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Daguillard, Robert [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=BBE9682B940C4F2C90732E4D37355DD4-DAGUILLARD,] .5/21/20185j48:36 PM__________
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Press [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=b293283291dc44eOb5dlc36be9281d8a-Press] John:,Your questions for EPA
John, on background, please:
1. W hat prompted the exception? Chlorpropham is a pesticide registered with EPA under FIFRA section 3 as plant growth regulator to inhibit sprouting in stored potatoes. In addition, chlorpropham is registered under section 24(c) of FIFRA for use in Washington, DC, on ginkgo trees, to prevent fruiting that produces an unpleasant odor, and in California for use on field-grown Easter lilies to remove floral buds that are susceptible to BotrytisfungdX infection. Section 24(c) of FIFRA provides that states (or the District of Columbia) can register a new pesticide product, or add a new use to an already-registered product (as is the case here), as long as there is a demonstrated "special local need." Washington, DC, demonstrated a special local need to use chlorpropham on ginkgo trees, and EPA concluded that the use did not pose a risk concern.
2. Who initiated the request for the use? DC's Department of Energy & Environment submitted the 24 (c) registration.
3. How unusual are such exceptions? 24 (c) registrations are not unusual. More information on this type of registration is available atwww.epa.gov/pesticide-registration/guidance-fifra-24c-registrations.
4. Why is it only Washington, D.C.? As stated above, Washington, DC, demonstrated a special local need to use chlorpropham on ginkgo trees. According to FIFRA, "special local need" means an existing or imminent pest problem within a state for which the state lead agency has determined that an appropriate federally registered pesticide product is not sufficiently available.
5. Has any other city or region sought the exception? No other state has submitted a 24 (c) registration for chlorpropham's use on ginkgo trees. However, as stated above, California has a 24(c) registration for the use of chlorpropham on field grown Easter lilies. Oregon also has an active 24(c) label for the same use. In addition, Idaho has an active 24(c) label for chlorpropham use in stored potatoes to inhibit sprouting.
6. Who has been monitoring the use of the agent in D.C. and its impact on the environment and effectiveness for the purpose intended, and what have been the results?
DC's Department of Energy & Environment and Department of Transportation are the best sources for this information. See https://ddot.dc.gov/page/female-ginkgo-tree-removal-policy. EPA conducted an ecological risk assessment for chlorpropham's registration review.
7. Is there any concern about impact on other trees from the spraying, such as impact on fruit trees in nearby gardens?
When used according to the label (see https://ddot.dc.gov/sites/default/files/dc/sites/ddot/publication/attachments/shield ginkgo fruit spray infer mation.pdf), there are no risks of concern to other fruiting trees.
Sierra Club v. EPA 18cv3472 NDCA
Tier 13
ED 002061 00014713-00001
8. Can you send the link to the September 2017 risk assessment and the most recent documents about the status of review of the use?
All documents related to the chlorpropham registration review case can be found atwww.regulations. gov/docket?D=EPA-HQ-QPP-2010-0923
Robert Daguillard U S. EPA Office of Media Relations Washington D C.
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202-564-6618 (6)
Sierra Club v. EPA 18cv3472 NDCA
Tier 13
ED 002061 00014713-00002