Document dnEq9DK05NoMmrznMrOON8kr0

Message From: Sent: To: CC: Subject: Daguillard, Robert [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=BBE9682B940C4F2C90732E4D37355DD4-DAGUILLARD,] 5/25/2018 5:45:54 PM John Bray | x."6 i Press [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=b293283291dc44eOb5dlc36be9281d8a-Press] RE: John:,Your questions for EPA Jcoohmnm, tehnatn,kass athgeayin'l.lSbteilsltobnebaabclekgtorouexnpdl:aWin eth'lleibrerereafseornrsinfgoryosueetkointhgethDeisetxreicmtpotfioCno. lumbia government for Have a great holiday week-end. Cheers, R. Robert Daguillard Office of Media Relations U.S. Environmental Protection Agency Washington, DC +1 (202) 5 6 4 -6 6 1 8 (O) Ex. 6 ! From: John Bray [mailto:! x. 6 j Sent: Friday, May 25, 2018T:T0'PM ' To: Daguillard, Robert <Daguillard.Robert@epa.gov> Subject: Re: John:,Your questions for EPA R, Was there anything in your file where DC explained its reason for seeking the exception? Wouldn't the application need to explain in some detail the motivation? Or can they just say, we think ginkgo smells bad. Thanks. John On Fri, May 25, 2018 at 11:51 AM, Daguillard, Robert <Daguillard.Robert@epa.gov> wrote: Hullo j ohn, I just heard your voicemail just now. Let me know what you need. Email is probably easiest. Cheers, R. Robert Daguillard Office of Media Relations U.S. Environmental Protection Agency Washington, DC Sierra Club v. EPA 18cv3472 NDCA Tier 13 ED 002061 00015754-00001 +1 (202) 564-6618 (O) Ex. 6 From: Daguillard, Robert Sent: Friday, May 25, 2018 10:50 AM To: 'John Bray'i x'" Ce: Press <Press@epa.gov> Subject: RE: John:,Your questions for EPA John, again on background --meaning for attribution to U.S. EPA, please: uEFthnonedrvleiEarrboPtenhAlmeftoeFornrpetcerhfodolvoorirmdapercoooapfpchIynoapofmoyf'rstmohufeasiDterioC2on4n'sA(g2cci)4nt(.rkce)ggAorinseitgnraialsDtttieroCrannt..iaotinUveasipanppglpitcrhaoetaiocfonhl,lwothwoeuinlrdgeqbliuenekts,ototahrsewkroeDuqClud'esnsDteoeerdpcataorntmsoubebtnmatiniot faaEcrenoqepruygeyostf& Cheers, R. Robert Daguillard Office of Media Relations U.S. Environmental Protection Agency Washington, DC +1 (202) 564-6618 (O) Ex. 6 From: John Bray fmailtoj Ex. 6 Sent: Tuesday, May 22, 2018 7:3 AM To: Daguillard, Robert <Daguillard.Robert@epa.gov> Subject: Re: John:,Your questions for EPA Hi Robert, Thanks for the information. What do you mean by "background." Do have a link to the original application from D.C.? Thanks. John Sierra Club v. EPA 18cv3472 NDCA Tier 13 ED 002061 00015754-00002 On Mon, May 21, 2018 at 1:48 PM, Daguillard, Robert <PaRuillard.Robert@epa.gov> wrote: John, on background, please: 1. What 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 Botrytisfungal 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. Sierra Club v. EPA 18cv3472 NDCA Tier 13 ED 002061 00015754-00003 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? DCs 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. 7.1s 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 inform ation.pdf), there are no risks of concern to other fruiting trees. 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 DaguiHard U,S, EPA Office of Media Relations Washington D.C, Ex. 6 202-564-6618 CO) Sierra Club v. EPA 18cv3472 NDCA Tier 13 ED 002061 00015754-00004