Proposal to Revoke Chlorpyrifos Food Residue Tolerances Related Information Basic information on chlorpyrifos uses and EPA actions Revised chlorpyrifos human health risk assessment Learn more about food residue tolerances In October 2015, EPA proposed to revoke all food residue tolerances for the insecticide chlorpyrifos. At this time, EPA is unable to make a safety finding as required under the Federal Food, Drug, and Cosmetic Act (FFDCA). We will respond to all comments received on the proposal and make a final decision by March 31, 2017. In November 2016, we revised our human health risk assessment. This revised analysis shows risks from dietary exposure (i.e., residues of chlorpyrifos on food crops) and drinking water. It does not result in a change to our proposal, but after considering the advice of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Scientific Advisory Panel (SAP), we are modifying the methods used to support that finding. Learn more about the revised human health risk assessment and opportunity to comment on the assessment. Read the proposed tolerance revocation rule. On this page: 1. Why is EPA proposing to revoke all tolerances for chlorpyrifos? 2. What uses of chlorpyrifos are affected by this proposed tolerance revocation? 3. What are the specific concerns associated with drinking water? 4. What are EPA's next steps? 1. Why is EPA proposing to revoke all tolerances for chlorpyrifos? In June 2015 EPA indicated its intention to issue a proposed rule revoking tolerances by April 15, 2016, to address previously identified drinking water concerns and in response to a petition from the Natural Resources Defense Council (NRDC) and Pesticide Action Network North America (PANNA). This schedule would have allowed time for EPA to complete its additional analysis, taking into consideration the public comments received on its December 2014 human health risk assessment. On August 10, the 9th Circuit Court rejected EPA's time line, instead ordering EPA by October 31, 2015, to: deny the petition, issue a proposed revocation, or issue a final revocation rule. At that time, EPA did not deny the petition because we were unable to make a safety finding based on the science as it stood. At that time, EPA did not issue a final revocation rule because we had not completed our revised human health assessment and refined drinking water assessment, so certain science issues were still unresolved. Based on the 2014 analysis, EPA could not conclude that the risk from aggregate exposure met the Federal Food, Drug, and Cosmetic Act (FFDCA) safety standard. EPA has determined that safe levels of chlorpyrifos may be exceeded in parts of the United States for people whose drinking water is derived from some small vulnerable watersheds where chlorpyrifos is heavily used. We informed the court, we proposed to revoke all chlorpyrifos tolerances based on the science as it stood. Issuing a proposed revocation provides an opportunity for public input prior to any final decision. The court also required EPA to provide the timeline for a final rule should EPA issue a proposed revocation. The court has extended the deadline for issuing a final rule to March 31, 2017. In November 2016, we revised our human health risk assessment and drinking water exposure assessment for chlorpyrifos that supported our October 2015 proposal to revoke all food residue tolerances for chlorpyrifos. The revised analysis shows risks from dietary exposure (i.e. residues of chlorpyrifos on food crops) and drinking water. 2. What uses of chlorpyrifos are affected by this proposed tolerance revocation? Because tolerances are the maximum residue of a pesticide that can be in or on food, this proposed rule revoking all chlorpyrifos tolerances means that if this approach is finalized, all agricultural uses of chlorpyrifos would cease. Learn more about tolerances. According to USDA data there are approximately 1.2 million crop producing farms in the U.S. EPA estimates that more than 40,000 crop producing farms currently use chlorpyrifos to control a wide range of insect pests. Cost effective alternatives are available to control many of the pests targeted by chlorpyrifos. Some farms growing certain crops (e.g., broccoli, cauliflower, cabbage, citrus, etc.) may be affected more than others by the loss of the use of chlorpyrifos. Learn more about the uses of chlorpyrifos. 3. What are the specific concerns associated with drinking water? EPA's 2014 revised human health risk assessment showed the potential for risks in small watersheds with high concentrations of farming where chlorpyrifos may be widely used. The 2014 assessment included a refined drinking water assessment for the Pacific Northwest and the Southeast, but not the entire country. EPA determined that safe levels of chlorpyrifos may be exceeded for people whose drinking water is derived from certain vulnerable watersheds in parts of the United States. EPA completed its refined drinking water assessment in 2016. While this drinking water assessment is more refined than the previous assessments, the results did not identify many areas where potential exposures of concern to drinking water can be ruled out. As a result, this assessment does not significantly alter the conclusions in the proposed rule regarding drinking water exposure and continues to indicate potential exposure to chlorpyrifos. While EPA completes the final rule, anyone who has concerns about contaminants in their public drinking water system should check with their local water utility or state. Local authorities are not required by EPA to test for chlorpyrifos, since EPA has no federal drinking water regulation for chlorpyrifos. However, some local authorities do test for contaminants beyond federal drinking water regulations. 4. What are EPA's next steps? EPA plans to issue a final rule on chlorpyrifos tolerances by the courtordered deadline of March 31, 2017, after considering comments received on the revised analyses. LAST UPDATED ON MARCH 30, 2017 American Agriculture Speaks Out in Support of Chlorpyrifos (Jan 16, 2017) The attached petitions with 2300 signatures in support of chlorpyrifos, represent American growers, farmers and others from across the U.S. who are involved in producing the food American consumers rely on and the crops that are important exports supporting U.S. trade. Signees have a simple, common message to EPA: We ask you, the US EPA to retain the current crop tolerances and the continued registration and availability of use of the chlorpyrifos-containing products we need. Those involved with production of citrus, corn &soybean, cotton, wheat and sugar beets have petitions specific to their crop so they could emphasize the critical importance of chlorpyrifos to their operations. Crop-specific petitions were signed by; 199 for citrus 619 for corn & soybean 187 for cotton 399 for wheat 224 for sugar beets For other crops, 672, representing the full range of crops on labels for chlorpyrifos products, signed the petition. Petitions were signed during EPA's public comment period for EPA's Chlorpyrifos: Tolerance Revocations; Notice of Data Availability and Request [EPA-HQ-2015-0653] from November 17, 2016 to January 16, 2017.Signatures were collected by Dow AgroSciences and are being submitted by Dow AgroSciences with the understanding and agreement of those who signed the petitions. Submitted on January 16, 2017 by: Dow AgroSciences, LLC 9330 Zionsville Rd Indianapolis, IN 46268 1 Chlorpyrifos is a critical tool for American crop production In the United States, growers of more than 50 different types of crops, including cereal, oil, forage, fruit, nut and vegetable crops count on chlorpyrifos as a critical tool. Farmers rely on chlorpyrifos because of its efficacy, broad-spectrum control, low cost, and tank mix compatibility. For many important pests, growers face limited or no viable alternatives to chlorpyrifos. And, when an outbreak of a new pest occurs, growers look to chlorpyrifos as a proven first-line of defense. Growers also look to chlorpyrifos for the ease of implementation into existing Integrated Pest Management and Integrated Resistance Management programs, and the minimal impact on beneficial insects compared to alternative chemistries. We ask you, the US EPA to retain the current crop tolerances and the continued registration and availability of use of the chlorpyrifos-containing products we need. First Name Last Name State Manfred Schosnig OR Yes I have read and understand that this petition will be submitted into official public comment dockets and any personal information included may be publicly viewable Indicate yes by checking here 1 KENNETH TAMURA IDAHO 1 Jimmy Wood Ga. 1 mark hawke GA 1 Don Tolmie Idaho 1 Katherine Blanchard WA 1 Joe Weitz ID 1 Leland Tiegs Idaho 1 Matthew Ray GA 1 Keith Kubik California 1 Gary Lucas Idaho 1 Gene Schmitt Idaho 1 Leslie Dean ID 1 Richard Matteson North Dakota 1 Justin Lynch Washington 1 Kevin Marshall Oregon 1 Sidney Naito ID 1 Grady Whiddon Ga 1 Matthew Hamilton OR 1 Austin Purvis Georgia 1 2 Talley Brim Ga 1 Joel Horn CO 1 Harold Mckay Oregon 1 Josh White GA 1 Darin Garland GA 1 Donna Cowart GA 1 Matt Taylor GA 1 Chase Floyd GA 1 Willie Wiggins GA 1 Jimmy Wiggins GA 1 Greg Howard Ga 1 Jeffrey Howard GA 1 Lamar White GA 1 Rebecca White GA 1 McKinley White GA 1 June Howard GA 1 Aaron Wolff KS 1 Kenneth Tucker KS 1 Michael Bahr Kansas 1 Cole McCurry KS 1 Ryan Mcbride Oklahoma 1 Shawn Thornton Ks 1 Travis Kolm Kansas 1 Keith Hulteen Colorado 1 Brett Despain Idaho 1 Julie Gordon MI 1 Brent Sutton DE 1 russell byerley washington 1 Josh Prow WA 1 Kevin Schwertfeger Kansas 1 Timothy Guttridge OREGON 1 Thomas Egan Oregon 1 jeff Newton Oregon 1 Justin Jones Georgia 1 Matt Storlie Idaho 1 Willis Connell NC 1 Tim Semler ND 1 shawn knudson north dakota 1 JP Tom Bodderij Arizona 1 Jason Richter North Dakota 1 Wayne Christ North Dakota 1 Ben Lee ND 1 Andy Grundstad North Dakota 1 William McMullin UT 1 3 Damon Christensen Washington 1 Alan Gilbert WASHINGTON 1 Brett Lolley Idaho 1 Lynn Register NC 1 Scott Ginn NC 1 Robbie Whitfield NC 1 Marvin Sutton NC 1 Brock Leonard WA 1 MERLE BLOCK ND 1 Douglas Duerst Oregon 1 Nancy Aerni OR 1 Kyle Gilbert WA 1 Marty Coble WA 1 James Cadwallader NM 1 Wyatt Smith Oregon 1 Brian Dugo California 1 Nicholas Martin KS 1 David George SC 1 Sarah Cassel North Dakota 1 Jerry Domes Oregon 1 Sam Krautscheid WA 1 James Boyles Georgia 1 Tamara Duchsherer ND 1 Angela Beehler WA 1 Steven Thonney Washington 1 Todd Crosby Oregon 1 Mark Millard Oregon 1 Wally D Huppert Washington 1 Michael McKoen Oregon 1 Craig St. Hilaire WA 1 John Meeks Georgia 1 Neal Braswell GA 1 Jay Hendley Georgia 1 William Ward NC 1 Joseph Brincks ND 1 Lily Hyman NC 1 Ross Greene GA 1 Brian Walsh North Dakota 1 Galen scheresky ND 1 Greg Schultheis WA 1 Justin Krieg ND 1 James Freeman Georgia 1 Crystal Gaillard Georgia 1 Ronald Juris Washington 1 4 To: Benton, Cc: Bangerter, Davis, From: Ferris, Lena Sent: Thur 3/2/2017 8:01 :50 PM Subject: RE: Farm Bureau Meetino with WA State embers of the American Farm Bureau Federationdocx Don here is the meeting summary from yesterday?s Farm Bureau Meeting. The synopsis of participant concerns is on page three so can act as a stand?alone document should you prefer that. Happy to follow up on any of the issues or set up meetings for you on speci?c topics that you would like to know more about with the program of?ce?s. Lena Ferris Special Assistant to the Agricultural Advisor Of?ce of the Administrator From: Benton, Donald Sent: Wednesday, March 01, 2017 5:02 PM To: Ferris, Lena Subject: Farm Bureau Lena, Could you please provide me with a synopsis of the concerns from the group as we went around the table. Thanks, Don Senator Don Benton Senior White House Advisor Of?ce of the Administrator 202.564.4711 Meeting with WA State Members of the American Farm Bureau Federation Wednesday March 1 2017 Al Alnl Conference Room EPA Headquarters EPA Staff from the Office of the Administrator: Don Benton Layne Bangerter Patrick Davis Lena Ferris WA State Farm Bureau Participants: first Name Middle Last {same ., I . . .- khti?i? . He?! Ljs?. i: 23.5':?ieh??t-ri??F act-tine Hawaii?: his 9.: as; Don Benton began the meeting with a series of opening remarks focused on the below themes: The new Administration is committed to a transparent and inclusive way ofmoving forward. The new Administration recognizes that farmers are stewards and conservationists as their livelihood is based on a healthy environment and therefore farmers and ranchers already come with an understanding and an inherit desire to protect the environment. The new Administration is committed to developing new relationships between EPA and the agricultural community; a relationship based on partnerships not on regulations and enforcement. The new Administration will be appointing many new political appointees to help implement this new relationship between EPA and the agricultural community. 10 new RA ?5 will be appointed and thousands ofother positions across the Administration. Our goal is to help farmers comply with the law in a way that make sense. Discussed the role ofEPA?s Farm Ranch and Rural Communities PACA Committee and opportunities for new membership in the next few months. Don also indicated that he has already talked to the Dairy Federation regarding issues related to the Yakima Valley nitrates and understands this is a real concern for the WA State Dairies. Administrator Prnittjoined the group for brief remarks. His remarks focused on the following themes: 3" Stressed that this is a new day. a new Future, for a common sense approach to environmental protection. 3? President Trump signed Executive Order for EPA to reconsider and rewrite the WOTUS regulation and Administrator Pruitt wasted no time signing a FR Notice to begin implementation of that process. 3? Regulations must be regular and provide the impacted communities with certainty about how to comply so that businesses can plan For necessary changes and resources. 3? Regulations need to be written based on language speci?cally addressed within the environmental statutes and not have the statutes interrupted to meet broader goals they were not specifically designed to meet. 3? The new Administration understands the tremendous economic impact agriculture plays in our economy and is looking forward to working closely with the agricultural community. The meeting then proceeded by allowing for each of the participants to go around the room and make an observation or raise a concern. Topics were not resolved rather it was designed as a listening session for EPA to hear the concerns of the participants. ObservationsiConcerns raised by participating members of the WA State Farm Bureau: ?What All the participants raised concern regarding the ?What?s Upstream" campaign that was funded through a subgrant awarded through Region 10 Of?ce. He miamijv ()veri'eacn: Members expressed concern that farmers and ranchers need for EPA to go back to what our statutes are designed to do. Partners are trying to Feed the world and EPA is making that mission harder and harder. EPA needs to be a partner in this mission not a barrier. (.?on?iciing Science: Outstanding issues regarding conflicts between EPA science and NRCS science. .S'eciian 319 Grants: The CWA 319 program has too many requirements that many farmers don't even consider applying For the grants any longer; which is just another example of EPA making is so dif?cult For farmers to want to be involved in EPA programs. zlr'atrix of?Regrilaiions: For small land owners and farmers it is usually the wife or a member of the family that is trying to navigate through the web of regulations and with more and more complicated requirements small farmers are being pushed out of business. The vulnerability of being prosecuted isn?t worth the risk to keep farming. Pesticide A The huge reduction in the number or" pesticides available is a large concern. When a pesticide is taken off the market farmers need more than one alternative to choose from. Farmers are always dealing with new invasive species and need more options not less for selecting pesticides to deal with those challenge. Worker Protection Standards: Concern regarding the IOU-foot exclusion zone (buffer zone) around the application equipment for the spraying of pesticides. (.?on?icrs; Concern regarding the often conflicting and confusing and mounting requirements between EPAKFDA Phase-0m: Concern regarding the phase-out and the impact on smaller Fanns that use cold storage warehouses and dif?cultiesicost impacts to transitioning to other options. Dairy Industry Concern that EPA does not understand enough about how the dairy industry works in real life and is hoping for better partnership with EPA in the coming months. Need a reasonable approach to regulating this pesticide and would like the farming community to be more involved in the process. Change: Members were excited about the new goals ofthe Administration. excited to be part ofthe change to WOTUS and expressed optimism andjoy to have opportunities to partner with an EPA that is trying to help them succeed. 6 To: Cc:​ ​From:​ ​Sent:​ ​Subject: Dravis,​ ​ ​Samantha[dravis.samantha@epa.gov] Minoli,​ ​Kevin[Minoli.Kevin@epa.gov];​​ ​ ​ ​Flynn,​ ​Mike[Flynn.Mike@epa.gov]​​ ​Jackson,​ ​Ryan Fri​ ​3/3/2017​ ​12:29:19​ ​AM Re:​ ​Chlorpyrifos​ ​Meeting​ ​on​ ​Friday I​ ​don't​ ​have​ ​anything​ ​on​ ​my​ ​calendar.​ ​ ​ ​ ​Wendy​ ​has​ ​ask​ ​to​ ​talk​ ​to​ ​me​ ​about​ ​it​ ​and​ ​I've​ ​been​ ​involved with​ ​the​ ​Administrator​ ​all​ ​the​ ​time.​ ​ ​ ​I'm​ ​expecting​ ​to​ ​meet​ ​with​ ​Wendy​ ​tomorrow. Ryan​ ​Jackson​ ​Chief of​ ​Staff U.S.​ ​EPA (202)​ ​564-6999 7 On​ ​Mar​ ​2,​ ​2017,​ ​at​ ​7:26​ ​PM,​ ​Dravis,​ ​Samantha​ ​ ​ ​wrote: The​ ​meeting​ ​wasn't​ ​set​ ​up​ ​by​ ​me,​ ​it​ ​must​ ​have​ ​been​ ​Robin​ ​on​ ​my​ ​behalf​ ​after​ ​I​ ​suggested​ ​that this​ ​was​ ​a​ ​hot​ ​topic​ ​that​ ​required​ ​attention. Ryan​ ​and​ ​I​ ​need​ ​a​ ​briefing​ ​with​ ​the​ ​appropriate​ ​parties​ ​as​ ​soon​ ​as​ ​is​ ​possible.​ ​Thanks, Samantha Sent​ ​from​ ​my​ ​iPhone On​ ​Mar​ ​2,​ ​2017,​ ​at​ ​6:49​ ​PM,​ ​Minoli,​ ​Kevin​ ​ ​ ​wrote: Hi​ ​Samantha-​ ​I​ ​wanted​ ​to​ ​reach​ ​out​ ​to​ ​you​ ​and​ ​discuss​ ​a​ ​meeting​ ​request​ ​the​ ​one​ ​of​ ​OGC's attorney's​ ​received​ ​earlier​ ​today​ ​for​ ​a​ ​meeting​ ​on​ ​chlorpyrifos​ ​tomorrow. While​ ​we​ ​are​ ​happy​ ​to​ ​meet​ ​with​ ​you​ ​and​ ​others​ ​on​ ​that​ ​subject,​ ​there​ ​were​ ​a​ ​couple​ ​points of​ ​concern​ ​I​ ​need​ ​to​ ​raise.​ ​I​ ​realize​ ​that​ ​you​ ​may​ ​not​ ​have​ ​actually​ ​set​ ​up​ ​the​ ​invitation​ ​(a ton​ ​of​ ​meetings​ ​get​ ​set​ ​up​ ​under​ ​my​ ​name),​ ​but​ ​as​ ​the​ ​senior​ ​person​ ​in​ ​OP​ ​I​ ​felt​ ​it​ ​was appropriate​ ​to​ ​write​ ​to​ ​you. Ex.​ ​5​ ​-​ ​Deliberative​ ​Process,​ ​Attorney​ ​-​ ​Client​ ​Privilege To:​ ​From:​ ​Sent:​ ​Subject: Dravis,​ ​ ​Samantha[dravis.samantha@epa.gov]​​ ​Minoli,​ ​Kevin Fri​ ​3/3/2017​ ​1:52:35​ ​AM Re:​ ​Chlorpyrifos​ ​Meeting​ ​on​ ​Friday Hi​ ​Samantha-​ ​That​ ​is​ ​nice​ ​of​ ​you​ ​to​ ​send​ ​this​ ​follow-up,​ ​but​ ​you​ ​do​ ​not​ ​need​ ​to​ ​sing​ ​Robin's praises​ ​to​ ​me​ ​--​ ​I​ ​know​ ​she​ ​is​ ​great!​ ​I​ ​wasn't​ ​thinking​ ​of​ ​anything​ ​other​ ​than​ ​passing​ ​along​ ​word​ ​to combine​ ​the​ ​two​ ​meetings​ ​if​ ​you​ ​wanted​ ​as​ ​I​ ​didn't​ ​want​ ​to​ ​presume​ ​folks​ ​wanted​ ​me​ ​to​ ​do​ ​that. Happy​ ​to​ ​have​ ​you​ ​touch​ ​base​ ​with​ ​her​ ​instead,​ ​but​ ​please​ ​don't​ ​think​ ​I​ ​was​ ​upset​ ​at​ ​her​ ​or​ ​really anyone.​ ​Normally​ ​I​ ​would​ ​have​ ​called​ ​you​ ​rather​ ​than​ ​sent​ ​an​ ​email,​ ​but​ ​I​ ​had​ ​just​ ​heard​ ​about​ ​it at​ ​6:00​ ​and​ ​am​ ​out​ ​in​ ​the​ ​morning,​ ​so​ ​felt​ ​it​ ​was​ ​my​ ​only​ ​option. I​ ​will​ ​send​ ​a​ ​note​ ​to​ ​my​ ​folks​ ​that​ ​that​ ​they​ ​will​ ​likely​ ​see​ ​a​ ​revised​ ​invite​ ​or​ ​at​ ​least​ ​that​ ​the​ ​ ​invite was​ ​not​ ​meant​ ​to​ ​exclude​ ​folks,​ ​so​ ​unless​ ​you​ ​reschedule​ ​it​ ​so​ ​Ryan​ ​can​ ​attend​ ​they​ ​should​ ​be there​ ​at​ ​10:00. Hope​ ​you​ ​have​ ​a​ ​good​ ​night​ ​as​ ​well.​ ​Kevin. Kevin​ ​S.​ ​Minoli Acting​ ​General​ ​Counsel Office​ ​of​ ​General​ ​Counsel 8 US​ ​Environmental​ ​Protection Agency​ ​Main​ ​Office​ ​Line: 202-564-8040 On​ ​Mar​ ​2,​ ​2017,​ ​at​ ​8:33​ ​PM,​ ​Dravis,​ ​Samantha​ ​ ​ ​wrote: Kevin,​ ​I​ ​also​ ​just​ ​wanted​ ​to​ ​make​ ​sure​ ​to​ ​say​ ​that​ ​I​ ​really​ ​don't​ ​think​ ​Robin​ ​intended​ ​to​ ​do​ ​any harm.​ ​ ​She​ ​has​ ​gone​ ​above​ ​and​ ​beyond​ ​to​ ​help​ ​me​ ​this​ ​week,​ ​and​ ​has​ ​made​ ​me​ ​feel​ ​welcome here. I​ ​hate​ ​to​ ​reprimand​ ​her​ ​for​ ​something​ ​when​ ​I​ ​think​ ​she​ ​was​ ​really​ ​just​ ​trying​ ​to​ ​help​ ​on​ ​an​ ​issue that​ ​I​ ​had​ ​indicated​ ​was​ ​a​ ​time​ ​pressing​ ​topic.​ ​ ​Please​ ​bear​ ​with​ ​us​ ​as​ ​we​ ​learn​ ​routines​ ​and appropriate​ ​processes,​ ​etc.​ ​ ​thanks​ ​and​ ​hope​ ​you​ ​have​ ​a​ ​great​ ​evening. Sent​ ​from​ ​my​ ​iPhone On​ ​Mar​ ​2,​ ​2017,​ ​at​ ​8:07​ ​PM,​ ​Minoli,​ ​Kevin​ ​ ​ ​wrote: Sounds​ ​like​ ​if​ ​we​ ​simply​ ​combine​ ​the​ ​two​ ​meetings​ ​we​ ​will​ ​have​ ​Ryan​ ​and​ ​Samantha, as​ ​well​ ​as​ ​OCSPP,​ ​OP,​ ​and​ ​OGC,​ ​which​ ​would​ ​be​ ​great.​ ​I​ ​am​ ​happy​ ​to​ ​email​ ​Sharnett and​ ​Robin​ ​tonight​ ​to​ ​ask​ ​them​ ​to​ ​work​ ​together​ ​to​ ​do​ ​that​ ​if​ ​that​ ​works​ ​for​ ​you.​ ​We definitely​ ​agree​ ​you​ ​both​ ​should​ ​be​ ​briefed​ ​as​ ​soon​ ​as​ ​possible,​ ​so​ ​this​ ​would​ ​be​ ​a​ ​great result​ ​if​ ​you​ ​are​ ​ok​ ​with​ ​it. To: Cc:​ ​From:​ ​Sent:​ ​Subject: Dravis,​ ​ ​Samantha[dravis.samantha@epa.gov] Jackson,​ ​ ​Ryanuackson.ryan@epa.gov];​​ ​ ​ ​Flynn,​ ​Mike[Flynn.Mike@epa.gov]​​ ​Minoli,​ ​Kevin Thur​ ​3/2/2017​ ​11:49:38​ ​PM Chlorpyrifos​ ​Meeting​ ​on​ ​Friday Hi​ ​Samantha-​ ​I​ ​wanted​ ​to​ ​reach​ ​out​ ​to​ ​you​ ​and​ ​discuss​ ​a​ ​meeting​ ​request​ ​the​ ​one​ ​of​ ​OGC's attorney's​ ​received​ ​earlier​ ​today​ ​for​ ​a​ ​meeting​ ​on​ ​chlorpyrifos​ ​tomorrow.​ ​While​ ​we​ ​are​ ​happy​ ​to meet​ ​with​ ​you​ ​and​ ​others​ ​on​ ​that​ ​subject,​ ​there​ ​were​ ​a​ ​couple​ ​points​ ​of​ ​concern​ ​I​ ​need​ ​to​ ​raise.​ ​I realize​ ​that​ ​you​ ​may​ ​not​ ​have​ ​actually​ ​set​ ​up​ ​the​ ​invitation​ ​(a​ ​ton​ ​of​ ​meetings​ ​get​ ​set​ ​up​ ​under​ ​ ​my name),​ ​but​ ​as​ ​the​ ​senior​ ​person​ ​in​ ​OP​ ​I​ ​felt​ ​it​ ​was​ ​appropriate​ ​to​ ​write​ ​to​ ​you. From: Microsoft Outlook Location: Importance: Norma! Subject: Meeting Forward Noti?cation: Chlorpyrifos Start DateiTime: Fri 3:00:00 PM End DateiTime: Fri 313L201 7 3:30:00 PM Your meeting was forwarded i?igf?gL?gfg?ir] has forwarded your meeting request to additional recipients. if Kati Chiorpyrifos gee-tire; ?rtrrae Friday, 03 March 2017 10:00-10:30. Retiree-53:5 Brown, Byron F?a?i "tint-2:5; hated are in the tater-Nero Era-?rte: ear-:4: Eaetern T-rn?ri vim-:3 tier:- 'ir'y' It} rc sci?. oh: ride Sec 10 From: Microsoft Outlook Location: lmporlance: Normal Subject: Meeting Forward Notification: Chlorpyrifos Start Datei'Time: Fri 3l3f201? 3:00:00 PM End DatelTime: Fri 3i?3i?2017 3:30:00 PM Your meeting wee forwarded gage-?gamma has forwarded your meeting request to additional recipients. . o. Chlorpyrifos fee-item Tz: fie Friday, 03 March 2017 10:00-10:30. #2695223; feet; Sarah itigheraotatt?tjtitan: KineRUh mgf?aumi? . r: EsCRooinaRoi3800f?PEI IL. . time-f. Late-t: are time- :?onri. eat-em Tint: (Lit; F. Canada}- From: Dravis, Samantha Location: Importance: Normal Subject: Canceled: Chlorpyrifos - lnvitees Only Start DatelTime: Fri 3/3/2017 3:00:00 PM End Date/Time: Fri 3/3/2017 3:30:00 PM Contact Robin with questions 564-6587. To: Schnare, Dravis, Brown, Cc: From: Connors, Sandra Sent: Tue 3/7/2017 9:16:50 PM Subject: As requested - for your furtherjoint review and discussion: Compited List of Briefings/Background Papers Priority Baokoround Sandra Sandra L. Connors Senior Advisor Of?ce of the Administrator US Envirormlentai Protection Agency 1200 Avenue, Room 3317 Washington, DC 20460 (202)564?4231 connors.sandra?lcpagov 11 12 From: Dravis, Samantha Sent: Tuesday, March 07, 2017 8:38 PM To: Cleland?Hamnett, Wendy <{T?leland Cc: Kenny, Shannon 935?; MeGartland, Al wrote: We?re still working on a short overall brie?ng which provides some background to this, and for which this would be the last slide. But here?s what we?ve developed with OGC on options. We would talk about impacts of different options in the brie?ng. Ex. 5 - Deliberative Process 13 To: Dravis, From: Benton, Donald Sent: Wed 3r'8i201 7 2:34:47 PM Subject: Re: Checking in Weird, I was responding to your email about the 3pm. We meet everyday to boil down all the hot issues into what is most important for Scott to get decisions from him the next morning at the 8am. Love to have you instead of Shannon. She was asked yesterday to prepare a chronological list ofissues based on deadline dates due to bring to each meeting. See you at 3 today. Don Sent from my iPad On Mar 8, 2017, at 9:22 AM, Dravis, Samantha wrote: I didn't get a message here. Original Message--?-- From: Benton, Donald Sent: Wednesday, March 8, 2017 8:02 AM To: Dravis, Samantha Subject: Re: Checking in Sent from my iPad On Mar 8, 201?, at 6:55 AM, Dravis, Samantha wrote: Good morning gentlemen! l'm not sure what the 3pm meeting Shannon is referring to is, but from now on I would like to attend that going forward instead of Shannon. Could you forward me calendar invitations? Thank you! Original From: Kenny, Shannon Sent: Tuesday, March 7, 2017 5:40 PM To: Dravis, Samantha Cc: Rees, Sarah Subject: Checking in Ex. 5 - Deliberative Process I attended the 3:00 daily meeting with David and Don today. We may want to tatk more about that process and how to make it serve the Administrator better. it may also be good to chat about how to make it serve you better in your AA role. 14 To: Jackson, Cc: Brown, From: Dravis, Samantha Sent: Wed 3t8i2017' 6:38:53 PM Subject: Reg Reform Officer and Task Force - Approval Needed Summan of Regulatory Ei?sdoex interim guidance on Reducino Renulations EC) Final Version emanate Fresidentiat Memorandum Streamlining Permittino and Reducino Reoulatory Burdens for Domestic ivlanutacturirigdocx Ry an, Per our discussion over the past few days, the Executive Order on Referring {he Regulatory Refer?? Agenda requires EPA to implement and enforce regulatory reform and alleviate unnecessary regulatory burdens. As part of this Executive Order, EPA needs to designate an agency official as its Regulatory Reform Of?cer. in past administrations, this person has typically been the OP director. We will also need to establish a ?Regulatory Reform Task Force." Below are my suggestions for what we should send over to OMB, notifying them of these designations. Nothing else is required. On your green light, we will email OMB with the following. Regulatory Reform Of?cer: Samantha Dravis Regulatory Reform Task Force (subject to changes after new political appointees join): a i Byron Brown Brittany Bolen . 2: 5 2 Samantha Dravis i; i 5 i Ryan Jackson (Chairman) (you could change this if you like) To: Benton, Sehnare, From: Dravis, Samantha Sent: Wed 3l8f2017 11:55:32 AM Subject: FW: Checking in Good morning gentlemen! i'm not sure what the 3pm meeting Shannon is referring to is, but from now on i would like to attend that going forward instead ofShannon. Could you forward me calendar invitations? Thank you! Original From: Kenny, Shannon Sent: Tuesday, March 7, 2017 5:40 PM To: Dravis, Samantha Cc: Rees, Sarah Subject: Checking in 15 16 To: Dravis, Brown, Cc: Kenny, Kime, From: Rees, Sarah Sent: Mon 3/6/2017 11:36:44 PM Subject: Regulatory actions for discussion - 3/7 Hi Samantha our ?hot? regulatory items to discuss tomorrow are those we discussed at our 4pm namely Chlorpyrifos and decision making regarding extension oft?ne effective data for the Risk Management Plan rule which is currently slated to become effective 3/21 if we take no further action. Ex. 5 - Deliberative Process 17 To: Dravis, From: Jackson, Ryan Sent: Wed 2:11:58 AM Subject: Re: Chlorpyrifos - Administrator Briefing l'm kidding. Wendy is actually very helpful. 1 think] did scare them or surprise them Friday. They are getting us infomiation from Friday but they know where this is headed and they are documenting it well. Ryan Jackson Chief of Staff US. EPA (202:) 564-6999 On Mar 7, 2017, at 8:58 PM, Jackson, Ryan wrote: They are trying to strong arm us. scared them Friday. Ryan Jackson Chief of Staff US. EPA (202) 564-6999 On Mar 7, 20175 at 8:48 PM, Dravis, Samantha wrote: I don?t know what she's talking about. Did Shannon tell her the administrator needs a brie?ng?? Sent from my iPhone Begin forwarded message: From: ?Cleland-Hamnett, Wendy" Date: March 7, 2017 at 6:53:32 PM EST To: "Kenny, Shannon" "Dravis, Samantha" . A^L\.r.-.A Qi o-"^+ rs-D =",1 -s&=.'tJo>( d --Jo,i-s,.Ar=-R-t+\:- *i-6 '.* \.-D - -:^rlc.*^e {- ;t* .d*"- ;^L ( slZ z tb .?Lu*L +rLEUR, ,{.a-4{L &-"..-,q.x-b, "--. C' o rf".)r-k:+9*d* -*u,&'q- )"^tl- t-- Ji_** ?;@ ,:44 4W -+u-,.-J.-:L= e-L *\\-q-+r#;.Co*-L= {-- w$ L Ul\(. agq NLnr. =!o1s, -D"&4' D"++ w-,9 & o.r*t '*'L, g**7-oL oP *T' a )_* ar*BlA *.--l oPP\- Oz.J' " , S u-F- b.. *[ *l-*.sve N.-"-: &*'^*s b Oo-t,. i3l*,-,rA*& 2 'o *St -7 - \i.x- d.--'""* -|-,J -.-q# &%. 18 Dravis,​ ​ ​Samantha[dravis.samantha@epa.gov]​​ ​Jackson,​ ​Ryan Wed​ ​3/8/2017​ ​1:58:05​ ​AM Re:​ ​Chlorpyrifos​ ​-​ ​Administrator​ ​Briefing They​ ​are​ ​trying​ ​to​ ​strong​ ​arm​ ​us.​ ​ ​I​ ​scared​ ​them​ ​Friday. Ryan​ ​Jackson​ ​Chief of​ ​Staff U.S.​ ​EPA (202)​ ​564-6999 On​ ​Mar​ ​7,​ ​2017,​ ​at​ ​8:48​ ​PM,​ ​Dravis,​ ​Samantha​ ​ ​ ​wrote: I​ ​don't​ ​know​ ​what​ ​she's​ ​talking​ ​about.​ ​ ​Did​ ​Shannon​ ​tell​ ​her​ ​the​ ​administrator​ ​needs​ ​a briefing?? Sent​ ​from​ ​my​ ​iPhone​ ​Begin forwarded​ ​message: From:​ ​"Cleland-Hamnett,​ ​Wendy" Date:​ ​March​ ​7,​ ​2017​ ​at​ ​6:53:32​ ​PM​ ​EST "Dravis,​ ​Samantha" Subject:​ ​Chlorpyrifos​ ​-​ ​Administrator​ ​ ​Briefing Can​ ​you​ ​let​ ​me​ ​know​ ​status?​ ​ ​Are​ ​we​ ​still​ ​waiting​ ​to​ ​find​ ​out,​ ​or​ ​is​ ​it​ ​not​ ​happening​ ​tomorrow? Thanks. Wendy​ ​Cleland-Hamnett Acting​ ​Assistant​ ​Administrator 19 i.-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-· -·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-i Sent​ ​from​ ​my​ ​iPhone To: Minoli, From: Brown, Byron Sent: Thur 3/9/2017 5:54:00 PM Subject: RE: question Hi Kevin 7 the issue I wanted to chat about relates to ehlorpyrifos. Ryan asked me to follow up on something that came up in a recent discussion he had with Wendy. She advised there were a Ex. 5 - Deliberative Process From: Brown, Byron Sent: Thursday, March 9, 2017 11:31 AM To: Minoli} Kevin Subject: question Hi Kevin I. stopped by but you were in a meeting. Could you give me a call when you are next free? My number is 564?1456. From: Willis, Sharnett Location: 3402 WJC-N Importance: Normal Subject: Discussion on Chiorpyrifos (pre-brief for the Administrator) Start DatelTime: Thur 3f9i2017 ?:00:00 PM End DatelTime: Thur 3/9l2017 7:30:00 PM 21 On​ ​Mar​ ​13,​ ​2017,​ ​at​ ​10:16​ ​PM,​ ​Jackson,​ ​Ryan​ ​ wrote:​ ​What's​ ​a​ ​full​ ​denial?​ ​ ​ ​ ​ ​You​ ​either​ ​do​ ​or​ ​you​ ​don't. Ryan Jackson Chief​ ​of Staff U.S.​ ​EPA (202)​ ​564-6999 22 From:​ ​Cleland-Hamnett,​ ​Wendy Sent:​ ​Thursday,​ ​March​ ​16,​ ​2017​ ​10:48​ ​AM To:​ ​Dravis,​ ​Samantha​ ​<​dravis.samantha@epa.gov​> Cc:​ ​Jackson,​ ​Ryan​ ​<​jackson.ryan@epa.gov​>;​ ​Brown,​ ​Byron​ ​<​brown.byron@epa.gov​> Subject:​ ​RE:​ ​Chloropyrifos Samantha, I​ ​received​ ​the​ ​first​ ​draft​ ​late​ ​yesterday​ ​and​ ​am​ ​now​ ​working​ ​through​ ​the​ ​40+​ ​pages.​ ​Will​ ​meet with​ ​OGC​ ​and​ ​the​ ​pesticides​ ​program​ ​at​ ​11:00.​ ​Will​ ​get​ ​back​ ​to​ ​you​ ​after​ ​that. Wendy​ ​Cleland-Hamnett Acting​ ​Assistant​ ​Administrator Principal​ ​Deputy​ ​Assistant​ ​Administrator Office​ ​of​ ​Chemical​ ​Safety​ ​&​ ​Pollution​ ​Prevention 23 From: Dravis, Samantha Sent: Thursday, March 16, 2017 11:04 AM To: Cleland-HamnetL Wendy Ce: Jackson, Ryan Brown, Byron Subject: RE: Chloropyiifos Great, thanks much! To: Schwab, Minoii, Cc: Brown, From: Dravis, Samantha Sent: Mon 3/20/2017 2:46:17 PM Subject: FW: Chloropyrifos CP?Y?FGSPeat?tion Ftesnensamd?ft?tldoe Justin and Kevin, lhave reviewed this but in case you have not, could you review the draft and submit your editsi?ehanges to Wendy? We need to get this eomp1eted and teed up for signature by the Administrator by the end of this week in order to stay on track for a 3/31 de1ivery. Thanks to you both, and happy Monday. From: Microsoft Outlook Location: Aim Conference Room Importance: Normal Subject: Meeting Forward Notification: Meeting Re: Chiorpyrifos Start Date/Time: Fri 311772017 6:00:00 PM End DateITime: Fri 3/17/2017 7:00:00 PM Your meeting was forwarded Andereen ?enise has forwarded your meeting request to additional recipients. it}? 2:23:23 it 31:13:; Meeting Re: Chlorpyrifos 1? 132mg: ?ne Friday, March 17, 2017 2:00 PM. wise: Louige Home: Andrea Quiaran Yu-Ting ?g?a?eoa gnome Anna Friedman Dana ,?gheyerriaatila?etta mow Kevin ner?atuner. 2:30:11 one at] 1.93%: so sense-.5 tune: Lone Du} Emsttesn 9 See-:11. 3. NW. roe-"211. Eszct?lar?soa fie-mm i 24 25 To: Dravis. Cc: Jackson, Brown, From: CIeiand-Hamnett, Wendy Sent: Thur aria/2017 6:57:21 PM Subject: RE: Chloropyrifos Petition Response. mt! . 3. 1 Eat Katee Samantha, still in the process of editing. If you see typos or citations, etc. to be ?lled in, folks are working on those. Also? it?s been reviewed at the Associate General Counsel level (Kevin McLean) but Kevin Minoli and Justin Schwab haven?t yet reviewed. But I think this version will allow you to see how we?re describing the basis for the denial. The most relevant sections, describing our basis for denying the petition at this time, are on pages 8-9 and 38?41. As you?ll read in the notice, the Agency previously provided 2 interim responses. In 2012 we denied one claim completely and, in 2014. expressed an intent to deny 6 other claims. In this document, we?re also finalizing the denial ofthosc 6 claims to completely close out the petition response. The description of the bases for these earlier denials are cut pasted from those earlier documents. Ex. 5 - Deliberative Process In the meantime, we?ll also work with OPA on communications. I?ve asked my coms people to hold off on preparing anything until we?ve settled on the substance. Always happy to answer questions or come over to discuss. 26 From: "Mclean, Kevin" Date: March 21, 2017 at 5:12:01 PM EDT To: "Minoli, Kevin? "Schwab, Justin" Cc: "Cleland?Hamnett, Wendy" "Keigwin, Richard" "Dyner, Mark" "Pcrlis, Robert" a? Subject: New draft chlorpyrifos petition response Attached is the new draft of the chlorpyn?t?os petition response, ref'l ecting input from OPP and as well as additional work by Mark. (Thanks, Mark, for doing such great and quick work. on this.) While some clean up remains, and Bob and 1 will be reviewing it as well, 1 think it?s ready for you to look at. Wendy?Were you able to connect with Samantha about the timing for how this should proceed, when does the ?nished product need to get to OP for signature by the Administrator? Kevin and Justin?As I?m not sure what the date is for having a ?nal package I?m not sure what to tell you in terms of review time for a precise date, so I?m afraid I just need to ask that you review and send comments back to Mark, Bob and me as soon as possible. The other Kevin 27 Thu Mar 23 09:22:18 EDT 2017 Hope.Brian@epamailepagov FW: Farmers need Chlorpyrifos To: CMS.OEX@epamail.epa.gov Daily Reading File From: EM -PersonaIPrivacy tnailtozi Ex. 6 - Personal Privacy Sent: Thursday, March 23, 2017 2:23 AM To: Pruitt, Scott Subject: Farmers need Chlorpyrifos Dear Adminstrator fo the US. EPA Scott Pruitt, The news that EPA plans to move forward with the Chiorpyrifos; Tolerance Revocation process is disappointing. As a Minnesota soybean farmer, there are fewer and fewer options for us to control soybean aphids and spider mites, two of the major pests threatening soybean yieids in the state. A major outbreak of soybean aphids can cut down my yield by 40 percent. A major outbreak of spider mites could do even more damage to soybean yieids. We used to rely on Organophosphates (Chlorpyrifos), Pyrethroids and Neonicotinoids, These days, we're seeing resistance to pyrethroids in our state, namely to bifenthrin and iambda-cyhalothrin. Additionally, neonicotinoids are also under attack in Minnesota, with Gov. Mark Dayton essentially banning the use ofthese chemicals due to concerns with its effect on poliinators. Additionally, Sufloxa?or was denied a iabel for use on soybeans due to poliinator concerns. We?re losing options to combat these pests, and there are a limited number of varieties avaiiable to plant in Minnesota. Currentiy, the University of Minnesota is developing multiple levels of genetic resistance to be used in all maturity groups grown in the state, but it wilt be severai years before these will be available. Furthermore, bioiogical control using insect diseases and insect predators is inconsistent at best. The court-ordered deadline forthe decision is March 31, leaving us insufficient time to adjust for this year's growing season. lfthe EPA recommends revocation of the Chlorpyrifos, Minnesota farmers will be left to battle soybean aphids and spider mites with littie more than a feather. i urge you to keep Chlorpyrifos in our inventory and give farmers the best chance to protect our crops. Regards, Ex. 6 - Personal Privacy From: Cleland-Hamnett, Wendy Sent: Friday, March 24, 2017 2:26 PM To: Jackson, Ryan byron Cc: Burden, Susan Mojiea, Andrea Subject: Fwd: New draft chiorpyrifos petition response Ryan, Here's the latest version i have. There are a few references, etc. to be ?lled in. Clean copy ready for signature will go to OP on Monday. Wendy Cleland?Hamnett Acting Assistant Administrator Principal Deputy Assistant Administrator Office of Chemical Safety Pollution Prevention US. EPA Begin forwarded message: From: Hofmann, Angela Sent: Friday, March 24, 2017 5:09 PM To: Cleland-Hamnett, Wendy; Wise, Louise Cc: Mojica, Andrea; Friedman, Dana; Chun, Melissa; Keigwin, Richard; Dyner, Mark; Guilaran, Yu?T?ng; Smith, Charies; Costello, Kevin; Strauss, Linda; Dunton, Cheryl Subject: Chlorpyrifos; Order Denying PANNA and Petition to Revoke Tolerances - Electronic Copy of Final Versions Hi Wendy, i just dropped offthe final signature package with Andrea. Attached is an electronic copy in case you want another look or want to share it with others. I have things lined up with OP to get the package to them in the morning on Monday, and they are ready to process it with deadline in mind. Susan is ready to track it once i get it to DP and will coordinate getting it signed on time and back to us - Angela 28 29 From:​ ​Dravis,​ ​Samantha Sent:​ ​Sunday,​ ​March​ ​26,​ ​2017​ ​5:21:14​ ​PM To:​ ​Rees,​ ​Sarah Subject:​ ​FW:​ ​Chlorpyrifos;​ ​Order​ ​Denying​ ​PANNA​ ​and​ ​NRDC's​ ​Petition​ ​to​ ​Revoke​ ​Tolerances​ ​-​ ​Electronic​ ​Copy​ ​of Final​ ​Versions 30 Let's​ ​have​ ​OEX​ ​tee​ ​this​ ​up​ ​for​ ​SPs​ ​signature. No​ ​autopen,​ ​I​ ​need​ ​to​ ​check​ ​with​ ​the​ ​White​ ​House​ ​on​ ​this​ ​because​ ​they​ ​may​ ​want​ ​to​ ​do​ ​something in​ ​conjunction​ ​with​ ​USDA​ ​on​ ​it​ ​and​ ​I​ ​don't​ ​want​ ​it​ ​executed​ ​before​ ​I​ ​have​ ​a​ ​chance​ ​to​ ​do​ ​that. Thanks! From:​ ​Cleland-Hamnett,​ ​Wendy Sent:​ ​Friday,​ ​March​ ​24,​ ​2017​ ​5:45​ ​PM To:​ ​Jackson,​ ​ ​Ryan​ ​;​​ ​ ​Dravis,​ ​Samantha​ ​; Brown,​ ​Byron​ ​ Subject:​ ​Fw:​ ​Chlorpyrifos;​ ​Order​ ​Denying​ ​PANNA​ ​and​ ​NRDC's​ ​Petition​ ​to​ ​Revoke​ ​Tolerances​ ​Electronic​ ​Copy​ ​of​ ​Final​ ​Versions Status​ ​of​ ​the​ ​order​ ​below,​ ​and​ ​copy​ ​attached.​ ​ ​Hope​ ​you​ ​all​ ​have​ ​a​ ​good​ ​weekend. From:​ ​Hofmann,​ ​Angela Sent:​ ​Friday,​ ​March​ ​24,​ ​2017​ ​5:09​ ​PM To:​ ​Cleland-Hamnett,​ ​Wendy;​ ​Wise,​ ​Louise Cc:​ ​Mojica,​ ​Andrea;​ ​ ​Friedman,​ ​Dana;​ ​Chun,​ ​Melissa;​ ​Keigwin,​ ​Richard;​ ​Dyner,​ ​Mark; Guilaran,​ ​Yu-Ting;​ ​Smith,​ ​Charles;​ ​Costello,​ ​Kevin;​ ​Strauss,​ ​Linda;​ ​Dunton,​ ​Cheryl Subject:​ ​Chlorpyrifos;​ ​Order​ ​Denying​ ​PANNA​ ​and​ ​NRDC's​ ​Petition​ ​to​ ​Revoke​ ​Tolerances​ ​Electronic​ ​Copy​ ​of​ ​Final​ ​Versions 31 To: Samantha Cc: Brittany George Kenny, Kime, Pritchard, Nickerson, Corraies. Curry, Owens, Peffers, From: Sarah Rees Sent: Tue 3i28f2017 7:59:23 PM Subject: OP Policy Review ORPM Of?ce Director Approval Noti?cation (SAN 5993 Notice Administrator?s Signature Review #1 IOCSPP - ?Chlorpyritos; Final Response to Petitions') Approval for Administrator's Signature: Notice 'Chiorpyrifos; Final Response to Petitions' This Policy Review is ready for OP Associate Administrator Approval. Link to Policy Review Document?> From: Dravis, Samantha Sent: Wednesday, March 29, 2017 10:08 AM To: Bowman, Liz Konkus, John Freircj JP Wilcox, Jahan Subject: Headline is too hyperbolic, tone it down. 32 From: Bowman. Lia Sent: Wednesday, March 29, 2017 3:55. PM T0: Freirc, CC: Dravia, Samantha aami?aat?iaa?sra?eon}; Konkus, John Subject: RE: For Ray Review: Updated Release USDA Quote Importance: High Updated with USDA Quote for joint release. Please let us know if you hear back from anyone reviewing. Do you think we could add ?With Support from USDA. Into the headline, to show it?s a joint release? Or is that. too much? Teonsidered a sub-head. butT think the quote speaks for Ex. 5 - Deliberative Process 33 From: Burden, Susan Sent: Wednesday, March 29, 2017 3:15 PM To: Mike Jackson, Ryan Brown, Byron Cleland-Hamnett, Wendy Cc: Mojica, Andrea Keigwin, Richard Strauss, Linda Hofmann, Angela Curry, Bridgid Kimc, Robin Owens, Nicole Jutras, Nathaniel Mojica, Andrea Knapp, Kn?stien Threet, Derek onseca, Silvina Subject: Signed Chlorpyrifos; Order Denying PANNA and Petition to Reyoke Tolerances This afternoon, Administrator Pruitt signed an order denying PANNA and petition to revoke tolerances for chlorpyrifos. A copy of the signature page is attached. Please let me know if you have any questions. Thanks} Susan To: Dravis, Cc: Rees, Owens, From: Kime, Robin Sent: Wed 3129/2017 7:02:41 PM Subject: Chlorpyrifos is signed, .pdf en route to you in a few minutes To: Cc: From: Sent: Subject: 34 . Admi?istratot?s Sigaamre engages 31'45 pages; FEL- 9960-31-7: 'Chlorpyt?lfes; Order Denying Petition to Revolte tolerances authority: 7 [5:3th and 2E Dated: gag} .- .1 . gr- E. Scott Pruitt. Administrator. Bowman, Freire, Konkus, Dravis, Samantha Wed 3i29!201? 8:01:29 PM RE: For Ray Review: Updated Release USDA Quote Ray approved this From: Bowman, Liz Sent: Wednesday, March 29, 2017 3:55 PM To: Freirc, JP Cc: Dravis, Samantha Konkus, John Subject: RE: For Ray Review: Updated Release USDA Quote Importance: High Updated with USDA Quote for joint release. Please let us know if you hear back from anyone reviewing. Do you think we could add ?With Support from USDA, Into the headline, to show it?s a joint release? 01' is that too much? 1 considered a sub-head, but 1 think the quote speaks for itself. 35 From: Dravis, Samantha Sent: Wednesday, March 29, 2017 4:01 PM To: Bowman, Liz Freire, JP Cc: Konkus, John Subject: RE: For Ray Review: Updated Release USDA Quote Ray approved this From: Bowman, Liz Sent: Wednesday, March 29, 2017 3:55 PM T0: reire. JP nigw> Cc: Dravis, Samantha Konkus, John Subject: RE: For Ray Review: Updated Release USDA Quote Importance: High Updated with USDA Quote for joint release. Please let us know if you hear back from anyone reviewing. Do you think we could add ?With Support from USDA, Admin. Into the headline, to show it?s a joint release? Or is that too much? I considered a sub-head, but I think the quote speaks for 36 To: Freire, Dravis, Cc: Bowman, Wilcox, Ferguson, Bolen, From: Konkus, John Sent: Wed 329201 7 2:01 :50 PM Subject: RE: For Review: Draft Press Release on Chlorpyrifos Petition We are working on an outstanding conims plan to push this out. Really outstanding. From: Freire, JP Sent: Wednesday, March 29, 10:00 AM To: Dravis, Samantha Cc: Bowman, Liz Konkus, John Wilcox, Jahan Ferguson, Lincoln Bolen, Brittany Subject: Re: For Review: Draft Press Release on hlomyrifos Petition We will pass to ray once you're through looking at it: J.P. Freire Environmental Protection Agency Associate Administrator for Public Affairs MObilC -E Ex. 6 - Personal Privacy i On Mar 29, 2017', at 9:59 AM, Dravis, Samantha wrote: Did you run this by Ray Starling at the White House? 1 will have some edits that I?ll send shortly. From: Bowman, Liz Sent: Wednesday, March 29, 2017 9:46 AM Konkus, John Konkus, John Qatari: CC: Wilcox, Jahan Subject: Fwd: NASDA Commends EPA Decision on C'hlorpyrifos Petition SPF validation failed] Chad -- wanted to thank you again for today's meeting (more soon from our end on that front). In the interim, we wanted to share the below NASDA press release supporting EPA's seienee- based decision to deny petitioner's request to revoke chlorpyrifos tolerances (please share with 42 43 To: Dravis, Rateike, Bradley A. Ex. 6 - Personal Privacy From: Bowman, LIZ Sent: Wed 3l29l2017 10:38:20 PM Subject: FW: EPA Administrator Pruitt Denies Petition to Ban Widely Used Pesticide CONTACT: FOR IMMEDIATE RELEASE March 29, 2017 EPA Administrator Pruitt Denies Petition to Ban Widely Used Pesticide Today, US. Environmental Protection Agency (EPA) Administrator Scott Pruitt signed an order denying a petition that sought to ban chlorpyrifos, a pesticide crucial to US. agriculture. ?We need to provide regulatory certainty to the thousands of American farms that rely on chlorpyrifos, while still protecting human health and the environment," said EPA Administrator Pruitt. "By reversing the previous Administration?s steps to ban one of the most widely used pesticides in the world, we are returning to using sound science in decision-making rather than predetermined results.? ?This is a welcome decision grounded in evidence and science," said Sheryl Kunickis, director of the Of?ce of Pest Management Policy at the US. Department of Agriculture (USDA). ?It means that this important pest management tool will remain available to growers, helping to ensure an abundant and affordable food supply for this nation and the world. This frees American farmers from significant trade disruptions that could have been caused by an unnecessary, unilateral revocation of chlorpyrifos tolerances in the United States. it is also great news for consumers, who will continue to have access to a full range of both domestic and imported fruits and vegetables. We thank our colleagues at EPA for their hard work.? In October 2015, under the previous Administration, EPA proposed to revoke all food residue tolerances for chlorpyrifos, an active ingredient in insecticides. This proposal was issued in response to a petition from the Natural Resources Defense Council and Pesticide Action Network North America. The October 2015 proposal largely relied on certain epidemiological study outcomes, whose application is novel and uncertain, to reach its conclusions. The public record lays out serious scientific concerns and substantive process gaps in the proposal. Reliable data, overwhelming in both quantity and quality, contradicts the reliance on and misapplication of? studies to establish the end points and conclusions used to rationalize the proposal. The USDA disagrees with the methodology used by the previous Administration. Similarly, the National Association of State Departments of Agriculture also objected to methodology. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Scientific Advisory Panel (SAP) also expressed concerns with regard to previous reliance on certain data the Agency had used to support its proposal to ban the pesticide. The SAP is a federal advisory committee operating in accordance with the Federal Advisory Committee Act and established under the provisions as amended by the Food Quality Protection Act of 1996. It provides scienti?c advice, information and recommendations to the EPA Administrator on pesticides and pesticide-related issues regarding the impact of regulatory decisions on From: Paul Schlegel Date: March 30, 2017 at 10:56:26 AM EDT To: "David Krcutzcr "dxravis .gamantha?qi one . gm? < Subject: Re: pesticide Ex. 5 - Deliberative Process Sent from my iPhone ?it- WW :1 ?t it: L39, 1% 7 r: SQEC wide-Ch (nth-1?5 {as 47 48 From: Freedhoff, Michal (EPW) Sent: Thursday, March 303 2017 9:09 AM To: Kaiser, SVen?Erik Subject: Re: Noti?cation: EPA Dcnics Petition to Ban Chlorpyrifos I saw this last night when it posted. Could you suggest that more timely noti?cations would be appreciated in the future? Thanks Sent from my iPhonc On Mar 30; 2017; at 9:03 Kaiser, Siren-Erik wrotc: Heads up that EPA denied a petition that sought to ban chlorpyrifos, a pesticide crucial to US. agriculture. ?We need to provide regulatory certainty to the thousands of American farms that To: Freire, Dravis, Bennett, Cc: Jackson, From: Brown, Byron Sent: Fri 3/31/2017 8:17:31 PM Subject: FW: FYI Pesticide Policy Coalition Praises EPA Chlorpyrifos Decision fyi Page 678 49 From: Sheryl Kunickis [mailtoj Ex. 6 - Personal Privacy Sent: Friday, March 31, 2017 3:17 PM To: Rebeckah Adcock Cc: Jackson, Ryan Ens-Personal Privacy Brown, Byron Klippenstein Ex. 6 - Personal Privacy 5 Ex. 6 - Personal Privacy 5; Kunickis 'Subject: Re: FYI Pesticide Policy Coalition Praises EPA Chlorpyrifos Decision Thank you! it is a great week for our growers and the decision is much appreciated. Sheryl Sent from my iPhone On Mar 3 2017: at 3:05 PM, Rebeckah Adeock wrote: PESTICIDE POLICY COALITION A Coalition Working for Sound Pest Management Poiicies NEWS RELEASE For more information, contact: Ethan Mathews, mathewsfd?ncrgam Work: (202) 326-0647 Celi: (202) 374-9566 Pesticide Policy Coalition Praises EPA Chlorpyrifos Decision WASHINGTON (March 30, 2017) Members ofthe Pesticide Policy Coalition (PPC) today praised the US. Environmental Protection Agency decision to deny a petition to remove the crop protection tool Chlorpyrifos from the market. ?We need to provide regulatory certainty to the thousands ofAmerican farmers that rely on 50 To: Paul Kreutzer. From: Dravis, Samantha Sent: Thur 4:34:15 PM Subject: RE: News release - Farm Bureau Praises EPA Chlorpyrifos Decision Thank you, Paul for your support. From: Paul Schlegel Sent: Thursday: March 30, 2017 10:56 AM To: Kreutzen David Dravis, Samantha {drawssamantha@epa.gov} Subject: News release - Farm Bureau Praises EPA Chlorpyrifos Decision Bavid 331 Esmeritha wanted you Ea the era-ass statea'ieni we have issued. Were very suppers-ire of the administraters decision yesterday, Paul PaoE ?ehiegel Skeeter, Eaargy and Emir-earnest Team ?ireot: {2.32} $935-$363? ?39.25: 5 Ex. 6 - Personal Privacy 5 Email: gaieis?s'sreerg From: Flowers, Sent: Thursday, March 30, 2017 9:00 AM To: Axelrad, Daniel Dockins, Chris Klemiek, Heather Cc: McQueen, Jacqueline Subject: cross?EPA epi discussion Hi all: 51 Thanks Flowers, DABT Associate Director for Science Of?ce of Science Policy US EPA 52 53 To: Brown, Jackson, From: Rebeekah Adeoek Sent: Thur 3(3012017 4:10:52 PM Subject: FW: FINAL CEO Council Meeting Agenda and Materials Pruitt Meetino 311100091 .htm FYI ?nal materials for today?s meeting. Reb CC: "Jay Subject: FINAL Meeting Agenda and Materials Sydney, We have re?ned our proposed topics for today?s CEO Council meeting with the administrator. Attached, please find: - Revised ?Final Proposed Agenda Topics,? which includes the list of those CEO Council members who will attend our meeting today, and their short bios - introduction Mission Overview of the E0 Council - CEO Council Letter to President Trump, dated February 9, 2017 We assume we can skip a formal ?round table ofintroduetions? at the beginning of the meeting as our time is short and we want to maximize time spent talking about issues. Mary .10 Tumalmski l-Ixecutive Assislanl lo the President 8; repLife America FINAL PROPOSEO AGENDA Meeting information: Office of EPA Administrator Scott Pruitt 1200 Avenue, NW Washington, DC Thursday, March 30, 201? 3:45-4:30 PM b. Chlorpyrifos Petition i Topic i Thanks to Trump Administration and Administrator Pruitt for early decisive actions: a. WOTUS 2. Top Priority Issues f; a. Ag Advisor Position We recommend adding additional title of ?Assistant Deputy i Administrator" as a title b. Water i. Next steps to refine I clarify beyond WOTUS ii. NPDES permits (CAFO Program needs work; legislation to fix water permits NOT ,i needed for lawful use of pesticides) i 0. Pesticides Policy i. Endangered Species Act conflicts with Pesticide Regulation and Biotech Regulation ii. Epidemiology Study Policy (as aftermath from Chlorpyrifos matter) Reform Certification 8: Training and Worker Protection Rules Suapend implementation and revise d. Renewable Fuels Standard current program kept consistent e. Communication Messaging Opinion Polling vital to all parties? ability to advance sound policyr EPA and USDA Cooperation and Coordination Already vast progress; moan be done! g. Environmental Justice, Research Development, and Children?s Health Offices Better integration with and reform of EPA program offices; sound science h. Regulation of Manufacturing 8. Mining Facilities for Ag Inputs Restore science and process i. Public and Science Advisory Panels at EPA Balance, strategic agendas j. ?Air Emissions" from farming operations CEO Attendees American Seed Trade Association Andrew ?Andy? LaVigne, President and CEO American Soybean Association Steve Censky, Chief Executive Of?cer {Co-Chair} Biotechnology Innovation Organization Dana O'Brien, Executive Vice President CropLife America Jay Vroom. President and CEO (Co-Chair} The Fertilizer Institute Chris Jahn, President National Association of Wheat Growers Chandler Goule, CEO National Corn Growers Association Chris Novak, CEO (Co-Chair) National Cotton Council Gary Adams, President and CEO National Council of Farmer Cooperatives Chuck Conner, President and CEO National Pork Producers Council Neil Dierks. CEO United Fresh Produce Association Torn Stenzel, President and CEO USA Rice Federation Betsy Ward. President 8: CEO National Association of State Barb Glenn, CEO, ex?offr'cr'o Departments of Agriculture Others American Farm Bureau Federation Dale Moore, Deputy Executive Director l[Born Refiners Association John Bode, President ti CEO National Farmers Union Rob Larew, Senior VP 54 55 56 February 9, 2017 The President The White House Washington, D.C. 20500 Dear Mr. President, We, the CEO Councii (undersigned herein), representing the production agricultural value chain, including many agricultural producers and farm input developers and suppliers, look forward to working with you and your Administration on matters of importance to American agriculture. The challenges we face in agriculture are significant. Many experts emphasize that producers must grow as much food in the next 50 years as was produced over all previous history to meet the demands of our expanding global population. A ?rm commitment by the U.S. government to aggressively support agricultural innovation and science-based regulatory decisions wiil be necessary to ensure farmers have the tools they need to produce a safe and abundant supply of nutritious food, in addition to feed, fuel and fiber, in an environmentally sound and sustainable manner. The policy and regulatory environment your Administration establishes can ensure that agricuiturai innovation fiourishes and American farmers are able to meet the food production goais necessary to feed biilions more people. We are ready to provide the White House and the Executive Branch Departments and Agencies, as well as Congress, with policy concepts that foster stability in the U.S. agriculture economy with a strong and predictable farm safety net and promotes American competitiveness through research; marketability and trade of agricultural commodities; rural economic growth; and plant, animal, and environmental health, among many other things. We appreciate your attention to these and other issues of value to American production agriculture and food consumers everywhere. Sincerely, American Fam1 Bureau Foundation, Zippy Duvall American Seed Trade Association, Andy LaVigne American Soybean A?ociation, Steve Censky Biotechnology Innovation Organ-tion Dana O'Brien CropLife America, Jay Vroom The Fertilizer Institute, Chris Ja hn National Association of Wheat Growers, Chandler Goule National Cattlemen?s Beef Association, Kendal Frazier National Com Growers Association, Chris Novak National Cotton Council, Gary Adams National Council of Farmer Cooperatives, Chuck Conner National Farmers Union, Roger Jo hnson National ilk Producers Federation, Jim Mul he rn National Pork ProducersCouncil, Neil Dierks United Fresh Produce Association, Tom Sten zel USA Rice Federation, Betsy Ward