EMERGENCY EXEMPTION REQUEST (Specific Exemption}

FOR THE USE OF FireWall SOWP Fungicide/Bactericide (streptomycin sulfate}

TO MANAGE Citrus Canker 

### (Xanthomonasaxonopodispv. citn)

ON Grapefruit

IN FLORIDA

December 18, 2014

1TABLE OF CONTENTS CONTACT PERSONCS) AND QUALIFIED EXPERTS 

### (166.20(al<1ll
....... .. .... . ......3 DESCRIPTION OF PESTICIDE REQUESTED 

### (166.20(a)(2))

.. ........ .. .......... .. ......3 DESCRIPTION OF PROPOSED USE 

### (166.20(a)(3ll

....... ........... .. ............ ..... .. . .. .4 ALTERNATIVE METHODS OF CONTROL 

### (166.20(alC4))
......................... ...........6 EFFICACY OF USE PROPOSED UNDER SECTION 

### 18 (166.20Cal<5))

.. ....... ...... .. 9 DISCUSSION OF RESIDUES IN FOOD 

### (166.20(a)(6))
.................... ................ 10 DISCUSSION OF RISK INFORMATION 

### (166.20(a)(7))

.. .................. .. ............. 10 FQPA INFORMATION (OCTOBER 

### 24, 1996 EPA LETTER).............................. ... 11 COORDINATION WITH OTHERAFFECTED FEDERAL, STATE, AND LOCAL AGENCIES 

### (166.20Ca)(8)
................ .......... ........... ........ ................... ... ..... .. ....... 12 NOTIFICATION OF REGISTRANT 

### {166.20(a)(9)).............................. .............. 12 DESCRIPTION OF ENFORCEMENT PROGRAM 

### (166.20(a)(10l)...................... 12 REPEAT USES 

### C166.20(al(11)) ...................................................................... . . 12 PROGRESS TOWARD REGISTRATION 

### (166.20(b)l2)(iil)............................ ... 12 NAME OF PEST 

### (166.20(b)(1))
........................................................................ 13 DISSUCION OF ECONOMIC LOSS 

### (166.20{b)(4))........................................ . .. 

### 16 ESTIMATED REVENUES FOR THE SITE TO BE TREATED (166.20(8)(4) ii 

### 8t iii) ········ ···· ······· ····· ················ ··································· ····· ····-··· 23

2CONTACT PERSONCSl AND QUALIFIED EXPERTS(Sl C166.20(al(l)) (i) The Contact Person for matters relating to the administration ofthis exemption : Michael J
. Aerts Florida F ruit 

### &Vegetable Association 800 Trafalgar Ct.; Suite 200 Post Office Box 948153 Maitland, FL 32794-8153 Phone: (321) 214-5200 Fax: (321) 214-0210 mike.aerts@ffva.com Charlie Clark, Environmental Admin

. FL Dept. ofAg and Consumer Services Pesticide Registration Section 3125 Conner Blvd. (Bldg. 6) Tallahassee, FL 32399-1650 Phone: (850) 617-7940 Fax: (850) 617-7949 charlie.clark@freshfromflorida.com (ii) The contact people for matters relating to the technical aspects ofthis exemption: For Florida, it has been agreed that questions relating to technical aspects in the field for this emergency exemption petition will work through the Florida Department ofAgriculture and Consumer Services and the Emergency Response Team within EPA's OPP.
DESCRIPTION OF PESTICIDE REQUESTED (166.20(al(2))
a. Common Chemical Name (Active Ingredient): Streptomycin Sulfate Trade Name and EPA Registration Number: FireWaiiSOWP Fungicide/Bactericide EPA Registration Number: 80990-4 Formulation: Wettable Powder Percent Active Ingredient: 65

.8°/o (equivalent to 50% streptomycin) 

### Manufacturer: AgroSource, Inc.
3b. Additional labeling: see Appendix Afor a proposed Section 18 label. DESCRIPTION OF PROPOSED USE 

### C166.20(a)(3)) (i) Sites to be Treated: Grapefruit (statewide)

. According to the lates t figures available from the USDA National Agricultural Statistics Service, for the 2012-13 season there were atotal of approximately 47,656 acres of grapefruit growing in Florida (44,900 bearing acres and 2,756 non-bearing acres). Putting this figure into perspective, prior to the discovery of citrus canker in Florida and the subsequent eradication program thatfollowed, a total of nearly 140,000 acres of grapefruit were grown in Florida. Grapefruit acreage statewide would be eligible for this fungicide/bactericide treatment, although much of the usage would occur in the commercial grapefruit producing counties such as Polk, Hendry, Highlands, De Soto, Hardee, St. Lucie, Indian River, Collier, Manatee and Martin Counties

. See Appendix Cfor Florida counties and acreages in grapefruit. (ii) Method ofAPplication: Ground application only. (iii) Rates ofApplication (in terms ofa.i. and product): 0.344 pounds of active ingredient per acre per application 0

.6875 pounds offormulated FireWall 50WP Fungicide/Bactericide per acre per application Maximum Number ofApplications: A maximum of 2 applications per crop can be made, totaling no more than 1.375 pounds of formulated product (0.6&f lbs.

**~(.**
**) per**  **~** .....

. · , (iv) Total Acreage (orother units) to be Treated: During 2012-13, approximately 47,656 acres of grapefruit were grown in Florida

.

4

### (v) Total Amount of Pesticide to be Used Cin terms ofa.i. and product): In an absolute worst-case scenario, 192,764 pounds of FireWall 50WP Fungicide/Bactericide, or 43,179 pounds ofstreptomycin sulfate, would be needed. (47,656 acres X 1.375 pounds= 65,527 pounds FireWall 50WP Fungicide/Bactericide; 47,656 acres X0.6875 lbs. a.i. = 32,763 lbs. a.i. streptomycin)

. While these amounts of product may be needed under a worst case scenario, it is highly probablethat considerably less than all ofthe eligible acreage will be treated, and a portion of that acreage will not receive the full 1.375 pounds of FireWall per acre per season rate

. 

### (vi) Use Season (period oftime forwhich use ofchemical is requested): Access would be needed by April 1, 2015 at the very latest. Availability subsequent to the date ofapproval is again requested and crucial over the ensuing 12 months, especially when considering the continued grapefruit tree losses due to citrus canker and also to citrus greening disease. 

### (vii) Additional Restrictions, User Precautions and Requirements, Qualifications ofApplicators, etc. : Products will be applied in accordance with the proposed Section 

### 18 label and all applicable provisions of the Section 

### 3 registered label. E xamples of various restrictions, requirements and qualifications include but are not limited to: • A total of two (2) applications of FireWall 

## SuWP

**Fungieid~/Bactericide** may be made at approximately 21 day interv

**~,. .**  Use will be during the summer when the risk of phytoxicity from alternate products is highest and/or when ·risk of wind-blown rains and associated inoculum redistribution isgreater. • Do not apply within 60 days of harvest. • Worker re-entry into treated areas during the restricted entry

**int~n13!** of 

### 12 hours is not allowed

. Personal protective equipment for applh:ntn•s and handlers includes: • Long-sleeved shirt; • L ong pants; • Chemical-resistant gloves made of any waterproof materia:; • Shoes plus socks; and, • MSHA /NIOSH approved dust /mist respirator with any 

### R, P0 r

**~E** filter

.



### 5• Personal Protective Equipment 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 over long-sleeved shirt and long pants; • Chemical-resistant gloves, made of any waterproof material; and, • Shoes plus socks. • For this proposed Emergency Exemption, applications through any type of irrigation system (i.e., chemigation) are prohibited. • Do not apply more than 

### 1.375 pounds offormulated FireWall SOWP Fungicide/Bactericide 

### (0.6875 lbs. a.i.) per acre per season. • Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean watermark. • Do not contaminate water when disposing of equipment wash water or rinsate or disposal of waste. • The FireWall label contains a CAUTION statement of hazard and this product is considered to be a "General Use" pesticide. As a nonrestricted pesticide, farmers without private applicator certification, farmers with private applicator certification, and, licensed commercial applicators, are allowed to apply FireWall. Other specific use directions to be followed are found on the proposed Section 18 label and the Section 3 label found in Appendix A. ALTERNATIVE METHODS OF CONTROL C166.20(a){4) ): (i) Detailed Explanation ofWhy Currently Registered Pesticides Are NotAvailable in Adequate Supply and/or Are Not Effective to Control the Emergency: No EPA-registered bactericides exist for citrus canker management other than copper. Multiple disadvantages ofseason-long, long-term use of copper bactericides for citrus canker control have been documented including fruit phytotoxicity when applying copper in hot weather, ind•- •ction of copper-resistance in Xanthomonas axonopodispv. citri(Xac) popvlr.ltit•ns, and accumulation of copper in citrus soils with potential phytotoxic and adverse environmental effects

. A risk of season-long application of copper fungicides to grapefruit, especially during/after hot, dry periods, is phytotoxicity to the fruit rind, which is what has now created this non-routine emergency situation. Copper phytotoxicity results when a "burn" causes rind tissues to

**dev~l0r** corky lesions, resulting in a blemish called "star melanose." On

**grape~r** uit, these blemishes make the fruit completely unacceptable for the fresh 6market, which is the market to which Florida grapefruit are initially grown. The production strategy for Florida grapefruit follows stringent requirements in order to make the crop available for the fresh market. A production strategy for a fresh market crop from the beginning ofthe season through to completion is significantly more intense, expensive and time consuming than for a crop destined for a processing market. In Florida on grapefruit, copper hydroxide and copper sulfate applied at 14- or 21-day intervals does in fact manage citrus canker on the fruit, but simultaneously the copper component causes considerable burning on the fruit rind when it's hot. Field studies have shown that alternation of streptomycin (FireWall) with a reduced rate of copper sulfate during warm periods ofthe summer provide similar reductions in diseased fruit with minimal copper burn compared to that ofthe full rate of copper alone. Burn reduction with a reduced rate ofcopper was similar to that seen by alternating copper with a strobilurin fungicide (Headline/pyraclostrobin; strobilurins do not have bactericidal properties, although they also are not phytotoxic to fruit ), wherein copper was applied at a 42-day interval. Thus, reducing the frequency or copper application rate during the high-risk period lowered risk ofcopper burn. In a 2006 trial, copper burn in July was preceded by below average rainfall from January to June leading to drought conditions by mid-summer. In subsequent trials in Ft. Pierce from 2007- 2009, copper burn occurred after recurring drought conditions that ended in June/early July of each season. The average ofthe peak incidence of copper burn rendering fruit unacceptable to the fresh market for the three seasons of experimentation was a full 24 percent. Based on the severity of copper burn, the percentage offruit that would be "out of grade" for packing is estimated at 75 percent, hence, the average reduction in packout strictly due to copper burn is estimated at 18 percent (24 X 0.75 = 18%}

. This figure is used to calculate reduced copper burn with the use of FireWall in the economic analysis. Alternative contact bactericides such as oxytetracycline are not as effective as copper for canker control because they lack sufficient activity to protect the fruit surface. In contrast, trials conducted in Parana State, Brazii fr0r11 2005-2007 substantiated that streptomycin in combination with

**red~,;cerl** rates of copper for canker control in young groves provides comparable disease control to the intermediate to full rates ofcopper, without

**th~** phytotoxicity problem. A specific trial to establish the efficacy of anc,tht!l

. registered "alternative", Regalia (extract of Reynoutria sachalinensis),

**·..v e~s**  conducted to determine its potential for citrus canker control in a FloridJ east coast grove. This same trial included three formulations of

**cop~·P.r** 

### widely used for citrus canker control, for comparative purposes
.
**Result~** showed that Regalia, applied at the label rate, was half as effective as tn€ copper treatments for reducing incidence of canker on citrus fruit (24.2%
7incidence) when compared to the untreated check treatment. See Appendix Bfor this Regalia trial summary. This same study also shows that 11 applications of Regalia (at the 1 gallon application rate), with an estimated $60/galjapplication, costs $660 per acre or approximately 8.5 times the cost of a copper formulation ($?/lb./application or $77 per acre). The estimated on-tree revenue for fresh market Red grapefruit with citrus canker was $1,156 in the 2010-11 crop season when this trial was conducted (Ron Muraro, UF-CREC Citrus Economist, unpublished analysis). Therefore, the cost of Regalia alone for canker control represents 57 percent ofthe on-tree profit, effectively/completely eliminating this product as a possible alternative whatsoever underthis emergency exemption request. (ii) Alternative Control Practices: Local or regional eradication may be practiced to establish and maintain areas free of citrus canker for the planting of new orchards with cultivars of low to moderate susceptibility (which grapefruit is not). In an attempt to prohibit the introduction ofthe disease, many citrus-growing areas restrict the importation of citrus from areas or countries known to have canker. New groves are established only in areas without history of citrus canker for at least one year after effective eradication is achieved

. The choice of planting site takes into account not only horticultural and climatic factors for cultivation of citrus, but minimizes environmental conditions favorable for the introduction ofXacand development of citrus canker. It is advised that sites exposed to strong winds be avoided because ofthe higher susceptibility created for the citrus trees, particularly in the early stages of development

. Compliance of orchard workers with measures for thorough disinfection of clothes, shoes, orchard machinery and harvesting equipment including boxes is also essential to maintain exclusion ofthe pathogen. Agreements have been issued statewide to citrus producers in Florida requiring decontamination of personnel and equipment to reduce the risk of spread of mechanical and inadvertent human distribution of Xac. This

**focuse~** attention on the situations of greatest risk for Xacsurvival and

**trans.ni~!--i0n**

**.** T

o determine the possibility ofsurvival and transmission of Xacon and from various surfaces, bacterial survival has been evaluated on various mat.:er:als including wood (representing crates, ladders, etc.), cotton cloth (clothir,y), cotton gloves, plastic (fruit crates), metal (vehicles, tractors, mower

**~lact~s,** etc.), leather (gloves and shoes), bird feathers and animal fur

. 

### Cultural practices including windbreaks and pruning or defoliation of diseased summer and autumn shoots are recognized throughout the ""oriJ as important measures for the management of citrus canker. Windbreaks 8are the most effective measure for the control of the disease on susceptible citrus cultivars

. Pruning ofthe citrus trees is performed during the dry season, when the environmental conditions are less favorable for spread of the bacterium from pruned to adjacent non-infected trees. However, pruning is very labor intensive and therefore expensive. In summary, alternative control practices are ineffective or insufficient for management of this disease. Most cultural control methods will have little effect on a pathogen that has already been identified across all ofthe grapefruit/citrus producing acreage of Florida. EFFECTIVENESS OF USE PROPOSED UNDER SECTION 18 (166.20(a)(S)) (166.20CalCS)) According to University of Florida Citrus Disease Management Specialists at the Citrus Research and Education Center, FireWall SOWP Fungicide/Bactericide (streptomycin) presents itself as the most effective chemical management tactic available to do away with the non-routine situation that has now arisen with respect to unacceptable levels of fruit phytotoxicity. In consideration ofthe risk ofcopper burn, Fir eWall applications made in 2008 and 2009 trials were timed during the July-August period when the risk of copper burn is the highest. In the 2008 trial, with highly favorable conditions for canker development before and afterTropical Storm Fay, the best treatment for reduction in total fruit disease incidence was two sprays of FireWall combined with a half rate of Kocide 3000. The reduction in total fruit disease incidence was 11.2 percent compared to the Kocide 3000 at the 2.0 lb/acre rate. Researchers attribute this 'best treatment" control to post-infection activity of FireWall against bacteria that overcame the surface film of copper by windblown rain mediated penetration of stomatal openings on the fruit surface at speed greater 18 mph (which prevailed for several hours during TS Fay). This control effect demonstrates that streptomycin is locally systemic in the fruit rind but that copper is not penetrating into the fruit rind. Local systemic activity of FireWall was confirmed in separate assays by measuring post-infection reduction in Xaclesions of populations in leaves and fruit. The additional control effect of FireWall combined with a half-rate of Kocide 3000 compared to Kocide was 0.8 percent in 2009, a season without a substantial occurrence of windblown rain events

. The average additional control t!fff'rt. of the FireWall combined with half-rate of Kocide 3000 for the 2008 and 2009 is 6.0 percent, the figure that is used to calculate increase in canker free fruit for pack-out resulting from FireWall use in the economic analysis presented later in this

**narrati"~.** This added improvement to citrus canker control b y FireWall was accomplished

**wi~hout** the reoccurring problem of excessive, unacceptable phytotoxicity to the fruit as well. Additional data and information describing the effectiveness of FireWall Fungicide/Bactericide is included in Appendix B.

9Concerns may arise pertaining to susceptibility ofXacto streptomycin. Prior to this Emergency Exemption request, streptomycin had not been used whatsoever in commercial citrus groves and the development ofXacstrains resistant to this antibiotic in the field has not been reported

. Further experimentation on this very topic has been conducted by University of Florida scientists, and this study has shown that even after three full seasons of 21-day interval streptomycin sprays (approximately 10 sprays per season), establishment of streptomycin resistant Xacin endemic areas is not as prone to occur as may have originally been presumed. Thus, since the intent is to use streptomycin. only twice in the season to aid with management of citrus canker, it is unlikely that streptomycin resistant strains will develop in Xacpopulations under disease management programs with only a few streptomycin intercalated or mixed with copper applications for management of citrus canker. Integrating streptomycin into the copperbased program would also possibly reduce the bacteria's selection pressure for copper as well. The use of streptomycin mixed with copper may aid in management of copper and streptomycin resistance to assure sustainability of both products for canker management in Florida grapefruit. Refer to the resistance analysis study included in Appendix Bfor further information and accreditation on this matter. 

### DISCUSSION OF RESIDUES IN FOOD 

### (166.20CalC6ll (166.20CalC6ll AgroSource, Inc. and the IR-4 Project have performing Magnitude of Residue studies for streptomycin sulfate in/on grapefruit. Field residue studies have been conducted and this information is being prepared for submission to the Agency. Based on available information, a temporary streptomycin tolerance of 0.2 ppm on grapefruit is proposed. For the dried pulp fraction, the proposed tolerance will be 1.0 ppm and for the oil and juice fractions the proposed tolerance is 0.005 ppm (50% ofthe LOQ). See the IR-4 letter of support and the summary ofthe residue data, and the corresponding risk assessment for streptomycin on grapefruit included in Appendix B. 

### DISCUSSION OF RISK INFORMATION 

### (166.20{a){7)l Descriotion of application sites, including proximity to residential areas, aquatic systems, endangered orthreatened species habitats, soil types, etc.: FireWall SOWP Fungicide /Bactericide will only be applied to commercial grapefruit groves. These groves are typical ofthose found in Florida. Commercial groves are intensive and no unreasonable risks to human health, endangered or threatened species, beneficial organisms, or the environment are expected from the proposed use ofthis product

.

10Possible risks posed by use: FireWall SOW Fungicide/Bactericide is an approved fungicide/bactericide registered by the U.S. Environmental Protection Agency that has been used in the field for more than 40 years
. Possible risks were evaluated during Section 3 registration and reregistration processes. It is currently registered for use on crops such as bean seed treatments, · celery, peppers, potatoes, tomatoes, apples and pears. No unreasonable adverse effects to man or the environment are anticipated with this proposed use of two applications of FireWall SOWP Fungicide/Bactericide to Florida grapefruit. Additional information on these subjects can be obtained from Taw Richardson from AgroSource. His phone number is (908) 215-3500. Facts pertaining to risk associated with the potential for incr easing the risk of human resistance to streptomycin have been addressed in the R.E.D. Facts publication for streptomycin and streptomycin sulfate. That EPA report says that "regarding the problem of drug resistance, EPA has no data indicating that streptomycin residues remaining in the food supply have a significant or even a measurable potential for increasing human resistance to that drug." The Regulatory Conclusion ofthat same publication says that "all currently registered pesticide products containing streptomycin or streptomycin sulf ate as the active ingredient are not likely to cause unreasonable adverse effects in people or the environment." EPA's Streptomycin R.E.D. Facts bulletin is included in Appendix B. Proposals to mitigate risks: Existing use restrictions already listed on the label will further reduce risk. These label restrictions include: do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high watermark; do not contaminate water when disposing of equipment wash water; only two applications of FireWall SOWP Fungicide/Bactericide are allowed per season; and, a prohibition for chemigation exists. Current labeling directives are sufficient to mitigate any potential risks. Full reports of tests and investigations made with respect to the safety of streptomycin, including all information pertaining to the methods and controls used in conducting these tests and investigations have been submitted and reviewed by the Agency.
FOPA INFORMATION {OCTOBER 24, 1996 EPA LEITER) EPA requested that additional information be submitted with Emergency Exemption requests to address new risk considerations associated with requirements of the Food Quality Protection Act. This information has been provided to the Agency. Since this product is approved for other Section 3 registrations (i.e., bean seed treatment, celery, peppers, potatoes, tomatoes, apples and pears) an initial FQPA review has already occurred.

11

### COORDINATION WITH OTHER AFFECTED FEDERAL, STATE, AND LOCAL AGENCIES C166.20CalC8)) As EPA's state lead agency, the Florida Department of Agriculture and Consumer Services should provide this information

. 

### NOTIFICATION OF REGISTRANT C166.20CalC9ll AgroSource, Inc. has been notified of this request. The company is supportive of this emergency exemption petition (see Appendix Bfor registrant support letter). 

### DESCRIPTION OF ENFORCEMENT PROGRAM C166.20CalC10U As EPA's state lead agency, the Florida Department ofAgriculture and Consumer Services should provide this informa tion

. 

### REPEAT USES (166.20Ca)C11U The specific emergency exemption for Firewall 50WP Fungicide/Bactericide has been approved previously. Streptomycin applications that occurred effectively prevented further, unacceptable progression of the citrus canker organism and inhibited rind phytotoxicity. During the last year in which this registration was in place, approximately 23,172 pounds of Firewall 50WP Fungicide/Bactericide (11,586 lbs. a.i.) was applied to just over 32,300 acres of F lorida grapefruit for management of citrus canker. Where the disease was problematic, application rates and numbers ofapplications varied somewhat between growers, with most producers making an average of 1 application of Firewall 50WP Fungicide/Bactericide at a rate of 0.6875 pounds of formulated product per acre per application. Where environmental conditions were conducive to citrus canker development, growers and university disease management specialists agree that Firewall 50WP Fungicide/Bactericide applications were very effective in preventing disease development while averting damage related to heat-induced phytotoxicity on the fruit. No other adverse effects were reported either.


### PROGRESS TOWARD REGISTRATION C166.25(blC2lCiill AgroSource, in conjunction with the IR-4 Project, continues to make progress toward new registrations for the use of streptomycin on grapefruit and a variety of other crops
. The company has prepared and submitted all the necessary documentation for a Section 3 registration for grapefruit. The application to amend the Section 

### 3 label for 

### FireWall has been submitted to EPA (Decision Number: 486863) and a Pesticide Registration Improvement E xtension Act (PRIA) due date of 05/04/2015 has been assigned. Further 12information regarding progress toward registration on grapefruit can be found within Appendix B.
NAME OF PEST 

### (166.20Cb)(1)) Scientific Name: Xanthomonas axonopodispv. Citri Common Name: Citrus Canker
DISCUSSION OF THE EMERGENCY CONDITION 

### (166.20(b)(2)) Background Citrus canker, caused by the bacterium Xanthomonas axonopodispv. citri(Xac) is a leaf, fruit, and stem blemishing disease that affects citrus. Grapefruit, Mexican lime and some early oranges are highly susceptible to canker; Navel, Pineapple and Hamlin oranges, as well as lemons and limes are moderately susceptible; mid-season oranges, Valencias, tangors, tangelos and other mandarin hybrids are less susceptible; and tangerines are basically tolerant. Increasing international travel and trade have rendered U.S. borders more porous and dramatically increased the risk of introductions of invasive plant pests into agricultural crops. The current USDA system for protecting agricultural industries has been overwhelmed and has sometimes failed to intercept a number of introductions of exotic/invasive pests, including plant pathogens such as citrus canker. Such introductions threaten crops and hinder national and international agricultural markets and trade. Currently in Florida, one such invasive species is Xac

. Citrus canker is an introduced plant disease, the eradication of which has received considerable press attention and legal challenges that has produced far-reaching political and socioeconomic impacts in Florida. Xacs leaf, stem and fruit-blemishing directly reduce fruit quality and quantity. Citrus canker has a long history in Florida. The disease was first found around 1912, spread throughout the southeastern U.S. on imported seedlings from Japan, and was declared eradicated from Florida and the adjacent states in 1933. Citrus canker was discovered again in Manatee County in 1986 and was declared eradicated in 1994. Then three years later the disease re-emerged in the same general area on the west coast of Florida where the 1980s outbreak had occurred. In the meantime, a new and separate infestation of citrus canker was discovered in urban Miami in 1995, with an estimated introduction some time in 1992 or 1993.

13When detected in Miami in 1995, the infected area was contained in approximately 14 square miles of largely residential properties southwest ofthe Miami International Airport. In response to this detection ofcitrus canker, a cooperative state/federal citrus canker eradication program (CCEP) was established between the Florida Department of Agriculture and Consumer Services (FDACS), the Division of Plant Industry (DPI) and the USDA Animal and P lant Health Inspection Service (APHIS). Concurrently, citrus canker was rediscovered in commercial citrus in Manatee County on the west coast of Florida in June 1997, where a similar eradication effort was initiated

. Subsequent outbreaks of citrus canker have also occurred in both residential and commercial citrus in Collier, Hendry, Hillsborough, Palm Beach, Martin, De Soto, Monroe and Brevard counties of Florida whose origins are believed to be related predominantly to the inoculum reservoir in residential Dade and Broward counties. Despite extensive eradication efforts, which resulted in the removal of over 1.56 million commercial trees and nearly 600,000 infected and exposed dooryard citrus trees statewide, the infected area grew to 657 square miles as of March 2002, and now encompasses the entire state. In January 2000, the Florida Department ofAgriculture adopted a policy of removing all infected trees and all citrus trees within a 1,900 foot radius of an infected tree in both residential areas and commercial groves. Each circle of 1,900 foot radius represents 0.41 square miles

. Previous to this eradication policy, the Department eradicated all citrus trees within 125 feet of an infected tree. The 1,900 foot tree removal program ended then in January 2006 following a statement from the USDA that eradication was infeasible

. Wind-driven rain is the primary short- to medium-distance dispersal mechanism for citrus canker, similar to other bacterial diseases. A single drop of rainwater can carry a load of Xacbacteria of about 107 to 108 cells. Canker is a serious disease of most all commercial citrus cultivars, but grapefruit is by far the most susceptible variety. Severe infections can cause defoliation, blemished fruit, premature fruit drop, twig dieback and general tree decline. As mentioned, in 2006 USDA researchers and officials announced that they no longer believed it was possible to eradicate citrus canker. Officials said that based on USDA's scientific analysis of the potential spread of the disease from the unprecedented 2004 and 2005 hurricane seasons, a new management plan must be devised. USDA said that the program needed to undertake a new approach that focused on maintaining bacteria at low enough levels to sustain citrus production and protect citrus groves that have not been infested with canker. This announcement came after a review of scientific research that indicated Hurricane Wilma may have spread the disease to the point where an estimated 168,000 to 220,000 acres of commercial citrus was infected and e xposed to canker. This was in addition to the more than 80,000 acres ofcommercial citrus that was affected by the 2004 hurricanes.

14Specific to the decrease in commercial acres of citrus present in Florida resulting from canker, citrus acreage reached a 20-year peak in 1996 with 857,687 acres. After that, acreage has declined steadily through the last census last year down to 524,640 acres, representing a decline of 333,047 acres or 39 percent. How much ofthis decline is directly attributable to citrus canker is unclear, but what is clear is that approximately 87,000 acres were destroyed in the citrus canker eradication effort alone

. On a county-by-county basis, St. Lucie County has suffered the largest decrease in the total acres of citrus production, with a loss of 59,151 acres between 1996 and 2008, representing a 55 percent decline in acreage in that County

. In terms of citrus variety impact, the lime industry in Miami-Dade County, even though small to begin with at 2,800 acres, was completely destroyed in the canker eradication effort. Grapefruit has been hit hard with atotal decline from a 1996 peak of 139,200 bearing acres to 44,900 bearing acres in 2013, a 71 percent reduction in acreage
. This is due in large part to grapefruit's relatively high susceptibility of citrus canker compared to other varieties

. Non-Routine Emergency Situation Citrus canker is an established disease that is here to stay and must now be dealt with continually by Florida grapefruit/citrus growers
. Copper is the only bactericide registered for management of citrus canker. No other EPA-registered bactericides exist. Prophylactic /preventative bactericide applications must be made continuously, seasonlong (March through October) at approximately 21-day intervals to protect the fruit from canker blemish

. As many as 14 applications of copper are required to protect fruit during this period. Numerous disadvantages of long-term use of copper for canker management have been documented, including induction of copper resis tance in Xacpopulations and accumulation of copper in citrus soils with potential adverse environmental effects. As such, EPA has set targets for the amount ofthe copper
. element entering citrus agroecosystems

. The most significant disadvantage of using copper for management ofcitrus canker on grapefruit, and the reason forthe development of this non-routine emergency situation, is the fact that now necessary application ofcopper before, during or after the hot periods ofspring/summer is causing excessive/unacceptable yield reducing phytotoxicity to the grapefruit rinds. This phytotoxicity results when the chemical "burn" causes rind tissues to develop corky lesions. These lesions/blemishes make the grapefruit unacceptable for the fresh market. Fruit are rejected and relegated to the juice sector, which pays only a fraction ofwhat would be returned had the fruit gone to fresh market as intended, purely because ofthe summer spray, copper-induced phytotoxicity.

15With the development/appearance of this phytotoxicity problem on grapefruit, researchers immediately initiated studies attempting to seek a solution. Subsequent studies demonstrated that copper hydroxide and copper sulfate applied at 14- or 21-day intervals season long would manage canker on fruit, but in fact did cause considerable copper burn to the fruit rind. This research however also proved that alternation of streptomycin with a reduced rate of copper provided a similar reduction in diseased fruit, with less copper burn than the full rate of copper alone. So ultimately, this research determined that reducing the frequency or rate of copper application during the high risk summertime periods lowered the risk of copper burn to acceptable levels. Use of streptomycin in this manner during hot/dry periods not only reduces the rate and frequency of copper applications but as mentioned previously also contributes to management of the risk for development of bacterial resistance to either copper or streptomycin. Trials from Brazil and Florida now prove the efficacy ofstreptomycin and the reduction of risk from phytotoxicity to fruit. The University of Florida has proposed that two applications ofstreptomycin be targeted to the window of risk for copper burn during the season. Use of streptomycin will be limited to minimize the risk of resistance ofXacto streptomycin and to maintain a sufficient preharvest interval for prevention of residues in harvested fruit. Aspecific economic overview analyzing the impacts of citrus canker with and without the availability of FireWall SOWP Fungicide/Bactericide follows in the Discussion of Economic Loss section. Resistance Monitoring As a condition of approval for this emergency exemption request, EPA mandated that Florida conduct testing and field monitoring to investigate whether microbial resistance to streptomycin sulfate is occurring because ofthis use on grapefruit. A resistance monitoring testing and field monitoring regimen/protocol proposal was submitted to EPA to allow this monitoring work to commence in correlation with the anticipated use season for Firewall. The protocol for this resistance monitoring as well as the requested progress report as a part ofthe approval process for this year are included in Appendix B. 

### DISCUSSION OF ECONOMIC LOSS C166.20CblC4ll In Florida, grapefruit accounted for 47,656 planted acres and a $111 million value of production during 2012-13. While it may be unlikely that the state will suffer 100 percent losses from this citrus canker,·losses from canker blemish and copper burn have been documented to be between 24
- 26 percent over the entire grapefruit acreage, and this trend can be expected to continue. No other efficacious fungicides/bactericides are 

### currently registered for this pest on grapefruit or any other variety of citrus. With no alternative fungicides/bactericides being available and no grapefruit varieties naturally resistant to this disease being available for many years to come, the Florida grapefruit 16industry will continue to experience a non-manageable, non-acceptable escalation offruit surface burning from applications of copper. Grapefruit in Florida is produced with the goal of selling to the fresh market, as fresh market Florida grapefruit provides average returns of $11.00 dollars per box, whereas grapefruit that had to be turned away and sent to the juice market because of copper phytotoxicity on the fruit rind only provided a $2.43 per box. This represents an approximately 78 percent reduction in potential income, which often was the result primarily because ofthe copper-induced phytotoxicity. Because ofthese realities, losses resulting from copper burn of grapefruit are and will continue to be significant. With the elimination ofthe eradication program and the lack of any additional federal assistance dollars, the canker/copper burn problems associated with production currently are unlike any experienced to date, before the availability of FireWall. Ifgrowers have to deal with this situation without continued access to FireWall, packout losses of the magnitude possible from this situation will affect the long-term economic viability and sustainability of Florida's grapefruit industry. The foundation for this non-routine Emergency Exemption request for FireWall (streptomycin) on grapefruit continues to be management of citrus canker during the high-risk for phytotoxicity summer period, by applying a limited number of FireWall applications in combination with a lower rate ofcopper to increase disease control during windblown rain events while simultaneously reducing the level of copper contacting the susceptible fruit rind during times of hot weather. A concerted use of FireWall combined with copper will also minimize concern for Xacdeveloping resistance to streptomycin or copper. Using the information discussed previously in this narrative, the economic analysis presented below for FireWall shows a substantial net revenue return of $195.42 per acre and potential net revenue to grapefruit growers of $8,774,506 industry wide.



### 17Summary 1. On
-Tree Revenue per Acre for Florida Grapefruit and L oss Due to Endemic Citrus canker- 2009-2010 to 2012-2013 Production Seasons White Grapefruit
- On-Tree Revenue Season Without Canker With Canker Revenue (Loss) ($/A) ($/A) ($/A) 2009
-2010 $2,757 $1 564 ($1 , 192) 2010-2011 $2,761 $1 689 ($1 ,072) 2011
-2012 $2,819 $2,051 ($ 786) 2012-2013 $2,668 $1_L 738 ($ 930) Red Grapefruit- On-Tree Revenue Season Without Canker With Canker Revenue (Loss) ($/A) ($/A) ($/A) 2009-2010 $3,398 $2 308 ($1,090) 2010-2011 $3,129 $2,355 ($ 774) 2011-2012 $3,246 $2 612 ($ 634) 2012-2013 $2,630 $1,635 ($ 995)

Summary 2. Estimated Total On-Tree Revenue Loss for Florida's Grapefruit Industry with Endemic Citrus Canker- 2009-2010 to 2012-2013 Production Seasons White Grapefruit

Total Bearing Red Grapefruit Total Acreage Bearing Acreage Season (1000 Acres) (1000 Acres) 2009-2010 14.6 33.5 2010-2011 14

.2 32.5 2011-2012 13.6 31.9 2012
-2013 13

.0 31.9 White Grapefruit

Total On-Tree Red Grapefruit OnRevenue (Loss) with Tree Revenue (Loss) Total On-Tree Season Canker with Canker Revenue (Loss) ($1,000 x) ($1,000 X) ($1,000 x) 2009
-2010 ($17,410) ($36 932) ($54,342) 2010-2011 ($15,229) ($25 738) ($40,967) 2011-2012 ($10,442) ($21,559) ($32,001) 2012-2013 ($12,091) ($31,740) ($43,830)

18Table 1. Before Citrus Canker Became Endemic in Florida
- Estimated Average Marketable Packout Florida Fresh Grapefruit- 2009-2010 to 2012-2013 Production Seasons Percent Packout* White Grapefruit 34.1% Red Grapefruit 52.0% *= From discussions with Florida fresh citrus packers and the Florida Citrus Administration Committee, 2012-13 Season Summary

Table 2. After Citrus Canker Became Endemic in F lorida
- Decrease in Average Marketable Packout Florida Fresh Grapefruit
- Using Only Copper Chemical Control Treatment Percent Packout** Incidence of Citrus Canker Lesioned Fruit 

### I 26.4% **= J.H

. Graham eta. "Streptomycin and Copper Formulations for Control of Citrus Canker on Grapefruit." Proc. Fla. State Hort

. Soc. 123:2010

Table 3

. Adjusted Average Marketable Packout Florida Fresh Grapefruit After Citrus Canker Became Endemic in Florida Percent Packout White Grapefruit (34.1 minus 26.4) 7.7% Red Grapefruit (52

.0 minus 26.4) 25.6%

Table 4. Average On-Tree Price for Fresh and Processed Market Florida Grapefruit2009-2010 to 2012-2013 P roduction Seasons White Grapefruit Fresh Market Processed Market Season ($/box) ($/box) 2009-2010 $13.95 $2.96 2010-2011 $13.20 $3.34 2011-2012 $12.05 $4.65 2012-2013 $12.35 j3.63 Red Grapefruit Fresh Market Processed Market Season ($/box) ($/box) 2009-2010 $12.60 $2.93 2010-2011 $10.55 $3.73 2011-2012 $10.40 

### $4.72 2012-2013 $10.80 $1.63 From: F lorida Agricultural Statistics Service 2012-2013 Citrus Summary 19Table 5. Estimated On-Tree Revenues for F lorida White Grapefruit With and Without Endemic C itrus canker- 2009-2010 to 2012-2013 Production Seasons Processed Juice Total White Grapefruit Fresh Market Market Revenue On-Tree Revenue Without Boxes/Acre $/Acre Boxes/A $/Acre $/Acre

Endemic Citrus Canker 2009-2010 140 $1955 271 $ 802 $2 757 2010-2011 140 $1854 272 $ 907 $2J61 2011 -2012 134 $1 615 259 $1204 $2,819 2012-2013 138 $1,701 266 $ 966 $2,668 Processed Juice Total White Grapefruit Fresh Market Market Revenue On-Tree Revenue With Endemic Boxes/Acre $/Acre Boxes/A $/Acre $/Acre Citrus Canker 2009-2010 32 $441 379 $1,123 $1564 2010-2011 32 $419 380 $1,270 $1689 2011-2012 30 $365 363 $1,687 $2,051 2012-2013 31 $384 373 $1,354 $1 738

Table 6. Estimated On-Tree Revenue for Florida Red Grapefruit With and Without Endemic Citrus Canker
- 2009-2010 to 2012-2013 Production Seasons Processed Juice Total Red Grapefruit Fresh Market Market Revenue On-Tree Revenue Without Boxes/Acre $/Acre Boxes/A $/Acre $/Acre Endemic Citrus Canker 2009-2010 222 $2,798 205 $601 $3,398 2010-2011 224 $2 359 206 $770 $3,129 2011-2012 220 $2 288 203 $958 $3,246 2012-2013 214 $2 308 197 $322 $2,630 Processed Juice Total Red Grapefruit Fresh Market Market Revenue On-Tree Revenue With Endemic Boxes/Acre $/Acre Boxes/A $/Acre $/Acre Citrus canker 2009-2010 109 $1,377 318 $ 931 $

_ 2,308 2010-2011 110 $1/161 320 $1193 $2 355 2011-2012 108 $1126 315 $1,485 $2 612 2012-2013 105 $1136 -306 $ 498 $1635

20Table 7. Spray Costs Used in the INDIAN RIVER Citrus Production Budgets for Fresh Market Grapefruit- 2012-2013 Total Pest Management Costs With Copper and Firewall With Only Copper Additional Cost to Add Firewall

Table 8. Fresh Grapefruit Exports from Florida- 2012-2013
Total Grapefruit Fresh Exports $/Acre
787.33 748.27

39.06

Cartons 10.073.000

Table 9. Estimated Percentage Increase in Packout- Marketable Florida Fresh Grapefruit if FIREWALL Had Been Used- 2009-2010 Reduced Canker Blemish Reduced Copper Burn Estimated Total Increase Pack-out 6.00% 18.00% 24.00%

Table 10. Estimated Additional Cartons of Florida Fresh Grapefruit That Would Have Been Exported if FIREWALL Had Been Used
- 2012-2013 Cartons Total Grapefruit Fresh E xports (10,073,000 x 24o/o) · 2.417.520 Total Florida Field Box Equivalent 1.208,760

21Table 11. Estimated Additional Net Revenue that Florida Growers Would Have Received from Fresh Grapefruit Exports IF FIREWALL Had Been Used- 2012-2013 Grapefruit Total Additional F.O.B. Revenue Less: Processed Juice Revenue Would Have Received from Eliminations [1,208,760 boxes x (5.0 pound solids/box x $0.75/p.s.)] less $1.23/box (elimination costs) Additional Packing Costs (2,417,520 cartons x $4.77/carton) Additional Spray Costs [44,900 bearing acres x $39.06] Total Additional Costs Total Net Revenue to Growers Estimated Net Revenue Per Acre F.O.B. Price F.O.B. $/carton Revenue

$11.00

$ 4,532,850 $11,531,570

$1,753,794 $26,592,720

$17,818,214 $ 8,774,506 $195.42

Grapefruit is the Florida citrus industry's most important fresh fruit variety with a value of more than $111 million in the 2012-2013 crop year. Compared with $172 million in 2004
-2005, there has been an unsustainable decrease in crop value mainly/largely attributable to loss of eligibility offruit for movement to the packinghouse because of canker blemish and diversion offruit to juice eliminations, loss or restriction of shipping to export markets, and abandonment of groves due to loss of profitability

. Increasing declines in pack-out of grapefruit is also attributable to epidemic conditions in grapefruit that continue to evolve with each season
. The impact of citrus canker on the citrus industry in Florida has been dramatic

. The Federal and State Governments have spent over $1.4 billion on the eradication effort and to support the regulatory framework established after the eradication program. Management of the disease following the elimination ofthe eradication effort has been challenging. W hile the management practices recommended to the grapefruit production industry come with higher production costs, on a statewide basis, citrus canker has continued to spread. Finally, while not totally attributable to citrus canker, as previously mentioned, grapefruit production acreage overall in Florida have declined 71 percent, to a 20-year low during Florida's battle with citrus canker.



### 22ESTIMATED REVENUES FORTHE SITES TO BE TREATED {166.2Q{b)(4)Ciil & Ciiil) C166.20Cb)C4Uiil 

### &Ciiil)
Florida Grapefruit Production Information* Total Total Total Bearing Boxes Yield per Acre Price per On
-Tree Season Acres (1,000 boxes**) (total boxes) Box Value (Millions) 2012-13 44,900 18 350 409 $6.06 $111.1 2011-12 44,500 18 850 414 $7.18 $135.4 2010-11 46,500 19 750 425 $6.72 $ 132.7 2009-10 48, 100 20,300 422 $7.50 $ 152

.2 2008
-09 51,900 21,700 418 $3.81 $82

.7

5-Year Average 47,180 19,790 418 $6.25 $122.8 *Source: Latest Available F lorida Agricultural Statistics Service Citrus Summary, March 2014. ** Box 

## =85 pounds.

Grapefruit Pricing Differential Information* Prices per Box (dollars) Season Fresh Processed Total 2012-13 $11.00 $2.43 $6.06 2011-12 $10.64 $4

.67 $7.17 2010-11 $10.99 $3.58 $6.72 2009
-10 $ 12.82 $2.94 $7.50 2008-09 $ 8.17 $0.52 $3.81 *Source: Latest Available Florida Agricultural Statistics Service Citrus Summary, March 2014

.



### 23Estimated net and gross revenues without the use ofthe proposed pesticide Cbut with next best alternative): Estimated yield, net and gross revenues for citrus without the availability of Firewall are computed using only conservative potential yield/packout loss values calculated by University of Florida field trial data

. According to University of Florida field data, packout reductions resulting from citrus canker and copperinduced phytotoxicity are calculated to be between 24
- 26 percent (Table 2 above) when incorporating the next best registered alternative (copper alone, season long) under standard summertime growing parameters. Overall, University data show that the net return experienced by Florida grapefruit growers when incorporating Firewall into the summertime citrus canker management strategy would be substantial at $930 per acre for white grapefruit ($2,668- $1,738 = $930) and $995 per acre for red grapefruit ($2,630

- $1,635 = $995) (Support Tables 5 and 6 above), equating to nearly $8

.8 million industry-wide.

24