United States Department of Agriculture

May 30, 2018

Yu-Ting Guilaran, Director Pesticide Re-Evaluation Division (7508P) Office of Pesticide Programs, Environmental Protection Agency 1200 Pennsylvania Ave., N.W. Washington, DC 20460-0001

Re: USDA comments on the Preliminary Environmental Fate and Ecological Risk Assessment for Acetamiprid, Docket ID Number, EPA-HQ-OPP-2012-0329.

Dear Ms. Guilaran:

The United States Department of Agriculture is pleased to comment on EPA’s ecological risk assessment for acetamiprid, published in the Federal Register on February 27, 2018. Acetamiprid is a broad-spectrum cyano-substituted neonicotinoid insecticide used to control a wide variety of insect pests including sucking insects on more than 30 agricultural crops in the United States. In some crops, acetamiprid is a critical component of growers pest management programs, targeting control of multiple key pests co-occurring temporally (e.g., apple and pear) or in providing excellent control of insect vectors of viruses (e.g., celery and lettuce) that make produce unmarketable.

USDA appreciates EPA’s expressed understanding of how the risk profile of acetamiprid differs significantly from the related class of nitroguanidine neonicotinoid insecticides, and requests that OPP risk characterization and risk management strategies take into account the most likely insecticide alternatives and adequately contextualize the risk-benefit balancing for acetamiprid in a comparative way to existing alternatives. USDA concurs with the conclusion on the low relative toxicity to bees (discussed below in taxa-specific comments). This makes acetamiprid an ecologically preferable option for growers of blooming crops to control problematic pest outbreaks at or around the bloom period—particularly on crops such as cotton, citrus, tree fruits, tree nuts, berries, cucurbits, and seed crops.

USDA stands ready to work with EPA for questions in providing data input for risk assessments and the characterization of benefits for pesticide use that minimizes exposure concerns. Our detailed comments follow. Please let me know if you would like to discuss.

Sincerely,

Sheryl H. Kunickis, Ph.D. Director

Office of Pest Management Policy 1400 Independence Avenue, S.W. Washington, D.C. 20250-0314 An Equal Opportunity Employer

USDA comments on the Preliminary Environmental Fate and Ecological Risk Assessment for Acetamiprid, Docket ID Number, EPA-HQ-OPP-2012-0329:

Ecological Risk Assessment Comments

USDA acknowledges that the ecological risk assessment for acetamiprid included a good deal of helpful risk characterization information regarding the identified risks of concern. The assessment is well-organized, well-written, and logically organized in a way that presents risks estimates within an understandable context. USDA particularly appreciates the discussion of upper-bound Kenaga vs. mean Kenaga exposure estimates for foliar applications, exposure refinements for a likely shorter-than-default chemical degradation half-life, and dietary sensitivity analysis for terrestrial vertebrate exposure. These characterizations provide risk managers with useful and more realistic/likely field exposure scenarios for a number of non- target taxa across multiple acetamiprid use patterns.

USDA further appreciates and supports the totality of effort and difficulty already undertaken by EPA in assessing ecological risks of the related class of nitroguanidine neonicotinoid insecticides. We appreciate the expressed understanding of how the risk profile of acetamiprid differs significantly from those chemicals, particularly with regard to pollinators. USDA herein offers some additional comments regarding the characterization of modeled ecological risks for acetamiprid and some additional discussion on the agricultural context of acetamiprid usage.

General Comments on Agricultural Importance and Potential Risk Management Acetamiprid has significant benefit to growers as a broad-spectrum insect control option that is also quite safe to bees when used at typical agricultural use rates (i.e., rates that are not anywhere near highest labeled non-ag rates that drove potential uncertainties in EFED’s risk assessment). USDA concurs with the conclusion on the low relative toxicity to bees (discussed later in taxa- specific comments). This makes acetamiprid an ecologically preferable option for growers of blooming crops to control problematic pest outbreaks at or around the bloom period— particularly on crops such as cotton, citrus, tree fruits, tree nuts, berries, cucurbits, and seed crops. While USDA understands that acetamiprid is not a ‘zero-risk’ option for all non-target taxa, we urge EPA to consider the likely exposure characterization for those identified non- pollinator ecological risks of concern, and also to appreciate the comparatively low risks posed to bees when compared with nitroguanidine neonicotinoids, pyrethroids, organophosphates, and other broad-spectrum options currently used by growers. In this vein, USDA requests that EPA consider the benefits of acetamiprid prospectively (i.e., in light of possible mitigation decisions for other insecticides such as nitroguanidine neonicotinoids) and for EPA risk managers to think strategically in terms of overall risk reduction options within the ‘universe’ of available pest management options, rather than viewing acetamiprid risk-benefit considerations in a chemical- specific snapshot manner--particularly for blooming crops with exposure concerns for bees.

USDA notes that acetamiprid was one of the primary alternative options cited by OPP in its assessment of the impacts of its Policy to Mitigate the Acute Risks to Bees from Pesticide Products (US EPA, 2017a, b, c). USDA appreciates that EPA considered differential grower impacts for a number of proposed implementation scenarios for this Policy. Ultimately, the Agency settled on a risk-driven policy (i.e., noting application rates and exposure) in the final proposal (US EPA, 2017a), which USDA supports. USDA notes that in developing this finalized policy, the availability of acetamiprid was of lynchpin importance for growers of blooming

crops, due to both its relatively low risk profile for bees and its broad-spectrum target pest efficacy. OPP-BEAD determined that the continued availability of acetamiprid (and indoxacarb) under the revised policy would considerably reduce the likely impacts on growers of blooming crops, particularly for crops such as pome/stone fruits and berries, etc. (US EPA, 2017b). As such, EPA recognized acetamiprid as an important tool that should remain available for bloom- time usage (US EPA, 2017c). USDA supported this determination in development of this policy.

Acetamiprid is likely to take on even more importance for growers in the future if significant mitigations are imposed on nitroguanidine neonicotinoids or other alternatives in ways that further limit the availability of those alternatives. USDA encourages EPA to be cognizant that some of the likely alternative insecticides to acetamiprid may pose different (or even comparatively greater) ecological risks, particularly for uses on blooming crops. USDA requests that EPA recognize that the high agricultural importance of acetamiprid must be considered as EPA develops any new or additional mitigation plans under registration review.

Terrestrial Vertebrate (Bird and Mammal) Risks

Treated Seed Exposure: USDA appreciates the characterization discussions around the differential risk estimates for potential bird and mammalian exposure to treated seeds. USDA notes that treated potato seeds (because they are large tuber slices and not true seeds) are too large for typical bird consumption and not likely to be a primary food source for birds.

Generally speaking, USDA concurs that treated mustard and canola seeds are a plausible exposure pathway for acute risks of concern for birds, particularly passerines, based upon the toxicity endpoints presented in the risk assessment. EFED has provided some useful characterization around the risk estimates, to which USDA would like to add a few points. USDA appreciates the characterization of the relatively low level of seed consumption that would be required to trigger acute risk concerns, at <5% of bird diet for large birds and <1% for small and medium birds. While some available anecdotal information indicates that canola and mustard are not likely to be highly preferred by most birds, this is also likely to vary significantly by bird species, and there is information to substantiate that some passerine species do indeed forage on rapeseed/canola for a substantial part of their dietary intake (Perkins et al., 2007).

USDA requests that EPA consider what information may be available and known regarding the potential repellence/reduced palatability of insecticide-treated seed relative to untreated seed. If treated seed is repellent or generally less palatable to most birds, this might be considered for additional characterization of risks for the passerine species that most commonly co-occur with areas of widespread canola and mustard seed production in the United States. EPA might also seek further information on the potential usage of bird repellant chemicals (for example anthraquinone, which was recently registered for Section 3 use on other grain crops) on canola and mustard seeds, as this could be another factor that would decrease the likelihood of exposure. USDA stands ready to assist with any additional information requests in support of such characterization.

For mammals, EFED notes that the percentage of diet required to trigger risk concerns is substantially higher than for birds. For acute risks, >33% of mammalian diet would have to be treated seeds, which is unlikely given the varied forage available near most agricultural fields.

USDA emphasizes that canola and mustard seed is typically soil-incorporated (Canola Council, 2017a), which would substantially limit surface availability to foraging birds and mammals. This would further preclude the likelihood of chronic exposure for either birds or mammals, since the bioavailability of seed would be limited over time, and plants would likely emerge in a time that is less than the dietary exposure period assumed for chronic risk estimates. Birds are exposed to test residues for 6-8 weeks of pre-reproductive exposure in OPP’s Guideline chronic toxicity study (OCSPP 850.2300), whereas most canola and mustard seed is likely to emerge in less than 3 weeks, even under worst-case, low temperature conditions (Kandel and Graves, 2014; Canola Council, 2017b). While USDA recognizes EFED’s stated concerns about chronic risk estimates being underestimated due to data gaps on chronic toxicity, we request that EPA consider that conversely, seed emergence biology is likely to greatly limit seed availability relative to the exposure estimates being assumed.

While seed pelleting might typically be considered to obviate risks to smaller bird taxa, USDA notes that seed pelleting is probably not a practical mitigation option for canola and mustard seed growers, given typical planting practices and seed emergence biology. USDA reached out to extension experts who pointed out that for small seeded crops like canola and brown mustard, pelleting to 40mg would essentially require a 10x increase in seed size, based on the average size of untreated seeds. Yellow mustard seeds are larger (Kandel, pers. comm, 2018). While modern planters could conceivably handle seeds of this size, the ability to plant at acceptable planting densities and depths, and the effects this would have on seed emergence are unknown.

USDA notes that many registrants offer to cooperate with outreach and stewardship activities related to the handling of treated seeds, including cleanup and burial of spilled seeds, and engage in collaborative approaches to extending information on best management practices to mitigate potential seed exposure concerns for birds. USDA submits that for canola and mustard, acetamiprid treated seeds are important for control of flea beetles (otherwise controlled by foliar applications of pyrethroids) and wireworms (otherwise controlled with nitroguanidine neonicotinoid seed treatments or applications of broad-spectrum soil insecticides). USDA received input from extension experts on the importance of acetamiprid seed treatments. One of the key advantages of acetamiprid seed treatment relative to foliar applications of pyrethroids (zeta-cypermethrin is the main foliar tool for canola and mustard) is the relative safety to non- target insects, including natural enemies (Knodel et al., 2017; Knodel, pers. comm., 2018). Zeta- cypermethrin is much more broad-spectrum in activity and therefore widely toxic to beneficial insects via contact toxicity (most predator or parasitic insect species would not directly contact acetamiprid applied via seed treatment, as it is systemic within the mustard/canola plant). For flea beetle control, acetamiprid seed treatments can obviate the need for one or more applications of zeta-cypermethrin (Knodel et al., 2017; Knodel, pers. comm., 2018). Therefore, USDA urges OPP risk managers to understand that the alternatives to acetamiprid seed treatments may pose different risk concerns, and to consider any proposed mitigation options strategically--in light of the few effective options available to canola and mustard growers to control flea beetles and wireworms.

Foliar Exposure: USDA appreciates EFED’s consideration and presentation of risk refinement and characterization for bird and mammal exposure to foliar acetamiprid residues, as previously discussed. USDA requests that EPA consider that when mean Kenaga exposures are modeled using the more likely 6-day foliar degradation half-life (more likely to be reflective of real-world

field conditions) there are no risk exceedances for mammals (Table L2). For birds, modeled RQs are significantly reduced for birds, on the order of 3-fold. USDA further points out that for many crop uses, particularly row crop uses such as cotton and vegetables where aggressive weed management is employed, exposure estimates (and durations of exposure) for birds or mammals feeding on weeds (i.e., short grass or tall grasses or seeds of weeds) in fields are highly unlikely. This is due both to the relatively low number of taxa that are exclusively herbivorous (particularly for small and medium-sized birds) and also given the lack of abundant weed presence for crops, such as cotton, vegetables, berries, and citrus, in fields throughout the growing season. USDA also notes that it is highly unlikely that many (if any) bird taxa would feed exclusively on treated crop foliage. While we appreciate that acetamiprid has high reported toxicity to birds, the relatively low likelihood, duration, and magnitude of actual exposure to foliar residues should be recognized by risk managers and contextualized relative to the comparative ecological risks of likely acetamiprid alternatives.

Terrestrial Invertebrate (Bee) Risk/Characterization USDA supports the stated conclusions regarding the relatively low toxicity of acetamiprid to bees, as compared to nitroguanidines, etc., and we agree with EFED’s projection of a low risk likelihood at the most common agricultural use rates of around 0.1 lbs AI/acre for potential adverse colony effects. USDA understands that additional bee data may change risk estimates in the future, but notes the generally accepted safety profile of acetamiprid, relative to the most likely alternative insecticides, is widely recognized by extension and pest management experts. Given this comparatively low risk to bees, USDA requests that EPA acknowledge the high agricultural value of acetamiprid for important pest management uses near bloom time on blooming crops, understanding that many insecticidal alternatives are going to pose higher risk to pollinators (Please see aforementioned discussion on the agricultural benefits of acetamiprid, and the associated importance of acetamiprid in EPA’s published policy on pollinator protection.).

Aquatic Invertebrate Risks USDA recognizes that it is not surprising that acetamiprid would show a high likelihood of risks to aquatic invertebrates, given its mode of action and target pest spectrum. EFED’s assessment underscores that the relative water solubility, moderate mobility, and moderate persistence of acetamiprid in water (albeit with relatively rapid soil degradation) all combine to make risks to aquatic invertebrates plausible, particularly for pore water exposure. However, it is widely known that numerous insecticide classes are likely to show similar (or higher) levels of risk to aquatic invertebrates.

As EPA develops a risk management strategy, USDA urges risk managers to recognize and consider the comparative risks of likely insecticide alternatives and focus on practical and feasible measures that minimize off-site movement of acetamiprid to retain the efficacy and utility of this important insecticide for growers.

More specific to this assessment, USDA notes that the only listed acute exceedances for estuarine invertebrates (in cranberries) are based upon the Pesticides in Flooded Agriculture Model (PFAM), which estimates in-field pesticide concentrations. Because PFAM does not quantitatively assess the likely concentrations of water moving off-site to estuarine water bodies, the applicability of this estimate is of limited value for risk management. It is known that variability is high for such a scenario and that the Estimated Environmental Concentrations (EECs) could decrease by substantial amounts (i.e., multiple orders of magnitude) after runoff

water exits the flooded field and is diluted by after field runoff. Further, from a usage perspective, Mr. John Wilson, The Cranberry Institute (personal communication), states that while acetamiprid is an important insecticide for controlling key pests, applications are usually limited to targeted hot spots where monitoring indicates the need for a treatment. Mr. Wilson reported to the USDA that for the years 2014, 2015 and 2016 approximately 5% of cranberry acres in Wisconsin were treated to control cranberry flea beetles, 6% of New Jersey acres were treated to control outbreaks of leaf hoppers and toad bugs, and less than 1% of Massachusetts acres were treated to control cranberry weevil.

USDA objects to use of the strawberry scenario that modeled three ‘seasons’ per year, as this is not reflective of strawberry production practices. Perennial strawberry production would only have one season per year, which includes June bearing and day-neutral varieties. Even for the more common annual production systems found in California and Florida, varieties are generally ‘everbearing’ cultivars, which will continually flower and fruit for months on end. Under either system, there is no feasible way to produce three distinct crops of strawberries within the same year in the same field. It is likely that in winter production zones (such as Florida) there are situations where one season could span two calendar years (with harvest running from fall through late winter/early spring), in which case a ‘per season’ restriction is actually more restrictive on applications than a ‘per year’ restriction. Even under this literal interpretation, a maximum of two years could be combined into one growing season, not three, and no area of the U.S. would grow three seasons worth of bearing strawberries in any given calendar year.

USDA appreciates the discussion of refinement estimates by modeling ‘parent-alone’ EECs, which substantially reduces the Levels of Concern (LOCs), as well as the discussion of available monitoring data. USDA requests that OPP acknowledge that peak monitoring values are not likely to persist in a way that makes them likely for long-term chronic exposure. We also welcome the presentation of modeled surface water EECs that take into account medium to coarse droplet size diameters, as this further reduces EECs marginally and is somewhat more reflective of likely practices by growers to mitigate drift. USDA requests that EPA make use of this information in developing mitigation strategies to prevent off-site movement of acetamiprid. As always, we are available to assist EPA with supportive information regarding the most likely methods of application and existing drift reduction measures used by growers applying acetamiprid.

Acetamiprid Usage and Benefits

Acetamiprid is widely used on more than 30 agricultural crops in the United States (Table 1). Crops with the most usage, in terms of percent crop treated, are apples, celery, and strawberries. Asparagus, cantaloupes, lettuce, pears and walnuts are crops with greater than 20% of total acres grown treated. Depending on the crop, the average number of annual applications tends to range from one to two, while the average rate is around 0.1 lbs/AI/acre, with some variation by crop (MRD, 2014-2016a,b). California has additional crops with a high percent of crop acres treated that are not reflected by national usage. This may indicate needs to manage regional niche pests or consideration of other production factors. For example, cotton production in California uses more acetamiprid in comparison to the rest of the country, with most applications targeting aphids (MRD, 2013-2017). Although about 60% of this usage is attributed to pima cotton production, typical cotton varieties in California also rely on acetamiprid. Similarly, usage on

watermelons in California is significantly higher than the national average in terms of percent crop treated.

While overall national usage on cotton is relatively low, it is notable that in areas that do use acetamiprid, it most often targets aphids, whiteflies, and sometimes the Lygus complex, with aphids and whiteflies of particular concern in California. Usage in Georgia targeting whiteflies also emerged in 2017 as an area worth noting (MRD, 2013-2017). USDA notes that aphids and whiteflies contribute to the ‘sticky cotton’ problem, which is a quality-loss impact for affected growers and cotton ginning facilities. Rather than re-stating that entire impact discussion in detail here, USDA directs EPA to review our previously submitted comments in response to the most recent ecological risk assessment for the nitroguanidine neonicotinoid insecticides (USDA- OPMP, 2018).

In Mid-South cotton production, acetamiprid usage targeting Lygus would likely take precedence over aphids and whiteflies, and currently, acetamiprid usage does not appear to be widespread (MRD, 2013-2017). However, acetamiprid has high efficacy against all of these sap-feeding species. As noted previously, the importance of acetamiprid for use on cotton could rise substantially if usage restrictions are placed on active ingredients such as nitroguanidine neonicotinoids, synthetic pyrethroids, organophosphates, etc. USDA requests that OPP consider USDA’s previously submitted comments on the economic impacts of sticky cotton, as well as the resistance management concerns for managing the problematic Lygus complex on cotton, particularly in the Mid-South United States.

Acetamiprid is the only insecticide in the neonicotinoid class that provides excellent control of several major pests of Eastern U.S.A. apple production, most importantly, apple maggot (AM), codling moth (CM) and Oriental fruit moth (OFM). Larry Gut, tree fruit entomology extension specialist for Michigan State University reports that apple maggot (Rhagoletis pomonella) is becoming the most significant pest in eastern apple production systems, and that monitoring in commercial orchards over the past five years has shown a dramatic increase in AM numbers (personal communication). Average catches in volatile-baited traps have been in excess of 75 flies/trap, while the treatment threshold is a cumulative catch of only 5 flies per trap. All three of these pests (AM, CM and OFM), have larval stages that chew their way directly into the interior of the fruit. Excellent efficacy is an absolute necessity in addressing the market’s zero tolerance for presence of larvae in harvested fruit. If a single infested apple is detected in a truck-load of harvested fruit at the processing/packing facility, the entire load of apples is rejected. Acetamiprid is one of only two pesticides, along with phosmet, rated as excellent for control of apple maggot, making it highly likely that resistance to phosmet will rapidly evolve if acetamiprid is not available. Acetamiprid applications targeting AM control begin in July and continue through late summer when the life stages of AM, CM and OFM coincide, so that applications targeting control of AM also provide excellent control of CM and OFM, rather than using multiple active ingredients targeting control of each pest, individually. Acetamiprid is also the only summer option for control of apple maggot that has minimal to no effect on natural enemies, and thus does not result in secondary pest outbreaks.

Acetamiprid is also a critical control material for management of pear psylla in Pacific Northwest pear production. Dr. Elizabeth Beers, Professor and Tree Fruit extension specialist at Washington State University, reports that acetamiprid was ranked as an excellent material in recently completed pear psylla insecticide assays, and that applications of acetamiprid timed to

control pear psylla collaterally control codling moth and grape mealybug (personal communication). Pear psylla is a notoriously difficult pest to control, due to its rapid development of insecticide resistance.

University of California IPM ranks acetamiprid as an excellent control for aphids in a number of crops. Acetamiprid is the most excellent control material for management of aphids in celery production. In addition to stunting plant growth and reducing yields, aphids vector virus diseases such as western celery mosaic, celery calico, cucumber mosaic, and celery yellow spot. Black bean aphids contaminate celery produce, particularly fresh market celery, with aphid honeydew and debris; this contamination can lower the crop value. UC IPM also ranks acetamiprid as the number one material for control of cucumber beetle in cucurbits, for management of walnut husk fly in walnut (maggots feed inside the husk, turning it very soft and black), for management of aphids and sweet potato whitefly (mid to late season) in cotton, and as one of only two excellent materials for the control of black peach aphid in nectarine. Other key crop uses in CA include control of peach twig borer in almond; control of walnut aphid and codling moth in walnuts, control of vine mealybug, Western Grapeleaf Skeletonizer, blue-green sharpshooter, glassy- winged sharpshooter and green sharpshooter in grapes; citrus thrips in blueberry; and lettuce, foxglove, green peach and potato aphids in lettuce production. Lettuce aphids vector several virus diseases including lettuce mosaic virus, alfalfa mosaic, beet western yellows, beet yellow stunt, and turnip mosaic.

Acetamiprid is also an important insecticide for control of key pests in strawberry production, with uses to manage aphids and lygus in CA, and for management of Japanese beetle, flea beetle, sap beetles, obliquebanded leafroller, gypsy moth, spotted wing drosophila, fruit flies, lygus, aphids, and thrips in Florida, Michigan, New York and North Carolina.

The Mid-Atlantic Commercial Vegetable Production Recommendations guide identifies important uses of acetamiprid in management of aphids, coleopterans, homopterans, thrips and lepidopterans in beans, potato, celery, cole crops, cucumbers, eggplant, garlic, mustard and turnip greens, leeks, Lettuce, Endive and Escarole. Acetamiprid is also an important control of asparagus beetle and aphids in Michigan and Washington asparagus production. Michigan State University vegetable crops extension specialist, Ben Werling (personal communication), reports that acetamiprid is becoming the most important insecticide for management of asparagus beetle because of its excellent efficacy and one-day pre-harvest interval. The only other excellent material is carbaryl, and growers are concerned with evolution of resistance of the beetle and potential mitigations facing carbaryl. Acetamiprid is rated as the number one most effective material for control of asparagus aphid in the Pacific Northwest Vegetable Extension Guide (http://mtvernon.wsu.edu/path_team/asparagus.htm). “Aphids feed on the fern and severely stunt growth.” “Nurseries with ferns infested in summer or fall may have 90 to 100% crown mortality the following spring. Mature stands may show loss of vigor and production.”

Mustard and Canola Seed Treatment uses acetamiprid to manage serious insect pests, including crucifer flea beetle, the striped flea beetle, and wireworms (larvae of elateridae beetles). High pest populations carry a high risk of canola seedling death, stand losses and having to reseed the field. Janet Knodel, PhD, Professor & Extension Entomologist, North Dakota State University states that there are no other efficacious alternative control strategies for wireworms other than seed treatment or soil-applied insecticide, that seed treatment eliminates the need for foliar

applications of insecticides for flea beetle control (2-3X), thus making seed treatments safer for natural enemies (personal communication).

Table 1. Comparison of National versus California Acetamiprid Usage, 2014-2016 Annual Average United States California Percent Crop Rate U.S. Crop Average Percent California Planted Total Treated U.S. Crop Base Area Total Area (lbs/AI/ Area Number of Crop Crop Acres Area (Likely Range Category Treated3 Treated4 Acre)1 Grown2 Applications Treated5 Category (2013)3 Treated4 or Upper- Bound)5

Apples 0.113 321,728 132,153 219,879 1.7 41.4% Apples 15,200 1,523 6-10%

Apricots 0.068 10,493 372 372 1.0 3.5% Apricots 9,500 239 3%

Asparagus 0.084 25,080 3,812 5,944 1.6 16.8% Asparagus 12,000 1,050 6-9% Blueberries Not surveyed Blueberries 4,800 904 19% Brussel Brussel Sprout Not surveyed Sprout 14,336 3,847 27%

Cabbage 0.072 58,440 6,339 10,124 1.6 11.3% Cabbage 14,300 1,719 8-12%

Raspberry 5,600 1,321 21-24% Caneberries 0.092 26,660 1,716 1,913 1.1 6.4%

Blackberry 2,598 688 26%

Cantaloupes 0.086 59,827 13,247 18,900 1.4 24.0% Cantaloupe 43,000 11,391 19-26%

Cauliflower 0.059 36,080 3,219 3,219 1.0 8.5% Cauliflower 32,900 625 2%

Celery 0.073 29,340 11,317 12,885 1.1 38.0% Celery 27,500 20,741 66-75%

Cherries 0.122 137,647 10,481 11,739 1.1 7.9% Cherries 33,000 463 1%

Cotton 0.053 10,389,200 109,959 126,330 1.1 1.1% Cotton 248,200 163,674 57-66%

Cucumber 0.084 115,606 834 1,119 1.3 0.8% Cucumber 3,800 2,324 61%

Kale Not surveyed Kale 28,996 1,883 6% Lettuce, Lettuce 0.063 266,660 48,664 55,466 1.1 18.4% Leaf 97,000 18,400 17-19%

United States California Percent Crop Rate U.S. Crop Average Percent California Planted Total Treated U.S. Crop Base Area Total Area (lbs/AI/ Area Number of Crop Crop Acres Area (Likely Range Category Treated3 Treated4 Acre)1 Grown2 Applications Treated5 Category (2013)3 Treated4 or Upper- Bound)5 Lettuce, Head 48,000 14,980 31% Nursery- Nursery- Outdoor Outdoor Plant Not surveyed Plant 24,736 3,772 15% Nursery- Nursery- Outdoor Outdoor Transplant Not surveyed Transplant 7,105 921 13%

Onions 0.135 126,792 487 487 1.0 0.4% Onion, Dry 18,826 1,710 9%

Oranges 0.168 645,795 14,538 18,345 1.3 2.4% Orange 175,000 16,466 7-9%

Peaches 0.116 104,394 11,277 19,939 1.8 11.7% Peach 46,000 2,263 3-5%

Pears 0.139 52,381 10,623 13,504 1.3 21.3% Pears 11,600 422 3-4% Pepper, Fruiting 20,100 4,569 14-23% Peppers 0.068 66,720 4,331 7,173 1.7 7.4% Pepper, Spice 3,045 171 6% Plum 18,000 1,559 8-9% Plums/Prunes 0.078 79,686 1,947 2,186 1.1 2.6% Prune 50,000 1,339 3%

Pumpkins 0.084 76,967 5,827 8,249 1.4 7.9% Pumpkin 5,900 1,635 20-28%

Radicchio Not surveyed Radicchio 4,995 312 6%

Spinach 0.075 46,577 2,797 2,797 1.0 6.6% Spinach 28,500 1,608 6%

Squash 0.080 46,035 2,878 3,316 1.2 6.6% Squash 6,900 1,510 19-22%

Strawberries 0.110 55,122 17,788 28,693 1.6 31.8% Strawberry 41,500 37,529 56-90%

United States California Percent Crop Rate U.S. Crop Average Percent California Planted Total Treated U.S. Crop Base Area Total Area (lbs/AI/ Area Number of Crop Crop Acres Area (Likely Range Category Treated3 Treated4 Acre)1 Grown2 Applications Treated5 Category (2013)3 Treated4 or Upper- Bound)5 Tomato, Fresh 34,600 3,980 10-12% Tomatoes 0.068 338,740 20,090 22,832 1.1 5.7% Tomato, Processing 263,000 15,729 6%

Walnuts 0.128 332,795 73,255 83,109 1.1 20.6% Walnut 280,000 91,529 29-33%

Watermelons 0.096 118,420 3,573 3,970 1.1 3.3% Watermelon 10,000 6,219 56-62% Source: MRD (2014-2016a,b); USDA NASS (2017); USDA NASS (2013). Crops with less than 5% crop treated either across the U.S. or in California are not reported in this table. 1 Product rates are only reported at the national level. Active ingredient rates are not available for California via MRD (2014-2016b). 2 Note that discrepancies exist between the U.S. crop area grown estimates and California planted acres. This is function of data sources, with U.S. crop area grown based on USDA NASS (2017) average annual survey estimates for 2012 to 2016 while California crop area grown reflects 2013 planted acres (or bearing acres in the case of perennial crops). 2013 California planting data was unavailable for crops not surveyed by NASS. In these cases, data reflect planted acres reported to the California Department of Pesticide Regulation, which may be overestimated as it accounts for all plantings on a particular field throughout the year. This could lead to percent crop treated estimates being underestimated for some crops in California. 3 Base area treated reflects the unique number of acres treated with this active ingredient, even if a particular acre is treated more than once annually. Base area treated is not reported by MRD (2014-2016b) for California. 4Total area treated reflects the sum total of acres treated with this active ingredient and may reflect a single acre treated more than once. For California, crops that are refined to sub-crop levels beyond what is surveyed at the national level by MRD (2014-2016a) are unique acres grown (e.g., tomatoes for processing are not a subset of tomato; they reflect separate acreage). 5 National percent crop treated estimates are a function of base area treated as a percent of crop area grown for a particular crop. California percent crop treated is presented as a range or as an upper-bound estimate given that base acres treated are not reported by MRD (2014-2016b). The lower-bound percent crop treated estimates in California accounts for the number of applications at the national level, when known. For crops that are not surveyed nationally, percent crop treated is an upper-bound estimate that reflects total area treated as a percent of planted acres. Application rates may also differ in California versus the rest of the U.S., and thus this upper-bound estimate is also provided for crops that have national level usage data available via MRD (2014-2016a).

References:

Canola Council, 2017a. Seed and Fertilizer Placement. Canola Encyclopedia. Online Production Guide, Canola Council of Canada. https://www.canolacouncil.org/canola- encyclopedia/crop-establishment/seed-and-fertilizer-placement/. Accessed May 10, 2018.

Canola Council, 2017b. Time of Seeding. Canola Encyclopedia. Online Production Guide, Canola Council of Canada. https://www.canolacouncil.org/canola-encyclopedia/crop- establishment/time-of-seeding/. Accessed May 24, 2018.

Kandel, H., 2018. Extension Agronomist for Broadleaf Crops, North Dakota State University. Personal Communication to USDA, comments sent via email dated. May 4, 2018.

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Market Research Data (MRD). 2012-2016a. Data collected and sold by a private market research firm. Data collected on pesticide use for about 60 crops by annual surveys of agricultural users in the continental United States. Survey methodology provides statically valid results, typically at the state level.

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United States Department of Agriculture, National Agricultural Statics Service (USDA NASS). 2017. Commodity Data, Various Years. Accessed November 1, 2017. Located at: https://quickstats.nass.usda.gov/ United States Department of Agriculture, Office of Pest Management Policy. 2018. USDA Comments on the Preliminary Ecological Risk Assessment for the Registration Review of Imidacloprid, EPA-HQ-OPP-2008-0844; Thiamethoxam, EPA-HQ-OPP-2011-0581; Dinotefuran, EPA-HQ-OPP-2011-0920; and Clothianidin, EPA-HQ-OPP-2011-0865. Submitted to EPA-OPP on April 20, 2018. Located at: https://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OPP-2008-0844- 1527&attachmentNumber=1&contentType=pdf. United States EPA, 2017a. U.S. Environmental Protection Agency’s Policy to Mitigate the Acute Risks to Bees From Pesticide Products. US EPA, Office of Pesticide Programs. January 12, 2017. https://www.regulations.gov/document?D=EPA-HQ-OPP-2014-0818-0477. Accessed May 8, 2018.

United States EPA, 2017b. Impact Estimates from Proposed and Revised Pollinator Labelling for Representative Blooming Agricultural Crops Utilizing Commercial Pollination Services. US EPA, Office of Pesticide Programs. January 12, 2017. https://www.regulations.gov/document?D=EPA-HQ-OPP-2014-0818-0479. Accessed May 8, 2018.

United States EPA, 2017c. Response to Public Comments Submitted on The Environmental Protection Agency’s Proposal to Mitigate Exposure to Bees From Acutely Toxic Pesticide Products. US EPA, Office of Pesticide Programs. January 12, 2017. https://www.regulations.gov/document?D=EPA-HQ-OPP-2014-0818-0478. Accessed May 8, 2018.