,000 mg/kg. InhalationLC50 >4.37 mg./Lair. Primary dermal irritation study indicated it is mildly irritating to rabbit skin (EPA Health Effects Division ofthe Office of Pesticide Programs, 2000).The EPA concluded that residues ofpyridate in drinking water do not contribute significantly to the aggregate acute human health risk. The acute human health risks resulting from exposure to pyridate in food and water are belowEPA'slevel ofconcernfor all population subgroups. As for chronic risk, the EPA also concludedthat no harm will result from aggregate chronic exposure.
Itwas also determined thatpyridate is notcarcinogenic in eitherrat or mouse, and therefore is not expectedto pose a cancer risk to humans.
The product label addresses the risksto worker/applicatorbyoutlininghandlerprecautions and required personal protective equipment.
b. Potential to be found indrinking water The potential for exposure to residues ofpyridate in drinking water is negligible due to its low water solubility (l.Smg/L at 20 C), strong soil adsorption (Kd = .3-26) and shmt half-life (7-21 days). Pyridate is essentially immobile in all soil types and any risks to surface or groundwater contamination will be negligible.
The EPA Health Effects Division determined that pyridate does notpossess the enviromnental fate parameters associated with a compound that could leachto groundwater. However, the parameters ofits degradate indicate that under unusual conditions such as flooding, where anaerobic conditions persistintopsoilfor up to 60 days, the degradate couldpossibly leach to groundwater orrun offto surface water. Pyridate is not listed in the EPA Pesticides in Ground Water Database, noris there anEPAMaximum Contaimnent Level or health advisory.

c. Residential Uses Pyridate is notregistered for use in ornamentals or in residential areas.
d. CommonMode ofAction Pyridate is a Group 6 herbicide, HRAC Group C3 (Herbicide Resistance Action Committee, www.hracglobal.com). Itbelongs to the phenyl-pyridazine family of herbicides. Its site ofaction is inhibitionphotosynthesis by blocking electrontranspmt in photosystem II (reactions taking place in the chloroplast thylakoid membranes).

e. Endangered or Threatened Species Endangered or threatened species listed by the USFWS withinthe mint production counties ofAda, Canyon, Elmore, Gem, Owyhee, Twin Falls, and Washington are listed in Attachment #9.
The use ofTough herbicide in accordance to the label in mint fields should not pose a risk to any threatened or endangered species.
f. Beneficial Organisms Tough is not toxic to bees and other beneficial insects (i.e. lady beetles, predatory mites). See the attached EPA Enviromnental Fate and Effects Division (EFED) report.g. Fish and Aguatic Organisms Pryridate is consideredtoxic to estuarine organisms. However, due to its strong soil adsorption and short half-life, ifapplied according to the label it should not pose a risk to estuarine organisms (see attached EPA EFED report). The label states that this material should not be applied within 100 yards ofany freshwater spring, directly to water, to areas where surface water is present, or to intertidal areas below the meanhigh water mark.
9. Coordinate with Other Agencies The Idaho Fish and Game Office ofthe U.S. Fish and Wildlife Service will receive a copy ofthis request. Any comments received will be forwarded to the U.S. EPA.
10. Notification ofRegistrant Belchim Crop Protection has beennotified and their letter ofsupport is attached (see Attach#11). In addition, Engage Agro USA Corp. is the U.S. distributor and they have also been notified. A letter ofsupport from Engage Agro USAis also attached (see Attach#12).
11. Enforcement Program The Idaho State Department ofAgriculture (ISDA) has adequate authorities for enforcing provisions ofSection 18 emergency exemptions. ISDA will require the registrant (or manufacturer, ifunregistered) ofTough herbicide, Belchim Crop Protection, to prepare and make available to end users supplemental labeling that complies with ISDA and EPA requirements for the emergency use, ifapproved. The Mint Industry Research Council (MIRC), incooperationwith Belchim Crop Protection and Engage Agro USA, will be required to provide the ISDA a report summarizingresults ofthe emergency use after the end ofthe use period.
12. Repeat Uses Tough has beenpreviously used under a Section 18 from 1999-2000. Tough was later registered under a Special Local Need registration from 2001-2007 after tolerances were established in 2000.
13. Progress Toward Registration Tough was originally registered as a pesticide for use on corn andpeanuts in the U.S. in 1997. The original registrant was Sandoz Agro and the product was registered under theEPAReg. No. 55947-168. Syngentaeventually assumedownership ofthe productand thenewEPARegNo. was 100-880. Additional residue information was submitted by IR-4 for mint and tolerances were established for peppe11nint and spearmint tops at 0.20 ppm (CFR 180.462) inthe Final Rule, published inthe Federal Register vol. 65, No. 86, May 3, 2000 pages 25647-25652. Even though mint was not added to the federal label, several states issued Special Local Need registrations for
use inmint. Productregistration was voluntarilycancelledbytheregistrant (Syngenta) in2004 and the product was no longer marketed in the U.S. Recently, Belchim Crop Protection acquired the marketing rights for pyridate fi·om Syngenta. Belchim is currently working with the USEPA to establish the necessary infonnationneeded to re-register Tough in the U.S.
B. Summary ofEconomic Loss1. Pest(s) to be Controlled The pests causing an emergency are broadleafweeds, in particularly Redroot Pigweed, Armaranthus retrojlexus and Kochia, Kochia scoparia.
2. Discussion ofthe Emergency Condition Thisrequest is due to the emergency condition existing inmintfrom thepost-emergence of pigweed, kochia, and other broadleafweed communities that cmmot be effectively controlled in active growing mint crops. All crops sufferyield losses from populations ofweeds, but unlike other crops, the quality ofmint oil is also affected byweeds. Boththe quality and marketability of the mint crop is dependent uponweed free fields. The recent increase in global demand for the production ofdouble-cut mint oil has created
a non-routine situation that poses additional stress onthe need for adequate post-emergence broadleafweedcontrol. Pre-emergenceherbicides appliedinFebruary andearly March to dormant mint dissipate to low levels that no longer control weeds after 4-6 weeks. The mint crop canopy suppresses any newweed emergence or establishment after this period. Once the mint canopy is removed with a mid to late June harvest (first cutting), new weed flushes follow. These new flushes include both summer mmual grasses and later germinating broadleafweeds, such as pigweeds. The grass weeds are easily controlled with registered grass active herbicides. However, there are no effective post-emergence herbicides that m·e labeled inmint for pigweed control during the second halfofthe growing season following the first harvest ofmint. The increased demand for double-cut mint is a result ofboth global regulatory challenges andthe increasing desire for the oil quality that is produced in double-cut production. The global regulatory issues involve the concernofmenthofuran andpulegone contents inthe mint oil andthe limits ofthese compounds that are allowable in oil to deem it acceptable in markets. The reduction ofthese compounds and the increase ofother desirable oil quality traits canbe achieved through double-cut production. The market has shifted to a higher demand for double-cut mint, but the acreage to meet the demand is not adequate due to management challenges associatedwith double-cutproduction. Post-emergence broadleafweed control is the primmy management challenge facing double-cut production. Producers do not have viable broadleafweed control options to address this challenge. Redroot pigweed present in mint at 1.6 weeds/yd2 renders mint oil unmarketable, due to off-flavors imparted during the distillation process. OSU resemch also demonstrated that a redroot pigweed infestation of 10 plants/ft 2 caused a peppermint oil yield reduction 34.4lbs/acre, a 46% reduction. Furthermore, both redroot andprostrate (A. blitoides) pigweeds have developed terbacil resistant biotypes. Kochia, a summer annual, cm1 reach heights ofsix feet high and several feet in diameter, hinderingharvest operations and competes for nutrients and light. In addition, an infestationof2.3 kochia plants/ft 2 canreduce mint oil yields by over 30% in addition to reducing oil quality. Mechanical tillage is not a post emergence weed control option in mintbecause tillage will destroy growing mint, eliminate irrigation rills in surface irrigated fields, and will spread devastating diseases inmint such as Verticillium wilt (Verticil!tum dahliae). Terbacil (Sinbar), the commonly used herbicide registered for weed control inmint, is weak on pigweed species and has become even less effective in controlling pigweeds due to the development ofresistant biotypes. Additionally, terbacil cannotbeused when weeds are beyond the seedling stage and whenrotating from mint to other crops due to residual carryover. The only alternative method ofcontrolling these weeds is hand-rogueing, but the unavailability oflaborand excessive cost where labor isavailable, eliminates rogueing as a viable weed control method. Again, there are presently no effective post-emergent means ofcontrolling these weeds inmint. The mint industry has been diligently investing research funds to discover effective post-emergent broadleafweed herbicides that are safe to the crop. Pyridate has proven to be effective on broadleafweeds as well as possesses acceptable post-emergence crop safety needed for mint production. Populations ofproblem weeds have reached economically devastating levels and is impactingthe producer's abilityto compete inthemarket. Additionally, the recent increased demand for double-cut minthas forced production into and created annon-routine situation for mint producers who have no effective and viable post-emergence broadleafweed control options. The use ofToughherbicide for post-emergence weed control 

### inmint is criticalto maintainingU.S. mint oil quality and market share in today's global economy.
3. Additional Benefits Information
4. Discussion ofEconomic Loss Redroot Pigweed/Kochia and broadleafweed communities have become serious weed pests ofmint growers in Idaho. The lack ofany post emergent weed control options, (no effective registeredherbicide, and the presence ofherbicide-resistant pigweed) have created an emergency situation for Idaho mint growers. Furthe1more, the recently increased demand for double-cut mint has created an non-routine situation in weed control for mint producers. Economic thresholds for these problem weeds are very low. Weeds resistant to herbicides which mature and form seeds,
soon establish large populations ofthe resistant biotype, ifnot controlled. Studies performed by OSU weed scientists show yield losses ranging from 22%to 47% from the target weeds individually. Kochia and Redroot Pigweed are often found in complexes of other weeds, which further reduces the yield and quality ofmint oil.
Five-Year History ofIdaho Production
Average Average Gross Cost of Net Year Yield Price Revenue Production Revenue (lbs

### I acre) 

### ($I lbl 

### ($I acre) 

### ($I acre) 

### ($I acre) 2011 103 $21 $2,170 $2,038 $132 2012 103 $21 $2,162 $2,038 $124 2013 96 $21 $2,016 $2,038 ($22) 2014 108 $21 $2,266 $2,038 $228 2015 118 $21 $2,477 $2,038 $439 Average 106 $21 $2,218 $2,038 $180

I. Yield and price data were obtained from mint industry oil growers and buyers. 2. Cost ofproduction is based on 2013 University ofIdaho Enterprise Budget. 3. A Joss does not necessarily mean a negative cash flow, but rather that the grower will not earn a return on capital and management contributions (hourly wage, labor, etc) equal to what could be earned in an alternative investment ofthe land producing the mint crop.Tier 2 Analysis A Tier2 SignificantEconomic Loss (SEL) analysis illustratesthereduction ofoil yield and quality as well as the loss ofgross revenuedue to thedevaluationoftaintedoilresulting from weed contaminants. The yield comparisonreflects a 35%yield reduction (OSU trial data) onthe portion ofthe acres (50%) faced withthe impact ofpost-emergent weed control challenges. Furthermore, the yield calculations are based onthe five-year average (2011-15) of 106 lbs/acre. As previously stated in this request, the estimated acreage ofldaho mint is 18,000 acres and approximately 9,000 acres (50%) would be treated with Tough herbicide. As for marketable oil quality, itis estimated thatthe use ofToughherbicide wouldincrease pure quality oil by 20%, thus reducing the amount oftainted devalued oil by the san1e. The devaluation oftainted oil ranges from a small percentage deduction to completerejection/loss. Based on industry knowledge, an average devaluation of35% was used for this analysis. The Emergency situation results in 20% more tainted oil that has 35% less value realized by the growers. In all, this is a loss greater than $13Million to the mint producers inIdaho.
Tier 2 Idaho Economic Analysis ofYield and Quality Loss

Baseline Emergency Change %Change
Yield (lbs/acre) 2,421,692 1,908,000 -513,692 -21%
Pure (%ofyield) 90% 70% (lbs/acre) 2,179,523 1,335,600 -843,923 -39%
Tainted (%ofyield) 10% 30% (lbs/acre) 242,169 572,400 330,231 136% Price, Pure ($/lb) $21.00 $21.00 Price, Tainted ($/lb) $13.65 $13.65
Gross Revenue ($/acre) $49,075,595 $35,860,860 -$13,214,735 -27% Summary Approximately 50% ofthe peppermint and spearmint grown inIdaho is harvested twice per year. Prior to the voluntary cancellation ofTough in 2004, this product was the only product available to mint growers to control broadleafweeds after the first cutting and before the rows closed. The presence ofthese broadleafweeds, such as kochia andredrootpigweed, steals light and nutrients, but can also impart flavors to the mint oil that make it unmarketable. Even thoughthe industry has invested a significant amount ofmoney inresearch to find a replacement herbicide, they have not been successful.The new owner ofthis active ingredient has recently beguntheprocess ofreregistering it inthe U.S. and intendsto include both peppermint and spearmint crops onthe federal label. The industry has notbeenableto find aneffective alternativeto pyridateinmint and is requestingtl1e USEPA to consider allowing them to once again use pyridate for the control broadleafweeds in both peppermint and spearmint. Please contact me ifthere are questions about this request.

Sincerely yours,

# a~.

# ~/r-

# ~:e**~nson,** Administrator Idaho State Dept ofAgriculture 208-332-8S31 (phone) 208-334-3547 (fax) george.robinson@isda.idaho.gov

Pc: Steve Salisbury, MIRC Roger Batt, Idaho Mint Commission DonMorishita, U ofI Ronda Hirnyck, U ofl Liesbeth Bosman, Belchim Crop Protection Eric Maurer, Engage Agro USA Russ Holder, US Fish & Wildlife David Priebe, ODA Steve Foss, WDA Supporting Attachments


### 1. Tough SEC Package Label. 2. Tough SEC Section 18 Supplemental Label. 3. Tough SEC MSDS. 4. Tolerance ofPeppermintto Pyridate. Oregon State University Efficacy Data. Hyslop Farm, Corvallis, OR. 1993. S. Efficacy and Crop Safety Data 1997, 1998,2002. Dr. Gary Lee, University ofldaho. Parma R&E Center. Parma, ID. 6. Letter ofSupport. Dr. Rick Boydston, USDA-ARS. Prosser, WA. 7. Federal Register. Vol. 6S, No. 86. Wednesday, May 3, 2000. pp. 2S647-256S2.8. EPA Health Effects Division Risk Assessment. Pyridate (i.e. Tough®) in/or on Brassica Head and Stem Subgroup, Collards and Mint. January 24, 2000. 9. Endangered/Threatened Species Found inIdaho Mint Producing Counties. February 2016. http://ecos.fws.gov/tess public/ 10. EPA Environmental Fate and Effects Division- Pyridate Report. December 12, 1989. 11. Belchim Crop Protection N.V./S.A. Letter ofSupport. January 13, 2016. 12. Engage Agro USA, LLC. Letter ofSupport. February 4, 2016. 13. The Effect ofWeeds on Mint Oil Yield and Quality. Heap, I. Department ofCrop and Soil Science. Oregon State University. 14. Herbicide Resistant Weeds inMint. Heap, I. WeedSmart, Corvallis, OR. 15. Pyridate Properties and Characteristics. Heap, I. pp. 89-91. 16. Costs & Returns Estimates for Peppermint Establishment & Production Center Pivot, No Fumigation. Painter, K, et.al. University ofldaho. 2013 17. Letter summarizing weed research efforts searching for altematives to pyridate. Dr. Rick Boydston. USDA-ARS. Prosser, WA. March 1, 2016.