2 of 12 Clothianidin Preliminary Work Plan. Valent also commented on trade irritants and conditionally required magnitude of residue studies.

On March 20, 2012, the EPA received an emergency citizen petition (referred to hereafter as “emergen cy petition”) seeking suspension of registration for clothianidin. The emergency petition requested action within 90 days. The agency is reviewing the emergency petition and will be respond ing to the petitioners' allegation that clothianidin poses an immin ent hazard to pollinators. Many of the comments received in the March 20, 2012 petition were also received during the 60 day comment period. Many of the matters raised in the emergency petition were also received as comments during the 60 day comment per iod on the Preliminary Work Plan (PWP) for the Registration Review of Clothianidin . Comments received on the PWP that are duplicated in the

emergency petition will be posted in the Clothianidin Petition for Emergency Suspension Docket (EPA

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- 033 4) at www.regulations.gov

. The responses in this document should not be interpreted as the Agency’s final/formal response to the emergency citizen petition.

Below are PRD ’s response s to those comments pertaining to policy, process, and benefits . Comments regarding the environmental fate or effects of clothianidin have been addressed by the Environmental
Fate and Effects Division’s (EFED) document, EFED Response to Comments Submitted to the Clothianidin Registrati on Review Docket (dated June 11, 2012)

. There were no comments pertinent to the health effects scoping document on the planned human health risk assessments.

BP & PANNA Campaign Comment s : More than 120,000 commenters requested the agency ban the use of o r “cancel the approval” of clothianidin. Approximately 120,000 of these ban requests were the result of a letter writing campaign organized by Beyond Pesticides. Commenters requesting clothianidin be banned, generally cited concern for pollinators as the reason why this compound should be banned, though many several noted additional points support their claim that clothianidin should be banned. Specifically mentioned were:

• Clothianidin was registered on the basis of an incomplete data set and should be banned until a data set that verifies it does not pose unreasonable risk to human health or the environment is produced.

• EPA has failed to consider all of the available data showing clothianidin is highly toxic to honey bees and EPA should suspend the use of clothianidin until this exhaustive review is complete.

• Clothianidin is highly toxic to honey bee and the lack of an acceptable field test for pollinators study for clothianidin, which was a condition of the original registration, means the registrant
h as not satisfied the conditions that their clothianidin registration was granted on.

• The existing data set provides enough evidence that clothiain i din cannot be used without causing unreasonable ad verse effects to pollinators.

• The risk clothianidin pos es to pollinators outweighs the benefits of clothianidin use.

Agency Response: The Agency has initiated the registration review of clothianidin pursuant to Section 3(g) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to determine whet her clothianidin continues to meet the FIFRA standard for registration. The preliminary work plan (PWP) for clothianidin and the supporting Ecological Problem Formulation and Human Health Scoping Document provide a3 of 12 background on what the Agency knows and does not know about clothianidin’s effects to human health and the environment when it is used as labeled. These documents also provide the Agency’s anticipated path towards re

- evaluating clothianidin. To further evaluate risks to pollinators and other
b eneficial insects, EPA intends to require data to assess honey bee toxicity. In the development of a quantitative risk assessment for pollinators, EPA will consider the recommendations of the Society of Environmental Toxicology and Chemistry (SETAC) Works hop on Pesticide Risk Assessment for Pollinators, and EPA is working with its federal and state partners, industry, and academia to determine appropriate assessment methodology.

• Clothianidin was registered on the basis of an incomplete data set and shou ld be banned until a data set that verifies it does not pose unreasonable risk to human health or the environment is produced.

The regulatory standards for taking currently registrered products off the market are set forth in section
6 of FIFRA. In conn ection with our response to the emergency petition, we are evaluating whether those standards have been met, including the assertion that EPA should suspend or cancel clothianidin based on missing data.

• EPA has failed to consider all of the available data showing clothianidin is highly toxic to honey bees and EPA should suspend the use of clothianidin until this exhaustive review is complete.

The Agency agrees that clothianidin is highly toxic to honey bees via acute oral and acute contact routes of expos ure. It is not uncommon that insecticides that are utilized to control or kill insects will be toxic to beneficial insects, such as honey bees, and to account for this the Agency has required mitigation measures for all clothianidin products that aim to r educe the exposure to beneficial insects. The purpose of registration review is to review the current state of the science, use knowledge, and effects knowledge and make a determination if the current risk mitigation measures for clothianidin
continue to meet the FIFRA registration standard. If at any point the Agency concludes that the existing mitigation measures required for clothianidin are not sufficient to prevent unreasonable adverse affects to human health or the environment, then the Agency will examine all available means of mitigating unacceptable risks.

• The existing data set provides enough evidence that clothiainidin cannot be used without causing unreasonable adverse effects to pollinators.

The Agency is assessing these issues in connectio n with both its review of the March 20, 2012 petition
and registration review . If following these reviews , or if at any other time additional information is made available that leads the Agency to conclude that clothianidin use cannot be used without caus ing unreasonable adverse effects to human health or the environment, the Agency will respond accordingly.

• The risk clothianidin poses to pollinators outweighs the benefits of clothianidin use.4 of 12 This comment was also r aised in the March 20, 2012 petiti on and response to it will be posted in the Clothianidin Petition for Emergency Suspension Docket (EPA

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- 0334) at www.regulations.gov

.

Comment : Several commenters noted that use of clothianidin has bee n banned in several European countrie s noting: “France, Italy, Slovenia, and Germany

-- the home of Bayer

-- have already banned clothianidin. The U.S.A. needs to ban it, too.” ( EPA

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- 0041 & EPA

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- 0058 )

Response: The Agency is aware that several European countries have suspended specific uses of clothianidin and other neonicotinoid insecticides such as imidacloprid and thiamethoxam. The Agency understands that these suspensions are only on the use of neonicotinoid insectici des as seed treatments on crops such as corn (maize) and sunflower and that these suspensions are temporary.

The Agency is in regular contact with many of the countries cited by the commenter on the topic of pollinator protection and assessing the risks o f pesticides to pollinators. The Agency regularly shares information on the topic of protecting non

- target organisms from exposure to pesticides and always welcomes information on other state’s experiences with mitigation measures to better inform mitigat ion measures the Agency considers.

Several European countries have suspended the use of certain neonicotinoid insecticides, including clothianidin, in response to incidents involving acute poisoning of honey bees. To EPA's knowledge,
none of the incidents that led to suspensions have been associated with Colony Collapse Disorder. The following are the countries in which pesticides have been suspended, the pesticides in question, and the current registration status for the pesticide:

France

- Sunflower and corn seed treatments of the active ingredient imidacloprid are suspended in France; other imidacloprid seed treatments, such as for sugar beets and cereals, are allowed, as are
foliar uses.

Germany

- The use of a number of seed treatment pesticides was t emporarily suspended following

an incident in May 2008 in which many bees were inadvertently poisoned. However, after investigating the factors contributing to the situation, Germany lifted the suspensions with the exception of the neonicotinoid clothianid in, which remains suspended as a seed treatment for corn.

Italy

- Clothianidin seed treatment uses on corn were suspended temporarily, and this temporary suspension is scheduled to expire on June 30, 2012. The Agency is not aware of foliar uses of
clothi anidin being suspended in Italy. This action was taken based on preliminary monitoring studies in northern and southern regions of Italy showing that bee losses were correlated with the application of seeds treated with these neonicotinoid compounds; Ital y also based its decision on the known acute toxicity of neonicotinoid compounds to pollinators.

Slovenia

- Neonicotinoid seed treatments for maize and oil seed rape (canola) were temporarily suspended. The suspension was based on poor seed treatment meth ods resulting in release of dust5 of 12 during the seed sowing process. In August 2008, the suspension for oil seed rape seed treatments was lifted due to improved seed treatment methods and seed sowing equipment.

Comment:

“ No major independent study has verifie d the safety of Clothianidin. However independent studies have shown that neonicotinoid pesticides like clothianidin are highly toxic to honey bees, providing compelling evidence that they should be immediately taken off the market until the E.P.A. can con duct
a full and valid scientific review.” ( EPA

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- 0080, EPA

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- 0041,
and EPA

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- 0143 )

Response: The Agency agrees that clothianidin is highly toxic to honey bees. It is common for insecticides, such
as clothiani din, to be highly toxic to beneficial insects such as honey bees. The Agency has imposed mitigation measures on the labels of registered clothianidin products and other insecticides to address the risk clothianidin poses to humans and the environment , inc luding risks to bees

. In connection with both its review of the emergency petition and registration review, EPA will determine whether there is a need to impose further limitations on use to ensure that clothianidin meets the requirements of
FIFRA

.

Com ment: “Shockingly, no major independent study has verified the safety of this pesticide. While clothianidin
has been used on corn

— the largest crop in the U.S.

— since 2003, it was officially approved by the Environmental Protection Agency in 2010 on the basis of a single study, conducted by Bayer. However, leaked documents show that the study was actually debunked by the agency's own scientists, so the pesticide was effectively approved with no scientific backing.” EPA

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- 0143
and EPA

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Response: The Agency disagrees that the registration of clothianidin relied on a single study. The Agency’s decision to grant or deny a registration is not based on the results of any single study, but instead the collection of data pres ented in the studies combined with other information. The other information can cover a variety of topics including but not limited to economic information (such as the economic benefit use of said pesticide can provide specific crops) and information on alternatives (such as is this pesticide an environmentally preferable substitute to pesticides used on the same pests).

BP Comment : Beyond Pesticides and others pointed out to the agency in December 2010 that at the time of conditional registration, th e agency was aware that clothianidin posed a threat to honey bees and other pollinators, yet went forward with authorizing its use in the wider environment, without the “required” honey bee data to support registration. The agency in response argued that “ the uses met the Federal Insecticide, Rodenticide and Fungicide Act (FIFRA) risk/benefit standard for registration.” In this letter the agency stated, “the 2003 conditional registration of clothianidin was granted based on.... the
submission of a field test for pollinators.” The letter goes on to state that this study was reclassified as a supplemental study, i.e. “a study that provides scientifically sound information, but did not follow all protocols set forth in EPA test guideline.” At the point of this r eclassification, the study was no longer acceptable to support registration. The reclassification is troubling given that clothianidin was already6 of 12 granted conditional registration by this time, after the agency acknowledged that clothianidin posed a
threat to bees and took no action. (EPA

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- 0104)

Response: The Agency will respond to requests to suspend clothianidin in its response to Emergency Citizen Petition to the United States Environmental Protection Agency Seeking Suspension of Regist ration for
Clothianidin , dated March 20, 2012, in docket number EPA

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- 0334 at www.regulations.gov for a response to this comment.

National Honey Bee Advisory Board (NHBAB) Comment : “The National Honey Be e Advisory Board (NHBAB) has reviewed EPA’s risk assessment documents for clothianidin. The “conditional registration” for clothianidin recognized this product as a potential problem for pollinators. An important component of that conditional approval wa s a requirement for a pollinator field study. We can find no documentation that an “acceptable” field test for pollinators has been listed by EPA risk assessors. We are unclear how a product can transition from condition al registration to full registration if all requirements are not met. FIFRA mandates EPA to “prevent unreasonable risk to the environment”. EPA must reconsider all registrations of clothianidin until an acceptable field study for pollinators has been app roved. We are particularly concerned about foliar applications of clothianidin on blooming crops. California recently enacted restrictions on this use on blooming cotton. We request EPA to suspend this method of application u ntil further studies confirm safety for pollinators.” EPA

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Response: The Agency will respond to requests to suspend clothianidin in its response to Emergency Citizen Petition to the United States Environmental Protection Agency Seeking Suspension of Registratio n for
Clothianidin , dated March 20, 2012, i n docket number EPA

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- 0334 at www.regulations.gov for a response to this comment.

Steve Ellis , Old Mill Honey Co. Comment: “Another subject of great concern to b eekeepers is the allowed higher rate use for homeowners, and landscaping and nursery businesses. This rate is sometimes as high as 40 times the allowable rate of agriculture. At this high rate, and with NO BEE CAUTION on their labels, these products are used on lawns, flowers and fruit trees. These areas may be smaller patches, but it is creating lethal dose exposure to pollinators. This practice must be halted immediately.” (EPA

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- 0123)

Response:
This comment was also raised in the Mar ch 20, 2012 petition and response to it will be posted in the Clothianidin Petition for Emergency Suspension Docket (EPA

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- 0334) at www.regulations.gov

.

Rachel Carson Council Comment : “The continuing ad verse impact of Colony Collapse Disorder and the association of neonicotinoids with honey bee population declines worldwide require the Agency to curtail availability of this neonicotinoid insecticide which also has been flagged for lacking adequate data t o support its registration.” (EPA

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- 0051)7 of 12 Response: The regulatory standards for taking currently registrered products off the market are set forth in section 6 of FIFRA. In connection with our response to the emergency petition, we are e valuating whether those standards have been met, including the assertion that EPA should suspend or cancel clothianidin based on missing data.

Valent Comment: “We respectfully request and encourage the EPA to harmonize data requirements with California Department of Pesticide Regulation (CDPR) and Health Canada’s Pest Management Regulatory Agency (PMRA). Valent has received requests for data addressing risk to honeybees from DPR, PMRA and EPA. In order to avoid duplicative or contradictory testing requir ements which could further cloud rather than illuminate the factors affecting pollinator health, we urge further cooperation and harmonization based on the best principles of risk assessment.” (EPA

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- 0070)

Response: The Agency is working w ith the CDPR and Health Canada’s PMRA to ensure that the necessary data will be available for assessing risk to insect pollinators by the time of registration review. It is the Agency’s intention to avoid requesting data that is duplicative, contradictory , or otherwise unduly
burdensome.

Valent Comment: Valent alerted the Agency to several discrepancies on the tolerances listed for several commodities in Canada and one commodity in the US listed in the Clothianidin Human Health Assessment Scoping
Documen t in Support of Registration Review , dated December 8, 2011. Valent also highlighted several

o f the tolerance disparities noted by the Agency in this document. (EPA

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- 0070)

Response: The Agency appreciates Valent bringing these discrepanci es to its attention and as stated in the PWP the Agency will modify tolerance levels as needed, and work to harmonize tolerances/maximum residue limits (MRL), where possible, in key export markets during registration review.

Valent Comment:
Valent noted that since the publication of the PWP in December, it had submitted side

- by

- side residue trials for leaf lettuce, non

- bell peppers, and cabbage. In the PWP these studies were listed as data gaps that were to be required through data call

- in to support the registration review of clothianidin. Valent also requested the Agency consider waiving the side

- by

- side residue trials for mustard greens due to there being adequate comparison data. (EPA

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- 0070)

Response:
This data will be reviewed and incorporated into future risk assessments as appropriate. Review of this data will also allow the Agency to determine whether an additional comparison study on mustard greens is needed.

Bayer CropScience (BCS) and Valent Comment:8 of 12 Both Valent and BCS su bmitted edits regarding Appendix A, Maximum Labeled Application Rates for
Clothianidin

. (EPA

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- 0070 and EPA

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- 00 69 )

Response: The Agency acknowledges the receipt of this information.

FESTF Comment: The FIFRA Endangered Species Task Force (FESTF) submitted a comment requesting that any technical registrant for clothianidin who is not a member of the FESTF (or a company having met its data compensation obligations) be asked to provide a formal offer

- to

- pay to FESTF for rel iance on
their data. ( EPA

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- 00 66)

Response: The Agency thanks FESTF for its comment and will consider it as it conducts the registration review
of clothianidin

.

Comment s on the agricultural benefits of clothianidin : Various i ndividuals from research universities (Mississippi State Agricultural Extension and University of Tennessee Agricultural Extension), and the pesticide industry (Florida Fruit & Vegetable Association) commented in support of the continued registration of clothianidin . They state that clothianidin is an effective and safe insecticide for managing yield

- robbing insect s in many crops

. C lothianidin use is beneficial for a number of reasons: a) clothianidin seed treatments results in less exposure to birds and other wil dlife because clothianidin is buried with the seed under the soil surface, b) clothianidin’s toxicity profile and low application rates minimize impact on human health and the environment, c) clothianidin use reduces the environmental load of other organop hosphate, carbamate, and pyrethroid pesticid es, d) application of clothianidin on the seed allows for direct targeting of pests, e) clothianidin us e increases agricultural yields, and f) the benefits of seed treatments

, with pesticides
such as clothianidin

, offer time savings and convenience to growers. Neonic otinoid alternatives to clothianidin include imidacloprid and thiamethoxam (of which clothianidin is a major degradate of)

. Imidacloprid requires higher application rates and does not provide the sam e level of control as
clothi anidin for some pests; similarly, thiam ethoxam does not control the same broad range of pests.

Response: The Agency acknowledges the receipt of this information and will consider all the benefits of clothianidin use for gro wers when it conducts its risk benefits analysis for registration review.

Commen ts on the general benefits of clothianidi n as a seed treatment: Various growers and other stakeholders (including Burros Bros Seed Company and Auburn University’s Horticult ure Extension Program ) commented in support of the continued registration of clothianidin seed treatments, stating that using clothianidin seed treatments in place of other pesticide formulations was preferable for several reasons: a) the convenience

— of using a systemic insecticide seed treatment, b) reduced occupational exposure since there is less dust and human contact with treated seeds, eliminating the need for handling bags of dry or liquid insecticide, c) some planters are not equipped to apply dry or liquid insecticide and using seed treatments eliminate this issue, d) the low use rate per acre associated with seed treatments, which results in more cost savings, e) its high efficacy against a broad range of insects, f) reduced environmental exposur e compared to other9 of 12 pesticide formulations

-- the total amount of clothianidin seed treatment applied to one acre of field corn can be up to 50 times less than for an organ ophosphate granular insecticide, and g) the reduced need for use of more harmful granu lar and foliar pesticides by using seed treatments

— before the availability of seed treatments, growers had to broadcast granular insecticides like terbufos and chlorpyrifos (Lorsban®) onto crops; these compounds were more dangerous and were known for killi ng most insects in the field and disrupting the ecosystem.

Response: The Agency acknowledges the receipt of this information and will consider all the benefits of clothianidin use for growers when it conducts its risk benefits analysis for registr ation review.

Comment s on clothianidin use on sugar b eet s : Growers and other representative s of the sugar beet industry (The Beet Sugar Development
Foundation

, The American Society of Sugar Beet Technologists

, Wyoming Sugar Growers, The American Crystal Sugar Company, and The Western Sugar Cooperative ) commented in support of the continued registration of clothianidin and highlighted clothianidin’s importance to the sugar beet industry in the United States. C lothianidin is a valuable tool in the sugar b eet industry for treating pests l ike leaf miner s, springtail insects, loopers, sugar beet leafhopper s , and other below ground insects such as root maggots and wireworms

. The sugar beet leafhopper in particular is a vector for curly top virus, which often afflicts many growers and has reduced crop yields in the past, even when the sugar beet varieties grown were engineered to be resistant to the disease . C lothianidin , in comparison with other pesticides, allows for better control of the leaf hopper and has replaced more harmful planting

- time organophosphate and carbamate pesticides

, which have been known to kill
wildlife . M oreover , clothianidin is particularly important because some of the pesticide alternatives used in the past have been take n off the mark et and are no longer available. Without the ability to treat curly top virus, sugar beet growers may see a 60

- 70% crop loss. Clothianidin has had a positive effect on the sugar beet industry in Idaho, Washington, and Oregon , where curly top disease is pr evalent but
use of clothianidin has resulted in consistently increased crop yields . Moreover, sugar beets grown for sugar production do not flower and so do not provide foraging for bees. Losing the ability to use
clothianidin would result in a large fin ancial loss to the sugar beet industry. Growers raised concerns that without the use of clothianidin it might not be profitable to grow sugar beets anymore , which
would close factories and force farmers out of business

.

USDA reinforced earlier points m ade by other growers, commenting that research conducted at different levels of host resistance and disease pressure indicate that clothianidin use could lead to a 20% increase in sugar beet root yield when applied as a seed treatment. Recent research ind icates that even under strong curly top disease pressure, seed treatment with clothianidin can provide excellent protection and lead to 55

- 95% increased sugar beet root yield. Clothianidin has been shown to control other pests such as leaf miner, black be an aphid, and root aphid. Because of this wide range of pest control, clothianidin can increase yields by 3

- 8% even without curly top disease pressure.

Response: The Agency acknowledges the receipt of this information and will consider all the benefit s of clothianidin use for growers when it conducts its risk benefits analysis for registration review.

Comment on the success of clothianidin use against the annual bluegrass weevil :10 of 12 One researcher ( EPA

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- 0021 ) commented on the instrumen tal use of clothianidin in controlling pests on golf courses. The annual bluegrass weevil is a serious pest on East Coast golf

courses ; both the adult and larvae feed on the annual bluegrass, which is a major component of turf

grass

. A combination of clo thi anidin and bi fenthrin is widely and effectively used to contr ol this pest. Two applications of clothianidin coformulated with bifenthrin are sufficient for season

- long control, even on golf courses with bifenthrin resistance, whereas alternative pestic ides require 4

- 6 applications to achieve control. The control achieved with clothianidin is better than with any other product on the market. Clothianidin is also effective against a broad spectrum of other golf course pests such as cutworms, grubs, bill bugs, sod web worms, mole crickets, and army worms

.

Response: The Agency acknowledges the receipt of this information and will consider all the benefits of clothianidin use for growers when it conducts its risk benefits analysis for registration rev iew.

Comment s on clothianidin use on field corn : Stakeholders from the corn industry, including Iowa Corn, The National Corn Growers Association (NCGA), Minnesota Corn Growers, and Illinois Corn Growers commented in support of the continued registratio n of clothianidin. In addition, state extension programs at Auburn University, Mississippi State University , and University of Tennessee provided similar comment. They state d that clothianidin
is an integral component of early

- season pest control (for pests like b illbugs, stinkbugs, and sugarcane beetles) and soil insect management (for pests such as wireworms, black cutworms, and white grubs) in field corn, citing various benefits like reduced handling, reduced occupational exposure, lower environmental risks, con venience to growers, high efficacy, precise application, and increased yields in comparison with alternate pesticides on the market

.

Illinois Corn G rowers stated that c lothianidin is used on approximately 60% of the corn in Illinois and produces a 6 bus hel per acre average yield increase which at current corn prices could result in an increased profit of $280 million dollars for the state of Illinois. Discontinuing clothianidin’s registration would result in a negative economic impact.

In general, comm enters were concerned about colony collapse disorder and its potential impact on the larger agricultural economy, but stated that corn growers can use best management practices to minimize exposure to bees. Although c lothianidin has been implicated with t he recent decline in bee populations in the US

, studies suggest that there are multiple and complex causes of colony collapse disorder. Corn farmers believe that the current science does not support discontinuing clothianidin’s registration.

Response: The Agency acknowledges the receipt of this information and will consider all the benefits of clothianidin use for growers when it conducts its risk benefits analysis for registration review.

Comment s on clothianidin use on cotton : Various stakeholde rs from the cotton industry (the Cotton Council, Plains Cotton Growers, the Georgia Cotton Commission, Southern Cotton Growers, the Plains Cotton Cooperative, the California Cotton Ginner and Growers Association, the South Texas Cotton and Grain Associatio n, and Florida Fruit & Vegetables) commented in support of the continued registration of clothianidin. They state that11 of 12 clothianidin is an important component of cotton production because it helps control several piercing /sucking insect p ests such as thrip s, aphids, plant bugs , and the pesky Lygus bug (the most destructive cotton pest in California) . Alternatives to the neonicotinoids are limited to pesticides like aldicarb, which has limited availability, and dicrotophos, which has annual rate restriction s. Growers have observed increased insect resistance with alternative pesticides and prefer neonicotinoid pesticides like clothianidin because they are able to move into the sap of plant parts and provide
enhance d protection from cotton pests. In additio n to its effectiveness against a broad range of pests, clothianidin use is convenient for growers because it allows precise and targeted application to crops

.

Response: The Agency acknowledges the receipt of this information and will consider all the benefits of clothianidin use for growers when it conducts its risk benefits analysis for registration review.

Comment s on clothianidin use on rice : The Cali fornia Rice Commission submitted comments in support of the continued registration o f
clothi anidin, stating that although clothianidin is not currently registered for use on rice, rice farmers could benefit from use of a systemic seed treatment insecticide like clothianidin to control pests like aster leafhoppers, army worms, rice seed midges, ri ce water weevils , and other pests . The rice water weevil in particular feeds on the leaf tissue and the roots of rice, inflicting heavy damage that result in grain losses of up to 44%. Pesticides currently used to control the rice water weevil include
di notefuran, lambda cyhalothrin, and s

- cypermethrin, but these only target the adult weevils and can’t
control the larvae. Clothianidin, as a systemic pesticide, is able to control both adult and larvae stages of pests.

Response: The Agency acknowle dges the receipt of this information. The Agency is currently reviewing an application for clothianidin use on rice ( seed and foliar uses) and if this use is registered, the Agency
will consider clothianidin use on rice during registration review.

Comment s on clothianidin use on canola : Stakeholders from the canola industry (the US Canola Association, the Northern Canola Growers Association, the Minnesota Canola Council, and the Great Plains Canola Association) commented in support of the continued registr ation of clothianidin, citing its various benefits to canola producers. US canola producers have turned to seed treatments like clothianidin to control insects and disease because of their effective control of pests, lower environmental and occupational e xposure, lower application costs, and added convenience. Loss of clothianidin use on canola would require producers to increase use of foliar applications of other more harmful pesticides to control insects such as flea beetles

, aphids, and wireworms , the reby increasing the risk to other beneficial insects, reducing efficiency, lowering profits, and impairing an already well

- established pest management program in canola producing areas

. Clothianidin is a very important tool for canola growers in North Dak ota, which produces about 90% of the canola in the US. Canola producers in North Dakota are beleaguered by the crucifer flea beetle, which can devastate seedlings and destroy a crop if not controlled. Seed treatments like clothianidin are the best option for controlling the crucifer flea beetle due to their high efficacy and affordability.

Response:12 of 12 The Agency acknowledges the receipt of this information and will consider all the benefits of clothianidin use for growers when it conducts its risk be nefits analysis for registration review.

Comment s on clothianidin use on soybeans: Various stakeholders from the soybean industry (Nebraska Soybean Association, Illinois Soybean Association, and Minnesota Soybean Growers Association) commented in support of the continued registration of clothianidin, citing the convenience of its seed treatment use , high efficacy against a broad range of pests (including nematodes), precision, reduced environmental and occupational exposure, higher yields, and the reduced need for early

- season sprays and other in

- furrow and foliar

sprays.

Response: The Agency acknowledges the receipt of this information and will consider all the benefits of clothianidin use for growers when it conducts its risk benefits analysis for re gistration review.

Comment s on clothianidin and wheat : The Washington Grain Alliance and other wheat growers submitted comments in support of the
continu ed registration of clothianidin. With the loss of lindane, wheat farmers in Washington have

seen a r ise in wireworms, which cause lots of damage to wheat. R esearch shows that Poncho (clothianidin) is superior to Gaucho ( imidacloprid ) or Cruiser ( thiamethoxam ) for control of wireworms. If clothianidin registrations are cancelled there will be no replace ment for it in the market and farmers will be forced to use higher rates of less effective chemicals to control wireworms

.

Response: The Agency acknowledges the receipt of this information and will consider all the benefits of clothianidin use for growe rs when it conducts its risk benefits analysis for registration review.