Document daNMz7m7m7VKgMRxZmrOGVj2Q

Message From: Sent: To: CC: Subject: Attachments: Scott Herndon [sherndon@americansugarbeet.org] 5/11/2017 12:28:53 PM Bennett, Tate [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=lfa92542f7ca4d01973bl8b2fllb9141-Bennett, El]; Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy] Palich, Christian [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=330ad62el58d43af93fcbbece930d21a-Palich, Chr]; Cassie Bladow [Cassie.Bladow@beetsugar.org]; Graham, Amy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=26722dfde5b34925b0ad9a8dd4aff308-Graham, Amy] RE: Section 18 Chlorothalonil Talking Points.docx Here is some additional information that was given to me by SipCam in case it is helpful. Thanks again! Scott Herndon Director o fBiotechnology and Regulatory Affairs American Sugarbeet Growers Association 1155 15th Street NW #1100 Washington, DC 20005 202-595-0786 202-480-5530 (cell) From: Bennett, Tate [mailto:Bennett.Tate@epa.gov] Sent: Wednesday, May 10, 2017 10:21 PM To: Beck, Nancy <Beck.Nancy@epa.gov> Cc: Palich, Christian <palich.christian@epa.gov>; Scott Herndon <sherndon@americansugarbeet.org>; Cassie Bladow <Cassie.Bladow@beetsugar.org>; Graham, Amy <graham.amy@epa.gov> Subject: Re: Section 18 Scott- Christian and Amy will be at the hearing tomorrow with Rick. Were you planning to be there? On May 10, 2017, at 10:05 PM, Beck, Nancy <Beck.Nancy@epa.gov> wrote: This is bizarre. On our call when we discussed reaching out to Stabenow, Rick clearly stated that he would state that believed his staff spoke prematurely and that they were looking at all the options. Rick seems like such a straight shooter this just isn't adding up. Are we sure that Rick was the only one that spoke w Stabenows office and there wasn't some other call with his staffer? I can check w Sven as he would have been on the call. Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273 Beck.Nancy@epa.gov Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00044384-00001 On May 10, 2017, at 9:27 PM, Palich, Christian <palich,christian@epa.gQv> wrote: I sat in on that call for a minute but was pulled away to another meeting, ill follow up with career staff in the morning to see a status. I'll defer to Nancy on how to handle this more technical response. Thanks so much for the heads up Scott. Christian R. Palich Deputy Associate Administrator Congressional & Intergovernmental Relations 202.306.4656 Sent from my iPhone On May 10, 2017, at 9:15 PM, Bennett, Tate <Bennett.Tate@epa.gov> wrote: Thank you for the heads up. Looping in Nancy as it relates to the imminent hearing tomorrow. We probably need to give some messaging instructions on this so he doesn't tie our hands "on the record." Thoughts? On May 10, 2017, at 9:10 PM, Scott Herndon <sherndon@americansugarbeet.org> wrote: Tate, I wanted to give you a heads up that Senator Stabenow's Ag. Committee staff spoke with EPA career staff this afternoon. The EPA staff don't believe that they have any room on this issue and still believe there is a data gap. From what Stabenow's staff relayed to me, EPA staff characterized the Section 18 component as relatively straightforward under FIFRA but the Food Drug and Cosmetic Act (FDCA) requirements for residues and granting tolerances are very strict. Under Section 18, the cost benefit analysis can weigh the economic harm, etc. I asked them to triple check with EPA that they were looking at the data SipCam submitted on Friday and they said they would (attached). Also, they may bring this up at the Senate Agriculture hearing tomorrow with the Director of Pesticide Programs. We did not ask them to do this but I also don't think that I can ask them not to do it. I just wanted to give you a heads up so you all wouldn't be caught offguard. Hearing info here: https://www.agriculture.senate.gov/hearings/pesticideregistration-under-the-federal-insecticide-fungicideand-rodenticide-act-providing-stakeholders-with- Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00044384-00002 certainty -through-the-pesticide-registrationimprovement-act Thanks again! Scott Scott Herndon Director of Biotechnology and Regulatory Affairs American Sugarbeet Growers Association 202-595-0786 From: Cassie Bladow [mailto:Cassie.Bladow@beetsugar.orgl Sent: Tuesday, May 09, 2017 4:43 PM To: Bennett, Tate <6ennatf.Tate@ep3.gov>; Scott Herndon <sherndon@americansugarbeet.org> Subject: RE: Section 18 Thank you, Tate! Really appreciate your help! From: Bennett, Tate [maiito:Bennett,Tate@epa,.gov1 Sent: Tuesday, May 9, 2017 4:37 PM To: Scott Herndon <sherndon@amercansugarbeet.org> Cc: Cassie Bladow <Cassie.Bladosv@heetsugar.org> Subject: RE: Section 18 FYI we are on it. Interesting. I'm not confident her management is aware of these conversations. Will find out. Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273 ZZZ^iZZZZZZ Beck.Nancy@epa.gov From: Scott Herndon [mailto:sherndon@amenc3nsugarbeet.org1 Sent: Tuesday, May 9, 2017 4:09 PM To: Bennett, Tate <BennettTate@epa.gov> Cc: Cassie Bladow <C3ssie.Bladow@beetsugar.org> Subject: RE: Section 18 Tate, I've looped Cassie back in and wanted to give you both an update. Dr. Mohamed Khan with NDSU had a conversation with Andrea Conrath at EPA (her contact Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00044384-00003 information is below) this morning about the new data that was supplied by SipCam. Dr. Khan prepared the Section 18 applications that were requested by the ND and MN Departments of Agriculture. He also prepared the application that we expect the Michigan Department of Agriculture to file soon. In his email to me he stated "I spoke to Andrea today at EPA. Unfortunately, she does not believe the new tolerance data submitted will help. Seems they are looking for some data for some other studies." I have been unable to determine what additional data they need and have asked Dr. Khan if that was relayed to him but have not yet heard back. <image001.jpg> Thanks! Scott Herndon Director of Biotechnology and Regulatory Affairs American Sugarbeet Growers Association 1155 15th Street NW #1100 Washington, DC 20005 202-595-0786 ---- Original Message----From: Scott Herndon Sent: Monday, May 8, 2017 5:43 PM To: 'Bennett, Tate' <Bennett.Tate@epa.gov> Subject: RE: Section 18 SipCam has state registrations for Cercos (brand name) in Michigan, North Dakota, Minnesota. North Dakota expires in 12/31/2017 Michigan expires in 6/30/2017 Minnesota expires 12/31/2017 SipCam will renew all of them Scott Herndon Director of Biotechnology and Regulatory Affairs American Sugarbeet Growers Association 1155 15th Street NW #1100 Washington, DC 20005 202-595-0786 ---- Original Message----From: Bennett, Tate [mailto:Bennett.Tate@epa.gov] Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00044384-00004 Sent: Monday, May 8, 2017 5:33 PM To: Scott Herndon <sherndon@americansugarbeet.org> Subject: Re: Section 18 Do these states currently have permits? What is the exact date of expiration? > On May 8, 2017, at 5:20 PM, Scott Herndon <sherndon@americansugarbeet.org> wrote: > > Tate, > > Apologies for the delay! I am now back at my computer and have put together a short backgrounder as well as relevant industry contacts. > > I have also attached the correspondence from EPA to the ND and MN Departments of Agriculture asking them to withdraw their request. > > In addition, I have attached a cover letter that SipCam submitted to EPA on Friday, May 5th with additional data. > > Thanks so much for your help and please don't hesitate to email or call if you have any questions. > > Have a great evening! > > Scott > > Scott Herndon > Director of Biotechnology and Regulatory Affairs American Sugarbeet > Growers Association > 1155 15th Street NW #1100 > Washington, DC 20005 > 202-595-0786 I Ex. 6 1 l__________________________________________________ : > > -- Original Message----- > From: Bennett, Tate [mailto:Bennett.Tate@epa.gov] > Sent: Monday, May 8, 2017 3:34 PM > To: Scott Herndon <sherndon@americansugarbeet.org> > Cc: Cassie Bladow <Cassie.Bladow@beetsugar.org> > Subject: Re: Section 18 > > Thanks! > On May 8, 2017, at 3:32 PM, Scott Herndon <sherndon@americansugarbeet.org> wrote: Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00044384-00005  Tate, I have all of the information in my office but am on the Hill right now. I'll send everything to you this evening. Thanks so much! Scott Sent from my iPhone > On May 8, 2017, at 3:13 PM, Bennett, Tate <Bennett.Tate@epa.gov> wrote: > > Hey Scott- do you have any summaries/background papers? > On May 8, 2017, at 2:47 PM, Cassie Bladow <Cassie.Bladow@beetsugar.org> wrote: Tate, Thank you for taking the time to chat this morning. As we discussed, I am looping Scott Herndon who works for the American Sugarbeet Growers Association into the conversation since he has done a lot of work on this issue and will be able to provide you with background and answer any questions you have. We really appreciate your guidance helping us move this along, especially given our tight timeline. Thanks again! Cassie > <Section 18 for Chlorothalonil Contacts.docx> <Chlorothalonil > Background.docx> > <2017-05-05 Chlorothalonil Tech- Echo 500 Sugarbeet Tol Pet-Label > Amend-C....pdf> <EPA email to ND and MN Departments of > Agriculture.docx> <2017-05-05 Chlorothalonil Tech- Echo 500 Sugarbeet Tol Pet-Label Amend-C....pdf> Sierra Club v. EPA 18cv3472 NDCA Tier 12 ED 002061 00044384-00006