### 1 Section 18 Application

– sulfoxaflor (Transform TM )

Louisiana Cotton Submitted by the Louisiana Dept. of Agriculture and Forest r y Baton Rouge, LA

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

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

Bobby Simoneaux, Assistant Director Louisiana Dept. of Agriculture and Forestry Agricultural & Environme ntal Sciences

- Pesticide & Environmental Programs

P.O. Box 3596 Baton Rouge, LA 70821

- 3596

Phone: 225

- 925

- 3763

Fax: 225

- 925

- 3760 Email: bobby_s@ldaf. state. la.us

David Fields, Assistant Director Louisiana Dept. of Agriculture and Forestry Agricultural & Environmental Sciences

- Pesticide & Environmental Programs

P.O. Box 3596 Baton Rouge, LA 70821

- 3596

Phone: 225

- 925

- 3763

Fax: 225

- 925

- 3760 Email: david_f@ldaf.state.la.us

(ii) University contact :

B. Rogers Leonard

, Professor of Entomology and

J. Ham ilton Regents Chair in Cotton Production Northeast Region

- Department of Entomology 212A Macon Ridge Rd. Winnsboro, LA 71295

- 5719

Off: 318

- 435

-

2157

Cell: 318

- 334

- 0147

Email: rleonard@agcenter.lsu.edu

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

(i) For a federally registered pesticide product:

### 2

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

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

(ii) For any other pesticide products:

Transform WG (EPA Reg. No. 62 719

- xxx) Active ingredient

– Sulfoxaflor (50%) Manufactured by Dow AgroSciences

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

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

sulfoxaflor.

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

The pro posed label is included as an attachment as Appendix LABEL. See

attached.

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

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

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

, Lygus lineolaris (Palisot de Beauvois). Historically, cotton has been produced in the parishes of Avoyelles, Bienville, Bossier, Ca ddo, Caldwell, Catahoula, Concordia, DeSoto, East Carroll, Evangeline, Franklin, Grant, LaSalle, Madison, Morehouse Natchitoches, Ouachita, Pointe Coupee, Rapides, Red River, Richland, St. Landry, Tensas, Union, Webster, West Carroll, West Feliciana (2000 Crop Profile for Cotton in Louisiana; http://www.ipmcenters.org/cropprofiles/docs/LAcotton.html.)

(ii) The method of application:

Foliar applied by air and ground

.

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

1.5

- 2.75 oz pr oduct/acre (0.047

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

.

(iv) The maximum number of applications:

Four applications per acre per year.

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

### 3

Louisiana planted a pproximately 255,000 acres of cotton during 2010. ( http://www.cotton.org/econ/cropinfo/varieties/midsouth.cfmacross ) . Louisiana producers treated ≈80% (20 4,000 acres) of the total planted acreage for the control

of tarnished plant bug

, Lygus lineolaris (Palisot de Beauvois) during 201 0 (data in press). During 2009, Louisiana treated 195,000 (85%) of the 230,000 planted cotton

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

- losses/data/). Cotton a creage in Louisiana is projected to increase during 2011 ≈20% above that in 2010 for a total planted acreage of 306,000 acres. During 2011, L ouisiana has the potential need to treat 70% (≈230,000) of its acreage with sulfoxaflor for control of tarnished plant bug. Th is

assessment is based on conservative esti mates of the 2011 acreage increases

and 2009

- 2010 historical treated acres for tarnished plant bug control in

Louisiana.

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

T arnished plant bug

, Lygus li neolaris (Palisot de Beauvois)

, infestations are likely

to caus e economic losses o n approximately 230,000 acres in Louisiana during 2011. Therefore up to four applications of sulfoxaflor will be required on these

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

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

- 2.75 oz of formulated product per acre per applica tion )

, treated (total sprayed) acreage will require no more than 1 22

, 1 88 pounds of formulated product on Louisiana‟s 230,000 acres.

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

All app licable restrictions and requirements will appear on the package label and

Section 18 label:

Pre

- harvest Interval: Do not apply within 14 d of harvest. Minimum Treatment Interval: Do not make applications less than 5 d apart. Do not make more than one app lication on pre

- bloom cotton. Do not make more than four applications per acre per season. Do not make more than two consecutive applications per crop. Do not apply more than a total of 8.5 oz of Transform WG (0.266 lb AI of sulfoxaflor) per acre per year.

(viii) The duration of the proposed use :

June

– September of the 2011 cotton growing season

(ix) Earliest possible harvest dates:

August 15, 2011

### 4

(4) Alternative methods of control. The application shall contain: (i) A detailed explanation of why th e pesticide(s) currently registered for the particular use proposed in the application is not available in adequate supplies and/or effective to the degree needed to control the emergency. If the applicant states that an available registered pesticide is i

neffective for the given situation, the statement must be supported by field data which demonstrate ineffectiveness of registered pesticides, or, if such data are unavailable, statements by qualified agricultural experts, extension personnel, university

pe rsonnel or other persons similarly qualified in the field of pest control;

Several IPM strategies are recommended for controlling tarnished plant bug in

cotton. Non

- chemical tactics include a rea

- wide control of non

- crop alternate hosts and selected host p lant resistance traits . These only serve to suppress populations and are not effective as stand

- alone practices

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

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

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

Even though acephate expressed partial efficacy against tarnished plant bugs in

Louisiana , higher rates (0.5 to 1.25 lb AI/acre) were necessary each year from

2007

- 2009 to maintain the infestations below the action threshold. The highest rate actually exceeded the labeled rate that could be used. These field efficacy results are supported by laboratory data from Snodgrass which show significant levels of OP resistance in tarnished plant bug populations throughout the hills

### 5

and de lta in Arkansas, Louisiana, and Mississippi

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

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

. ( Snodgrass 2010 abstract

, See Appendix A ).

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

sub

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

- season insecticide screen was used to evaluate a list of products for control of tarnished plant bug. Six sprays were applied to the Louisiana trial which was designed to simulate moderate to high pest infestati on levels, typical of the situation in many Louisiana and M id

- South cotton fields (Figure 1

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

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

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

with a n asterisk (*) illustrate that six applications of those treatments exceeded the total allowable seasonal AI/acre. Only Vydate and Intruder AI‟s were not

exceeded. Yield losses have become severe in these situations in spite of multiple insecticide sprays. Currently, the only chemical strategy recommended

is to co

- apply two insecticides and rotate among chemical classes.

In some areas across Louisiana and the Mid

- South region , tarnished plant bug

infestatio ns have reached outbreak levels and become uncontrollable. In

### 6

Mississippi during 2007, producers averaged approximately 7

- 10 insecticide applications for this pest (Catchot 2007). The highest insecticide application frequency in Mississippi prior to 2007 w as 5.2 sprays per year and occurred during 2004 in that state. Louisiana ‟s producers averaged 3.9 applications during 2007 (Williams 2008) for this pest, but some areas received 6

- 9 treatments.
Current trends with insecticide resistance and lack of effe ctive alternative technologies will allow problems with tarnished plant bug management to intensify across Louisiana and the Mid

- South states. Chemical control options that provide consistent efficacy are not available to manage this pest. Effective Lygus control is a serious, unmet need for Mid

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

situation.

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

- susceptible and

- resistant populations of tarnished plant bug

, thereby improving the overall cotton IPM system . This would be a tremendous econo mic opportunity for cotton

growers , and more environmentally

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

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

reduce the frequency of selected insecticides use , es pecially acephate,

dicr otophos, and oxam yl. The ecological and toxicological profile of sulfoxaflor is considered to be more favorable than the ecological and toxicological profiles of

these insecticides. Limited d ata currently suggest that sulfoxaflor is not likely to flare ap hids and mites.

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

Several IPM strategies are recommended for controlling tarnished plant bug in

cotton (Gore et al. 2008 )

. Non

- chemical tactics include a rea

- wide control of non

crop alternate hosts and selected host plant resistance traits . Proper selection of varieties and managing the optimum planting period are being to produce a rap id fruiting and early maturing crop; thereby reducing the time the crop is su s ce p tibl e to this pest. Careful insecticide application timing based upon revised spray action thresholds are used to precisely target populations before they reach

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

- alone practices

. Effective chemical

### 7

control practices are still necessa ry to provide tarnished plant bug management

in cotton.

(5) Effectiveness of proposed use.

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

.

Sulfoxaflor ( DAS test code GF

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

in the order H e teroptera . Insects in the genus Lygus are included this 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 m odes of action. T he effectiveness of sulfoxaflor against insecticide

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

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

Numerous field trials were performed during 2008

- 2010 across the Mid

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

- 2010

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

a co

- application trial with a pyrethroid

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

- treatment

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

the Louisiana results.

A multi

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

- 20 1 0 is reported in Appendix F . These results demonstrated sulfoxaflor at one or more rates demonstrated control of plant bugs (high population levels) superior to the OP, dicrotophos. The residual efficacy of sulfoxaflor was greater than that for both dicrotophos and thiamethoxam. Efficacy was similar to a co

- application of a pyrethroid + neonicotinoid. In a comparison of cotton yields among treatments for

these trials, sulfoxaflor was similar to that of acephate (Acephate is broad er

### 8

spectrum and may have provided some yield increase from additional caterpillar pest control). Pest management practitioners recognize that sulfoxaflor should not be used as a single , season

- long treatment, so chemical control strategies

with co

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

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

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

treatments (without sulfoxaflor) would have re quired additional applications to reduce populations. In the season

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

- treated and non

- treated plots. Willrich et al. (2010, see Appendix G ) further summ arized results for 2008

- 2009 as an abstract and reported sulfoxaflor ‟s acute toxicity for knockdown of tarnished plant bug infestations at ≤ 5 d and residual control extending for ≥ 7 d. In addition, cotton treated with sulfoxaflor produced lint yield s eq ual to or superior than cotton treated with acephate (1.0 lb AI/acre) across 16 trials.

All available data indicates that s ulfoxaflor is an alternative product to the insecticides currently used to manage tarnished plant bug on cotton. It will be an excel lent tool for Louisiana and Mid

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

insect icide

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

(6) Discus sion of residues for food uses. If the proposed use is expected to result in residues of the pesticide in or on food, the application shall list the food likely to contain

such residues and shall contain an estimate of the maximum amount of the residue lik ely to result from the proposed use, together with the information on which such estimates

are based.

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

accordance with the Section 18 label directions will not exceed a residue in c otton of 0.17 ppm (Proposed MRL 0.20 ppm; 0.0015 ppm for cotton

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

(7) Discussion of risk information.

The sulfoxaflor registration application submitted to EPA July 31, 20 10 by Dow AgroSciences ha s address ed the potential risks to human health, endangered or threatened species, beneficial organisms, and the environment expected to result from the proposed use, together with references to data and other supporting

informatio n.

Studies done with sulfoxaflor indicate there is no reason to expect that any increased risk from this use on cotton would occur either to beneficial organisms or to the environment compared with the current regimen of insecticides used on

### 9

cotton today. The products that sulfoxaflor would replace are acephate and dicrotophos among others. Sulfoxaflor has a softer profile on beneficial organisms and endangered species than the insecticides it will replace.

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

- level residues, 100% crop treated) and a refined chronic dietary exposure assessment (i.e., average residues from field trials with processing factors, or as estimated for meat, milk, poultry and eggs) demonstr ate dietary (food + water) exposures that are below the aPAD and cPAD, respectively, for all subpopulations. Thus, this dietary exposure assessment demonstrates a reasonable certainty of no harm associated with the proposed use of sulfoxaflor.

Sulfoxaflor exhibits low acute mammalian toxicity (EPA Toxicity Categories III

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

effects of limited concern o r no relevance to humans. Acute bolus doses caused transient signs of cholinergic toxicity, but neurotoxicity did not occur at high doses in a dietary subchronic study, or in a developmental neurotoxicity study. Reproduction and developmental studies ident ified a marginal delay in puberty onset in males with no apparent sequelae. Peri

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

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

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

Endangered Species

A list of the endangered species present in thi s application was obtained from the

US Fish and Wildlife Service website and provided by the registrant (see

attachment

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

Beneficial Organisms

The acute and long

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

sulfoxaflor inclu de midge larvae, Chironomus species (sediment

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

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

- term, early

- life

- stage

### 10

toxicity tests in the freshwater fish fa thead minnow and the saltwater fish sheepshead minnow, slight effects on reproduction at a high concentration of 100 mg/L in a life

- cycle test on Daphnia magna, and effects on time to first brood in mysid shrimp in a life cycle study. Sulfoxaflor may be co nsidered by US EPA standards to be „slightly‟ to „moderately‟ toxic to birds in acute oral toxicity studies. Sulfoxaflor did not exhibit any effects on reproduction in birds. Sulfoxaflor exhibited acute toxicity to honey bees in the direct contact toxicity test. However, aged residue toxicity tests in which honey bees were exposed to

field

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

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

Resulting Environment F rom U se

Louisiana‟s farmscape should experience a reduction in the numerous insecticide applications used to control tarnished plant b ug. This reduction will be even more important considering that many of those replaced applications will be for organophosphate s and/or carbamates. The availability of sulfoxaflor on cotton will directly reduce alternative sprays for the target pest, but also indirectly reduc e probability of flaring secondary pests. This can further reduce the number of total sprays (all products) on cotton.

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

The following state agen cies have been contacted :

Louisiana Department of Agriculture and Forestry

(9) Acknowledgment by registrant. The application shall contain a statement by the registrants of all pesticide products proposed for use acknowledging that a request has

been m ade to the Agency for use of the pesticide under this section. This acknowledgment shall include a statement of support for the requested use, including the expected availability of adequate quantities of the requested product under the use scenario propos ed by the applicant(s); and the status of the registration in regard to the requested use including appropriate petition numbers, or of the registrant's intentions regarding the registration of the use.

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

Dow AgroSciences has submitted sulfoxaflor for a Section 3 registration on July 31, 2010, including use on cotton. A com plete residue package has been submitted to EPA for cotton on July 31, 2010. In addition, sulfoxaflor is part of a

### 11

Global Joint Review with two other countries, Canada and Australia. Estimated time for a full Section 3 registration in the US is January 1, 2012.

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

(Currently N/A

- sulfoxaflor is not yet registered in US)

Provisions provided under the Section 18 Emergency Exemption

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

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

.

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

emergency:

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

Lygus lineolaris (Palisot de Beauvois) , tarnished plant bug

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

Prior to the mid

- 1990‟s , tarnished plant bugs were generally 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

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

2008 ) and the eradication of the boll weevil, Anthonomus grandis grandis Boheman (Coleoptera: Curculionidae), many of the foliar applications for other pests during flowering have been 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 th ese Southern production system change s is that tarnished plant bug ha s beco me the dominant season

- long pest across this

### 12

region d uring the last decade

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

. Typically, f ewer 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 an d Gore (2007) has reported resistan c e 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. In

additi on, 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 highest dose labeled for a single application. Tarnished plant bug management in many Mid

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

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

- South cotton.

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

See above discussion. Sulfoxaflor is expected to replace significant quantities of

al ternative products that are used at higher rates and represent greater risk to the environment and beneficial organisms.

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

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

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

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

- South was

at least three

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

### 13

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

. ) in each cotton producing state during 2007.

Tarnished plant bug is a pest that is not a restricted problem on local acreage. During the past 5 years, this pest infested an average of 87.8% of the planted acreage in Louisiana (Table 1) . Direct losses from this pest in Louisiana indicate

a 2.2

- >7.5 % yield loss in spite of spending an average of >$10 mill/year for control. This should be considered a conservative estimate because currently there is no alternative strategy which can be used to eliminate crop dama ge and cotton yield losses from tarnished plant bug. Based on L ouisiana‟s 2009 historical insect losses and yield data, producers spent $5.8MM with an estimated yield loss of $4.1MM. Th ese data are outlined in the chart/Excel file below and published on the website: http://www.entomology.msstate.edu/resources/tips/ cotton

- losses/

data/. Estimates for the 2010 season are not yet complete and the impact of tarnished plant bug will be sligh tly less, but within the range of costs and losses observed during the past 5 years.

### 14

### 15

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

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

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

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

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

The absence of new products to manage tarnished plant bug has seriously impaired the econom ic viability of cotton across Louisiana and the rest of the Mid

South region. Use of the available products in the recommended chemical control strategy is not economically feasible, sustainable, or environmentally friendly. During the anticipated conditi onal Section 18 registration period (2011)

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

References used to support previous statements and Section 18 request :

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

, See Appendix C ).

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

. http://www.msucares.com /newsletters/pests

/cis/index.html.

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

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

C opes, J. T., G. L. Snodgrass, J. Sharp, B. R. Leonard, D. R. Ring, and D. Blouin. 2010. Acephate resistance is widespread in Louisiana tarnished plant bug

pop ulations. La. Agric. 53: 14

- 15.

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

### 16

Lorenz, G, T. Barber, S. D. Stewart, A. Catchot, J. Gore and D. Cook. 2009. Evolving pest management in cotton. Proc. Beltwide Cott on 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. Price, J. T. Copes, J. W. Sharpe, E. Burris and K. A. Fontenot. 2010. Proc. Beltwide Cotton Conf. 817

- 819.

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

T. Hardke

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

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

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

. http://www.entsoc.org/

Protected/AMT/ members only /AMT35/F/F27.pdf.

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

. Proceedings, Cotton Incorpo rated Seminar

, Memphis, TN (November 9

- 11, 2010)

See Appendix A

.

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.

Snodg rass, G. L., C. A. Abel, R. E. Jackson, and J. Gore. 2008. A Bioassay for Determining Resistance Levels in Tarnished Plant Bug Populations to Neonicotinoid Insecticides. Southwestern Entomologist 33: 173

- 180.

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

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

Willrich

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

- South cotton, pp. 1204.

. In

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

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

, and J. D. Thomas. 2010.



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

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

, See Appendix C ).