Acetamiprid Registration Review

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity This study has been broken into multiple parts, and

Please find the attached comments from the Center for Biological Diversity and Pesticide Action Network. Due to the covid-19 pandemic, we are unable to send additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted our additional materials to docket #EPA-HQ-OPP-2008-0844. We request those additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

These are additional materials to accompany the comments by Center for Biological Diversity. Due to the covid-19 pandemic, we are unable to send these additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted these additional materials to docket #EPA-HQ-OPP-2008-0844. We request these additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you. See attached files. Center for Biological Diversity

Please find the attached comments from the Center for Biological Diversity and Pesticide Action Network. Due to the covid-19 pandemic, we are unable to send additional materials via U.S. Mail. Due to the cumbersome nature of uploading many documents on this site, we have only submitted our additional materials to docket #EPA-HQ-OPP-2008-0844. We request those additional materials be incorporated into the record for all 5 neonicotinoids currently under registration review in dockets EPA-HQ-OPP-2012-0329, EPA-HQ-OPP-2011-0865, EPA-HQ-OPP-2011-0920, EPA-HQ-OPP-2008-0844, EPA-HQ-OPP-2011-0581. Thank you

In addition to the attached comments, the Center for Biological Diversity would like to remind the agency that acetamiprid is a neonicotinoid pesticide. While other neonics are currently undergoing enhanced scrutiny due to the demonstrated negative effects this class of pesticides is having on pollinators and other terrestrial invertebrates, aquatic invertebrates and bird and mammal populations, somehow acetamiprid only received a generic ecological risk analysis with enough data gaps to drive a large truck through. This is absolutely unacceptable for a systemic insecticide that has the potential to be very widely used based on current crop use approvals (fruit and fruit trees, tree nuts, vegetables, tuberous crops, alfalfa, canola, sweet corn, cotton, soybean, ornamentals, and tobacco). Any mitigation measures, product cancellations, and/or mandatory label requirements for any of the other four neonicotinoids currently receiving enhanced scrutiny during registration review must be applied in a similar manner to acetamiprid as well. Failure to do so will be a direct violation of EPA's duties under FIFRA.