Section 18 request for Closer - Sulfoxaflor on pecans to control aphids (16NM01)

Section 18 request for Closer - Sulfoxaflor on pecans to control aphids (16NM01) The NMDA specific exemption (16NM01) for use of sulfoxaflor (Closer) on pecans to control aphids is currently under review. The Agency’s Biological Economic and Analysis Division (BEAD) has preliminarily reviewed your application. Additional information is needed from the state to substantiate an urgent and non-routine emergency situation. The request is deficient in meeting the criteria for a section 18 request for the following reasons: 1) The black-margined aphid and black pecan aphid can reportedly be controlled by a number of active ingredients such as chlorpyrifos, clothianidin, pymetrozine, acetamiprid, and dimethoate (among others). These alternatives are not mentioned in the request. 2) Resistance management is not a criterion for a section 18 emergency exemption request; the situation does not appear to meet the thresholds for an emergency situation. While the absence of sulfoxaflor may be non-routine, the emergency situation does not appear urgent as there are alternative chemistries to control these pests. 3) The economic data are insufficient to determine significant economic loss. NMDA did not provide any information on: • yields with sulfoxaflor (routine situation) and with the best available alternative (necessary for Tier 1 analysis), • prices (if needed, for Tier 2 analysis) to estimate revenue and distinguish any quality impacts between use of sulfoxaflor and the best available alternative, and • production costs (if needed for Tier 3 analysis) which might include changes in cost with the use of an alternative or additional sorting costs if there are quality impacts. At your earliest convenience, please respond via email to the request for more data detailed above. This data will support your application that EPA received on 6/24/16. (1) Provide more information on why these other active ingredients (registered alternatives) are insufficient to control black pecan aphid and black margined aphid? (2) Provide more information on economic loss from the absence of sulfoxaflor? Without this information, it will be difficult for the Agency to determine if an emergency situation exists. Thanks,