## SECTION 18 EMERGENCY EXEMPTION REQUEST

For the State of Wyoming

- 20 11

TYPE OF EXEMPTION

– SPECIFIC

CONTACT PERSON(S) AND QUALIFIED EXPERT(S) (166.20(a)(1))

CONTACT PERSON: QUALIFIED EXPERT:

Name: Polly Cross Name: Terri Hass

Title: Assistant Manager Title: Technical Manager

Organization: Wyoming Dept. of Organization: Chemtura Corp

.

Agricultur e

Address: 2219 Carey Ave. Address: 199 Benson Road

Cheyenne, WY 82002 Middlebury, CT 06749

Phone: 307

- 777

- 6 590 Phone: 203

- 573

- 2027

Fax: 307

- 777

- 6593 Fax: 203

- 573

- 2610

Email: pcross@state.wy.us Email: terri.hass@chemtura.com

### DESC RIPTION OF PESTICIDE REQUESTED ( 166.20(a)(2))

Common Chemical Name (Active Ingredient): diflubenzuron

Trade Name(s) and EPA Reg. Number: Dimilin 2L, EPA Reg. #400

- 461

Formulation: % Active Ingredient: 2 lbs. A.I./gallon

Manufacturer(s): Chumtura Corp.

DESCRIPTION OF PRO POSED USE (166.20(a)(3))

Sites to be Treated: All counties in Wyoming where Mormon crickets and grasshoppers have or may occur.

Method of Application: Application by aerial and ground equipment only i s requested. Application through irrigation equipme nt is prohibited.

Rate of Application: 2 fl. Oz of Dimilin 2L

Maximum Number of Applications: Do not exceed 2 fl. Oz. of Dimilin 2L per acre per cutting, or a total of 4 fl. Oz per growing season. Wyoming alfalfa hay fields are harvested

2

- 4 times per growing season, depending on the elevation. Lower elevations have as many as 4 cuttings, with higher elevations typically having only 2 cuttings, due to the shortened growing season.

Total Acreage (or other units) to beTreated: All alfalfa hay acreage ( 5 50,000 acres) could potentially suffer grasshopper or Mormon cricket outbreaks. Due to proximity to extensive federal lands, it is anticipated that 6 % of the hay ground could be severely impacted and require treatment. Acreage to be treated is anticipa ted to be 26,000 acres.

Total Amount of Pesticide to be Used: At 2 fl oz of product applied to 26,000 acres of alfalfa (assuming the maximum of two applications per acre) would require 407 gallons (814 lbs. a.i.) of Dimilin 2L.

Use Season: The first applications would be made after May 1 st and the last applications

would be made no later than October 31 st , 20 1 1

.

Additional Restrictions. User Precautions and Requirements. Qualifications of Applicators, etc:

This application is being submitted for U SDA/APHIS/PPQ and Wyoming Weed & Pest

Districts. Private sector use will be very minimal.

Dimilin 2L is not effective in controlling Mormon crickets or grasshoppers once they reach the adult stage.

All applicable restrictions, directions and precautions on the Federal Label and Section 18

use directions must be followed.

Applications are to be made in accordance with the USDA/APHIS rangeland grasshopper suppression program.ALTERNATIVE METHODS OF CONTROL (166.20)(a)(4))

Several chemical controls for grasshoppers and crickets are available in Wyoming , but all available products for control have minimal residual activity. There are at least 6 species of grasshoppers with overlapping generations and emergence dates, which results in multiple application s per generation for control of the various species hatching at different times throughout the season. Regulations prohibiting more than one application and/or prohibitive cost of multiple applications make these options ineffective. Non

- selectivity

toward beneficials, which could reduce predator populations, is another negative impact of all registered products. For specific explanations, see below.

The following products are registered, but have shortcomings that make them inadequate

for control for th e indicated reasons. “Most of the registered insecticides currently registered for grasshopper control are not effective, are toxic to beneficial arthropods, or provide only short residual control of grasshoppers necessitating multiple pesticide applicatio ns.”

Carbaryl (Sevin): It is effective, but two to three applications would be necessary for

seasonal control. The label directions state only one application per year. This product is

d etrimental to beneficial insects.

Chlorpyrifos : It is an effective product, but the two to three applications are required. It is also more expensive than carbaryl and could not be used in an alfalfa hay cropping system without eliminating the profit margin

. This product is detrimental to beneficial

insects. Not in USD A/APHIS/PPQ Environmental Impact Statements so not an option for

their use.

Lambda

- Cyhalothrin (Warrior): 7

- 10 day residual (requiring two to three treatments for control) $ 7 .60

- $9.90/acre. This product is also more expensive than carbaryl.

. This product is detrimental to beneficial insects. Not in USDA/APHIS/PPQ Environmental Impact Statements so not an option for their use.

Methyl parathion (generic): The length of residual on the crop is very short (24

- 48 hour residual), requiring multiple treatment s at $ 8 .00/acre. More expensive than carbaryl and requires more treatments than alternatives due to short residual.

. This product is

detrimental to beneficial insects. Not in USDA/APHIS/PPQ Environmental Impact Statements so not an option for their use.

Malathion : Very short period of residual activity. Three to four applications would be necessary for control, making the product more expensive than other alternatives.

. This product is detrimental to beneficial insects.

Additional alternatives are li sted on attachment # 6. However, those products

mentioned are detrimental to beneficial insects.

Dimilin provides early season control without subsequent spraying. It has been proven effective in grasshopper control. It has a greater than 30

- day residua l on treated foliage and does not impact non

- target beneficial insects. These qualities make the product unique in controlling outbreaks of multiple species of grasshopper throughout the growing season. All alternative products have a period of residual c ontrol of between two and ten days, necessitating repeat applications. The cost of these multiple applications in lowrainfall areas are cost prohibitive requiring growers to make a decision of whether to

control grasshoppers and lose any hope of profit o r lose the crop from feed damage.

Dimilin’s longer period of residual activity provides a longer control window which allows for the control of delayed hatching nymphs, later hatching grasshopper species, and secondary infestations, negating the need of a dditional applications prior to harvest of the foliage for hay. When a grasshopper nymph is exposed to Dimilin, it is unable to successfully molt. Dimilin also demonstrates transovarial activity that can weaken or prevent hatching of subsequent population s. Grasshoppers that succeed in molting may exhibit deformity that could contribute to slower movement, limited jumping, reduced feeding and lack of ability to fly. Any adult/nymph exhibiting these symptoms would more likely be susceptible to predatory and /or parasitic insects (that would be eliminated by the use of other products).

Biological Control: Natural

- occurring pathogens have shown little success and often, complete failure, even if successful, they are not commercially available. Surveys wer e conducted with Nosema Locustae that did show some effectiveness on small instars. However, when looking at infestations that are being predicted for Wyoming in 201 1 using this type of control would not be effective or economical feasible

.

EFFICACY OF U SE PROPOSED UNDER SECTION 18 (166.20(a)(s))

Chronic dietary exposure, including drinking water, was evaluated for the U.S. population and various population subgroups including infants and children. One

- day single dose

oral studies in rats and mice indic ated there were no significant acute effects observed. As only marginal effects were noted, an acute exposure assessment is not needed for

diflubenzuron.

Dietary Exposure from diflubenzuron was estimated based on the average residue

values from the curre proposed uses on pear, nut crops, pistachios, stonefruits (except cherries), peppers, and alfalfa. Percent of crop treated was also factored into the estimate. Residues in meat, milk and egg products were obtained from extrapolation of metabolism study data to anticipated livestock dietary burdens. The dietary exposure analysis was estimated based

on 1989

- 92 USDA food consumption data. For the U.S. population (total), the dietary

exposure o f diflubenzuron was estimated as 0.000157 mg/kg/day. For nursing and non

nursing infants, the exposure was estimated as 0.000140 and 0.000410 mg/kg/day, respectively. For children, the exposure was 0.000343 and 0.000219 mg/kg/day for 1

- 6 year olds and 7

- 12 year olds, respectively.

The dietary exposure from p

- chloroaniline and 4

- chlorophenylurea (CPU), which have been detected in some food products, was also determined. Average residues or 1⁄2 LOQ from field trials for mushrooms, rice, pears, almonds, pe cans, stonefruits (peaches, prunes, plums), and peppers were used. Residues in meat, milk, and eggs were obtained from extrapolation of metabolism data to anticipated livestock dietary burdens. The percent treated of each crop was also factored into the exposure estimate. For the U.S. population (total), the dietary exposure of PCA and CPU was estimated at 0.000001 mg/kg/day and 0.000017 mg/kg/day, respectively.

Drinking Water: Diflubenzuron degrades in soil relatively quickly with an aerobic half

- life ranging from 3

- 7 days. Major degradates include difluorobenzoic acid (DFBA) and CPU. DFBA is further metabolized through decarboxylation and ring cleavage by soil microbes whereas CPU is slowly degraded to soil

- bound entities. Under anaerobic aquatic

condi tions, diflubenzuron has a half

- life of 34 days with the main degradates being DFBAand CPU. In surface water, diflubenzuron is degraded by microbes with a half

- life of 5

- 10

days.

The soil mobility of diflubenzuron is considered quite limited based on a number of experimental studies as well as by computer modeling. CPU has also been shown to be relatively immobile in soil. Although DFBA shows mobility in soil, it is rapidly degraded. Therefore, based on results of laboratory and field studies, it is not likely that diflubenzuron or it’s degradates will impact ground water quality to any significant extent.

The Drinking Water Level of Concern (DWLOC) for chronic (non

- cancer) exposure to diflubenzuron in drinking water was determined as 695 ppb for the U .S. population (total) and 197 ppb for infants and children. The DWLOC for chronic (cancer) exposure to CPU in drinking water was determined as 1.7 ppb for the U.S. population (total). Based on SCI

GRO and Tier II PRZM

- EXAM modeling, estimated residues o f diflubenzuron in ground and surface water are not expected to exceed 0.0023 ppb and 0.09 ppb, respectively, and residues of CPU in ground and surface water are not expected to exceed 0.065 ppb and 0.23 ppb, respectively. Because PCA is only a minor metab olite in the environment, it is not considered in the drinking water assessment. The estimated concentrations of diflubenzuron and CPU in ground and surface water are less than the DWLOCs as a contribution to chronic aggregate exposure.

Non

- dietary expo sure . Diflubenzuron is a restricted use pesticide based on its toxicity to aquatic invertebrates. This restricted use classification makes it unavailable for use by homeowners. Occupational uses of diflubenzuron may expose people in residential
locations, parks, or forests treated with diflubenzuron. Based on very low residues detected in forestry dissipation studies, a low dermal absorption rate (0.5%), and extremely low dermal and inhalation toxicity, these uses are expected to result in insignificant ris k, and are therefore not included in the aggregate risk assessment.

Cumulative Effects Compton Chemical has considered the potential for cumulative effects of diflubenzuron and other substances with a common mechanism of toxicity. The mammalian toxicity of diflubenzuron is well defined. We are not aware of any other pesticide product registered in the United States that could be metabolized to p

- chloroaniline. For this reason, consideration of potential cumulative effects of residues from pesticidal subs tances with a common mechanism of action as diflubenzuron is not appropriate. Thus, only the potential exposures to diflubenzuron were considered in the total exposure assessment.

Safety for U.S. Population

The total non

- occupational aggregate exposure fr om diflubenzuron would occur from food and drinking water routes. Based on the 0.02 mg/kg/day RfD (reference dose) derived from the dog chronic NOEL of 2 mg/kg/day and a 100

- fold safety factor, chronic dietary exposure to the U.S. population (total) is 0. 8% of the RfD. Aggregate exposure does not exceed 100% of the RfD when the potential theoretical residues in drinking water are

included.

The total non

- occupational aggregate exposure from PCA would occur from the dietary

route. The risk from diflubenz uron

- derived PCA can be estimated using a linear extrapolation of the dose

- response from the rat chronic study conducted by the National Toxicology Program in which rats were dosed via gavage with p

- chloroaniline [hydrochloride] for 24 months. EPA has det ermined the q1* as 0.112 based on the combined incidence of liver adenomas and carcinomas in male mice. Using this q1*, the theoretical risk to the U.S. population (total) from dietary exposure to diflubenzuron

derived PCA was estimated at 8.18 x 10
- 8

.For CPU, total aggregate exposure could occur from food and drinking water. The EPA

has determined that since CPU is structurally related to monuron, the most potent Q1* of

1.52 x 10 - 2 (based on male rat liver neoplastic nodule and/or carcinoma combined t umor rates) from the NTP carcinogenesis data for monuron should be used for assessing cancer risk from CPU. Using this Q1* the theoretical risk to the U.S. population (total) from dietary exposure to CPU was estimated at 2.51 x 10
- 7. The aggregate cancer risk including drinking water does not exceed the level of concern.

Safety for Infants and Children The chronic dietary exposure of diflubenzuron of nursing and non

- nursing infants is 0.7% and 2.0% of the RfD, respectively, and for children 1

- 6 and 7

- 12 years old is 1.7% and 1.1% of the RfD, respectively. Aggregate exposure does not exceed 100% of the RfD when the potential theoretical residues in drinking water are included.

The NOEL for maternal and developmental toxicity in rats and rabbits were gr eater than 1,000 mg/kg/day, and the NOEL for reproductive toxicity was greater than 5,000 mg/kg/day. Therefore, based on the completeness and reliability of the toxicity data and the conservative exposure assessment, there is reasonable certainty that no harm will result in infants and children from aggregate exposure to residues of diflubenzuron and its conversion products containing the p

- chloroaniline moiety.

Safety to beneficial insects

DIMILIN 2L is not hazardous to bees when used alone. Apiarists in Wyoming have seen a significant decrease (25%

- 33%) in bee numbers over the last few years. All other products that are labeled for grasshoppers and Mormon c ricket control in alfalfa and hay fields are detrimental to bee population. To use product s o ther then Dimilin 2l would jeopardize the a piary industry in the state of Wyoming. ( Wyoming Apiarist s were sent question e rs over the last two years to determine bee losses in the state.)

ENFORCEMENT PROGRAM (166.20(a)(10))

Although Wyoming does not hav e enforcement primacy at this time, the department has two (2) full

- time and one ( 2 ) part

- time pesticide enforcement inspectors, which will enable us to enforce the restrictions under Section 18. All inspection records will be available to EPA Region VIII inspectors for any additional monitoring they deem necessary.

REPEAT USES (166.20(a)(11)

This is Wyoming’s third request for a Section 18 for Dimilin 2L. Wyoming’s first request ed

the use of Dimilin 2L on alfalfa to control grasshoppers and Mormon cr ickets in 2005

. Wyoming’s second request was submitted in 2010. This application is being submitted for

USDA/APHIS/PPQ a nd Wyoming Weed & Pest Districts and for the Wyoming Beekeepers for protection against more production losses. U se from P rivate applica tor s will be very

minimal

. The 201 1 request is due to project ed numbers from USDA/APHIS/PPQ. PPQ projects an outbreak of grasshoppers from 15 + per square foot depending on location within the state and weather conditions this spring. The action thresho ld lever for grasshoppers in Wyoming is 8 insects per square yard. In 20 10 numerous counties in the state of Wyoming reported as high as 50 insects per square yard . If PPQ is correct in their projections

, the devastation within several counties in Wyomi ng could be at astronomical proportions again in 2011

. R angeland areas being sprayed by APHIS/PPQ and Weed and Pest Districts have alfalfa fields located within the spray area or adjacent to them . To spray rangelands and not include alfalfa fields that ar e located within the rangeland oradjacent to them would only give a safe haven to grasshoppers and Mormon crickets

causing more damage and economic losses to Wyoming alfalfa producers

.

PDF FILES: 1. Wyoming Adult Grasshopper survey 2009 (attachment #2)

2. Wyoming Adult Grasshopper survey 20 10 (attachment #3)

PROGRESS TOWARD REGISTRATION (166.25(a)(2))

The I R

- 4 08678 diflubenzuronialfalfa residue study was initiated in 2004. This study consists of a total of 4 field trials (1 in Idaho, 1 in Washin gton, I in California and 1 in Colorado). Two treatments were included in the study. Treatment 02 consisted of applications of diflubenzuron at 0.0325 lb ai/A one day before sample cutting of forage and hay for a total of 3 applications and 3 cuttings. Tre atment 03 consisted of three applications of diflubenzuron at 0.0325 lb ai/A, at 14 day intervals with the last application 1 day before the collection of seed samples. The samples in this study have been analyzed (see attached summary of residues) and the analytical summary report has been

received at IR

- 4 Headquarters. Diflubenzuron parent residues in forage samples after the third cutting ranged from 0.824 to 2.890 ppm. Diflubenzuron parent residues in hay samples after the third cutting ranged from 2.60 8 to 9.072 ppm. Diflubenzuron parent residues in seed samples ranged from 0.056 to 0.434 ppm. A second study (A8678) was initiated in 2008 to include analysis of metabolites (CPU and PCA) and storage stability samples. These samples have not been analyzed yet.

Below is the residue test application scenario:

PCR: 0.0325 LB.AI/A; AERIAL APPLIC: 1

- 5 GAL/A; GROUND APPLIC: 20

- 30 GAL/A; ONE APPLIC/CUTTING; 14 DAY PHI Protocol: (THE 2008 PROTOCOL A8678 WILL COMPLETE THE STUDY, ADDING

ANALYSIS OF METABOLITES A ND STORAGE STABILITY) 0.0325 LB AI/A; MAKE A

SINGLE BROADCAST APPLIC IN 20

- 30 GPA AT 1

- DAY BEFORE EACH OF 3 FORAGE AND HAY SAMPLE CUTTINGS; AND MAKE 3 BROADCAST APPLIC IN 20

- 30 GPA AT

14

- DAY INTERVALS, WITH A 1

- DAY PHI FOR SEED; FOR ALL TREATMENTS

INCLUDE 1 PT/A EMULSIFIED VEGETABLE OR PARAFFINIC CROP OIL

Also see Attachment IR

- 4 08678/ Diflubenzuron /Alfalfa ( Attachment # 9)

NAME OF PEST (166.209(b)(1))

Scientific Name: Approximately 120 species (mainly Acrididae family , a few

Tettigoniidae)

Common Na me: Grasshopper

Scientific Name: Anabrus simplex

Common Name: Mormon cricket

DISCUSSION OF EVENTS OR CIRCUMSTANCES WHICH BROUGHT ABOUT THE

EMERGENCY CONDITION (166.20(b)(2))

Grasshoppers are a historic threat to all crops. The Mormon cricket is not a true cricket. The insect resembles more a lifestyle of a grasshopper. Mormon crickets are of economic importance in the fact that they destroy plants on rangeland, cropland, and vegetable gardens. Male and female Mormon crickets are large insects and can reach lengths of two

and one

- half inches during the adult stage. The female Mormon cricket is distinguished bythe long ovipositor that also looks like a type of "stinger" located at the end of the

abdomen. The male lacks this ovipositor. The Mormon cricke t can be economically devastating.

It has been calculated that a Mormon cricket, at a density of one per square yard, can consume 38 pounds of dry weight rangeland forage per acre. The Mormon cricket destroys sagebrush, alfalfa, small grains, seeds, gr asses, and vegetable crops. In the past, conventional tillage, summer fallow and burning have worked to control infestations. Occasionally, there would be a mild winter which allowed grasshopper nymphs to survive the winter and multiply to economic thresh olds. This would bring on area wide treatments and emergency control measures. The spring of 20 1 1 is predicted to be warmer than average throughout most of the state and pressures from both Mormon crickets and grasshoppers is already mounting. Fremont, G oshen and Niobrara County in Wyoming

are major producer s of alfalfa hay and grass hay in the state. Niobrara County was also

one of the counties that w ere hardest hit in 20 10 , reporting loss es up to 90% of all crops due to grasshopper and Mormon cricket in festation. These counties also have some of the highest number of apiary locations. Beekeepers in these counties saw a drop in honey production of 70 % to 8 0 %. (See beekeepers letter

– Attachment #7 )

Registered pesticide alternatives with some activi ty on grasshoppers also control a wide variety of beneficial insects. The available pesticides are short

- lived in the environment and require multiple applications to control a single generation of grasshoppers or Mormon

crickets. Available insecticides only control the adult insects and the next generation expands quickly to economically significant numbers, requiring multiple applications. Predatory insects, which provide good control without the need of chemical controls for the aphid, do not exist fo r the grasshoppers and Mormon crickets.

The economic effects from grasshoppers are expected to be disastrous, due to the warmer winter this year and the warm, moist spring. The moisture has provided vegetation for the nymphs to grow and grasshoppers ar e becoming a major problem. Dimilin has shown longer effectiveness without harming beneficial insects. The increased length of control coupled with the “safer” technology will gain the producers more integrated pest management, and longer term control.

For the 201 1 crop years USDA/APHIS/PPQ has made projections of 15 + grasshoppers per square yard in alfalfa producing counties in the state. The state relies on information supplied by USDA/APHIS/PPQ for grasshopper population densities

. APHIS has

repo rted that their survey in 20 10 consisted of 2,135 stops statewide between the dates of

7/19/2010 and 9/2/2010

. Survey stops were collected by APHIS employees using the (18 sq. foot)/2 method

. S urvey is attached for complete survey collection informati on

.

PDF FILES: 1. Assessing Rangeland Grasshopper Populations (Protocol for

survey) (Attachment #1)

2. Wyoming Adult Grasshopper Survey 20 09

. (Attachment #2)

3. Wyoming Adult Grasshopper Survey 20 10. (Attachment #3)

Control strategies.

The n ew levels of pest pressure, combined with the multiple species/extended nymph

hatching characteristics of grasshoppers, results in growers being faced with pest pressure over longer periods of time. Alfalfa hay growers are faced with low prices for

their crop and the cost of making multiple applications for grasshopper control will remove any likelihood of the growers making any profit. Due to the short residual of available pesticides growers would suffer significant crop losses from insect migration fr om surrounding ground that was not treated. Within a few days of treatments, the currently available products will not offer any further protection and the crop is vulnerable toextensive damage from migrating grasshoppers and Mormon crickets. The combin ation of

cost of product, costs of multiple application and crop losses (including contaminated hay with insect carcass) have created an urgent, non

- routine situation.

EXPECTED RESIDUE LEVELS IN FOOD (166.20(a)(6))

Chemtura Corp. has conducted two separa te residue studies on fresh and dried grass
treated with Dimilin. Tests were conducted in a total of nine locations, one each in Wyoming, North Dakota, Nebraska, California, Pennsylvania, Florida, Oklahoma, South Dakota and Montana. The Dimilin was appli ed either by ground or aerially. Applications were made using 2 oz. or 1 oz. of formulated product in a total spray volume of one quart. Fresh grass samples were harvested at 2 hours following application of the Dimilin. Dried grass samples were also obt ained from the residue test plots.

Residues of diflubenzuron were determined using high

- pressure liquid chromatography. The LOQ was determined to be 0.05 ppm.

Residues of diflubenzuron in fresh and dried grass treated with Dimilin had residues of:

Fr esh grass

– 2 oz. appl. = 0.24

– 3.82 ppm

1 oz. appl. = 0.06

– 5.47 ppm

Dried grass

– 2 oz. appl. = 0.41

– 5.68 ppm

1 oz. appl. = 0.63

– 5.11 ppm

DISCUSSION OF RISK INFORMATION (166.20(a)(7) )

Diflubenzuron is not toxic to mammals, birds, terrestrial vertebrates, fish, mollusks, or plants. Although diflubenzuron is toxic to certain sensitive aquatic invertebrates, alfalfa in Wyoming is not grown in the vicinity of any listed aquatic invertebr ate. Dimilin 2L is applied at very small use rates (2 ounces per acre) and is sprayed in bands, with equal amounts of untreated ground between the treated bands (Reduced Area & Agent Treatment

- RAAT).
Therefore, the use of Dimilin 2L on alfalfa is not ex pected to adversely affect endangered or threatened species.

COORDINATION WIT H OTHER AFFECTED FEDERAL, STATE, AND LOCAL AGENCIES (166.20(a)(8))

The U.S. Fish and Wildlife Service, Wyoming State Office and the Wyoming Game & Fish Department will be pro vided a copy of this request. Comments will be forwarded to the Agency.

NOTIFICATION OF REGISTRANT (166.20(a)(9))

Chemtura Corp. has been contacted concerning this application and has agreed to support the request. (See attached letter of support.)

DISCUSSION OF ECONOMIC LOSS (166.20(b)(4))Hay is by far the leading crop in Wyoming in terms of value of production. Drought

conditions have reduced the value of Wyoming hay products

. H owever, the market maintained its leading status due to demand for alfalfa in the two largest agricultural

commodities in the state

– sheep and beef cattle. Dairy quality alfalfa receives the highest price and is sold throughout the state, and region. Dairy quality alfalfa has also been shipped as far as Texas and Kentu cky. Alfalfa is harvested from two to four times per

year

, depending upon the elevation, with higher altitudes producing lower yields. On irrigated fields in lower elevations over seven tons per acre of alfalfa can be harvested.

Mormon crickets and gr asshoppers extensively impact the producer’s bottom line, either from crop damage or from chemical costs in controlling the insects. The quality of the alfalfa is also an important consideration from an economic standpoint. Damaged hay will be downgraded from dairy quality, known as “Supreme” and “Premium” to only “Good” or “Fair”. Most of the nutrition is in the leaves, so alfalfa hay with a higher percentage of stems is not acceptable to dairies, which require the maximum nutritional value. Alfalfa

ha y that has lost 20% or more leaf material will be used to mix with other feeds as filler, or used as a supplemental feed for grazing livestock and is currently only worth about $ 55

- $60 per ton. A change in classification result s in loss es of $ 60

- $4 5 per ton. At 10% damage and a downgrade in classification to $6 8 per ton would result in lost revenue to the grower.

Without Dimilin 2L, each cutting in the affected areas is expected to suffer losses of 10% or greater. The first cutting is generally the la rgest crop harvested and is also hit the hardest by Mormon crickets and grasshoppers . Mormon crickets usually don’t affect the later crops as much, because they have finished their life cycle. Grasshopper damage will continue throughout the growing seaso n until frost kills the hay or the grasshopper life cycle is completed and they die.

Without the use of Dimilin 2L on alfalfa and pasture ground, we anticipate approximate losses of $ 4,740,320 .00 (26,000 acres x $ 182.32 , which is the average between gros s revenues in the chart) to alfalfa hay growers in Wyoming.

THREATENED AND ENDANGERED SPECIES (Plants)

Wyoming has one plant that is classified as endangered. The Blowout penstemon is located in 11 counties in Wyoming. Wyoming also has three other pl ant species that are

classified as threatened : 1 . Colorado Butterfly plant located in three counties; 2 . Desert Yellowhead located in one county 3 . Ute Ladies

- Tresses located in 22 counties. The use

of d iflubenzuron instead of less environmentally safe pesticides that harm beneficial pollinators may insure the viability of these species.
(Threatened and Endangered Species Info. from W yoming US FWS web

- site)

Files: 1. Blowout Penstemon

2. Colorado Butterfly plant

3. Desert Yellowhead

4. Ute Ladies

- Tresses

Files located in submission of the 2010 Section 18 Application.APIARISTS

Using d iflubenzuron in place of other approved pesticides that are harmful to bees and other beneficial pests also p rotects Wyoming Apiarists against further losses in revenue

due to bee number decline

.

Wyoming Honey Production Down 2 5 Percent

Honey production during 2009 in Wyoming was down 25 percent. Producers reported seeing a drop from the 2008 production amou nt of 2.38 million pounds to 1.78 million pounds in 2009. There were 37,000 colonies in Wyoming during 2009 with an average of 48 pounds of honey per colony. A drop from the 43,000 colonies in 2008 with an average honey production weight of 61 pounds per colony. According to the Wyoming Agricultural Statistic Service the total value of production was down 22 percent from 2008’s $3.26

million to the 2009 total value of production at only $2.54 million. The 2010 production

number s have not yet been rele ased by the Agricultural Statistics Service. However, I contacted several Wyoming beekeepers who stated that due to crop deprivation caused by grasshoppers many yards had to be moved and no honey was extracted for the months of July and August. Most stat ed that they had a drop in overall honey production of 70 to

8 0 percent. Another extensive loss to Wyoming Honey producers.

Transient Honey Bee Hives : Approximately 65% of Wyoming apiaries are transient

, traveling to almond and fruit groves in Californi a and other warmer states during winter months. Hives are usually brought back to Wyoming in early late March or early April for placement in registered yards.

Wax Production: Wyoming Agricultural Statistics does not gather information regarding

the p roduction or revenues generated from the s ales of excess wa x. However, the National Beekeepers Association reported that the average hive produces 1 pound of wax for every 6 to 8 pounds of honey. The average prices per pound of wax were $6

- $10

, dependi ng on the quality of the wax.

(Information on honey stocks were gathered from Wyoming Agricultural Statistics & letter from the Wyoming

B eekeepers P resident ( Attachment #7 ) Also see Econom ic honey production Attachment #8

.

ECONOMIC DATA (166

. 20(b) (1))

Year Acres Yield per

acre (tons) Price per

ton ($) Gross

Revenue

per acre Average

Cost per

acre Net

Revenue per Acre

20 10 * 550, 000 * 2. 9 * $ 1 2 5 .00 * $3 62

. 50 * $150.00 * $ 212.50 *

2009 550,000 2.9 $120.00 $348.00 $150.00 $198.00

2008 530,000 2.9 $118.00 $342.20 $150.00 $192.20

2007 570,000 2.7 $109.00 $294.30 $150.00 $144.30

2006 500,000 2.3 $101.00 $232.30 $150.00 $82.30

AVERAGE 540,000 2.7 $114.60 $315.86 $150.00 $182.32

w/ Dimilin

2L 540,000 2.7 $114.60 $315.86 $150.00 $182.32

w/o

D im ilin 2L

at 10% damage 5 4 0 ,000 2.4 $68 $160.80 $150.00 $10.80

w/o 5 4 0 ,000 2.3 $68 $156.40 $150.00 $6.40Dimilin 2L

at 15% damage

w/o

Dimilin 2L

at 20% damage 5 4 0 ,000 2.1 $61 $128.10 $150.00

- $22.00

All acreage, yield data and price per ton data were ta ken from the 20 10 Wyoming Agricultural Statistic book

* estimated



### Estimated costs of aerially applied RAATs treatments of carbaryl and diflubenzuron against rangeland grasshoppers,

Treatment Specific Mix Chemical cost Application cost Total cost Strategy per acre per acre per acre
Protected protected protected

RAATs carbaryl 8 fl oz + 0.70 0.78 1.48 to 50% of acreage 8 fl oz H 2 O

8 fl oz/acre treated per treated acre (0.25 lb AI/acre) TV = 16 oz

RAATs carbaryl 12 fl oz + 1.04 0.78 1.82 to 50% of acreage 1 2 fl oz H 2 O

12 fl oz/acre treated per treated acre (0.375 lb AI/acre) TV = 24 oz

RAATs diflubenzuron 0.75 fl oz + 0.63 Dimilin 0.78 1.57 to 50% of acreage 10 fl oz oil + 0.16 Oil

0 .75 fl oz/acre treated 20.25 fl oz H 2 O 0.79 Total (0.0117 lb AI/acre) per treated acre 5.3g/acre treated TV = 31 oz



### Mean percentage control of grasshoppers treated with RAATs treatments

Days after treatment (1)

Treatment Rate (2) 7 14 21 28

Fl oz

diflubenzuron 0.75

- 50 61.4 c 95.0 b 97.6 b 98.5 a (60.2) (94.6) (97.6) (98.6)

Carbaryl 8

- 50 84.8 b 87.9 c 89.7 c 89.5 b (85.9) (88.2) (89.8) (90.7)

(1) Corrected for natural mortality (unadjusted values in pa rentheses). A one

- way analysis of variance was performed on a rank transformation of the data. A Tukey multiple comparisontest was used to separate means. Means in the same column followed by the same letter are not significantly different (P 0.05). The untreated check population decreased an average of 0.4% per day.

(2) Fluid ounces of undiluted material applied/acre and percentage of acreage treated.

Field studies comparing carbaryl, Malithion and 

### diflubenzuron were conducted on rangeland . However, there is very little information regarding data comparisons on alfalfa. Please find the below material in the submission of the 2010 Section 18 Application.

1. Bran Bait or Liquid Insecticide Treatments for Managing Grasshoppers on Croplands Adjacent to Rangeland or Conservation Reserve Program Acreages

2. Impact of Dimilin® on Nontarget Arthropods and Its Efficacy Against Rangeland Grasshoppers

3. Field and Economic Evaluation of Operational Scale Reduced Agent and Reduced Area Treatments (RAATs) for Manage ment of Grasshoppers on South Dakota Rangeland, 1997

- 1999



### 4. Pest Management Strategic Plan for Western U.S. Alfalfa and Clover Seed Production ( Special interest a. page 96

– TABLE Insect Management in Alfalfa and Clover seed. b. page 98

– TABLE

- Biological control. c. page 99

- TABLE

– Toxicity Ratings on Pollinators and Beneficial in PNW Alfalfa and Clover Seed)