### 1 Section 18 Application

– sulfoxaflor (Transform TM )

Mississippi Cotton Submitted by the Mississippi Department of Agriculture

(a) General information required in an application for a specific, quarantine or public health exemption. An application must be submitted in writing by the head of the Federal or State agency, the Governor of the State involved, or their official designee. If a designee has been delegated authority to request exemptions, written authorization of such delegation must accompany th e request or be on file with the Agency. In addition, the application must contain all applicable information specified in paragraphs (a) (1) through (11) of this section.

(1) Identity of contact persons. (i) Unless otherwise specified, the person who sub mits the application will be considered the contact person for all matters relating to administration of the emergency exemption.

Tommy McDaniel

, Director Pesticide Division Bureau of Plant Industry Mississippi Department of Agriculture

705 Stone Blvd. Ro bert H. McCarty Building

P.O. Box 5207 Mississippi State, MS 39762

Phone: 662 323

- 9379

Fax:

Email: tommym@mdac.state.ms.us

(ii) University contact :

Angus Catchot, Associate Professor of Extension

Miss issippi State University Department of Entomology

100 Twelve Lane Mississippi State, MS 39762

Off: 662 325

-

2085

Cell: 662 418

- 8163

Email: acatchot@ext.msstate.edu

(2) Description of the pesticide. The appli cation shall contain a description of the pesticide(s) proposed for use under the exemption. Such information shall include:

(i) For a federally registered pesticide product:

( A) A copy of the label(s) if a specific product(s) is/are requested; or the fo rmulation(s) requested if a specific product is not requested; and

(B) A copy of any additional labeling proposed for the emergency exemption; or

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(ii) For any other pesticide products:

Transform WG (EPA Reg. No. 62719

- xxx) Active ingredient

– Sulfoxaflo r (50%) Manufactured by Dow AgroSciences

(A) A confidential statement of formula or reference to one already submitted to the Agency; and

A Confidential Statement of Formula has been previously submitted to EPA with the Section 3 registration package f or Transform WG (GF2372, active ingredient sulfoxaflor). Transform WG is a WDG formulation of the active ingredient

sulfoxaflor.

(B) C omplete labeling to be used in connection with the proposed exemption use.

The proposed label is included as an attachmen t as Appendix LABEL. See

attached.

(3) Description of the proposed us e . The application shall identify all of the following:

(i) Sites to be treated, including their locatio ns within the State:

The insecticide will be restricted to use on c otton fields w ithin the state of Mississippi for the purpose of controlling the tarnished plant bug

, Lygus lineolaris (Palisot de Beauvois).

(ii) The method of application:

Foliar applied by air and ground

.

( iii) T he rate of application in terms o f active ingredien t and product:

1.5

- 2.75 oz product/acre (0.047

- 0.086 lb AI /acre). Annual use will not exceed 0.266 lbs active ingredient per acre

.

(iv) The maximum number of applications:

Four applications per acre per year.

(v) The total acreage or other appropriate unit proposed to be treat ed:

Mississippi planted a pproximately 425 ,000 acres of cotton during 2010. http://www.nass.usda.gov/Charts_and_Maps/graphics/cotnacm.pdf ) . Mississippi producers treated ≈98% (396,950 acres) of the total planted acreage for the control

of tarnished plant bug

, Lygus lineolaris (Palisot de Beauvois) during 201 0 (data in press). During 2009, Mississippi treated 259,555 (96 %) of the 286,902 planted

cotton acres for tarnished plant bug control ( http://www.entomology.msstate.edu/ resources/tips/ cotton

- losses/data/). Cotton a creage in Mississippi is projected to increase during 2011 ≈20

- 25 % above that in 2010 for a total planted acreage of

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550,000 acres. During 2011, Mississippi has the potential need to treat 75% (≈412,500 ) of its acreage with sulfoxaflor for control of tarnished plant bug. Th is

assessment is based on conservative estimates of the 2011 acreage i ncreases and 2009

- 2010 historical treated acres for tarnished plant bug control in Mississippi

.

(vi) The total amount of pesticide proposed to be used in terms of both active ingredient and product :

T arnished plant bug

, Lygus lineolaris (Palisot de Beau vois)

, infestations are likely

to caus e economic losses o n approximately 467,500 acres in Mississippi during 2011. Therefore up to four applications of sulfoxaflor will be required on these

acres to reduce the impact of this pest . The high rate ( 2.75 oz /a cre) can only be used in three of those applications to prevent exceeding total annual rate of 8.5 oz product or 0.266 AI per acre

. Based upon th is maximum allocation of 8.5 oz (1.5

- 2.75 oz of formulated product per acre per application )

, treated (total s prayed) acreage will require no more than 292,186 pounds of formulated product on Mississippi ‟s 550,000 acres.

(vii) All applicable restrictions and requirements concerning the proposed use w hich may not appear on labeling:

All applicable restrictions and requirements will appear on the package label and

Section 18 label:

 Pre

- harvest Interval: Do not apply within 14 d of harvest.

 Minimum Treatment Interval: Do not make applications less than 5 d apart.

 Do not make more than one application on pre

- bloom cotton.

 Do not make more than four applications per acre per season.

 Do not make more than two consecutive applications per crop.

 Do not apply more than a total of 8.5 oz of Transform WG (0.266 lb AI of sulfoxaflor) per acre per year.

(viii) The duration of the proposed use :

June

– September of the 2011 cotton growing season

(ix) Earliest possible harvest dates:

August 25 , 2011

(4) Alternative methods of control. The application shall contain: (i) A detailed explanation of why the pesticide(s) curren tly registered for the particular use proposed in the application is not available in adequate supplies and/or effective to the degree needed to control the emergency. If the applicant states that an available registered pesticide is ineffective for the gi ven situation, the statement must be supported by field data which demonstrate ineffectiveness of registered pesticides, or, if such data are unavailable, statements by qualified agricultural experts, extension personnel, university personnel or other pers ons similarly qualified in the field of pest control;

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Several IPM strategies are recommended for controlling tarnished plant bug in

cotton. Non

- chemical tactics include a rea

- wide control of non

- crop alternate hosts and selected host plant resistance trait s . These only serve to suppress populations and are not effective as stand

- alone practices

. C hemical control strategies remain the primary tool used to manage this pest. Presently, numerous insecticides are recommended against tarnished plant bug, but var ying levels of resistance has been documented to nearly every class of these compounds among Mid

- S outh (Arkansas, Louisiana, Mississippi, Tennessee) populations of

this insect. Populations have demonstrated resistance to pyrethroids and some organophosph ates for several years (Snodgrass and Gore 2007) , but many populations remained susceptible to neonicotin oid insecticides including thiamethoxam and imidacloprid (Snodgrass et al. 2008). Acephate has been the most widely used and effective insecticide for control of plant bugs in cotton but efficacy continues to decrease in Mississippi and much of the mid South. Three years of study by Copes et al. (2010) clearly shows that acephate efficacy is rapidly eroding across Louisiana ( Figure 2 , Copes et al. 2010 ).

Even though acephate expressed partial efficacy against tarnished plant bugs in Mississippi, higher rates (0.75 to 1.25 lb AI/acre) were necessary each year from

2007

- 2009 to maintain the infestations below the action threshold. The highest

rate ac tually exceeded the labeled rate that could be used. These field efficacy results are supported by laboratory data from Snodgrass which show significant levels of OP resistance in tarnished plant bug populations throughout the hills

and delta in Arkansas, Louisiana, and Mississippi

. During the past two years, populations in these states also have been expressing lower susceptibility t o

n eonicotin oid products , but no high levels of resistance have been documented

. ( Snodgrass 2010 abstract , See Appendix A ).

C ook et al. (2007) showed that standard insecticide use strategies can reduce tarnished plant bug numbers, but none are consistently effective and can maintain

sub

- economic injury levels for the season. During 2009, a regional (Arkansas, Louisiana, Miss issippi, and Tennessee) full

- season insecticide screen was used to

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evaluate a list of products for control of tarnished plant bug. Six sprays were applied to the Louisiana trial which was designed to simulate moderate to high pest infestation levels, typic al of the situation in many Louisiana and M id

- South cotton fields (Figure 1

, Sharp et al. 20 1 0 and B. R. Leonard unpublished ).

Using seasonal means of tarnished plant bug nymphs as a metric for insecticide efficacy, all treatments significantly re duced numbers relative to a non

- treated control. However, only Endigo and Diamond successfully reduced numbers below the action threshold (line marked with AT) used to gauge the need for additional treatments to stop yield losses. In addition, all of the bars highlighted

with a n asterisk (*) illustrate that six applications of those treatments exceeded the total allowable seasonal AI/acre. Only Vydate and Intruder AI‟s were not exceeded. Yield losses have become severe in these situations in spite of

mul tiple insecticide sprays. Currently, the only chemical strategy recommended

is to co

- apply two insecticides and rotate among chemical classes.

In some areas across Mississippi and the Mid

- South region , tarnished plant bug

infestations have reache d outbreak levels and become uncontrollable. In Mississippi during 2007, producers averaged approximately 7

- 10 insecticide applications for this pest (Catchot 2007). The highest insecticide application frequency in Mississippi prior to 2007 was 5.2 sprays per year and occurred during 2004 in that state. Mississippi producers averaged 6.5 applications during 2007 (Williams 2008) for this pest, but some areas received 10

- 14 treatments.
Current trends with insecticide resistance and lack of effective altern ative technologies will allow problems with tarnished plant bug management to intensify across Mississippi and the Mid

- South states. Chemical control options that provide consistent efficacy are not available to manage this pest. Effective

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Lygus control i s a serious, unmet need for Mid

- South cotton growers and one that requires immediate and urgent action. This has now become an emergency

situation.

These results have shown that regardless of the registered insecticide, tarnished plant bug populations in these States have become significantly more difficult to control using common recommended insecticides (Lorenz et al. 2009; Moore et al. 2010). As a result, the numbers of applications and use rates needed to control tarnished plant bug have increased. W ith a novel mode of action and chemical class, sulfoxaflor will successfully control both insecticide

- susceptible and

- resistant populations of tarnished plant bug

, thereby improving the overall cotton IPM system . This would be a tremendous economic opport unity for cotton

growers , and more environmentally

- friendly alternative to the sustained frequency of the currently used products.

As expected, the excessive use of some products for tarnished plant bug are now beginning to induce additional pest probl ems (spider mites and cotton aphids) in some areas. This is of great concern to many producers and pest management practitioners. Organophosphate, carbamate and pyrethroid insecticides can impact natural beneficial arthropod populations and flare secondar y insects. Acephate is commonly used for Lygus control and can flare aphids and mites. Pyrethroid insecticides may flare aphids and mites, as well. Sulfoxaflor should

reduce the frequency of selected insecticides use , es pecially acephate, dicrotophos, a nd oxam yl. The ecological and toxicological profile of sulfoxaflor is considered to be more favorable than the ecological and toxicological profiles of

these insecticides. Limited d ata currently suggest that sulfoxaflor is not likely to flare aphids and m ites.

( ii) A detailed explanation of why alternative practices, if available, either would not provide adequate control or would not be economically or environmentally feasible.

Several IPM strategies are recommended for controlling tarnished plant bug in

cotton (Gore et al. 2008 )

. Non

- chemical tactics include a rea

- wide control of non

crop alternate hosts and selected host plant resistance traits . Proper selection of varieties and managing the optimum planting period are being to produce a rapid

fruitin g and early maturing crop; thereby reducing the time the crop is su s ce p tibl e to this pest. Careful insecticide application timing based upon revised spray action thresholds are used to precisely target populations before they reach

outbreak levels. All of these practices are currently in place and are being used by cotton producers. However, these strategies only serve to suppress populations and are not effective as stand

- alone practices

. Effective chemical control practices are still necessary to prov ide tarnished plant bug management

in cotton.

(5) Effectiveness of proposed use.

The application shall contain data, a discussion of field trials, or other evidence which provide the basis for the conclusion that the proposed pesticide treatment wil l be effective in dealing with the emergency

.

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Sulfoxaflor ( DAS test code GF

- 237 2 , proposed trade name Transform TM ) has been evaluated in laboratory and field trials for the past several years. R ecent publication s by Babcock et al. (2010 , See Appendix B ) and Zhu et al. (2010, See Appendix C ) clearly define the biology and biochemistry of s ulfoxaflor and demonstrate a novel mode of action against sap feeding insects including those

in the order H e teroptera . Insects in the genus Lygus are included this orde r. Sulfoxaflor

- induced mortality was similar between insecticide

- resistant and

– susceptible strains of several Homoptera and Heteroptera. No cross

- resistance was detected to sulfoxaflor in populations expressing resistance to a broad range

of modes of ac tion. T he effectiveness of sulfoxaflor against insecticide

susceptible populations of tarnished plant bug, Lygus lineolaris ( Palisot de Beauvois) was comparable to those of other labeled classes of insecticides

. These research projects support a novel m ode of action for sulfoxaflor including those insecticides with similar chemical structures (neonicotinoids).

Numerous field trials were performed during 2008

- 2010 across the Mid

- South States against tarnished plant bug and are in the process of being p ublished. The first field results were reported by Smith et al. (2010, See Appendix D ) for Mississippi trials and show levels of efficacy comparable to or significantly better than standards (acephate, Bifenthrin, thiamethoxam) on one or more sample perio ds against tarnished plant bug nymphs. For Louisiana during 2009

- 2010

, Hardke (2011, Submitted to Entomological Society of America‟s Arthropod Management Tests, See Appendix E ) summarized the results of field trials for sulfoxaflor performance against ta rnished plant bug. In the 2009 trials, e ffective rates and application frequencies were defined c ompared to standard products. In

a co

- application trial with a pyrethroid

- resistant population, sulfoxaflor outperformed Endigo and Bifenthrin (alone) on one o r more post

- treatment

evaluation dates. Based upon total insects d uring 2010, sulfoxaflor at the upper rate and in combination with novaluron demonstrated significantly better control of tarnished plant bugs than acephate and efficacy equivalent to a comb ination a pyrethroid and thiamethoxam (Endigo). Reports of additional field trials from Arkansas, Mississippi, and Tennessee are in preparation and will serve to support

the Louisiana results.

A multi

- state (AR, LA, MS, TN) summary of field trial s against “high pressure” tarnished plant bug infestations on cotton during 2008

- 20 1 0 is reported in Appendix F . These results demonstrated sulfoxaflor at one or more rates demonstrated control of plant bugs (high population levels) superior to the OP,

d icrotophos. The residual efficacy of sulfoxaflor was greater than that for both dicrotophos and thiamethoxam. Efficacy was similar to a co

- application of a pyrethroid + neonicotinoid. In a comparison of cotton yields among treatments for these trials, su lfoxaflor was similar to that of acephate (Acephate is broader spectrum and may have provided some yield increase from additional caterpillar pest control). Pest management practitioners recognize that sulfoxaflor should not be used as a single, season

- lo ng treatment, so chemical control strategies

with co

- applications and/or rotation for sequential treatments are the logical use
pattern.

When sulfoxaflor was evaluated as a component of this type of strategy, those use patterns with sulfoxaflor m aintained tarnished plant bug populations below the action threshold for the duration of the trial; whereas a standard strategy was

### 8

unable to provide satisfactory control. In a commercial field, the standard

treatments (without sulfoxaflor) would have required addi tional applications to reduce populations. In the season

- long trials, strategies relying on sulfoxaflor significantly increased cotton yield above the standard

- treated and non

- treated plots. Willrich et al. (2010, see Appendix G ) further summarized resu lts for 2008

- 2009 as an abstract and reported sulfoxaflor ‟s acute toxicity for knockdown of tarnished plant bug infestations at ≤ 5 d and residual control extending for ≥ 7 d. In addition, cotton treated with sulfoxaflor produced lint yield s equal to or

s uperior than cotton treated with acephate (1.0 lb AI/acre) across 16 trials.

All available data indicates that s ulfoxaflor is an alternative product to the insecticides currently used to manage tarnished plant bug on cotton. It will be an excellent tool f or Mississippi and Mid

- South cotton IPM programs by improving efficacy, reducing input costs, and increasing yields. This compound has a selective spectrum of activity, has not flared other pest s, can be used as a rotational partner with other chemistries, and has demonstrated value against

insect icide

- resistant populations. It is likely that sulfoxaflor will be the backbone of chemical control strategies for tarnished plant bug and is desperately needed in this emergency situation.

(6) Discussion of r

esidues for food uses. If the proposed use is expected to result in residues of the pesticide in or on food, the application shall list the food likely to contain such residues and shall contain an estimate of the maximum amount of the residue likely

to re sult from the proposed use, together with the information on which such estimates

are based.

For the Section 18, cotton is the crop to be treated. Applications made in

accordance with the Section 18 label directions will not exceed a residue in cotton

of 0.17 ppm (Proposed MRL 0.20 ppm; 0.0015 ppm for cotton

- oil, is 0.15 ppm for seeds). EPA will establish a temporary tolerance for this use.

(7) Discussion of risk information.

The sulfoxaflor registration application submitted to EPA July 31, 2010 by Dow AgroSciences ha s address ed the potential risks to human health, endangered or threatened species, beneficial organisms, and the environment expected to result from the proposed use, together with references to data and other supporting

information.

Studi es done with sulfoxaflor indicate there is no reason to expect that any increased risk from this use on cotton would occur either to beneficial organisms or to the environment compared with the current regimen of insecticides used on cotton today. The prod ucts that sulfoxaflor would replace are acephate and dicrotophos among others. Sulfoxaflor has a softer profile on beneficial organisms and endangered species than the insecticides it will replace.

Human Health (provided by registrant) The Tier 1 acute di etary exposure assessment (i.e., MRL

- level residues, 100% crop treated) and a refined chronic dietary exposure assessment (i.e., average residues from field trials with processing factors, or as estimated for meat, milk, poultry and eggs) demonstrate

dieta ry (food + water) exposures that are below the aPAD and cPAD, respectively,

### 9

for all subpopulations. Thus, this dietary exposure assessment demonstrates a reasonable certainty of no harm associated with the proposed use of sulfoxaflor.

Sulfoxaflor exhibits low acute mammalian toxicity (EPA Toxicity Categories III

- IV). No effects occurred in any genotoxicity study. Results from subchronic and chronic toxicity studies revealed the liver to be the primary target organ with

effects of limited concern or no rele vance to humans. Acute bolus doses caused transient signs of cholinergic toxicity, but neurotoxicity did not occur at high doses in a dietary subchronic study, or in a developmental neurotoxicity study. Reproduction and developmental studies identified a m arginal delay in puberty onset in males with no apparent sequelae. Peri

- post natal effects occurred in rats but not in rabbits and were shown not to be relevant to humans. Carcinogenicity

studies in rats and mice demonstrated that the rodent liver effects resulted in tumors following a lifetime of exposure, but the underlying mechanism is well

known and has been found to be of little or no concern to humans. In rats but not mice, high doses of sulfoxaflor increased the size of naturally occurring testicular tumors, which, in turn, led to several secondary effects in associated tissues. Based on these results, the principal target organ for sulfoxaflor is the liver, the most common target organ for the toxicity of pesticides. Sulfoxaflor has no genotoxic pote ntial, has little to no concern from a reproduction perspective, and has low concern for carcinogenicity. When used as directed, sulfoxaflor represents a low hazard to humans.

Endangered Species

A list of the endangered species present in this applica tion was obtained from the

US Fish and Wildlife Service website

. (see attachment

, Appendix H ). None of these species would be impacted by applications of sulfoxaflor to control plant bugs, due to very low toxicity to these organisms and/or the fact that t hey do not

occur in the Mississippi cotton ecosystem.

Beneficial Organisms

The acute and long

- term environmental toxicology studies of sulfoxaflor conducted to fulfill the requirements of the US EPA as indicated in Subpart G 40 CFR §158.630 are to pro vided by Registrant . Regarding aquatic species, sulfoxaflor exhibits very low acute toxicity to fish, freshwater crustaceans ( Daphnia ), oysters, algae, and aquatic vascular plants. Species sensitive to sulfoxaflor include midge larvae, Chironomus species ( sediment

- dwelling insects), and the mysid shrimp Americamysis bahia (a saltwater free

- swimming crustacean). Sulfoxaflor exhibited effects on growth in long

- term, early

- life

- stage toxicity tests in the freshwater fish fathead minnow and the saltwater fish

s heepshead minnow, slight effects on reproduction at a high concentration of 100 mg/L in a life

- cycle test on Daphnia magna, and effects on time to first brood in mysid shrimp in a life cycle study. Sulfoxaflor may be considered by US EPA

standards to be „s lightly‟ to „moderately‟ toxic to birds in acute oral toxicity studies. Sulfoxaflor did not exhibit any effects on reproduction in birds. Sulfoxaflor exhibited acute toxicity to honey bees in the direct contact toxicity test. However, aged residue toxicity tests in which honey bees were exposed to

field

- aged residues on alfalfa leaves indicated significant reduction of acute toxicity to acceptable levels after at least 3 hours of aging. At labeled use rates,

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sulfoxaflor exhibited no phytotoxicity in seedlin g emergence and vegetative vigor tests in 10 crop species.

Resulting Environment F rom U se

Mississippi ‟s farmscape should experience a reduction in the numerous insecticide applications used to control tarnished plant bug. This reduction will

be even mo re important considering that many of those replaced applications will

be for organophosphate s and/or carbamates. The availability of sulfoxaflor on

cotton will directly reduce alternative sprays for the target pest, but also indirectly

reduc e probability of flaring secondary pests. This can further reduce the number

of total sprays (all products) on cotton.

8) Coordination with other affected State or Federal agencies. If the proposed use of the pesticide is likely to be of concern to other Federal or St ate agencies, the application shall indicate that such agencies have been contacted prior to submission of the application, and any comments received from such agencies shall be submitted to EPA.

The following state agencies have been contacted :

Missis sippi‟s Bureau of Plant Industry

(9) Acknowledgment by registrant. The application shall contain a statement by the registrants of all pesticide products proposed for use acknowledging that a request has been made to the Agency for use of the pesticide un der this section. This acknowledgment shall include a statement of support for the requested use, including the expected availability of adequate quantities of the requested product under the use scenario proposed by the applicant(s); and the status of the registration in regard to the requested use including appropriate petition numbers, or of the registrant's intentions regarding the registration of the use.

Dow AgroSciences is the registrant for sulfoxaflor. Dow AgroSciences supports

the use of sulfoxaf lor for a Section 18 emergency use on cotton for the control of Lygus in the states of Mississippi, Arkansas, Louisiana , and Tennessee as a regional emergency use (See Appendix I ) . At this time, Dow AgroSciences predicts that it will be able to supply adeq uate quantities of sulfoxaflor for the emergency use on cotton in the designated region.

Dow AgroSciences has submitted sulfoxaflor for a Section 3 registration on July 31, 2010, including use on cotton. A complete residue package has been

submitted to E PA for cotton on July 31, 2010. In addition, sulfoxaflor is part of a Global Joint Review with two other countries, Canada and Australia. Estimated time for a full Section 3 registration in the US is January 1, 2012.

(10) Description of proposed enforcem ent program. Prior to approval, the applicant shall provide an explanation of the authority of the applicant or related State or Federal agencies for ensuring that use of the pesticide under the proposed exemption would comply with any special requirements imposed by the Agency and a description of the program and procedures for assuring such compliance.

(Currently N/A

- sulfoxaflor is not yet registered in US)

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Provisions provided under the Section 18 Emergency Exemption

(11) Repeated uses. Applications for the use of a pesticide at a site for which the applicant has previously been exempted under section 18 shall contain an interim report summarizing the results of the specific, quarantine, or public health exemption previously issued, if the applicatio n is submitted prior to the time the final report for the previous exemption is due. The interim report shall contain that information specified in §166.32 to the extent available at the time the application is made.

This is the first year this use has be en requested under a Section 18 of FIFRA

.

(b) Information required for a specific exemption. An application for a specific exemption shall provide all of the following information, as appropriate, concerning the nature of the

emergency:

(1) The scientific an d common name of the pest or pest complex;

Lygus lineolaris (Palisot de Beauvois) , tarnished plant bug

(2) A discussion of the events which brought about the emergency condition;

Prior to the mid

- 1990‟s , tarnished plant bugs were generally control led by insecticides directed at other pests during the flowering period of cotton; therefore, economic damage from tarnished plant bugs during flowering was relatively uncommon. However, with >80% of Mid

- S outh (Arkansas, Louisiana, Mississippi, Tennessee) cotton now being planted to transgenic cotton expressing one or more toxins derived from Bacillus thuringiensis (Bt) ( Williams

2008 ) and the eradication of the boll weevil, Anthonomus grandis grandis Boheman (Coleoptera: Curculionidae), many of the foliar applications for other pests during flowering have been eliminated. An increase in federal

conservation/

wetlands reserve programs, wide scale adoption of conservation tillage systems, and increased diversity of the summer farmscape with crop rotations have created a more favorable environment enhancing tarnished plant bug population development. Recently, t his region has experienced a significant reduction in cotton acres and subsequent increase in field corn which also has exacerbated this emergency situation. The tarnished plant bug has adapted to some grass crops with reproduction on field corn which prov ides a non

- sprayed

on

- farm refuge for immigration to “fewer” cotton acres; thereby concentrating the population. The consequence of th ese Southern production system change s is that tarnished plant bug ha s become the dominant season

- long pest across this region d uring the last decade

. Just due to higher p opulations which persist longer during the season, c ontrol costs and crop losses associated with tarnished plant bugs have increased dramatically

. Typically, fewer than two applications per season were di rected towards this pest prior to the mid

- 1990‟s. By 2007, an average of 7.5 insecticide applications targeted this pest the Delta region of Mississippi ( Williams 2008 ).

In addition, an increase in the frequency of chemical control strategies for this pest has intensified selection for resistance. Snodgrass and Gore (2007) has

### 12

reported resistan c e to a nu mber of OP‟s, carbamates, and pyrethroids. Producers were relying heavily on neonicotinoids (thiamethoxam, imidacloprid), but now some populations are expressing reduced sensitivity to those products. In addition, the actual seasonal AI/acre of neonicotin oids further restricts product availability. In order to obtain some level of population management, there has been an increase in rates to the highest dose labeled for a single application. Tarnished plant bug management in many Mid

- S outh fields has degr aded to a point where the only option to reduce yield impacts is co

- application of products with different modes of action. As referenced by Luckmann and Metcalf (1982) on the stages of crop protection, cotton producers and pest management practitioners a re in crisis phase with tarnished plant bug. The subsequent step is that of the disaster phase which would result in a collapse of the existing pest management system for Mid

- South cotton.

3) A discussion of the anticipated risks to endangered or th reatened species, beneficial organisms, or the environment that would be remedied by the proposed use of the pesticide; and

See above discussion. Sulfoxaflor is expected to replace significant quantities of alternative products that are used at higher ra tes and represent greater risk to the environment and beneficial organisms.

(4) A discussion of the anticipated significant economic loss, together with data and other information supporting the discussion that addresses one or more of the following,

as appropriate:

(i) Yield or utilized yield reasonably anticipated in the absence of the emergency and expected losses in quantity due to the emergency;

In a review of pest significance by regions, the tarnished plant bug has had the most severe impact on M id

- South cotton during the past 5 years . In these areas, specifically in the delta regions of Arkansas, Louisiana, and Mississippi, it has been ranked the number one most yield limiting pest over the last several years (Williams 2008). In 2007, control cos t for tarnished plant bug in the Mid

- South was

at least three

- fold greater than the national average control cost (Figure 3 ).

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Figure 3 . Average cost of control per acre for plant bugs ( Lygus spp

. ) in each cotton producing state during 2007.

Tarnish ed plant bug is a pest that is not a restricted problem on local acreage. During the past 5 years, this pest infested greater than 90 % of the planted acreage

in Mississippi (Table 1) . Direct losses from this pest in Mississippi indicate a ~1

- 4

- % yield l oss in spite of spending an average of >$ 5 mill/year for control. This should be considered a conservative estimate because currently there is no alternative strategy which can be used to eliminate crop damage and cotton yield losses from tarnished plant bug. Based on Mississippi ‟s 2 010 historical insect losses and yield data, producers spent $4.5 MM with an estimated yield loss of $ 56.00/Acre for this pests alone and as high as $93.00 per acre loss in 2010

. Th ese data are outlined in the chart/Excel f ile below and published on the website: http://www.entomology.msstate.edu/resources/tips/ cotton

- losses/ data/.

### 14

Table 1. Historical perspective of economic losses for cotton production ass ociated with the tarnishe plant bug

MS Acre Bale $ Lost Application Cost Chemical Cost Totals

Year Acres Planted Treated Acres Bales Lost Yield Loss $ Lost to Lygus/Acre App Cost Total Chem $ Total $ loss

2010 425,000 396,950 42,907 3.87% $93.80 $1,9 84,750.00 $4,533,169.00 $39,864,936.00

2009 296,344 259,555 19,996 2.60% $72.81 $1,297,775.00 $2,964,118.10 $21,575,528.00

2008 362,611 302,249 9,122 1.06% $42.32 $1,511,245.00 $3,451,683.58 $12,791,177.68

2007 666,000 555,000 21,458 1.01% $48.14 $2,775 ,000.00 $6,338,100.00 $26,717,700.00

2006 1,200,000 1,040,557 25,063 0.65% $22.93 $5,202,785.00 $11,883,160.94 $23,859,972.01

5 YA 589,991 510,862.20 23,709.20 1.84% $56.00 $2,554,311.00 $5,834,046.32 $24,961,862.74

### 15

(ii) The information in paragraph (b ) ( 4 ) ( i) of this section plus prices reasonably anticipated in the absence of the emergency and changes in prices and/or production costs due to the emergency;

The trends previously described (Section b4i) clearly show the recent (5 years) significance of the problem and magnitude of costs and yield losses associated with tarnished plant bugs in cotton.

(iii) The information in paragraph (b ) ( 4 ) ( ii) of this section plus operating costs reasonably anticipated in the absence of the emergency;

The tren ds previously described (Section b4i) clearly show the recent (5 years) significance of the problem and magnitude of costs and yield losses associated with tarnished plant bugs in cotton.

(iv) Any other information explaining the economic consequences of the emergency.

The absence of new products to manage tarnished plant bug has seriously impaired the economic viability of cotton across Mississippi and the rest of the

Mid

- South region. Use of the available products in the recommended chemical

control s trategy is not economically feasible, sustainable, or environmentally friendly. During the anticipated conditional Section 18 registration period (2011)

, sulfoxaflor has the potential to mitigate the substantial financial losses , and become part of a holis tic IPM program for cotton growers.

References used to support previous statements and Section 18 request :

Babcock, J. M, C. B. Gerwick, J. X. Huang, M. R. Loso, G. E. Nakamura, S. P. Nolting, R. B. Rogers, T. C. Sparks, J. D. Thomas, G. B. Watson and Y. Zhu. Biological Characterization of Sulfoxaflor, a Novel Insecticide. 2010. Pest Mgmt. Sci. (In press

, See Appendix C ).

Catchot, A. 2007. Mississippi Crop Situation. No. 21

. http://www.msucares.com /newsletters/pests /cis/index.html.

Cook, D. R., B. R. Leonard, E. Burris, and D. R. Burns. 2007. Tarnished plant bug management in Northeast Louisiana, pp. 1704

- 1710. In Proc. Beltwide Cotton Prod. Res. Conf., National Cotton Council, Memphis, TN.

C opes, J. T., G. L. Snodgrass, J. Sharp, B. R. Leo nard, D. R. Ring, and D. Blouin. 2010. Acephate resistance is widespread in Louisiana tarnished plant bug populations. La. Agric. 53: 14

- 15.

Gore, J., G. Andrews, J. Robbins, A. Catchot, F. Musser, J. Smith, G. Snodgrass, R. Jackson, C. Abel, D. Dodds, G . Lorenz, S. Akin, G. Studebaker, R. Leonard, R. Bagwell, S. Stewart, and K. Tindall. 2008. Strategies for managing tarnished plant bugs in cotton. Miss. State Univ. White Paper Recommendations Report, 4 pp. released April 2008.

### 16

Lorenz, G, T. Barber, S. D. Stewart, A. Catchot, J. Gore and D. Cook. 2009. Evolving pest management in cotton. Proc. Beltwide Cotton Conf. 1395.

Luckmann W. H. and R. L. Metcalf. 1982. Why pest management, pp. 1

- 33? In R

. Metcalf and W. Luckmann eds. Introduction to Pest M anagement . John Wiley and Sons, New York, NY.

Moore, J. L., J. H. Temple, J. T. Hardke, K. Emfinger, P. P. Price, J. T. Copes, J. W. Sharpe, E. Burris and K. A. Fontenot. 2010. Proc. Beltwide Cotton Conf. 817

- 819.

Sharp, J. W., J. T. Copes, B. R. Le onard, E. Burris, P. P. Price, J. H. Temple and J.

T. Hardke

. 2010. Can we rely on any single insecticide for season long tarnished plant bug control in Louisiana cotton

, p. 1170. In Proceedings, 2010 Beltwide Cotton Conferences, National Cotton Council, Memphis, TN.

Smith, J. F., L. N. Owen, and A. L. Catchot. 2010. Efficacy of foliar insecticides against tarnished plant bug on cotton (TEST 2), 2009

. http://www.entsoc.org/

Protected/AMT/ members only /AMT35/F/F27.pd f.

Snodgrass, G. L. 2010. Status of Insecticide Resistance: Tarnished Plant Bug

. Proceedings, Cotton Incorporated Seminar

, Memphis, TN (November 9

- 11, 2010)

See Appendix A

.

Snodgrass, G. L. and J. Gore. 2007. Status of insecticide resistance for the

tar nished plant bug, pp. 56

- 59. In Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis, TN.

Snodgrass, G. L., C. A. Abel, R. E. Jackson, and J. Gore. 2008. A Bioassay for Determining Resistance Levels in Tarnished Plant Bug Populations to

Neon icotinoid Insecticides. Southwestern Entomologist 33: 173

- 180.

Williams, M. R. 2008. Cotton insect losses, pp. 927

- 929. In Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis, TN.

Willrich

- Sieber t, M., L.C Walton, R.B. Lassiter, R.A. Haygood, J.D. Thomas, and J.S. Richburg. 2010. Performance of Dow AgroSciences‟ Sulfoxaflor insecticides against tarnished plant bug, Lygus lineolaris, in Mid

- South cotton, pp. 1204.

. In

Proc. Beltwide Cotton Res. C onf., National Cotton Council, Memphis, TN.

Zhu, Y., M. R. Loso, G. B. Watson, T. C. Sparks, R. B. Rogers, J. X. Huang, C. B. Gerwick, J. M. Babcock, D. Kelley, V. B. Hegde, B. M. Nugent, J. M. Renga, I. Denholm, K. Gorman, G. DeBoer, J. Hasler, T. Meade

, and J. D. Thomas. 2010.



### D iscovery, Biology and Biochemistry of Sulfoxaflor: A Novel Sap

- Feeding Insecticide. J. Agric. Food Chem. ( A ccepted for publication

, See Appendix C ).