Overview
Title
Clothianidin; Receipt of Application for Emergency Exemption; Solicitation of Public Comment
Agencies
ELI5 AI
The EPA is asking people what they think about using a special spray to help Florida farmers protect young orange trees from getting sick, but some are worried that using this spray too much might not be safe for nature or other animals.
Summary AI
The Environmental Protection Agency (EPA) has received a request from the Florida Department of Agriculture and Consumer Services to allow the use of the pesticide clothianidin on up to 75,000 acres of young citrus trees to fight Huanglongbing (HLB) disease. This exemption request, repeated for several years, argues that without clothianidin, farmers might face significant financial losses as there are limited alternative solutions available. The EPA is asking for public comments before deciding whether to approve this exemption. Comments must be submitted by January 29, 2025.
Abstract
EPA has received a specific exemption request from the Florida Department of Agriculture and Consumer Services (FDACS) to use the pesticide clothianidin (CAS No. 210-880-92-5) to treat up to 75,000 acres of immature (3-5 years old) citrus trees to control the transmission of Huanglongbing (HLB) disease vectored by the Asian Citrus Psyllid. The applicant proposes a use that has been requested in 5 or more previous years and for which a complete application for registration or tolerance petition has not been submitted to the Agency. Therefore, EPA is soliciting public comment before making the decision whether or not to grant the exemption.
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AnalysisAI
The Environmental Protection Agency (EPA) has published a notice about a request it received from the Florida Department of Agriculture and Consumer Services (FDACS). This request seeks to use a pesticide, clothianidin, to treat up to 75,000 acres of young citrus trees. The intention is to control the spread of Huanglongbing (HLB) disease, a severe condition affecting citrus trees and vectored by the Asian Citrus Psyllid. This exemption application, notably resubmitted over multiple years, highlights the ongoing struggle to control this disease effectively with limited alternatives. The EPA invites public comments on this exemption request, which must be submitted by January 29, 2025.
Significant Issues and Concerns
The primary concern raised by this notice is the apparent reliance on clothianidin due to the stated "lack of available alternative pesticides and effective control practices." This dependency could discourage exploration of other integrated pest management strategies that might offer more sustainable solutions. Furthermore, with the application submitted multiple times without approval for registration or tolerance petition, it suggests ongoing unresolved regulatory or safety concerns. The document does not provide clarity regarding the factors contributing to previous decisions not to register or tolerate this use, leaving room for public uncertainty.
Moreover, potential impacts of the pesticide on non-target species and broader ecological systems are not discussed in the notice. This absence might contribute to public apprehension, particularly given wider environmental consciousness and concerns on pesticide use.
Public Impact
The document signifies a significant regulatory decision that could impact both agricultural practices and environmental health. Broadly, the public might experience varied consequences from this decision. Approval of the exemption could help citrus growers combat HLB disease, protecting economic interests in Florida's citrus industry. This provides some assurance regarding agricultural livelihoods and market stability. However, dependence on a single pesticide, especially with outstanding regulatory questions, invites concerns about health, safety, and environmental impacts.
Impact on Specific Stakeholders
Citrus Growers: The exemption could potentially safeguard their crops against HLB disease, mitigating financial losses which have been a recurring threat. The availability of an effective pesticide is likely to be seen positively within this group, especially in the absence of equally effective alternatives.
Environmental Groups: These stakeholders may express concerns about the environmental implications of authorizing the use of clothianidin, particularly around its effects on biodiversity and ecological health. The absence of addressed concerns regarding non-target impacts may attract substantial scrutiny.
Public Health Advocates: There is likely to be ongoing interest from public health perspectives due to questions surrounding the safety and regulatory status of clothianidin. Without detailed explanations for previous non-approvals, advocates may continue to press for stringent safety assessments.
Conclusion
In conclusion, the EPA's notice regarding FDACS's exemption application for using clothianidin on citrus trees highlights a complex decision point straddling economic, environmental, and regulatory considerations. While the request aims to address a pressing agricultural challenge, the gaps in discussion about alternative solutions, comprehensive impact evaluations, and prior decision criteria leave room for cautious deliberation among stakeholders and the public. The period for comment represents an opportunity to influence a critical decision in the management of Florida's citrus industry and broader environmental health policy.
Issues
• The document suggests reliance on clothianidin due to 'lack of available alternative pesticides and effective control practices,' which raises concerns about potential dependency on a single pesticide without exploration of other integrated pest management strategies.
• The application has been requested in five or more previous years without approval for registration or tolerance petition, indicating persistent unresolved regulatory or safety concerns.
• The document does not clarify what considerations are driving the decision to not register or tolerate the use previously, which could be important for public understanding.
• The language used to describe the environmental justice considerations could be expanded to ensure it is inclusive of all possible impacts, not solely those based on ethnicity or income.
• Potential concern over the impact of clothianidin on non-target species and the broader ecosystem is not addressed in the document, which could be a contributing factor to public interest or concern.