## Request for Section 18 emergency use of Sulfoxaflor (Transform® WG

Insecticide) to control tarnished plant bug ( Lygus lineolaris ) in cotton

fields in the state of Mississippi.

Type of Exemption

- Mississippi Section 18; Specific Exemption Request; March 1, 2016 This is an application for a specific exemption to authorize the use of Sulfoxaflor (Transform® WG Insecticide EPA Reg. No. 62719

- 625) to control tarnished plant bug in cotton . The following information is submitted in the format indicated in the p roposed rules for Chapter 1,
Title 40 CFR, Part 166.

SECTION 166.20(a) 1: IDENTITY OF CONTACT PERSONS

i. The following are the contact persons responsible for the administration of the emergency exemption :

John G. Campbell, Director Mississippi Department of Agriculture & Commerce Bureau of Plant Industry

P. O. Box 5207 Mississippi State, MS 39762

Tel: 662.325. 3390

Email: Johnca@mdac.ms.gov

Jasper L. Cobb , Branch Director Mississippi Department of Agriculture & Commerce Bureau of Plant Industry

P. O. Box 5207 Mississippi State, MS 39762

Tel: 662

. 325

. 3390

Email: jasper @mdac.ms.gov

ii. The following qualified experts are also available to answer questions:

University Representative Dr. Angus Catchot Mississipp i State University

Extension Professor Biochemistry, Molecular Biology, Entomology & Plant Pathology

Box 9775 Mississippi State, MS 39762

Tel: 662

. 325

. 2085

Fax: 662

. 325

. 8837 Email: acatchot@entomology.mstate.edu

### Registrant Representative

Tami Jones

- Jefferson U.S. Regulatory Leader U.S. Regulatroy & Government Affaris

– Crop Protection Dow AgroSciences

9330 Zionsville Road Indianapolis IN, 46268

Tel: 317.337.3574 Email: tjjonesjefferson@dow.com

Jamey Thomas US Regulatory Man ager Dow AgroSciences

9330 Zionsville Road Indianapolis, IN. 46268

Cooperating Agency Mississippi Cooperative Extension Service Mississippi State University Mississippi State, MS 39762

SECTION 166.20(a) 2: DESCRIPTION OF PESTICIDE REQUESTED

Common Chemical Name (Active Ingredient ): Sulfoxaflor

Brand/ Trade Name and EPA Reg. No.: Transform® WG Insecticide

, EPA Reg. No. 62719

- 625 Formulation: Active Ingredient 50%

SECTION 166.20(a) 3: DESCRIPTION OF PROPOSED USE

i. Sites to be treated:

The insecticide will be restricted to use on cotto n fields within the state of Mississippi for the purpose of controlling the tarnished plant bug, Lygus lineolaris (Palisot de
Beauvois) before, during, and after the flowering period when cotton is susceptible to pest damage

.

ii. Method of Application: Applications will be made by foliar application.

iii. Rate of Application:

1.5

– 2.25 oz/ac (0.047

– 0.071 lb ai/ac). A nnual use will not exceed 0.266 lb ai/ac.

iv. Maximum Number of Applications:

No more than four application s per season.

### v. Total Acreage to be Treated: Cotton acreage in Mississippi is projected to be ~450,000 acres in 2016. During 2016, Mississippi has the potential need to treat 75% (337,500) of its acreage with sulfoxaflor for control of tarnished plant bug

vi. Total Amount of Pesticide to be used: Tarnished plant bug, Lygus lineolaris (Palisot de Beauvois), infestations are likely to cause economic losses on all Mississippi cotton acres but emergency use will be
restricted to 337,500 acres in Mississippi dur ing 2016. Therefore, up to four

app lications of sulfoxaflor may be required on these acres to reduce the impact of thi s pest. However, no more than 4 ap plications per growing season . There will be no

more than 8.5 oz of product used per acre per season . Maximum amount of

for mulated produc t would be 179,297 lbs or 89,649 lb ai.

vii. Restrictions and Requirements: Refer to the Transform® WG container label for first aid, precautionary statements, directions for use and conditions of sale and warranty information. It is a violation of

federal law to use this product in a manner that is inconsistent with all applicable label directions, restrictions and precautions found in the container label and this supplemental label. Both the container label and this supplemental section 18 quarantine exemptio n label must be in the possession of the user at the time of application.

Applicable restrictions and requirements concerning the proposed use and the qualifications of applicators using Transform® WG are as follows:

 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 four applications per acre per season.

 Do no t apply more than a total of 8.5 oz. of Transform WG (0.266 lb AI of sulfoxaflor) per acre per year.

 Label must include a pollinator advisory statement including but not limited to the following:

o If known apiaries are within one mile of cotton fields inten ded for treatment, applications should be made within three hours of sunset during the flow ering period.

o Prior to use of Transform WG, growers and the beekeepers hosted on their farm are advised to implement cooperative standards outlined in the Mississippi Honeybee Stewardship Program.

 Before Tra nsform WG can be used tarnished plant bug densities must reach or

exceed thresholds published in MSU

- ES Insect Control Guide P2471 (equal to

or greater t han 15 per 100 Sweeps or 3 per 5 row ft on a drop cloth).

### viii. Duration of the Proposed Use:

June , 201 6

– October , 201 6

ix. Earliest Possible Harvest Date: September 15 in Mississippi, typically.

SECTION 166.20(a) 4: ALTERNATIVE METHODS OF CONTROL IN MISSISSIPPI

Insecticide Resistance: Pyrethroids

Presently, several insecticides are recommended against tarnished plant bug, but varying levels of resistance has been documented to nearly every class of these compounds among Mid

- South (Arkansas, Louisiana, Mississippi, Tennessee) populations of this insect. Populations have demonstrated resistance to pyrethroids (Snodgrass 1996, Snodgrass and Scott 2000) since the

mid

- 1990’s. Currently, none of the pyrethroids are recommended for tar nished plant bug control in Mississippi because resistance to this class has become wides pread and field experiments generally show poor control. A summary of all trials conducted at the Delta Research and Extension Center in Stoneville Mississippi from 2004 to 2010 revealed that control with the pyrethroids ranged from 0 to 47% control. In g eneral, bifenthrin (ex. Brigade) showed better activity against plant bugs than other pyrethroids, but control was still less than adequate (Figure
1).

Insecticide Resistance: Organophosphates and Carbamates

More recently, resistance has been documented to several organophosphates (Snodgrass and Gore 2007, Snodgrass et al. 2009). Acephate has been the most widely used and effective insecticide for control of plant bugs in cotton but efficacy continues to decre ase in Mississippi

and much of the mid

- South . For the purpose of measuring tarnished plant bug resistance to the

### organophosphates, acephate has been used in bioassays to represent the entire class because it is

the most utilized for field control. For th e most part, populations that show greater than 3

- fold levels of resistance to acephate also have high levels of resistance to dicrotophos (Figure 2). Figure 2 shows the resistance ratios (yellow bars) Baythroid (pyrethroid), Bidrin (OP), Orthene
(OP), an d Vydate (carbamate) for tarnished plant bugs. This particular population shows high levels of cross resistance to all classes of insecticides evaluated. The orange bars show percent mortality of tarnished plant bugs caged on cotton plants sprayed with e ach of the insecticides. In all cases except Vydate, the highest labeled rate was used. None of the insecticides provided greater than 48% mortality at field use rates. Additionally, preliminary research suggests that there are multiple mechanisms of re sistance to the OP’s. There appears to be populations with
target site insensitivity, and metabolic resistance. Most of the p lant bug populations across Mississippi express target site insensitivity, which confers cross resistance to the other organophosp hates and carbamates. Populations that only have metabolic resistance do not always exhibit cross resistance with other insecticides and the cross resistance appears to be linked to the specific enzymes involved.

In Mississippi , field efficacy with both acephate and dicrotophos has been steadily declining in recent years. Table 1 provides a summary of results from insecticide screening trials conducted Mississippi State University personnel at various locatio ns across Mississip pi from 2005 through 2010. In 2005, acephate and dicrotophos provided 84.0 and 79.3 percent control, respectively. By 2010, control declined to 45.8 and 28.2 percent control, respectively, for these insecticides. Similar results were seen for yield losse s attributed to tarnished plant bugs over that same time period (Table 1). With these levels of control, growers commonly experience field control failures with all of the organophosphates currently labeled for tarnished plant bug control in mos t

areas of Mississippi . As a result, organophosphates are no longer recommended by MSU

- ES specialists unless they are applied in a tank mix with another class of insecticide.

### Table 1. Average (Standard Error) yields for Acephate and Dicrotophos from trials

conducted in Stoneville, MS from 2005 to 2010 and percent yield reductions compared to

2005. 

### Acephate Dicrotophos

Year %

Control Yield

(Lint/A) % Yield

Reduction %

Control Yield

(Lint/A) % Yield

Reduction

2005 84.0 (5.0) 1342 (47.4)

--- 79.3 (5.8) 1374 (78.6)

--- 2006 81.7 (3.8) 1213 (131.3) 9.6 83.3 (3.5) 1149 (129.8) 16

2007 83.5 (3.7) NA NA 86.0 (2.6) NA NA

2008 71.6 (2.7) 946 (60.5) 29.5 67.0 (3.1) 936 (93.4) 31.9

2009 55.8 (5.7) 676 (92.6) 49.7 NA NA NA

2010 45.8 (2.3) 984575.9 26.6 28.2 (4.3) 970 (77.0) 29.4

P <0.01 <0.01 <0.01 <0.01

Neonicotinoids

The neonic otinoid class of insecticides are recommended for both tarnished plant bug and cotton aphid control in Mississippi. The insecticides in this class have historically only shown marginal control of tarnished plant bug in most cases. Thiamethoxam is by far the most active insecticide

in thi s clas s

. In contrast, acetamiprid is least effective in this group against tarnished plant bug. In general, the neonicotinoids provide similar control to that observed with acephate at 1 lb ai/A. In an experiment from 2008, all of the treatments reduced t arnished plant bug numbers and flower bud injury compared to the non

- treated control (except plant bug numbers for Trimax
Pro) (Table 2).

Table 2. Percent square damage 5 days after treatment 2 with neonicotinoids and neonicotinoid/pyrethroid premixes in 2008.

Treatment Rate (lb ai/A) Mean No. TPB Damage

Centric 0.0625 19b 28 b Endigo 5.5 fl oz/A 17b 11 c

Trimax Pro 0.062 29ab 37 b Leverage 5 fl oz/A 22b 21 bc

Orthene 1.0 20b 36 b Orthene + Brigade 0.5 + 0.1 19b 19 bc

Non

- treated

--- 34 a 61 a



### Although no resistance has been documented and confirmed with field control failures to this
class of insecticide, in 2015 numerous reports of field control failures with thiamethoxam were reported. C ontrol of tarnished plant bug has alw ays been highly variable with the neonicotinoids,

but monitoring data since 2006 shows elevated resistance ratios with imidacloprid every year
(Table 3).

### Table 3. Results of monitoring tarnished plant bug susceptibility to neonicotinoids in the

mid

- South. Imidacloprid Thiamethoxam

Year Mean RR Highest RR Mean RR Highest RR

2006 3.2 7.6 1.0 1.6

2007 3.0 5.0 0.8 1.6

2008 2.9 6.5 0.7 1.2

2009 3.1 5.7 0.9 1.8

2010 2.7 5.8 1.8 9.0



### Thiamethoxam has remained more susceptible, but one population in 2010 showed an elevated resistance ratio compared to a susceptible population. This may represent the initial stages of resistance development to neonicotinoids by tarnished plant bug. Based on reports of field control failures with thiamethoxam in 2015, we are planning an increased effort for monitoring

in 2016 . Small plot studies are currently limited, but our data is also indicating a decline in efficacy with thiamethoxam (Figure 3)

.

Figure 3.

Others

There are currently only two other insecticide classes labeled for tarnished plant bug control. The first is flonicamid (Carbine) a pyridine ca r boxamide. Although this insecticide does show some activity against tarnished plant bugs and provides g ood control of western tarnished plant bug
( Lygus hesperus ), results have not been promising in the mid

- South. The data below shows the results for an experiment conducted in Stoneville, MS in 2009. The data show the number of

### nymphs 5 days after the seco nd application of each insecticide in an overall control program. A

total of 7 insecticide applications were made to the entire field. Five of those applications were blanket applications applied across the entire field. Carbine did not reduce tarnished pl ant bug

densities below that observed in the non

- treated control (Table 4).

Table 4. Results from an experiment conducted in Stoneville, MS in 2009.

Treatment Rate Nymph/5 ft.

Centric 2 oz/A 12.6 B

Bidrin 8 fl oz/A 9.4 B Acephate 0.75 lb ai/A 5.9 B

Carbine 2.8 oz/A 22.1 A

Non

- treated 24.3 A



### The other insecticide is novaluron (Diamond), an insect growth regulator. Because novaluron is an insect growth regulator, it only controls the immature stages of tarnished plant bug and has no activity against adults. Field testing of this insecticide generally showed variable results in terms of tarnished plant bug control. In a trial conducte d in Sunflower county, MS in 2006, large blocks of cotton on a growers farm were treated with Bidrin at 0.5 lb ai/A, Orthene at 1.0 lb ai/A,
Orthene at 1.0 lb ai/A + Diamond at 0.04 lb ai/A, Bidrin at 0.5 lb ai/A + Diamond at 0.04 lb ai/A,

and Diamond at 0 .06 lb ai/A. Treatments were applied by ground with a high clearance sprayer and all treatments were replicated 4 times. The treatments were applied to an established population and pre

- treatment counts averaged 22.6 nymphs per 5 row ft. Two applications were made 7 days apart. Seven days after the second application, tarnished plant bug densities in all of the treatments remained well above the action threshold of 3 bugs per 5 row ft, ranging from
7.2 for Orthene (1.0 lb ai/A) + Diamond (0.04 lb ai/A) to 15.6 nymphs per 5 row ft for Diamond alone (0.06 lb ai/A). Similar results were observed in other trials and by consultants and growers for the first few years that Diamond was commercially available. Other research has shown that Diamond is not very effective on large nymphs. In an experiment conducted in Stoneville, MS in 2007, fifth instar nymphs were exposed to cotton plants treated with a range of field use rates in a spray chamber. The nymphs were allowed to feed on the treated plants until they molted into adults or died (Table 5). The percentage of nymphs that molted into the adult stage ranged from 47.8 at the highest labeled rate to 83.3 at the lowest rate tested. This combined with the rapid growth rate of tarnished plant bug makes timing of the application critical. Adverse weather conditions (rain, high wind, etc.) are common and can delay applications up to a week. In that time frame, susceptible stages of nymphs (1 st



### - 3 rd 

### Instars) have time to develop to less susceptible

stages.

Table 5. I mpact of Diamond insecticide (novaluron) on late instar tarnished plant bug nymphs in a controlled experiment in Stoneville, MS.

Treatment Rate Percent Adults

UTC

--- 96.7 A

Diamond 2 83.3 AB

Diamond 4 60.0 BC

Diamond 6 58.5 C

Diamond 9 69.7 BC

Diamond 12 47.8 C

### Over the last several years, we have discovered better ways to use Diamond in an overall TPB

management program. Research in Mississippi, Louisiana, and Arkansas has shown that early preventative applications can help reduce the impact of tarnished plant bugs in cotton. Howev er, the timing of these applications is critical and must target the eggs and early instar stages. The difficulty in using eggs as a trigger is that tarnished plant bugs insert their eggs into plant tissue

and are not visible in the field. This combined wi th the difficulty in controlling late instar nymphs a less than desirable for managing this pest.

In some areas across Mississippi and the Mid

- South region, tarnished plant bug infestations have

reached outbreak levels and become uncontrollable. In Missi ssippi 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. Miss issippi producers averaged 6.5 applications during 2007 (Williams 2008) for this pest, but some areas received 10

- 14 treatments.

Current trends with in secticide resistance without effective alternative 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 have not been available to manage this pest prior to the us e of Transform . Effective Lygus control in the absence of

Transform is a serious, unmet need for Mid

- South cotton growers and one that requires immediate and urgent action. Loss of Transform has now put Mississippi producers back into an

emerg ency situati on.

These results have shown that regardless of the registered insecticide prior to the use of

Transform for tarnished plant bug

, populat ions in these States were 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 c ontrol tarnished plant bug increased during that period . Because sulfoxaflor is a novel mode of action and chemical class, successfully control ling both insectic ide

- susceptible and

- resistant populations of tarnished plant bug , it has become a valuable part of our overall cotton IPM system. Table 6 shows a study

co nducted in Mississippi where all of the currently registered classes of insecticides were used in an overall management program. In this trial, a total of 7 applications were made. Each of the insecticides being tested was applied four times, but no more than two times in a r ow. Ratings of tarnished plant bug control were made after the underlined treatments. These data show that none of the treatment programs provided consistent control of tarnished plant bugs over the entire season. As a result, yields for all of the spra y programs were very low compared to state averages in 2010. This experiment shows that an overall tarnished plant bug program is not feasible or economical for producers with the few insecticide classes that are currently labeled in

the mid

- South.

### Table 6. Evaluation of tarnished plant bug management programs in Mississippi in 2010.

Treatment 5 DAT 1

% Control 13 DAT 1

% Control 7 DAT 2

% Control 14 DAT 2

% Control 7 DAT 3

% Control 7 DAT 4

% Control Lint

Yield

Vydate 0.33 lb fb Centric 2.5 oz fb

Orthene 0.75 lb fb

Orthene 0.75 lb fb

Diamond 6 oz fb

Orthene 0.75 lb fb

Orthene 0.75 lb 69 54 50 0 57 0 549

Vydate 0.33 lb fb Centric 2.5 oz fb

Diamond 9 oz fb

Diamond 9 oz fb

Orthene 0.75 lb fb

Diamond 9 oz fb

Diamond 9 oz 60 72 0 31 62 73 482

Vydate 0.33 lb fb Centric 2.5 oz fb

Bidrin 6 oz fb

Bidrin 6 oz fb

Diamond 6 oz fb

Bidrin 6 oz fb

Bidrin 6 oz 53 36 0 0 38 0 343

Vydate 0.33 lb fb Centric 2.5 oz fb Vydate 10 oz fb Vydate 10 oz fb

Diamond 6 oz fb Vydate 10 oz fb Vydate 10 oz 31 0 75 0 72 0 343

Vydate 0.33 lb fb Centric 2.5 oz fb

Centric 2 oz fb

Centric 2 oz fb

Diamond 6 oz fb

Centric 2 oz fb

Centric 2 oz 21 16 0 0 72 0 405

Vydate 0.33 lb fb Centric 2.5 oz fb Endigo 5 oz fb Endigo 5 oz fb

Diamond 6 oz fb Endigo 5 oz fb Endigo 5 oz 19 12 0 0 26 67 567

Vydate 0.33 lb fb Centric 2.5 oz fb

Trimax Pro 1.5 oz fb

Trimax Pro 1.5 oz fb

Diamond 6 oz fb

Trimax Pro 1.5 oz fb

Trimax Pro 1.5 oz 0 0 0 0 31 23 358

Vydate 0.33 lb fb Centric 2.5 oz fb

Carbine 2.5 oz fb

Carbine 2.5 oz fb

Diamond 6 oz fb

Carbine 2.5 oz fb

Carbine 2.5 oz 0 40 0 0 18 0 405

Vydate 0.33 lb fb Centric 2.5 oz fb Leverage 360 3.2 oz fb Leverage 360 3.2 oz fb

Diamond 6 oz fb Leverage 360 3.2 oz fb Leverage 360 3.2 oz 0 0 0 0 15 0 397

Vydate 0.33 lb fb Centric 2.5 oz fb

Intruder 1.1 oz fb

Intruder 1.1 oz fb

Diamond 6 oz fb

Intruder 1.1 oz fb

Intruder 1.1 oz 0 12 0 0 42 0 372

Vydate 0.33 lb fb Centric 2.5 oz fb Brigade 5.12 oz fb Brigade 5.12 oz fb

Diamond 6 oz fb Brigade 5.12 oz fb 0 24 0 17 38 0 312Brigade 5.12 oz

Check NA NA NA NA NA NA 225
*Ratings start after 4 th application



### It has been clearly documented in the past that excessive use of non

- selective and disruptive products for tarnished plant bug can induce additional pest p roblems (spider mites and cotton aphids) in some areas. In Mississippi there is a strong correlation between the numbers of applications targeting tarnished plant bugs and other pests such as cotton aphids and spider mites
(Fi gure 4 ). 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 secondary insects. Acephate is commonly used for Ly gus control and can flare aphids and mites. Pyrethroid insecticides may flare aphids and mit es, as well. Sulfoxaflor

use will reduce the frequency of selected insecticides used, especially acephate, dicrotophos, and oxamyl. The ecological and toxicologic al profile of sulfoxaflor is considered to be more favorable than the ecological and toxicological profiles o f these insecticides. D ata curren tly suggest that sulfoxaflor will not flare aphids and mites and will be safer to pollinators than

alternatives.

Figure 4.



### 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 area

- wide control of non

- crop alternate hosts and selected host plant resistance traits. Proper selection of varieties an d managing the optimum planting period are being used to produce a rapid fruiting and early maturing crop; thereby reducing the time the crop is susceptible to this pest. Careful insecticide application timing based upon revised spray action thresholds ar e 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

- a lone practices. Effective chemical control practices are still necessary to provide tarnished

### plant bug management in cotton. As highlighted above the current situation in Mississippi has

produced severe economic burdens on cott on producers . Mississippi and other mid

- South states have experienced greater reductions in cotton acres compared to other cotton producing regions of the country. The recent increase in cost of tarnished plant bug control is an important reason

for the decrease in cotton acres in the mid

- South. Currently, tarnished plant bugs have widespread resistance to the pyrethroids, organophosphates, and carbamates. In the case of the organophosphates, resistance is partially dominant. A recent study by Snodgrass and Gore

showed that beca use the trait is not recessive, resistance levels do not decline during the winter. Also, relevant genetics data suggests that gene flow can occur between populations that are up to approximately 10 miles apart. These factors have contributed to the rapid spread of resistance in the Mississippi, Arkansas, and Louisiana . Also, this makes predicting where the resistance levels will be highest from year to year extremely difficult. The widespread resistance to pyrethroids, organophosphates, and carbamates re nders these insecticides nearly useless for economical cotton production without effective alternatives

. In years prior to Transform use,

field use rates have more than d oubled and control continued to decline wi th available products

. This put a tremendous pressure on the neonicotinoid class. Of that class, thiamethoxam had by

far been the most effective in the class for tarnished plant bug control , however there is now elevated concern due to widespread reports of field failures in 2015 . Consequently, two to four

pre

- flower applications in cotton target both tarnished plant bugs and cotton aphids. Centric
(thiamethoxam) has been the insecticide of choice in th is situation because it provided better control of the whole pest complex than other neonicotin oids at that time of the year. The most common rate used at that time of year is 2 oz formulated product per acre (0.05 lbs ai/A). The
maximum seasonal use rate for Centric is 5.0 oz (0.125 lb ai thiamethoxam). Therefore, two applications of Centric at 2 oz/A (0.05 lbs ai per acre per application) during the pre

- flowering period does not leave enough active ingredient for later applications of either Centric or Endigo
(thiamethoxam + lambda

- cyhalothrin). The only other labeled insecticides available are Carbine (flonicamid) and Diamond (novaluron). Table 4 above shows typical results observed with Carbine in Mississippi and other mid

- South states for tarnished plant bug. Diamond is the only other insecticide available for late season tarnished plant bu g control. As mentioned previously, Diamond is an insect growth regulator that only controls the immature stages. Therefore, Diamond applications are exclusively used with another class of chemistry to control adults. Also, application timing is critical w ith this insecticide and applications are often sprayed too late to provide the most effective levels of control. Therefore, the use of Transform will and has provide d significant economic benefits fo r cotton growers in Mississippi and are demonstrated in the tier 1 and tier 2 analysis provided. Furthermore, the use of Transform since 2012 has replaced products that are well known to be more toxic to honeybees therefore increasing the overall

safe ty to bees in Mississippi (Zhu et al.)

SECTION 166.20(a) 5: EFFECTIVENESS OF PROPOSED USE

Value of Transform in an Overall IPM Approach for Tarnished Plant Bug in Cotton

Multiple experiments have been conducted throughout Mississippi to evaluate an overall integrated pest management approach for tarnished plant bug in cotton and the importance of various insecticides in that approach. Inconsistent control with most of the currently labeled insecticides due to documented resistance highlighted above has forced growers to adopt multiple best management practices to economically manage tarnished plant bug. Although these

### best management practices have improved tarnished plant bug management, insecticides remain

an important component. In particular, the registration of sulfoxaflor in 2012 (Section 18 in 2012

and Section 3 in 2013

- 15) increased the adoption of the overall IPM approach.

Sulfoxaflor rapidly became the foundation for the IPM approach because of its high level of efficacy against tarnished plant bug and the relative safety for beneficial insects ( Fig. 5 ). Even at very high use rates (100 g ai/ha=3.0 oz/A), significantly more beneficia l arthropods were conserved compared to the pyrethroid (Warrior) and the organophosphate (Orthene). Similar results were observed by Kerns et al. (2011) where densities of convergent lady beetles for sulfoxaflor were not significantly different than Carbin e. Both the Carbine and sulfoxaflor had significantly lower densities than the untreated control which was most likely due to the reduction in prey (cotton aphid) in the treated plots.

Figure 5

. Impact of various rates of sulfoxaflor and other insecti cides on natural enemy

populations in cotton in California.

Although natural enemy populations provide little benefit for tarnished plant bug management,

sprays with high rates of organophosphates and pyrethroids (usually applied as a tank mix)

targeting tarnished plant bug reduce natural enemy populations and “flare” other pests such as

twospotted spider mite or cotton aphid. A study conducted in Stoneville, MS in 2013 compared

### overall management programs. The treatments included cotton grown with all c lasses except

neonicotinoids or sulfoxaflor, all classes except sulfoxaflor, and all available classes. Overall,

one to two applications were needed for twospotted spider mite in the treatments where

sulfoxaflor was not used (Figure 6 ). Additionally, the t reatments that did not include sulfoxaflor

each needed to be sprayed separately for cotton aphid (Figure 6 ). A portion of this is due to

sulfoxaflor ’s ability to control cotton aphids, but preservation of beneficial insects also

contributed. In summary, th e use of sulfoxaflor for tarnished plant bug management can reduce

the number of insecticide applications targeting other pests because of the lower toxicity to

beneficial arthropods. Overall, yields and economic returns were greater where all classes of

i nsecticides were included.

Figure 6 . Impact of insecticide use programs for tarnished plant bug management on the number

of insecticide sprays for twospotted spider mite and cotton aphid.

The tarnished plant bug IPM program has been important for inc reasing the profitability of

cotton programs in Mid

- South cotton. However, diversity in the available classes of insecticides

available to manage tarnished plant bug is critical to make the overall IPM approach successful.

In particular, insecticides that provide high levels of efficacy against tarnished plant bug that do

not flare other pests provide the foundation for the overall cotton IPM program. Two insecticides

have proven to be very important in this respect. Research throughout the Mid

- South has sh own that a single application of the insect growth regulator, novaluron, can provide long term benefits

for tarnished plant bug management. However, novaluron does not control adult plant bugs and it

consistently flares cotton aphids. As a result, sulfoxaf lor is the ideal insecticide to use as one to

two applications immediately following the novaluron application. Additionally, the registration

of sulfoxaflor provided growers with a legitimate insecticide rotation strategy to make the

tarnished plant bug I PM program successful.

### The figures below (Figure 7 ) show insecticide rotation strategies recommended by the

Mississippi State University Extension Service for managing tarnished plant bug in cotton. The

graph on the left shows the rotation strategy with sulfoxaflor available to producers and the

graph on the right is without sulfoxaflor. It is plain to see from these graphs, that when

sulfoxaflor is not available, growers do not have enough insecticides available to provide a

legitimate rotation strategy to effectively implement a realistic IPM program. Since its

registration in 2013, sulfoxaflor has become the most important insecticide providing a

foundation for the overall IPM program for tarnished plant bug and the loss of this insecticide

will severel y limit the success of integrated pest management for all arthropod pests of cotton in

the Mid

- South because it will result in increased use of broad spectrum insecticides.

Figure 7 . Insecticide rotation strategies to manage tarnished plant bug when sul foxaflor is

available (left) and when it is not available (right).

From 2014 to 2015 a graduate student at Mississippi State University conducted a study

comparing the tarnished plant bug IPM program to a standard approach at multiple planting dates

Hills and Delta regions of Mississippi. In the IPM approach, sulfoxaflor was a standard

component of the insecticide use strategy. It was also occasionally used in the standard approach

when aphids were also present. Overall, the IPM program resulted in greater yields, fewer

insecticide applications, and greater economic returns compared to the standard approach (Fig.

8 ).

### Figure 8

. Economic returns for a tarnished plant bug IPM program compared to a Standard

approach in the Delta and Hills regions of Mississippi averaged across 2014 and 2015. The BMP

treatments included sulfoxaflor as a foundation of the overall IPM program. It was occasionally

used in the standard approach mainly to manage cotton aphid.

In general, tarnished plant bug management relies on an overall integrated pest management

approach in the Mid

- South to maintain economically sustainable cotton production. Insectic ides

remain the most important component of this IPM approach and sulfoxaflor rapidly became the

most important insecticide because of its high level of efficacy against tarnished plant bug and its

low likelihood of flaring other pests such as twospotted s pider mite and cotton aphid. These

characteristics have resulted in sulfoxaflor providing significant economic benefits in terms of

improved yield protection and decreased number of insecticide applications ( reported later in

the document ).

Additional Use and Efficacy Data

Sulfoxaflor (DAS test code GF

- 2372, proposed trade name Transform TM 

### ) has been evaluated in laboratory and field trials for the past several years. Recent publications by Babcock et al.
(2010 , See Appendix B ) and Zhu et al. (2010, See Appendix C ) clearly define the biology and biochemistry of sulfoxaflor and demonstrate a novel mode of action against sap feeding insects including those in the order Heteroptera. Insects in the genus Lygus are included in this order.

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 action. These research p rojects support a novel mode of action for sulfoxaflor including those insecticides with similar chemical
structures (neonicotinoids).

### Numerous field trials are highlighted below showing the impact of sulfoxaflor use in areas where

high levels of resistance to pyrethroids and organophosphates are common. In the first example, Transform was used at two rates in a program approach and rota ted with Orthene. These two treatments were compared to a standard insecticide rotation strategy that did not include

Transform. The two treatments that included Transform at either 0.045 or 0.067 lbs ai/A provided significantly better control of tarnish ed plant bugs (Table 7). Additionally, yields were significantly higher for the Transform treatments compared to the standard program.

Table 7. Percent control and yields from a tarnished plant bug program trial conducted in Wayside, MS in 2010.

Treatme nt Seasonal Mean

TPB Seasonal Mean

TPB % Control Lint Yield

Transform 0.045 lb fb

Transform 0.045 lb fb

Orthene 1 lb fb

Transform 0.045fb

Transform 0.045 46.8 c 84 a 1266 a

Transform 0.067 lb fb

Transform 0.067 lb fb

Orthene 1 lb fb

Transform 0.067 lb fb

Transform 0.067 42.1 c 85 a 1267 a

Orthene 0.5 lb +

Diamond 9 oz fb

Bidrin 0.5 lb fb Endigo 0.08 lb fb

Orthene 0.75 lb +

Karate 0.04 lb fb

Orthene 1.0 lb 128.3 b 56 b 1019 b

Untreated Check 292.3 a NA 664 c

1 Means followed by the same letter are not significantly different (P<0.05).



### In the second example, a single application of Transform was made and compared to Endigo,
Orthene, and Bidrin (Table 8). Both rates of Transform provided significantly better control of tarnished plant bugs than the other treatments. Also, yields were significantly higher where a single application of Transform was used in an overall management program (Table 9 )

.

Table 8. Percent control and yields from a tarnished plant bug trial following a single application in Wayside, MS in 2010.

Treatment Seasonal Mean

TPB Seasonal Mean

TPB % Control Lint Yield

Transform 0.045 lb 57.5 b 60 a 1158.4 a

Transform 0.067 lb 62.3 b 57 a 1065.4 a

Orthene 1 lb 104 37 b 895.6 bc
Endigo 0.08 102.6 38 b 849.3 bc

Bidrin 0.05 lb 142.9 0 b 787.5 c

Untreated 143 NA 772.1 c

### Table 9. Impact of tarnished plant bug management in cotton with different classes of

insecticides on cotton yields in 2009. These data show yields from an experiment in Stoneville, MS where two applications of the treatments were made in an overall tarn ished
plant bug management program.

Treatment Rate

(lb
ai/A) Nymphs

(Total
No.) 1 

### Nymphs

(Season
Mean) 1 

### Yield

(lbs
lint/A) 1 

### Percent

Yield 2



### Sulfoxaflor 0.045 27.3 c 5.45 c 872.7 a 100%
Acephate 1.0 49.5 b 9.90 b 675.6 b 77%

Centric 0.047 50.0 b 10.0 b 688.8 b 79%

Non

treated --- 116.3 a 23.25 a 517.4 c 59%

1 

### Means followed by the same letter are not significantly different (P<0.05).

2 

### The percent yield is calculated based on the highest yielding treatment (e.g. Acephate yielded
23% lower than Sulfoxaflor).

Tables 10 and 11 show Transform compared to other registered products used for tarnished plant bug control. These trials were conducted in producer fields prior to any organophosphate applications and were crop destructed following treatment. Transform w hether applied alone or mixed with a pyrethroid provided significantly better control than the alternatives in both years except for acephate in 2010.

Table 10. Standard efficacy test comparing Transform to standard insecticides in the Mississippi Delta in 2010.

Treatment Seasonal Mean

TPB Adults and
Nymphs

Transform 0.045 lb

+ Bifenthrin 4.27

oz 13.3 e

Transform 0.067 lb 14.0 de

Transform 0.067 lb

+ Bifenthrin 4.27

oz 16.8 de

Endigo 0.08 27.5 bc

Bidrin 0.05 lb 35.0 b

Orthene 1 lb 23.0 cd

Untreated 135.8 a

P = 0.0001

### Table 11. Standard efficacy test comparing Transform to standard insecticides in the

Mississippi Delta in 2009.

2009 Transform Efficacy Test Compared to Common Standards for Tarnished Plant Bug

Product Seasonal Mean

TPB Adults and
Nymphs

Transform 0.067 lb 8.5 d

Orthene 1 lb 16.3 c

Bifenthrin 6.4 oz 20.3 c

Centric 2.5 oz 33.5 c

Bidrin 0.05 lb 35.0 b

Transform 0.067 lb

+ Bifenthrin 6.4 oz 8.0 d

Untreated 82.0 a

P = 0.0001



### All available data indicates that sulfoxaflor is an alternative product to the insecticides currently used to manage tarnish ed plant bug on cotton. It has proven to be an excellent tool for Mississippi and Mid

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

- resistant p opulations. Sulfoxaflor has become the backbone of chemica l control strategies for tarnished plant bug and is desperately needed in this emergency situation. Even in regions where resistance levels are not as high as the Mississippi Delta, sulfoxaflor has been widely adopted by producers because of safety to pol linators and other beneficial insects. This product has allowed growers to further implement IPM programs due to the safety profile. Additionally, since its use in 2012 in cotton there has not been a single incident reported with managed bees.

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

Acute Assessment Food consumption information from the USDA 1994

- 1996 and 1998 Nationwide Continuing Surveys of Food Intake by Individuals (CSFII) and maximum residues from field trials rather

than tolerance

- l evel residue estimates were used. It was assumed that 100% of crops covered by the registration request are treated and maximum residue levels from field trials were used.

Drinking water. Two scenarios were modeled, use of sulfoxaflor on non

- aquatic row a nd orchard crops and use of sulfoxaflor on watercress. For the non

- aquatic crop scenario, based on the Pesticide Root Zone Model/Exposure Analysis Modeling System (PRZM/EXAMS) and Screening Concentration in Ground Water (SCI

- GROW) models, the estimated dri nking water concentrations (EDWCs) of sulfoxaflor for acute exposures are 26.4 ppb for surface water and 69.2 ppb for ground water. For chronic exposures, EDWCs are 13.5 ppb for surface water and 69.2 ppb for ground water. For chronic exposures for cancer assessments, EDWCs are 9.3 ppb for surface water and 69.2 ppb for ground water. For the watercress scenario, the EDWCs for

### surface water are 91.3 ppb after one application, 182.5 ppb after two applications and 273.8 ppb

after three applications.

Dietary risk estimates using both sets of EDWCs are below levels of concern. The non

- aquatic

crop EDWCs are more representative of the expected exposure profile for the majority of the population. Also, water concentration values are adjusted to take into account the source of the water; the relative amounts of parent sulfoxaflor, X11719474, and X11519540; and the relative liver toxicity of the metabolites as compared to the parent compound. For acute dietary risk assessment of the general population, the groundwa ter EDWC is greater than the surface water EDWC and was used in the assessment. The residue profile in groundwater is 60.9 ppb X11719474 and 8.3 ppb X11519540 (totaling 69.2 ppb). Parent sulfoxaflor does not occur in groundwater. The regulatory toxicologic al endpoint is based on neurotoxicity.

For acute dietary risk assessment of females 13

- 49, the regulatory endpoint is attributable only to the parent compound; therefore, the surface water EDWC of 9.4 ppb was used for this

assessment.

A tolerance of 0. 3 ppm for sulfoxaflor on grain sorghum has been established. There is no expectation of residues of sulfoxaflor and its metabolites in animal commodities as a result of the proposed use on sorghum. Thus, animal feeding studies are not needed, and toleranc es need not be established for meat, milk, poultry, and eggs.

Drinking water exposures are the driver in the dietary assessment accounting for 100% of the exposures. Exposures through food (sorghum grain and syrup) are zero.

The acute dietary exposure f rom food and water to sulfoxaflor is 16% of the aPAD for children

1

- 2 years old and females 13

- 49 years old, the population groups receiving the greatest exposure.

Chronic Assessment The same refinements as those used for the acute exposure assessment were used, with two exceptions: (1) average residue levels from crop field trials were used rather than maximum values and (2) average residues from feeding studies, rather than maximum values, were used to

derive residue estimates for livestock commoditie s. It was assumed that 100% of crops are treated and average residue levels from field trials were used.

For chronic dietary risk assessment, the toxicological endpoint is liver effects, for which it is possible to account for the relative toxicities of X 11719474 and X11519540 as compared to sulfoxaflor. The groundwater EDWC is greater than the surface water EDWC. The residue profile in groundwater is 60.9 ppb X11719474 and 8.3 ppb X11519540. Adjusting for the relative toxicity results in 18.3 ppb equivale nts of X11719474 and 83 ppb X11519540 (totaling 101.3 ppb). The adjusted groundwater EDWC is greater than the surface water EDWC (9.3 ppb) and was used to assess the chronic dietary exposure scenario.

The maximum dietary residue intake via consumption of sorghum commodities would be only a small portion of the RfD (<0.001%) and therefore, should not cause any additional risk to

### humans via chronic dietary exposure. Consumption of sorghum by sensitive sub

- populations

such as children and non

- nursing infants is essentially zero. Thus, the risk of these subpopulations to chronic dietary exposure to sulfoxaflor used on grain sorghum would be insignificant.

The major contributor to the risk was water (100%). There was no contribution from grain sorghum to the dietary exposure. All other populations under the chronic assessment show risk

estimates that are below levels of concern. Chronic exposure to sulfoxaflor from food and water is 18% of the cPAD for infants, the population group receiving the greatest expo sure. There are no residential uses for sulfoxaflor.

Short

- term risk. Because there is no short

- term residential exposure and chronic dietary exposure has already been assessed, no further assessment of short

- term risk is necessary, the chronic dietary risk assessment for evaluating short

- term ris k for sulfoxaflor is sufficient.

Intermediate

- term risk. Intermediate

- term risk is assessed based on intermediate

- term residential exposure plus chronic dietary exposure. Because there is no residential exposure and chronic dietary exposure has already been assessed, no further assessment of intermediate

- term risk is

necessary.

Cumulative effects. Sulfoxaflor does not share a common mechanism of toxicity with any other substances, and does not produce a toxic me tabolite produced by other substances. Thus, sulfoxaflor does not have a common mechanism of toxicity with other substances.

Cancer. A nonlinear RfD approach is appropriate for assessing cancer risk to sulfoxaflor. This approach will account for all chro nic toxicity, including carcinogenicity that could result from exposure to sulfoxaflor. Chronic dietary risk estimates are below levels of concern; therefore,

cancer risk is also below levels of concern.

There is a reasonable certainty that no harm will r esult to the general population, or to infants and children from aggregate exposure to sulfoxaflor as used in this emergency exemption

request.

The content in the above Section 166.20(a)(6): “Expected Residues For Food Uses” was
prepared by Michael Hare, Ph.D., Texas Department of Agriculture.

SECTION 166.20(a) 7 : DISCUSSION OF RISK INFORMATION

Human Health Effects

– Michael Hare, Ph.D. Ecological Effects

– David Villarreal, Ph.D.

Environmental Fate

– David Villarreal, Ph.D.

Human Health

Toxicological Profile
Sulfoxaflor is a member of a new class of insecticides, the sulfoximines. It is an activator of the nicotinic acetylcholine receptor (nAChR) in insects and, to a lesser degree, mammals. The

### nervous system and liver are the target orga ns, resulting in developmental toxicity and

hepatotoxicity.

Developmental toxicity was observed in rats only. Sulfoxaflor produced skeletal abnormalities likely resulting from skeletal muscle contraction due to activation of the skeletal muscle nAChR in utero. Contraction of the diaphragm, also related to skeletal muscle nAChR activation, prevented normal breathing in neonates and increased mortality. The skeletal abnormalities occurred at high doses while decreased neonatal survival occurred at sligh tly lower levels.

Sulfoxaflor and its major metabolites produced liver weight and enzyme changes, and tumors in
subchronic, chronic and short

- term studies. Hepatotoxicity occurred at lower doses in long

- term studies compared to short

- term studies.

Reprod uctive effects included an increase in Leydig cell tumors which were not treatment related due to the lack of dose response, the lack of statistical significance for the combined tumors, and the high background rates for this tumor type in F344 rats. The p rimary effects on male reproductive organs are secondary to the loss of normal testicular function due to the size of the Leydig Cell adenomas. The secondary effects to the male reproductive organs are also not treatment related. It appears that rats are u niquely sensitive to these developmental effects and are unlikely to be relevant to humans.

Clinical indications of neurotoxicity were observed at the highest dose tested in the acute neurotoxicity study in rats. Decreased motor activity was also observed in the mid

- and high

dose groups. Since the neurotoxicity was observed only at a very high dose and many of the effects are not consistent with the perturbation of the nicotinic receptor system, it is unlikely that

these effects are due to activation of t he nAChR.

Tumors have been observed in rat and mouse studies. In rats, there were significant increases in hepatocellular adenomas in the high

- dose males. In mice, there were significant increases in hepatocellular adenomas and carcinomas in high dose mal es. In female mice, there was an increase in carcinomas at the high dose. Liver tumors in mice were treatment

- related. Leydig cell tumors were also observed in the high

- dose group of male rats, but were not related to treatment. There was also a significan t increase in preputial gland tumors in male rats in the high

- dose group. Given that the liver tumors are produced by a non

- linear mechanism, the Leydig cell

tumors were not treatment

- related, and the preputial gland tumors only occurred at the high dose

i n one sex of one species, the evidence of carcinogenicity was weak.

Ecological Toxicity
Sulfoxaflor (N

- [methyloxido[1

- [6

- (trifluoromethyl)

- 3

- pyridinyl]ethyl]

- lambda 4

- sulfanylidene]) is a new variety of insecticide as a member of the sulfoxamine subclass of neonicotinoid insecticides. It is considered an agonist of the nicotinic acetylcholine receptor and exhibits excitatory responses including tremors, followed by paralysis and mortality in target insects.

Sulfoxaflor consists of two diastereomers in a r atio of approximately 50:50 with each diastereomer consisting of two enantiomers. Sulfoxaflor is systemically distributed in plants when applied. The chemical acts through both contact action and ingestion and provides both rapid knockdown (symptoms are t ypically observed within 1

- 2 hours of application) and residual

### control (generally provides from 7 to 21 days of residual control). Incident reports submitted to

EPA since approximately 1994 have been tracked via the Incident Data System. Over the 2012

gro wing season, a Section 18 emergency use was granted for application of sulfoxaflor to cotton in four states (MS, LA, AR, TN). No incident reports have been received in association with the

use of sulfoxaflor in this situation.

Sulfoxaflor is classified a s practically non

- toxic on an acute exposure basis, with 96

- h LC 50 

### values of >400 mg a.i./L for all three freshwater fish species tested (bluegill, rainbow trout, and common carp). Mortality was 5% or less at the highest test treatments in each of these st udies.

Treatment

- related sublethal effects included discoloration at the highest treatment concentration (100% of fish at 400 mg a.i./L for bluegill) and fish swimming on the bottom (1 fish at 400 mg
a.i./L for rainbow trout). No other treatment

- related su blethal effects were reported. For an estuarine/marine sheepshead minnow, sulfoxaflor was also practically non

- toxic with an LC 50 

### of 288 mg a.i./L. Sublethal effects included loss of equilibrium or lying on the bottom of aquaria at 200 and 400 mg a.i./L. T he primary degradate of sulfoxaflor is also classified as practically non

toxic to rainbow trout on an acute exposure basis (96

- h LC 50 

### >500 mg a.i./L).

Adverse effects from chronic exposure to sulfoxaflor were examined with two fish species
(fathead minno w and sheepshead minnow) during early life stage toxicity tests. For fathead
minnow, the 30

- d NOAEC is 5 mg a.i./L based on a 30% reduction in mean fish weight relative to controls at the next highest concentration (LOAEC=10 mg a.i./L). No statistically si gnificant

and/or treatment

- related effects were reported for hatching success, fry survival and length. For sheepshead minnow, the 30

- d NOAEC is 1.3 mg a.i./L based on a statistically significant reduction in mean length (3% relative to controls) at 2.5 mg a.i./L. No statistically significant

and/or treatment

- related effects were reported for hatching success, fry survival and mean weight.

The acute toxicity of sulfoxaflor was evaluated for one freshwater invertebrate species, the water

flea and two saltwa ter species (mysid shrimp and Eastern oyster). For the water flea, the 48

- h

EC 50 

### is >400 mg a.i./L, the highest concentration tested. For Eastern oyster, new shell growth was significantly reduced at 120 mg a.i./L (75% reduction relative to control). The 9 6

- h EC 50 

### for shell growth is 93 mg a.i./L. No mortality occurred at any test concentration. Mysid shrimp are the most acutely sensitive invertebrate species tested with sulfoxaflor based on water column only exposures, with a 96

- h LC 50 

### of 0.67 mg a.i./L. T he primary degradate of sulfoxaflor is also classified as practically non

- toxic to the water flea (EC 50 

### >240 mg a.i./L).

The chronic effects of sulfoxaflor to the water flea were determined in a semi

- static system over a period of 21 days to nominal conce ntrations of 6.25, 12.5, 25, 50 and 100 mg a.i./L. Adult mortality, reproduction rate (number of young), length of the surviving adults, and days to first brood were used to determine the toxicity endpoints. No treatment

- related effects on adult mortality or adult length were observed. The reproduction rate and days to first brood were significantly (p<0.05) different in the 100 mg a.i./L test group (40% reduction in mean number of offspring; 35% increase in time to first brood). No significant effects were observed on survival, growth or reproduction at the lower test concentrations. The 21

- day NOAEC and LOAEC were determined to be 50 and 100 mg a.i./L, respectively.

### The chronic effects of sulfoxaflor to mysid shrimp were determined in a flow

- through syste m

over a period of 28 days to nominal concentrations of 0.063, 0.13, 0.25, 0.50 and 1.0 mg a.i./L. Mortality of parent (F 0 

### ) and first generation (F 1 

### ), reproduction rate of F 0 

### (number of young), length of the surviving F 0 

### and F 1 

### , and days to first brood by F 0 

### were used to determine the toxicity endpoints. Complete F 0 

### mortality (100%) was observed at the highest test concentration of 1.0 mg a.i./L within 7 days; no treatment

- related effects on F 0 

### /F 1 

### mortality, F 0 

### reproduction

rate, or F 0 

### /F 1 

### length were observ ed at the lower test concentrations. The 28

- day NOAEC and LOAEC were determined to be 0.11 mg and 0.25 mg a.i./L, respectively.

Sulfoxaflor exhibited relatively low toxicity to aquatic non

- vascular plants. The most sensitive aquatic nonvascular plant is t he freshwater diatom with a 96

- h EC 50 

### of 81.2 mg a.i./L. Similarly, sulfoxaflor was not toxic to the freshwater vascular aquatic plant, Lemna gibba , up to the limit amount, as indicated by a 7

- d EC 50 

### for frond count, dry weight and growth rate of >100 mg a.i./L with no significant adverse effects on these endpoints observed at any treatment concentration.

Based on an acute oral LD 50 

### of 676 mg a.i./kg bw for bobwhite quail, sulfoxaflor is considered slightly toxic to birds on an acute oral exposure basis. On a subacute, dietary exposure basis, sulfoxaflor is classified as practically nontoxic to birds, with 5

- d LC 50 

### values of >5620 mg/kg

diet for mallard ducks and bobwhite quail. The NOAEL from these studies is 5620 mg/kg

- diet as no treatment related mortality of sublethal effects were observed at any treatment. Similarly, the primary degradate is classified as practically nontoxic to birds on an acute ora l exposure basis

with a LD 50 

### of >2250 mg a.i./kg bw. In two chronic, avian reproductive toxicity studies, the 20

- week NOAELs ranged from 200 mg/kg

- diet (mallard, highest concentration tested) to 1000 mg/kg

- diet (bobwhite quail, highest concentration teste d). No treatment

- related adverse effects were observed at any test treatment in these studies.

For bees, sulfoxaflor is classified as very highly toxic with acute oral and contact LD 50 

### values of 0.05 and 0.13 μg a.i./bee, respectively, for adult honey bee s. For larvae, a 7

- d oral LD 50 

### of >0.2 μg a.i./bee was determined (45% mortality occurred at the highest treatment of 0.2 μg a.i./bee).
The primary metabolite of sulfoxaflor is practically non

- toxic to the honey bee. This lack of toxicity is consistent wit h the cyano

- substituted neonicotinoids where similar cleavage of the cyanide group appears to eliminate their insecticidal activity. The acute oral toxicity of
sulfoxaflor to adult bumble bees ( Bombus terrestris ) is similar to the honey bee; whereas its

ac ute contact toxicity is about 20X less toxic for the bumble bee. Sulfoxaflor did not demonstrate substantial residual toxicity to honey bees exposed via treated and aged alfalfa (i.e., mortality was <15% at maximum application rates).

At the application rates used (3

- 67% of US maximum), the direct effects of sulfoxaflor on adult forager bee mortality, flight activity and the occurrence of behavioral abnormalities is relatively

short

- lived, lasting 3 days or less. Direct effects are considered those that r esult directly from interception of spray droplets or dermal contact with foliar residues. The direct effect of sulfoxaflor on these measures at the maximum application rate in the US is presently not known. When compared to control hives, the effect of su lfoxaflor on honey bee colony strength when applied at 3

- 32% of the US maximum proposed rate was not apparent in most cases. When compared to hives prior to pesticide application, sulfoxaflor applied to cotton foliage up to the maximum rate proposed in the US resulted in no discernible decline in mean colony strength by

### 17 days after the first application. Longer

- term results were not available from this study nor

were concurrent controls included. For managed bees, the primary exposure routes of concern

i nclude direct contact with spray droplets, dermal contact with foliar residues, and ingestion through consumption of contaminated pollen, nectar and associated processed food provisions. Exposure of hive bees via contaminated wax is also possible. Exposure of bees through contaminated drinking water is not expected to be nearly as important as exposure through direct contact or pollen and nectar.

In summary, sulfoxaflor is slightly toxic to practically non

- toxic to fish and freshwater water aquatic inverte brates on an acute exposure basis. It is also practically non

- toxic to aquatic plants
(vascular and non

- vascular). Sulfoxaflor is highly toxic to saltwater invertebrates on an acute exposure basis. The high toxicity of sulfoxaflor to mysid shrimp and benth ic aquatic insects relative to the water flea is consistent with the toxicity profile of other insecticides with similar MOAs. For birds and mammals, sulfoxaflor is classified as moderately toxic to practically non

toxic on an acute exposure basis. The th reshold for chronic toxicity (NOAEL) to birds is 200 ppm and that for mammals is 100 ppm in the diet. Sulfoxaflor did not exhibit deleterious effects to terrestrial plants at or above its proposed maximum application rates.

For bees, sulfoxaflor is clas sified as very highly toxic. However, if this insecticide is strictly used as directed on the Section 18 supplemental label, no significant adverse effects are expected

to Louisiana wildlife. Of course, standard precautions to avoid drift and runoff to w aterways of the state are warranted. As stated on the Section 3 label, risk to managed bees and native pollinators from contact with pesticide spray or residues can be minimized when applications are made before 7 am or after 7 pm or when the temperature is below 55 ◦ 

### F at the site of application.

Environmental Fate Sulfoxaflor is a systemic insecticide which displays translaminar movement when applied to foliage. Movement of sulfoxaflor within the plant follows the direction of water transport within the pl ant (i.e., xylem mobile) as indicated by phosphor translocation studies in several plants. Sulfoxaflor is characterized by a water solubility ranging from 550 to 1,380 ppm. Sulfoxaflor has a low potential for volatilization from dry and wet surfaces (vapo r pressure= 1.9 x 10 - 8 

### torr and Henry’s Law constant= 1.2 x 10 - 11 

### atm m 3 

### mole - 1 

### , respectively at 25 °C). Partitioning coefficient
of sulfoxaflor from octanol to water (K

ow 

### @ 20 C & pH 7= 6; Log K

ow 

### = 0.802) suggests low potential for bioaccumulation. No fi sh bioconcentration study was provided due to the low K

ow 

### , but sulfoxaflor is not expected to bioaccumulate in aquatic systems. Furthermore, sulfoxaflor is not expected to partition into the sediment due to low K

oc 

### (7

- 74 mL/g).

Registrants tests indicate that hydrolysis, and both aqueous and soil photolysis are not expected to be important in sulfoxaflor dissipation in the natural environment. In a hydrolysis study, the parent was shown to be stable in acidic/neutral/alkaline sterilized aqueous buffered so lutions (pH values of 5, 7 and 9). In addition, parent chemical as well as its major degradate, were shown to degrade relatively slowly by aqueous photolysis in sterile and natural pond water (t 1⁄2 

### = 261 to

> 1,000 days). Furthermore, sulfoxaflor was stable to photolysis on soil surfaces. Sulfoxaflor is expected to biodegrade rapidly in aerobic soil (half

- lives <1 day). Under aerobic aquatic conditions, biodegradation proceeded at a more moderate rate with hal f

- lives ranging from 37 to 88 days. Under anaerobic soil conditions, the parent compound was metabolized with half

- lives

### of 113 to 120 days while under anaerobic aquatic conditions the chemical was more persistent

with half

- lives of 103 to 382 days. In c ontrast to its short

- lived parent, the major degradate is expected to be more persistent than its parent in aerobic/anaerobic aquatic systems and some aerobic soils. In other soils, less persistence is expected due to mineralization to CO 2 

### or the

formation of other minor degradates.

In field studies, sulfoxaflor has shown similar vulnerability to aerobic bio

- degradation in nine out of ten terrestrial field dissipation studies on bare

- ground/cropped plots (half

- lives were <2 days in nine cropped/bare soils in CA, FL, ND, ON and TX and was 8 days in one bare ground soil in TX). The chemical can be characterized by very high to high mobility (Kf

oc 

### ranged from 11

- 72
mL g - 1 

### ). Rapid soil degradation is expected to limit chemical amounts that may potentially leac h and contaminate ground water. Contamination of groundwater by sulfoxaflor will only be expected when excessive rain occurs within a short period (few days) of multiple applications in vulnerable sandy soils. Contamination of surface water by sulfoxaflor is expected to be mainly related to drift and very little due to run

- off. This is because drifted sulfoxaflor that reaches aquatic systems is expected to persist while that reaching the soil system is expected to degrade quickly with slight chance for it t o run

- off.

When sulfoxaflor is applied foliar on growing crops it is intercepted by the crop canopy. Data presented above appear to indicate that sulfoxaflor enters the plant and is incorporated in the plant foliage with only limited degradation. It appea rs that this is the main source of the insecticide sulfoxaflor that would kill sap sucking insects. This is because washed

- off sulfoxaflor, that reaches the soil system, is expected to degrade.

In summary, sulfoxaflor has a low potential for volatilizatio n from dry and wet surfaces. This chemical is characterized by a relatively higher water solubility. Partitioning coefficient of sulfoxaflor from octanol to water suggests low potential for bioaccumulation in aquatic organisms such as fish. Sulfoxaflor is resistant to hydrolysis and photolysis but transforms quickly in soils. In contrast, sulfoxaflor reaching aquatic systems by drift is expected to degrade rather slowly. Partitioning of sulfoxaflor to air is not expected to be important due to the low

vap or pressure and Henry’s Law constant for sulfoxaflor. Exposure in surface water results from

the drifted parent compound, and only minor amounts are expected to run

- off only when rainfall and/or irrigation immediately follow application. The use of this i nsecticide is not expected to adversely impact Louisiana ecosystems when use d according to the Section 18 label. Of course, caution is needed to prevent exposure to water systems because of toxicity issues to aquatic

invertebrates. As state d on the Secti on 3 label, this product should never be applied directly to water, to areas where surface water is present or to intertidal areas below the mean water mark. Also, the label includes the statement “ Do not contaminate water when disposing of equipment

rins ate.”

Endangered and Threatened Species in Mississippi No impacts are expected on endangered and threatened species by this very limited use of this insecticide as delineated in the Section 18 application. Sulfoxaflor demonstrates a very favorable

ecotox icity and fate profile as stated above and should not directly impact any protected mammal, fish, avian, or plant species. This product does adversely affect insects and aquatic invertebrates, especially bees, but the limited exposure to these species shou ld not negatively

### affect endangered and threatened species in Mississippi when all applications label precautions

are followed and preformed.

The above content in Section 166.20(a)(7): Discussion of Risk Information was, for the most

part, prepared by M ichael Hare, Ph.D. (Human Health Effects), David Villarreal, Ph.D.

(Ecological Effects), and David Villarreal, Ph.D. (Environmental Fate), all with the Texas

Department of Agriculture. The parts of the above content in this section, with references to

Mississippi , were prepared by MD AC

- BPI.

SECTION 166.20(a) 8: COORDINATION WITH OTHER AGENCIES IN MISSISSIPPI

The Mississippi Department of Wildlife, Fisheries, and Parks will be notified of this request. Any comments received will be forwarded to the U.S. EPA.

SECTION 166.20(a) 9: NOTIFICATION/SUPPORT OF REGISTRANT

Dow AgroScience has been notified of this agency’s intent regarding this application and has offered a letter of support. They have also provided a copy of a label with the use directions for this use (although this use is dependent upon the approval of this section

- 18 by EPA)

.

SECTION 166.20(a) 10: ENFORCEMEN T PROGRAM IN MISSISSIPPI

The Mississippi Department of Agriculture and Commerce (MDAC) has adequate authorities for

enforcing provisions of Section 18 emergency exemptions. MDAC will require Dow

AgroScience to prepare Section 18 labeling that complies wi th MDAC and EPA requirements

for this emergency use, if approved, to ensure that product distributed for the exemption is

properly labeled.

SECTION 166.20(a) 11: REPEAT USES

This is the second time MDAC has applied for this specific exemption

.

SECTION 166.20( b ) 1: NAME OF THE PEST

Lygus lineolaris (Palisot de Beauvois), tarnished plant bug

SECTION 166.20( b ) 2 : DISCUSSION OF EVENTS OR CIRCUMSTANCES WHICH

BROUGHT ABOUT THE EMERGENCY SITUATION

Prior to the mid

- 1990’s , tarnished plant bugs were generally controlled 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

- South
( 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

elim inated. 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 p lant bug population development. Recently, this 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 cro ps with reproduction on field corn which provides a non

- sprayed on

- farm refuge for immigration to “fewer” cotton acres; thereby
concentrating the population. The consequence of these Southern production system changes is that tarnished plant bug has beco me the dominant season

- long pest across this regio n during the

last decade. D ue to higher populations which persist longer during the season, control costs and crop losses associated with tarnished plant bugs have increased dramatically. Typically, fewer than two applications per season were directed 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) reported resistance to a number 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 and widespread repor ts of thiamethoxam crop failures were reported in 2015 . In addition, the actual seasonal AI/acre of neonicotinoids further restricts product availability. In order to obtain some level of population management, there has been an increase in rates to the

hi ghest dose labeled for a single application. Tarnished plant bug management in many Mid

South fields has degraded to a point where the only option to reduce yield impacts is co

application of products w ith different modes of action, since 2012 sulfoxaflor has filled this gap. As referenced by Luckmann and Metcalf (1982) on the stages of crop protection, cotton producers and pest management practitioners are in crisis phase with tarnished plant bug. Th e subsequent step is that of resorting back to the disas ter phase which would result in a collapse of the existing pest management system for Mid

- Sout h cotton and losing the IPM based approach to plant bug management that all regions of the state have come to rely on since 2012 when

Transform was first introduc ed as a Section 18 and then with a full section 3 in 2013. As mentioned, there has not been a single documented case of bee loss in cotton with 4 years of use with sulfoxaflor in any region of Mississippi.

SECTION 166.20( b ) 3 : DISCUSSION OF ANTICIPATED RISKS TO ENDANGERED
OR THREATENED SPECIES, BENEFICIAL ORGANISMS, OR THE ENVIRONMENT

REMEDIED BY PROPOSED USE

As previously stated, it is not anticipated that there should be any anticipated risk to endangered or threated species, beneficial organisms, or the environment if all applications are made in

accordance to the section 18 use directions.

 See Attachment

– 201 5 Mississippi Threatened and Endangered Species List

### SECTION 166.20( b ) 4 : DISCUSSION OF SIGNIFICANT ECONOMIC LOSS

TIER 1 ANANLYSIS

Table 12 . Tier one analysis of emergency situation (Pre Transform Use) compared to non

- emergency
(Post Transform Use) for tarnished plant bug (TPB) in cotton in Mississippi.

1 

### Source: http://www.nass.usda.gov/Statistics_by_State/Mississippi/

2 

### Source: http://entomology.msstate.e du/resources/cottoncrop.asp



### Table 12 shows a comparison of yields from the emergency period (Pre Transform) and the non

emergency period (Post Transform) for the state of MS. Since the Transform became available it is clear that yields have increased (21%) and overall plant bug applications have decreased by 13%. This information supports the criteria for emergency exemption under Tier 1 analysis for

the state of MS. Pre Transform Use In Mississippi Post Transform Use in Mississippi

Year Yield 1 

### Acres 1 

### TPB 2



### Sprays Year Yield 1 

### Acres 1 

### TPB 2



### Sprays

2008 911 360000 4.9 2012 1014 470000 5

2009 672 295000 5.4 2013 1203 287000 5

2010 993 410000 5.4 2014 1232 420000 4

2011 952 605000 6 2015 1021 315000 4.9

Percent Change Pre and Post Transform Use 21%

- 11%

- 13%

### TIER 2 ANANLYSIS

Table 13 . Yields from e mergency (Baseline

, Pre Transform ) and non

- emergency (Post Transform) periods and associated increased control cost related to tarnished plant bug.

Price $0.62

Yield/Acre TPB

Cost Revenue Gross

Revenue

Prior to Transform Availability 

### 2008 911.00 $42.32 $564.82 $522.50

2009 672.00 $54.16 $416.64 $362.48

2010 993.00 $57.14 $615.66 $558.52

2011 952.00 $78.89 $590.24 $511.35

Avg 2008

- 09 882.00 $58.13 $546.84 $488.71

During Transform Availability 

### 2012 1014.00 $64.61 $628.68 $564.07

2013 1203.00 $60.44 $745.86 $685.42

2014 1232.00 $42.11 $763.84 $721.73

2015 1021.00 $46.56 $633.02 $586.46

Avg 2012

- 15 1117.50 $53.43 $692.85 $639.42

Change 2012

- 15 235.50

- $4.70 $146.01 $150.71

% Change '08

- '09 vs '12

- '15

- 21.1% 8.8%

- 21.1%

- 23.6%

1 

### Source: http://www.nass.usda.gov/Statistics_by_State/Mississippi/

2 

### Source: http://entomology.msstate.edu/resources/cottoncrop.asp



### Table 13 shows percent yield loss for the state of MS from emergency period (Pre Transform

2008

- 2011) to non

- emergency (Post Transform, 2012

- 2015) period was reduced by 21.1 %. Control cost per acre for tar nished plan t bug increased decreased by 8.8 % during period when Transform was used prior to when it was not . Overall loss o f gross revenue between the emergency period and the non

- emergency period is 23.6 %. These data clearly demonstrate a loss greater than 20% gross revenue considering the emergency period (Pre Transform) and the non

emergency period (Post Transform) for the state of Mississippi. There is no doubt that the producers in the state of MS would be back in an emergency situation without this product in

2016.

SUMMARY

Sulfoxaflor (Transform) has been used by producers in Mississippi since 2012 in cotton for control of tarnished plant bugs. The above referenced information on the tier analysis required by EPA for emergency exemption clearly demonstrate s that all criteria are met for both tier 1 and tier 2 analys e s for sul foxaflor in the state of MS. The s e data also demonstrate that since

Tran sform has become available for use in cotton

, MS producers have benefited greatly both in terms of gross revenue and increased yield protection, as well as reducing the overall number of

### tarnished plant bug applications. Furthermore, during the 4 year peri od that Transform has been

used, there have been no reports of bee kills associated with this product. Additionally

, many growers in regions with only moderate resistance levels have also benefitted from the safety

toward beneficial insect populations in t he field. Overall, Transform has become one of the foundation products in our IPM cotton program. Furthermore, studies by Whalen et al. indicate

that in mid

- south agroecosystems cotton is not a preferred foraging host.

Attachments: 2016 Proposed Transform Section 18 Label Dow Letter of Support for Transform emergency exemption Mississippi State University Extension letter of support for Transform emergency exemption Mississippi Beekeepers Association letter of support for Transform emergency exemption 2015 Mississippi Threatened and Endangered Species List

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.

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 ma naging tarnished plant bugs in cotton. Miss. State Univ. White Paper Recommendations Report, 4 pp. released April 2008.

Kerns, D. L., B. J. Kesey, B. A. Baugh, and D. R. Patman. 2011. Evaluation of insecticides against cotton aphids and convergent lady beetle larvae in cotton, 2010. Arthropod Manag. Tests

36:F44.

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 Management . John Wiley and Sons, New York, NY.

Moore, J. L., J. H. Temple, J. T. Hardke, K. Emfinger, P. P. Pr ice, J. T. Copes, J. W. Sharpe, E.
Burris, K. A. Fontenot , and B.R. Leonard . 2010. Summary of Insecticide Efficacy Trials for Control of Tarnished Plant Bugs in Louisiana Proc. Beltwide Cotton Conf. 817

- 819.

### Snodgrass, G. L. and J. Gore. 2007. Status of insecticide resistance for the tarnished plant bug,

pp. 56

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

Whalen, A., A.L. Catchot, J. Gore, D. Cook, S. Stewart, and G. Lorenz. 2015. Populations of

For aging Honeybees in Mid

- South Crops. Mid

- South Entomologist. p. 53 v. 8.

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

- 929. In Proc. Beltwide Cotton Res. Conf.,

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

- Feedin g Insecticide. J. Agric. Food Chem. (Accepted for publication,

See Appendix C ).

Zhu, Y., J. Adamczyk, T. Rinderer, J. Yao, R. Danka, R. Luttrell, and J. Gore. 2015. Spray toxicity and risk potential of 42 commonly used formulations of row crop pesticides to adult honey bees (Hymenoptera: Apidae). J. Econ. Entomol.

108:2640

- 2647.C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

file: R396-082 Transform WG Sec 18 MS Cotton 22Feb16d.doc



# Transform ® 

# WG

EPA Reg. No. 62719-XXX



## Registration Notes:

Proposed Section 18.

This Section 18 labeling is provided in two components: (1) The base label and label booklet containing all of the information needed to use this product, except crop-specific use directions; and (2) crop-specific use directions which must be approved by EPA which allow use in a specific state.Component (1) allows the product to be shipped to locations where it can be used in anticipation of EPAapproval of crop-specific use directions in component (2).

® Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of DowC1C / Transform WG / Sec 18 MS Cotton / 02-22-16

(Base label):



# Transform ® 

# WG

INSECTICIDE

For Control of Lygus Bugs in Cotton

ATTENTION

• Section 18 Specific Exemption

• For Distribution and Use Only in States with a Valid Section 18 Label

This product cannot be used without a valid state-specific Section 18 label which

must be in the possession of the user at the time of application.

Active Ingredient:

sulfoxaflor ........................................................ 50% Other Ingredients ................................................... 50%

Total .................................................................... 100%

Contains 50% active ingredient on a weight basis.



### Keep Out of Reach of Children 

# DANGER PELIGRO

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not understand the label, find someone to explain it to you in detail.)



### Agricultural Use Requirements
Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. Refer to the label booklet under "Agricultural Use Requirements" in the Directions for Use

section for information about this standard.



### Precautionary Statements

Hazard to Humans and Domestic Animals

Corrosive • Causes Irreversible Eye Damage • Harmful If Swallowed

Do not get in eyes or on clothing.



### Personal Protective Equipment (PPE)

Applicators and other handlers must wear:

• Long-sleeved shirt and long pants

• Shoes plus socks

• Protective eyewear

Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this product’s concentrate. Do not reuse them. Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry.



### User Safety Recommendations

Users should:

• Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet.

• Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on cleanC1C / Transform WG / Sec 18 MS Cotton / 02-22-16

clothing.

• Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing.



### First Aid

If in eyes: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or

doctor for treatment advice.

If swallowed: Call a poison control center or doctor immediately for treatment advice. Have person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by a poison control center or doctor. Do not give anything by mouth to an unconscious person.

Note to Physician: Probable mucosal damage may contraindicate the use of gastric lavage.

Have the product container or label with you when calling a poison control center or doctor, or going for treatment. You may also contact 1-800-992-5994 for emergency medical treatment information.



### Environmental Hazards

This product is highly toxic to bees exposed through contact during spraying and while spray droplets are still wet. This product may be toxic to bees exposed to treated foliage for up to 3 hours following application. Toxicity is reduced when spray droplets are dry.

Risk to managed bees and native pollinators from contact with pesticide spray or residues can be minimized when applications are made before 7:00 am or after 7:00 pm local time or when the temperature is below 55 o F at the site of application.

Refer to the Directions for Use for crop specific restrictions and additional advisory statements to protect pollinators.

Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwaters.



### Storage and Disposal

Do not contaminate water, food, or feed by storage and disposal. Pesticide Storage: Store in original container only. Pesticide Disposal: Return any unopened, unused container of this unregistered product to the manufacturer or distributor, or dispose of it in accordance with Resource Conservation and Recovery Act regulations, following the expiration of the emergency exemption. Container Handling: Nonrefillable container. Do not reuse or refill this container. Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the container 1/4 full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure

two more times. Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank. Hold container upside down over application equipment or mix tank or collect rinsate for later use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 psi for at least 30 seconds. Drain for 10 seconds after the flow begins to drip. Then offer for recycling if available or puncture and dispose of in a sanitary landfill, or by incineration, or by other procedures allowed by

state and local authorities.

Refer to label booklet for Directions for Use.

Notice: Read the entire label. Use only according to label directions. Before using this product, read Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies at end of label booklet. If terms are unacceptable, return at once unopened.

In case of emergency endangering health or the environment involving this product, call 1-800-992-5994.C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Agricultural Chemical: Do not ship or store with food, feeds, drugs or clothing.

EPA Est. _________

® Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow

Produced for Dow AgroSciences LLC

9330 Zionsville Road Indianapolis, IN 46268 

### NET WEIGHT ____C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

(Cover, shipping container):



# Transform ® 

# WG

INSECTICIDE

For Control of Lygus Bugs in Cotton

ATTENTION

• Section 18 Specific Exemption

• For Distribution and Use Only in States with a Valid Section 18 Label

This product cannot be used without a valid state-specific Section 18 label which

must be in the possession of the user at the time of application.

Active Ingredient:

sulfoxaflor ........................................................ 50% Other Ingredients ................................................... 50%

Total .................................................................... 100%

Contains 50% active ingredient on a weight basis.



### Keep Out of Reach of Children 

# DANGER PELIGRO

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not understand the label, find someone to explain it to you in detail.)



### Agricultural Use Requirements
Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. Refer to the label booklet under "Agricultural Use Requirements" in the Directions for Use

section for information about this standard.

Refer to inside of label booklet for additional precautionary information including Directions for

Use.

Notice: Read the entire label. Use only according to label directions. Before using this product, read Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies at end of label booklet. If terms are unacceptable, return at once unopened.

In case of emergency endangering health or the environment involving this product, call 1-800-992-5994.

Agricultural Chemical: Do not ship or store with food, feeds, drugs or clothing.

EPA Est. _________

® Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow

Produced for Dow AgroSciences LLC

9330 Zionsville Road Indianapolis, IN 46268 

### NET WEIGHT ____C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

(Page 1 through end):



### Precautionary Statements

Hazard to Humans and Domestic Animals 

# DANGER

Corrosive • Causes Irreversible Eye Damage • Harmful If Swallowed

Do not get in eyes or on clothing.



### Personal Protective Equipment (PPE)

Applicators and other handlers must wear:

• Long-sleeved shirt and long pants

• Shoes plus socks

• Protective eyewear

Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this product’s concentrate. Do not reuse them. Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry.



### User Safety Recommendations

Users should:

• Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet.

• Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing.

• Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing.



### First Aid

If in eyes: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or

doctor for treatment advice.

If swallowed: Call a poison control center or doctor immediately for treatment advice. Have person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by a poison control center or doctor. Do not give anything by mouth to an unconscious person.

Note to Physician: Probable mucosal damage may contraindicate the use of gastric lavage.

Have the product container or label with you when calling a poison control center or doctor, or going for treatment. You may also contact 1-800-992-5994 for emergency medical treatment information.



### Environmental Hazards

This product is highly toxic to bees exposed through contact during spraying and while spray droplets are still wet. This product may be toxic to bees exposed to treated foliage for up to 3 hours following application. Toxicity is reduced when spray droplets are dry.

Risk to managed bees and native pollinators from contact with pesticide spray or residues can be minimized when applications are made before 7:00 am or after 7:00 pm local time or when the temperature is below 55 o F at the site of application.

Refer to the Directions for Use for crop specific restrictions and additional advisory statements to protect pollinators. Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwaters.C1C / Transform WG / Sec 18 MS Cotton / 02-22-16



### Directions for Use

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Read all Directions for Use carefully before applying.

Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in the area during application. For any requirements specific to your state or tribe, consult the agency responsible for pesticide regulation.



### Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. This Standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE), and restricted entry interval. The requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard.

Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 24 hours.

PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that involves contact with anything that has been treated, such as plants, soil, or water, is:

• Coveralls

• Shoes plus socks



### Storage and Disposal

Do not contaminate water, food or feed by storage and disposal. Pesticide Storage: Store in original container only. Pesticide Disposal: Return any unopened, unused container of this unregistered product to the manufacturer or distributor, or dispose of it in accordance with Resource Conservation and Recovery Act regulations, following the expiration of the emergency exemption. Container Handling: Nonrefillable container. Do not reuse or refill this container. Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the container 1/4 full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure

two more times. Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank. Hold container upside down over application equipment or mix tank or collect rinsate for later use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 psi for at least 30 seconds. Drain for 10 seconds after the flow begins to drip. Then offer for recycling if available or puncture and dispose of in a sanitary landfill, or by incineration, or by other procedures allowed by

state and local authorities.



### Product Information

Carefully read, understand and follow label use rates and restrictions. Apply the amount specified in the following tables with properly calibrated aerial or ground spray equipment. Prepare only the amount of spray solution required to treat the measured acreage. The low rates may be used for light infestations of the target pests and the higher rates for moderate to heavy infestations. Transform ® WG insecticide may be applied in either dilute or concentrate sprays so long as the application equipment is calibrated and adjusted to deliver thorough, uniform coverage. Use the specified amount of Transform WG per acre regardless of the spray volume used.


### Use Precautions

Integrated Pest Management (IPM) Programs Transform WG is recommended for IPM programs in labeled crops. Apply Transform WG when field scouting indicates target pest densities have reached the economic threshold, i.e., the point at which the insect population must be reduced to avoid economic losses beyond the cost of control. Other than reducing the target pest species as a food source, Transform WG does not have a significant impact on most parasitic insects or the natural predaceous arthropod complex in treated crops, including big-eyedC1C / Transform WG / Sec 18 MS Cotton / 02-22-16

bugs, ladybird beetles, flower bugs, lacewings, minute pirate bugs, damsel bugs, assassin bugs, predatory mites or spiders. The feeding activities of these beneficials will aid in natural control of other insects and reduce the likelihood of secondary pest outbreaks. If Transform WG is tank mixed with any insecticide that reduces its selectivity in preserving beneficial predatory insects, the full benefit of Transform WG in an IPM program may be reduced.

Insecticide Resistance Management (IRM) Transform WG contains a Group 4C insecticide. Insect biotypes with acquired resistance to Group 4C insecticides may eventually dominate the insect population if Group 4C insecticides are used repeatedly in the same field or area, or in successive years as the primary method of control for targeted species. This may result in partial or total loss of control of those species by Transform WG or other Group 4C

insecticides.

To delay development of insecticide resistance, the following practices are recommended: • Avoid consecutive use of insecticides on succeeding generations with the same mode of action (same insecticide subgroup, 4C) on the same insect species. • Consider tank mixtures or premix products containing insecticides with different modes of action (different insecticide groups) provided the products are registered for the intended use. • Base insecticide use upon comprehensive IPM programs. • Monitor treated insect populations in the field for loss of effectiveness. • Do not treat seedling plants grown for transplant in greenhouses, shade houses, or field plots. • Contact your local extension specialist, certified crop advisor, and/or manufacturer for insecticide resistance management and/or IPM recommendations for the specific site and resistant pest problems. • For further information or to report suspected resistance, you may contact Dow AgroSciences by calling

800-258-3033.



### Mixing Directions

Application Rate Reference Table

Application Rate of

Transform WG (oz/acre) Active Ingredient Equivalent (lb ai/acre)

0.75 0.023

1.5 0.047

2.25 0.071

Transform WG – Alone Fill the spray tank with water to about 1/2 of the required spray volume. Start agitation and add the required amount of Transform WG. Continue agitation while mixing and filling the spray tank to the required spray volume. Maintain sufficient agitation during application to ensure uniformity of the spray mix. Do not allow water or spray mixture to back-siphon into the water source.

Transform WG - Tank Mix When tank mixing Transform WG with other materials, conduct a compatibility test (jar test) using relative proportions of the tank mix ingredients prior to mixing ingredients in the spray tank. If foliar fertilizers are used, the jar test should be repeated with each batch of fertilizer utilizing the mixing water source. Vigorous, continuous agitation during mixing, filling and throughout application is required for all tank mixes. Sparger pipe agitators generally provide the most effective agitation in spray tanks. To prevent foaming in the spray tank, avoid stirring or splashing air into the spray mixture. Mixing Order for Tank Mixes: Fill the spray tank with water to 1/4 to 1/3 of the required spray volume. Start agitation. Add different formulation types in the order indicated below, allowing time for complete dispersion and mixing after addition of each product. Allow extra dispersion and mixing time for dry flowable products.

Add different formulation types in the following order: 1. Transform WG and other water dispersible granules 2. Wettable powders 3. Suspension concentrates and other liquidsC1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Maintain agitation and fill spray tank to 3/4 of total spray volume. Then add:

4. Emulsifiable concentrates and water-based solutions 5. Spray adjuvants, surfactants and oils

6. Foliar fertilizers

Finish filling the spray tank. Maintain continuous agitation during mixing, final filling and throughout application. If spraying and agitation must be stopped before the spray tank is empty, the materials may settle to the bottom. Settled materials must be resuspended before spraying is resumed. A sparger agitator is particularly useful for this purpose.

Premixing: Dry and flowable formulations may be premixed with water (slurried) and added to the spray tank through a 20 to 35 mesh screen. This procedure assures good initial dispersion of these formulation
types.



### Application Directions

Proper application techniques help ensure thorough spray coverage and correct dosage for optimum insect control. Apply Transform WG as a foliar spray at the rate indicated for target pest. The following directions are provided for ground and aerial application of Transform WG. Attention should be given to sprayer speed and calibration, wind speed, and foliar canopy to ensure adequate spray coverage.



### Spray Drift Management

Wind: To reduce off-target drift and achieve maximum performance, apply when wind velocity favors ontarget product deposition.

Temperature Inversions: Do not make ground or aerial applications during a temperature inversion. Temperature inversions are characterized by stable air and increasing temperatures with height above the ground. Mist or fog may indicate the presence of an inversion in humid areas. The applicator may detect the presence of an inversion by producing smoke and observing a smoke layer near the ground

surface.

Droplet Size: Use only medium or coarser spray nozzles (for ground and non-ULV aerial application) according to ASABE (S-572.1) definition for standard nozzles. In conditions of low humidity and high temperatures, applicators should use a coarser droplet size except where indicated for specific crops.

Ground Application To prevent drift from groundboom applications, apply using a nozzle height of no more than 4 feet above the ground or crop canopy. Shut off the sprayer when turning at row ends. Risk of exposure to sensitive aquatic areas can be reduced by avoiding applications when wind directions are toward the aquatic area.

Row Crop Application Use calibrated power-operated ground spray equipment capable of providing uniform coverage of the target crop. Orient the boom and nozzles to obtain uniform crop coverage. Use a minimum of 5 to 10 gallons per acre, increasing volume with crop size and/or pest pressure. Use hollow cone, twin jet flat fan nozzles or other atomizer suitable for insecticide spraying to provide a fine to coarse spray quality (per ASABE S-572.1, see nozzle catalogs). Under certain conditions, drop nozzles may be required to obtain complete coverage of plant surfaces. Follow manufacturer's specifications for ideal nozzle spacing and spray pressure. Minimize boom height to optimize uniformity of coverage and maximize deposition (optimize on-target deposition) to reduce drift.

Aerial Application Apply in a minimum spray volume of 3 gallons per acre. Mount the spray boom on the aircraft so as to minimize drift caused by wing tip or rotor vortices. Use the minimum practical boom length and do not exceed 75% of the wing span or 80% of the rotor diameter. Flight speed and nozzle orientation must be considered in determining droplet size. Spray must be released at the lowest height consistent with pest control and flight safety. Do not release spray at a height greater than 10 feet above the crop canopy unless a greater height is required for aircraft safety. When applications are made with a crosswind, the swath will be displaced downwind. The applicator must compensate for this displacement at the downwind edge of the application area by adjusting the path of the aircraft upwind.C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Spray Adjuvants The addition of agricultural adjuvants to sprays of Transform WG may improve initial spray deposits, redistribution and weatherability. Select adjuvants that are recommended and registered for your specific use pattern and follow their use directions. When an adjuvant is to be used with this product, Dow AgroSciences recommends the use of a Chemical Producers and Distributors Association certified adjuvant. Always add adjuvants last in the mixing process.



### Rotational Crop Restrictions

The following rotational crops may be planted at intervals defined below following the final application of Transform WG at specified rates for a registered use.

Crop Re

- Planting Interval

cotton no restrictions
all other food and feed crops 360 days



### Application Rates

Refer to state-specific Section 18 label for approved uses, application timing and

restrictions.

This product cannot be used without a valid state-specific Section 18 label. The label must be in the possession of the user at the time of application. The Section 18 label can be obtained from state and/or county authorities where it is valid. Please contact your Dow AgroSciences representative for further

information.

Terms and Conditions of Use

If terms of the following Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies are not acceptable, return unopened package at once to the seller for a full refund of purchase price paid. Otherwise, use by the buyer or any other user constitutes acceptance of the terms under Warranty
Disclaimer, Inherent Risks of Use and Limitation of Remedies.



### Warranty Disclaimer

Dow AgroSciences warrants that this product conforms to the chemical description on the label and is reasonably fit for the purposes stated on the label when used in strict accordance with the directions, subject to the inherent risks set forth below. Dow AgroSciences MAKES NO OTHER EXPRESS OR

IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR

ANY OTHER EXPRESS OR IMPLIED WARRANTY.



### Inherent Risks of Use

It is impossible to eliminate all risks associated with use of this product. Plant injury, lack of performance, or other unintended consequences may result because of such factors as use of the product contrary to label instructions (including conditions noted on the label, such as unfavorable temperature, soil conditions, etc.), abnormal conditions (such as excessive rainfall, drought, tornadoes, hurricanes), presence of other materials, the manner of application, or other factors, all of which are beyond the control of Dow AgroSciences or the seller. All such risks shall be assumed by buyer.



### Limitation of Remedies

To the extent permitted by law, the exclusive remedy for losses or damages resulting from this product (including claims based on contract, negligence, strict liability, or other legal theories), shall be limited to, at Dow AgroSciences' election, one of the following:

1. Refund of purchase price paid by buyer or user for product bought, or 2. Replacement of amount of product usedC1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Dow AgroSciences shall not be liable for losses or damages resulting from handling or use of this product unless Dow AgroSciences is promptly notified of such loss or damage in writing. In no case shall Dow AgroSciences be liable for consequential or incidental damages or losses.

The terms of the Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies cannot be varied by any written or verbal statements or agreements. No employee or sales agent of Dow AgroSciences or the seller is authorized to vary or exceed the terms of the Warranty Disclaimer or Limitation of Remedies in any manner.

® Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow

Accepted __/__/__Dow AgroSciences LLC 9330 Zionsville Road Indianapolis, IN 46268-1054 USA 

# Transform ® 

# WG

EPA Reg. No. 62719-625 

### For Control of Lygus Bugs in Cotton Section 18 Emergency Exemption

File symbol: XXXXXX

FOR DISTRIBUTION AND USE ONLY IN MISSISSIPPI UNDER SECTION 18 EMERGENCY

EXEMPTION This Section 18 Emergency Exemption is effective XXXXX and expires XXXXXXX.

• This labeling must be in the possession of the user at the time of application.

• It is in violation of federal law to use this product in a manner inconsistent with its labeling.

• All application directions, restrictions, and precautions on the registered product label for Transform WG (EPA Reg. No. 62719-625) are to be followed.

• Any adverse effects resulting from the use of Transform WG under this emergency exemption must be immediately reported to the Mississippi Department of Agriculture and Commerce.



## Directions for Use

Pests and Application Rates:

Pests Transform

WG (oz/acre)
tarnished plant bug 1.5 – 2.25 (0.047 – 0.071 lb ai/acre)

Advisory Pollinator Statement: Notifying known beekeepers within 1 mile of the treatment area 48 hours before the product is applied will allow them to take additional steps to protect bees. If known apiaries are within one mile of cotton fields intended for treatment, applications should be made within three hours of sunset during the flowering period. Prior to use of Transform WG, growers and the beekeepers hosted on their farm are advised to implement cooperative standards outlined in the Mississippi Honeybee Stewardship Program.

Application Timing: Treat in accordance with local economic thresholds. Consult your Dow AgroSciences representative, cooperative extension service, certified crop advisor or state agricultural experiment station for any additional local use recommendations for your area.

Application Rate: Use a higher rate in the rate range for heavy pest populations. Two applications may be required for optimum tarnished plant bug control under high pest pressure or heavy immigration of plant bugs from other crops.

Restrictions:

• Preharvest Interval: Do not apply within 14 days of harvest.

• Minimum Treatment Interval: Do not make applications less than 5 days apart.

• Do not make more than four applications per acre per year.

• 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.

Environmental Hazards

This product is highly toxic to bees exposed through contact during spraying and while spray droplets are still wet. This product may be toxic to bees exposed to treated foliage for up to 3 hours following application. Toxicity is reduced when spray droplets are dry.Risk to managed bees and native pollinators from contact with pesticide spray or residues can be

minimized when applications are made before 7:00 am or after 7:00 pm local time or when the temperature is below 55 ° F at the site of application.

Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwaters.

® TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow

R396-082 Approved: __/__/__ Initial printing

### February 22 , 2016

To whom it may concern:

The purpose of this letter is to request an emergency exemption (Section 18) for the use
of sulfoxaflor (Transform WG TM 

### , Dow AgroSciences) to manage tarnished plant bug, Lygus lineolaris , in cotton. Cotton prod ucers throughout Mississippi have successfully

used sulfoxaflor since 2012 to manage tarnished plant bugs. Since its introduction, Transform has reduced overall tarnished plant bug applications

, and provided significant yield increases and returns in gross revenues. Over the last four years, sulfoxaflor has replaced more toxic insecticides including pyrethroids, organophosphates, and neonicotinoids. Because of its high level of efficacy, relative safety to beneficial arthropods and pollinators , and protecti on of cotton yields, Tra nsform has become the foundation of the insecticide component of Mississippi’s overall IPM program. Since the initial Section 3 registration in 2013, Transform has been used on more than three million

acres across the mid

- south regi on with zero reported incidents of adverse effects on bees or other pollinators. Despite the higher cost of Transform relative to other products used for tarnished plant bug control, cotton growers and consultants have incorporated

Transform into their ove rall insect management programs. This demonstrates their commitment to selecting safe alternatives to more toxic insecticides as long as they do not sacrifice yields.

Cotton growers, beekeepers, and other stakeholders in the state of Mississippi

demonstr ated their commitment to the protection of managed honey bees with their adoption of the Mississippi Honey Bee Stewardship Program. Since the introduction of this program, the level of cooperation and communication between beekeepers and

farmers has been u nprecedented. In particular, the vast majority of growers in Mississippi have bought into this program and view beekeepers as fellow farmers. As a result, they have shown real concern about the livelihood of beekeepers they host on their farms. The

recent cancellation of the Transform registration as a result of the actions of the Pollinator Stewardship Council has severely damaged the relationships between many farmers and beekeepers. I have already heard of beekeepers being demanded to remove their bees from some farms throughout the state. If Transform is not available to growers throughout Mississippi in 2016, it will set the relationships between farmers and beekeepers back to before the adoption of the Mississippi Honeybee Stewardship Program. In fact , those relationships will be more strained than it was before the program.

### Finally, Transform has become the foundation of our integrated pest management

program for cotton in Mississippi. It provides a high level of efficacy and yield protection

from ta rnished plant bug and cotton aphid, preserves beneficial insect populations, and more importantly replaces more toxic insecticides. Because of these attributes, Transform rapidly became the foundation of our cotton integrated pest management program for

ta rnished plant bug. The recent cancellation of Transform has been damaging to our overall IPM program and to the relationships between beekeepers and farmers in all regions of Mississippi.

Thank you.

Sincerely,

Angus Catchot, Extension Entomologist

- MS U

- ES

## Representing beekeepers across Mississippi Mississippi Beekeepers Association

214 Shadow Wood Dr
Clinton, MS 39056

601

- 924

- 2582

22 February 2016 

### To Whom It May Concern:

The Executive Board of the Mississippi Beekeepers Association (MBA) met on 18 February 2016 to address some concerns and issues that have arisen with relationships between Mississippi beekeepers and Mississippi row crop producers. This letter is supported by the Executive Board of M BA. As an organization made up of commercial, sideline, and hobby beekeepers, we recognize the important and mutually beneficial relationship between beekeepers and row crop farmers in Mississippi. This was clearly demonstrated in the development of the Mi ssissippi Honeybee Stewardship Program that brought together famers and beekeepers to work on cooperative standards between both groups. The request from the MBA Board with regards to the Transform ® 

### WG, sulfoxaflor, “Section 18” Emergency Exemption application is as follows: The Mississippi Beekeepers Association would like to express our support for the cotton and grain sorghum (milo) farmers of Mississippi to be able to use Transform ® 

### WG, sulfoxaflor, for the control of

t arnished plant bug s

, Lygus lineolaris , in Mississippi cotton and s ugarcane aphid s

, Melanaphis sacchar i

, in Mississippi grain sorghum. We understand that a “Section 18” Emergency Exemption is being requested for the control of these pests in Mississippi. The Board supports the use of Transform ® WG on grain sorghum and cotton, but we would like to request during plant bloom (flowering) that if a known apiary ( bee yard of managed honey bee colonies) is within one (1) mile of the site of treatment that application occur within three (3) hours of sunset. Recently, there has been considerable press and media coverage on the decline of the honeybee populations worldwide. There are numerous factors that affect colony health and overwintering losses of honeybees. It has been clearly documented that honeybee losses are due to a variety of factors including Varroa mites, pesticide exposure , habitat loss, viral diseases, nutrition inadequacies, e tc . These stressors may b e acting alone or in combination thereof

. As beekeepers in the state of Mississippi

, we are fully aware of the risk taken when we place our hives on or in the vicinity of row c rop farms. We rely annually on planted and farmed crops such as soybeans and cotton to provide pollen and nectar for our bees despite the fact that c otton, c orn, s oybeans, g rain s orghum, w heat, r ice, and p eanuts make

up greater than 99% of all row crops in the Mid

- South regio n

. These cultivated crops do not require bee pollination to produce, but some do benefit to varying degrees from bee pollination , depending the crop and varieties planted. Many Mississippi beekeepers have worked diligently to maintain their relationships with the row crop producers of Mississippi. Recent lawsuits, launched by non

- governmental organizations (NGOs), along with media coverage, ha ve given the impression that b eekeepers , in general, are against the use of “all” pesticides. This misrepresentation has caused tension on relationships that we have developed over many years, and in several cases, generations of beekeepers and row crop producers. Beekeepers have appreciated the relationships with their host farmers in the past

, a nd this is now in dange r. We want to remain profitable, we want row crop producers to be profitable, and we realize that pesticide applications will be necessary in many cases , including on those crops attractive to honey bees

. We recognize that just as

gr owers in the Mid

- South region routinely experience high levels of pest pressure and need products such as Transform ®



### WG to remain profitable, we need our bees foraging on their crops for us (beekeepers) to remain profitable. Furthermore,

we find that most farmers appreciate our bees foraging their crops and do appreciate the relationship formed between them and beekeepers. Moreover, most farmers realize a need for our partnership for us (beekeepers) to remain profitable.

In conclusion , w e would ask that EPA grant Mississippi row crop producers the “ Section 18 ” Emergency

E xemption to use Transform ® 

### WG in 2016 for control of t arnished p lant b ugs in cotton and s ugarcane aphids in grain sorghum

. Again, w e would also request that if managed be es are within one (1) mile of the treated area that applicators

mak e applications within three (3) hours of sunset if flowering is occurring in cotton

.

Sincerely,

Austin C. Smith

MBA President

### 1 

## MISSISSIP PI

List of Federally Threatened and Endangered Species by Count y

Codes: E = Endangered C = Candidate

CH = Critical Habitat P = Proposed

T = Threatened

November 2015

The following list contains species that are known to occur in Mississippi

. It inclu des historic range

information, known species locations, as well as the “Section 7 range” or “Area of Influence” of a species
population which identifies the area within which, if an action is proposed, potential effects to this species

should be considered.

NOTE: The b rown p elican ( Pelecanus occidentalis) was delisted in 2009 but the pelican is still protected by
the Migratory Bird Treaty Act. The American b ald e agle (Haliaeetus leucocephal us) was delisted in 2 007 but
nesting eagles and their nest trees are still protected under the Bald and Golden Eagle Protection Act

.

Statewide T Wood Stork Mycteria a mericana

Adams E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

E Pallid sturgeon Scaphirhynchus albus

Alcorn E Indiana bat Myotis sodalis

E Mitchell ’ s satyr butterfly Neonympha mitchellii mitchellii

T Northern long

- e ared bat Myotis septentrionalis

T Price ’ s potato bean Apios priceana

PT White fringeless orchid Platanthera integrilabia

Amite T Louisiana black bear Ursus a mericanus luteolus

E Red

- cockaded woodpecker Picoides borealis

Attala T Northern long

- eared bat Myotis septentrionalis

Benton E Indiana bat Myotis sodalis

T Northern long

- eared bat Myotis septentrionalis

Bolivar E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T North ern long

- eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

Calhoun T Northern long

- eared bat Myotis septentrionalis

Carroll T Louisiana black bear Ursus amer icanus luteolus

T Northern long

- eared bat Myotis septentrionalis

### 2 Chickasaw T Northern long

- eared bat Myotis septentrionalis

T Price ’ s potato bean Apios priceana

Chocta w T Norther n long

- eared bat Myotis septentrionalis

Claiborne T Bayou darter Etheostoma rubrum

E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

E Pallid sturgeon Scaphirhynchus albus

T Rabbitsfoot mussel Quadrula cyl indrica cylindrica

Clarke T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

C Pearl darter Percina aurora (Pascagoula River System)

T Yellow

- b lotched map turtle Graptemys flavimaculata

Clay T Northern long

- eared bat Myotis septentrionalis

T Price ’ s potato bean Apios priceana

Coahoma E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Norther n long

- eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

Copiah T Bayou darter Etheostoma rubrum

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Urs us a mericanus luteolus

C Pearl darter Percina aurora (Pearl River System)

E Red

- cockaded woodpecker Picoides borealis

T Ringed map turtle Graptemys oculifera

Covington T Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise G opherus polyphemus

C Pearl darter Percina aurora (Pascagoula River System)

T Yellow

- blotched map turtle Graptemys flavimaculata

DeSoto E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Northern long

- ear ed bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

Forrest T /P CH Black pine snake Pituophis melanoleucus lodingi

ECH Dusky gopher frog Rana sevosa

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipe nser oxyrinchus desotoi

T Louisiana black bear Ursus a mericanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System )

E Red

- cockaded woodpecker Picoides borealis

T Yellow

- blotched map turtl e Graptemys flavimaculata

### 3 Franklin T Louisiana black bear Ursus a mericanus luteolus

E Red

- cockaded woodpecker Picoides borealis

George T/P CH Black pine snake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturg eon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red

- cockaded woodpecker Picoides borealis

T Yellow

- blotch ed map turtle Graptemys flavimaculata

Greene T/P CH Black pine snake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Lou isiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red

- cockaded woodpecker Picoides borealis

T Yellow

- blotched map turtle Graptemys flavimaculata

Gre nada T Northern long

- eared bat Myotis septentriona lis

Hancock T Gopher tortoise Gopherus polyphemus

T Green sea turtle Chelonia mydas

TCH Gu lf sturgeon Acipenser oxyrinchus desotoi

T Inflated heelsplitter mussel Potamilus inflatus

E Kemp ’ s r idley sea turtle Lepidochelys kempii

E Leather back sea turtle Dermochelys coriacea

T Loggerhead sea turtle Caretta caretta

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pearl River System)

TCH Piping p lover Charadrius melodus

T Red k not Calidris canutus rufa

T Ringed map turtle Graptemys oculifera

E West Indian manatee Trichechus manatus

Harrison E Alabama red

- bellied turtle Pseu demys alabamensis

T/P CH Black pine snake Pituophis melanoleucus lodingi

ECH Dusky gopher frog Rana sevosa

T Gopher tortoise Gopherus polyphemus

T Green sea turtle Chelonia mydas

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

E Kemp ’ s r idley sea turtle Lepidochelys kempii

E Leatherback sea turtle Der mochelys coriacea

T Loggerhead sea turtle Caretta caretta

T Louisiana black bear Ursus america n us luteolus

E Louisiana quillwort Isoetes louisianensis

TCH Piping p lover Charadrius melodus

T /P CH Red k not Calidris canutus rufa

E Red

- cockaded w oodpecker Picoides borealis

E West Indian manatee Trichechus manatus

### 4 Hinds T Bayou darter Etheostoma rubrum

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus a merica n us luteolus

T Northern long

- eared bat Myo tis septentrionalis

T / CH Rabbitsfoot mussel Quadrula cylindrica cylindrica

T Ringed map turtle Graptemys oculifera

Holmes T Louisiana black bear Ursus a mericanus luteolus

T Northern long

- eared bat Myotis septentrionalis

E Pondberry Lin dera melissifolia

Humphreys T Louisiana black bear Ursus americanus luteolus

T Northern long

- eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

E Sheepnose mussel Plethobasus cyphyus

Issaquena E Fat p ocketbook mussel Pot amilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

T Northern long

- eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

Itawamba T CH Alabama moccasinshell Medionidus acutissimus

E CH Black clubshell mussel Pleurobema curtum

E CH Heavy pigtoe mussel Pleurobema taitianum

T Inflated heelsplitter mussel Potamilus inflatus

E Mitchell ’ s satyr butterfly Neonympha mitchellii mitchellii

T Northern long

- eared bat Myotis septentrionalis

TCH Orange

- nacre mucket Lampsilis perovalis

E CH Ovate clubshell mussel Pleurobema perovatum

E CH Southern clubshell mussel Pleurobema decisum

E CH Southern combshell mussel Epioblasma pe nita

PT White fringeless orchid Platanthera integrilabia

Jackson E Alabama red

- bellied turtle Pseu demys alabamensis

T Black pine snake Pituophis melanoleucus lodingi

ECH Dusky gopher frog Rana sevosa

T Gopher tortoise Gopherus pol yphemus

T Green sea turtle Chelonia mydas

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

E Kemp ’ s r idley sea turtle Lepidochelys kempii

E Leatherback sea turtle Dermochelys coriacea

TCH Loggerhead sea turtle Caretta caretta

T Louis iana black bear Ursus americanu s luteolus

E Louisiana quillwort Isoetes louisianensis

ECH Mississippi sandhill crane Grus canadensis pulla

C Pearl darter Percina aurora (Pascagoula River System)

TCH Piping p lover Charadrius melodus

T Red k not Calidris canutus rufa

E Red

- cockaded woodpecker Picoides borealis

E West Indian manatee Trichechus manatus

T Yellow

- blotched map turtle Graptemys flavimaculata

### 5 Jasper T Gopher tortoise Gopherus polyphemus

E Red

- cockaded woodpecker Picoides borealis

Jefferson E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus a mericanus luteolus

E Pallid sturgeon Scaphirhynchus albus

E Red

- cockaded woodpecker Picoides bor ealis

Jefferson Davis T Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

Jones T/P CH Black pine snake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon A cipenser oxyrinchus desotoi

T Louisiana black bear Ursus a mericanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red

- cockaded woodpecker Picoides borealis

T Yellow

- blotched m ap turtle Graptemys flavimaculata

Kemper T Northern long

- eared bat Myotis septentrionalis

T Price ’ s potato bean Apios priceana

Lafayette T Northern long

- eared bat Myotis septentrionalis

Lamar T Black pine snake Pituophis melanoleucus lodin gi

T Gopher tortoise Gopherus polyphemus

T Louisiana black bear Ursus a mericanus luteolus

E Red

- cockaded woodpecker Picoides borealis

Lauderdale T Northern long

- eared bat Myotis septentrionalis

Lawrence T Black pinesnake Pituophis mel anoleucus lodingi

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

C Pearl darter Percina aurora (Pearl River System)

T Ringed map turtle Graptemys oculifera

Leake T Northern long

- eared bat Myotis septentrionalis

C Pearl darter Perc ina aurora (Pearl River System)

T Ringed map turtle Graptemys oculifera

Lee T Northern long

- eared bat Myotis septentrionalis

T Price ’ s potato bean Apios priceana

Leflore T Louisiana black bear Ursus americanus luteolus

T Northern long

- ea red bat Myotis septentrionalis

E Pondberry Lindera melissifolia

Lincoln T Bayou darter Etheostoma rubrum

T Louisiana black bear Ursus a mericanus luteolus

E Red

- cockaded woodpecker Picoides borealis

### 6 Lowndes TCH Alabama moccasinshell Medionidus acutissimus

E CH Black clubshell mussel Pleurobema curtum

E CH Heavy pigtoe mussel Pleurobema taitianum

T Inflated heelsplitter mussel Potamilus inflatus

T Northern long

- eared bat Myotis septentrionalis

T CH Orange

- nacre mucket Lamp silis perovalis

E CH Ovate clubshell mussel Pleurobema perovatum

T Price ’ s potato bean Apios priceana

E CH Southern clubshell mussel Pleurobema decisum

E CH Southern combshell mussel Pleurobema penita

Madison T Northern long

- eared bat Myotis septe ntrionalis

T Rabbitsfoot mussel Quadrula cylindri c a cylindrica

T Ringed map turtle Graptemys oculifera

Marion T /P CH Black pine snake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyr inchus desotoi

T Louisiana black bear Ursus americanus luteolus

C Pearl darter Percina aurora (Pearl River System)

T Ringed map turtle Graptemys oculifera

Marshall E Indiana bat Myotis sodalis

T Northern long

- eared bat Myotis septentrional is

Monroe TCH Alabama moccasinshell Medionidus acutissimus

E CH Black clubshell mussel Pleurobema curtum

E CH Heavy pigtoe mussel Pleurobema taitianum

T Inflated heelsplitter mussel Potamilus inflatus

E Mitchell ’ s satyr butterfly Neonympha mitchell ii mitchellii

T Northern long

- eared bat Myotis septentrionalis

TCH Orange

- nacre mucket Lampsilis perovalis

E CH Ovate clubshell mussel Pleurobema perovatum

T Price ’ s potato bean Apios pric e ana

E CH Southern clubshell mussel Pleurobema decisum

ECH S outhern combshell mussel Epioblasma penita

PT White fringeless orchid Platanthera integrilabia

Montgomery T Northern long

- eared bat Myotis septentrionalis

Neshoba T Northern long

- eared bat Myotis septentrionalis

T Ringed map turtle Grapt emys oculifera

Newton T Northern long

- eared bat Myotis septentrionalis

E Red

- cockaded woodpecker Picoides borealis

Noxubee T Alabama moccasinshell Medionidus acutissimus

T Inflated heelsplitter mussel Potamilus inflatus

T Northern long

- eared bat Myotis septentrionalis

T Orange

- nacre mucket mussel Lampsilis perovalis

T Price ’ s potato bean Apios priceana

E Red

- cockaded woodpecker Picoides borealis

E Southern clubshell mussel Pleurobema decisum

### 7 Oktibbeha T Northern long

- eared b at Myotis septentrionalis

T Price ’ s potato bean Apios priceana

E Red

- cockaded woodpecker Picoides borealis

Panola T Northern long

- eared bat Myotis septentrionalis

Pearl River T Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Inflated heelsplitter mussel Potamilus inflatus

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Perc ina aurora (Pearl River System)

E Red

- cockaded woodpecker Picoides borealis

T Ringed map turtle Graptemys oculifera

Perry T/P CH Black pine snake Pituophis melanoleucus lodingi

ECH Dusky gopher frog Rana sevosa

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red

- cockaded woodpecker Picoides b orealis

T Yellow

- blotched map turtle Graptemys favimaculata

Pike TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

T Ringed map turtle Graptemys oculifera

Pontotoc T Northern long

- e ared bat Myotis septentrionalis

T Price ’ s potato bean Apios pric e ana

Prentiss E Indiana bat Myotis sodalis

E Mitchell ’ s satyr butterfly Neonympha mitchellii mitchellii

T Northern long

- eared bat Myotis septentrionalis

T Price ’ s potato bean Apios pric e ana

PT White fringeless orchid Platanthera integrilabia

Quitman T Northern long

- eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

Rankin TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T North ern long

- eared bat Myotis septentrionalis

T Ringed map turtle Graptemys oculifera

Scott T Northern long

- eared bat Myotis septentrionalis

C Pearl darter Percina aurora (Pearl River System)

E Red

- cockaded woodpecker Picoides borealis

T Ringed map turtle Graptemys oculifera

### 8 Sharkey T Louisiana black bear Ursus a mericanus luteolus

T Northern long

- eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

E Sheepnose mussel Plethobasus cyphyus

Simpson TCH Gul f sturgeon Acipenser oxyrinchus desotoi

C Pearl darter Percina aurora (P earl River System)

T Ringed map turtle Graptemys oculifera

Smith T Gopher tortoise Gopherus polyphemus

E Red

- cockaded woodpecker Picoides borealis

T Yellow

- bl otched map turtle Graptemys flavimaculata

Stone T/P CH Black pine snake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

E Red

- co ckaded woodpecker Picoides borealis

Sunflower T Louisiana black bear Ursus americanus luteolus

T Northern long

- eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

T CH Rabbitsfoot mussel Quadrula cylindrica cylindric a

E Sheepnose mussel Plethobasus cyphyus

Tallahatchie T Northern long

- eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

Tate T Northern long

- eared bat Myotis septentrionalis

Tippah E Indiana bat Myotis sodalis

T Norther n long

- eared bat Myotis septentrionalis

Tishomingo ECH Cumberlandian combshell Epioblasma brevidens

E Gray bat Myotis grisescens

E Indiana bat Myotis sodalis

E Mitchell ’ s satyr butterfly Neonympha mitchellii mitchellii

T Northern long

- eare d bat Myotis septentrionalis

T CH Rabbitsfoot mussel Quadrula cylindrica cylindrica

E CH Slabside p earlymussel Lexingonia dolabelloides

T Snail darter Percina tanasi

E Snuffbox mussel Epioblasma triquetra

PT White fringeles s orchid Platanthera integrilabia

Tunica E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Northern long

- eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Linder a melissifolia

Union T Northern long

- eared bat Myotis septentrionalis

T Price ’ s potato bean Apios pric e ana

### 9 Walthall T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursu s americanus luteolus

Warren E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus a meric an us luteolus

T Northern long

- eared bat Myotis septentrionalis

E Pallid sturgeon S caphirhynchus albus

E Pondberry Lindera melissifolia

T CH Rabbitsfoot mussel Quadrula cylindrica cylindrica

Washington E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus ameri canus luteolus

T Northern long

- eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

E Sheepnose mussel Plethobasus cyphyus

Wayne T/P CH Black pine snake Pituophis melanoleuc us lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River S ystem)

E Red

- cockaded woodpecker Picoides borealis

T Yellow

- blotched map turtle Graptemys flavimaculata

Webster T Northern long

- eared bat Myotis septentrionalis

Wilkinson E Fat p ocketbook mussel Potamilus capax

E Least tern (interior) Stern a antillarum

T Louisiana black bear Ursus a mericanus luteolus

E Pallid sturgeon Scaphirhynchus albus

E Red

- cockaded woodpecker Picoides borealis

Winston T Northern long

- eared bat Myotis septentrionalis

E Red

- cockaded woodpecker Picoi des borealis

Yalobusha T Northern long

- eared bat Myotis septentrionalis

Yazoo T Louisiana black bear Ursus a mericanus luteolus

T Northern long

- eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

T Rabbitsfoot mussel Quadrula cylindrica cylindrical

END