Emergency Petition Seeking Suspension of Registration for Clothianidin

September 25, 2012 Ms. Marianne Lewis Director, Registration Division Office of Pesticide Programs US Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, NW Washington, DC 20460 Re:Clothianidin Docket EPA-HQ-OPP-2012-0344; FRL-9355-1 The California Specialty Crops Council (CSCC) respectfully submits our comments regarding the continued registration of clothianidin. We recommend the Agency deny the request to immediately suspend the registrations, initiation of special review and issuance of a stop sale, use, and removal order of products which contain this active ingredient. The California Specialty Crops Council supports the continued use of this product on non-blooming crops per label instructions and at all times urges growers, pest control advisors and consultants to utilize products and practices which protect and minimize impacts to honey bees, native pollinators and other beneficial insects. The California Specialty Crops Council is a grower supported 501(c) 5 non-profit organization and is a resource for field based information spanning horticultural crop production, pest management and stewardship activities. Our membership includes beekeepers, pest control advisors, and producers of fruit, root, leafy green, vegetable, vine, and berry crops (fresh, dried, and processed). The combined value and acreage of CSCC stakeholders includes $6 Billion annual production on approximately 700,000 acres of California farmland. The California Specialty Crops Council is committed to transparent scientific and technical exchange, responsible agricultural practices and effective public policy solutions developed through partnerships with growers, beekeepers, the scientific community, policymakers and other stakeholders. In California, agriculture is a primary industry generating over $37 billion dollars annually from approximately 350 specialty crops. Many of our most important crops (almonds, cherries, plums, appl