ECONOMIC ANALYSIS OF PESTICIDES EMERGENCY EXEMPTION PROCESS REVISIONS Prepared by:

BIOLOGICAL AND ECONOMIC ANALYSIS DIVISION OFFICE OF PESTICIDE PROGRAMS September 12, 2005 U. S. Environmental Protection Agency 1200 Pennsylvania Ave, NW Washington, DC 20640 Table of Contents I. Background for the Proposed Rule: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 A. Overall Approach: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 B. Reason for the Proposed Changes Are: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 C. Description of the Current Revenue Variation Method . . . . . . . . . . . . . . . . . . . . . . . 3 D. Description of the Proposed Loss based ( Tiered) Approach: . . . . . . . . . . . . . . . . . . . 3 1. Tier Thresholds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2. Basis for Tier Thresholds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 E. Statutory and Regulatory Requirements: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1. Statutory Provisions: FIFRA, Section 18 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2. Regulatory Provisions: 40 CFR, Part 166 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 II. Methodology of Economic Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 A. Purpose of EA ( economic analysis) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 B. Significant Economic Loss ( SEL) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 C. Re certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 III. Results of the Analysis of Proposed Method for Determining SEL . . . . . . . . . . . . . . . . . . 8 A. Summary of exemption requests. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 B. Dataset . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 C. Losses Qualifying as a SEL under the Revenue Variation Method. . . . . . . . . . . . . 10 D. Cost Savings as a Result of Changing Data Requirements for Determining SEL . 12 E. Comparison of Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 IV. Results of Analysis of Re certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 A. Applicant ( States) Savings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 B. EPA Savings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 C. Total Savings from Re certification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 V. Combined Savings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 VI. Information Collection Request ( ICR) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 VII. Limitations of Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 A. Total Savings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 B. Average Savings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 C. Unrealized Savings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 D. Time Savings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 E. Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 VIII. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 A. Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 B. Impacts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 IX. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 1 Economic Analysis of Pesticides Emergency Exemption Process Revisions I. Background for the Proposed Rule: 1 EPA is proposing several revisions to the regulations at 40 CFR part 166, which govern such 2 FIFRA section 18 emergency exemptions. The most significant of these proposed improvements are 3 two revisions intended to streamline and improve the application and review process by reducing the 4 burden to both applicants and the EPA, allowing for quicker decisions by the Agency, and providing 5 for more equitable determinations of " significant economic loss" as the basis for an emergency. 6 These two proposals are currently being employed in limited pilot programs. The first would allow 7 applicants for certain exemptions to re certify that the emergency conditions, which initially qualified 8 for an exemption, continue to exist. The second proposal would allow greater flexibility in the 9 submission of data to demonstrate significant economic loss ( SEL) and corresponds to a change in 10 methodology to make that determination. The new methodology focuses on the loss compared to 11 current economic and agronomic conditions rather than conditions over the past five years. In 12 addition, EPA is proposing to revise the regulations to clarify that quarantine exemptions may be used 13 for control of invasive species, and to update or revise certain administrative aspects of the 14 regulations. All of these proposed revisions can be accomplished without compromising protections 15 for human health and the environment. 16 A. Overall Approach: 17 This is primarily a cost saving rule, reducing burden on states and on EPA. In conducting the 18 economic analysis the Agency is analyzing the benefits and impacts of the proposed rule. The benefits 19 of the proposed rule are the cost savings from both the re certification and reduction in data 20 requirements by using the loss based method. The impacts of the proposed rule are analyzed by 21 comparing the outcomes of SEL findings for both the current method and the proposed method. 22 1. Benefits  estimating cost savings. The re certification part of the rule reduces costs for both 23 states and EPA with respect to submitting and reviewing section 18 packages. The new 24 data requirements for demonstrating a SEL do not demand historical information, 25 particularly the more onerous requirement for yearly production costs. Because the 26 proposed SEL method uses a tiered screening system, states may be able to submit less data 27 and will in no case need to submit more. This EA estimates how often a cost savings event 28 occurs and adds up the reduced burden using the section 18 ICR estimates of burden. The 29 analysis demonstrates that the proposed rule would result in considerable cost savings to 30 the applicants and some savings to EPA. 31 2. Impacts  comparing findings of SEL ( significant economic loss) under the current and 32 proposed methods for determining SEL. The analysis demonstrates that there would be no 33 change in the overall likelihood of a SEL finding, although there would be different SEL 34 findings in about 12% of the requests. EPA believes that these differences would be more 35 equitable than the current findings. 36 2 B. Reason for the Proposed Changes Are: 37 1. Re certification: The Agency believes that most candidates for re certification can be 38 determined relatively quickly. This will allow applicants for certain repeat exemptions to 39 re certify that the emergency conditions, which initially qualified for an exemption, continue 40 to exist. The applicants' own certification that the emergency situation is ongoing, along 41 with their incorporation by reference of their earlier full application, will take the place of 42 the submission of data generally required to support a repeat request for an emergency 43 exemption. In this way, the burden associated with the application process for select repeat 44 requests will be significantly reduced. In addition, re certification will often allow EPA to 45 make quicker decisions on exemption requests. 46 2. Determination of Significant Economic Loss ( SEL): In developing a more appropriate 47 methodology for determining SEL, the Agency considered three factors: 48 a. To focus the determination of losses due to emergencies caused by urgent and non 49 routine pest problems on existing conditions. The current methodology may confound 50 the issue with past price volatility and may result in an inappropriate criterion of 51 significant economic loss. Historical data have been used to provide a baseline for 52 estimating both normal profits and variation in the absence of the emergency condition 53 for the affected area. However: 54 ( 1) Historical data may not be representative of existing physical and economic 55 conditions. While unusual weather conditions may lead to pest outbreaks, the 56 weather conditions themselves should not influence the calculation or significance 57 of loss. Similarly, many crops have demonstrated high price variability or 58 significant changes in price over the past several years. 59 ( 2) Historical data are often affected by the emergency condition. Pest pressure 60 related to the emergency condition in previous years ( even if not significant) may 61 reduce revenues and distort the estimation of baseline revenues and variation. 62 For example, historical data often reflect increasing pesticide resistance that may 63 have begun before an emergency exemption was requested, but where the 64 resistance later becomes the basis for requesting the exemption. In the case of 65 repeat emergency exemptions, the historical data are affected by both the 66 revenue decreasing emergency condition and revenue increasing use of the 67 requested pesticide, which will not necessarily equally offset each other. 68 ( 3) Historical data may be unavailable in many states for minor and new crops. 69 ( 4) The focus on historical data may make it difficult to demonstrate some pest 70 related losses. While pest damage usually results in a loss in quantity harvested, 71 sometimes the losses are due to reduced quality of the product that decrease the 72 price received by growers. Damage to orchards and other perennial crops may 73 result in losses over several years. These types of losses have not fit well under 74 the present method of analysis. 75 b. To increase transparency and establish more consistent measures of economic loss. In 76 the current revenue variation method, crops with high yield variability ( such as many 77 non irrigated crops) or with high price variability must have high pest losses to meet 78 the criterion of SEL compared to crops with stable yields and prices. Therefore, this 79 3 criterion may be unfair to farmers already facing high yield and price risk while 80 inappropriately granting exemptions to farmers of low risk crops with minor pest 81 losses . 82 c. To reduce the burden of data collection and analysis on the part of the states and the 83 Agency. In many cases a decision can be made with less information, thus speeding 84 decisions for these cases and permitting more resources to be devoted to more 85 complex situations. 86 C. Description of the Current Revenue Variation Method 87 The revenue variation method defines an economic loss as significant if it would cause expected 88 net revenue to fall below the minimum historical net revenue over a period of typically five years. In 89 some cases, past yields and/ or prices may be considered to be outside normal bounds. For example, 90 drought may reduce yields such that one year in the data cannot be considered typical. Analysts may 91 use judgement to eliminate outliers from the determination of the minimum net revenue. 92 The economic consequences of the emergency are determined separately. In most cases, yield 93 losses are predicted, but the impacts may also include quality losses or increases in pest control costs. 94 For example, an unusual pest outbreak might be controlled by multiple applications of a registered 95 pesticide when typically only one application would be necessary. If these predicted losses would 96 result in net revenue that is lower than the lowest net revenue over the past five years ( after 97 eliminating outliers) then these losses are considered significant. 98 D. Description of the Proposed Loss based ( Tiered) Approach: 99 The loss based approach uses the same methodology to calculate the economic consequences of 100 an unusual pest outbreak. States will still have to submit data to demonstrate the emergency nature 101 of the outbreak and the expected losses in quantity, quality and/ or additional production costs. The 102 proposed approach would provide applicants with greater flexibility in establishing the baseline 103 scenario. Even though 5 years of historical economic data are not required under the proposed 104 approach, applicants may continue to utilize historical data to establish baseline gross and net 105 revenues from which to estimate economic losses in Tiers 2 and 3 described below. The new 106 approach imposes a standard criterion for determining the significance of that loss, rather than 107 comparing losses to past revenues. The goal of the criterion is to compare losses to expected farm 108 income in a manner that can be easily measured. Further, successive screening levels have been 109 chosen that will permit situations that clearly qualify to be resolved quickly and with a minimum of 110 data. 111 1. Tier Thresholds 112 Tier 1, Yield loss $ 20%: The first screen is based on crop yield loss and is a quantity based 113 measure. EPA will conclude that a significant economic loss will occur if the projected yield loss due 114 to the emergency condition is verified to be 20% of expected yields or greater. The yield loss 115 threshold in Tier 1 will be the same for all crops and regions. This threshold is set at a level such that 116 a loss which exceeds the threshold would generally also meet the thresholds in Tiers 2 and 3, if the 117 additional economic data were submitted and analyzed. Therefore, for large yield losses it is not 118 4 necessary to separately estimate economic loss, which requires detailed economic data. Yield losses 119 are measured as the difference between expected yields in the absence of the emergency and yields 120 under the emergency condition when using the best available, registered alternative. 121 Tier 2, Economic Loss $ 20% of Gross Revenues: For situations with yield losses that do not 122 meet the yield loss criterion for Tier 1, EPA will evaluate estimates of economic loss as a percent of 123 gross revenue in Tier 2. Economic losses result not only from yield losses, but also from causes such 124 as quality losses and changes in production costs, including pest control, harvesting, sorting and 125 processing. EPA will conclude that a significant loss will occur if the projected losses due to the 126 emergency condition are verified to be 20% of expected gross revenues or higher. This threshold will 127 be the same for all crops and regions. Quality losses occur when damage results such that the 128 commodity fails to meet the market standards for a high value segment ( e. g., export or fresh market) 129 and must be sold in a lower value outlet ( e. g., domestic or processed market). Quality losses can 130 occur without loss in quantity or can occur in conjunction with yield losses. This tier will also 131 consider losses due to higher production costs. Higher production costs could include additional pest 132 control costs, for example, mechanical weeding, or additional harvest costs, for example, sorting into 133 different grades. However, these costs must be a result of the emergency before the expenses can be 134 included in the projected loss. 135 Tier 3, Economic Loss $ 50% of Net Revenues above Operating Costs: For situations in 136 which losses do not meet the criteria for Tiers 1 and 2, EPA will evaluate estimates of economic loss 137 as a percent of net revenue in Tier 3 . Economic losses are defined as in Tier 2. EPA will conclude 138 that a significant loss will occur if the projected losses due to the emergency condition are 50% of 139 expected net revenues or higher. This threshold will be the same for all crops and regions. For this 140 purpose, the Agency defines net revenue as gross revenues less variable operating costs ( purchased 141 inputs and hired labor). The Agency considers only variable operating costs because these costs are 142 easier to measure and document than fixed costs, such as overhead and depreciation of machinery, 143 and because they are likely to be more reflective of short term impacts due to emergency conditions. 144 The Agency recognizes that net revenues above operating costs overstate grower income, but 145 believes the facility of measurement and verification make it a more useful measure. 146 Losses that do not fit into this general pattern will be evaluated on a case by case basis. For 147 example, damage to perennial crops that may result in losses over several years could be evaluated as 148 a loss in capital or in returns on an investment, depending on the situation. In those cases, the states 149 must submit data appropriate to their case. 150 2. Basis for Tier Thresholds 151 The choice of thresholds 20%, 20%, and 50% is based on the following three considerations. 152 a. Farm income 153 The tier thresholds are based on average farm income and production expenses for the USA. 154 The latest annual report from USDA shows farm production expenditures in the USA to average 155 about 80% of gross revenue ( USDA, 2003). The remainder, net farm income, is essentially the wages 156 earned by the growers. See table below. 157 5 Table 1. Aggregate Farm Income and Costs for the U. S. in $ billions 158 1997 1998 1999 2000 2001 Average % of gross revenue Gross Revenue 159 $ 238.1 $ 232.1 $ 234.5 $ 241.7 $ 246.5 $ 238.6 100.0%

Total Production Costs 160 $ 187.6 $ 186.5 $ 188.3 $ 193.7 $ 200.8 $ 191.4 80.2% Operating Costs 161 $ 136.1 $ 134.8 $ 136.5 $ 140.4 $ 147.0 $ 139.0 58.2% Fixed Costs 162 $ 51.5 $ 51.7 $ 51.8 $ 53.3 $ 53.7 $ 52.4 22.0%

Net Revenue = 163 gross revenue  operating 164 costs 165 $ 102.0 $ 97.3 $ 98.0 $ 101.3 $ 99.5 $ 99.6 41.8%

Net Farm Income = 166 gross revenue  167 total production cost 168 $ 50.5 $ 45.6 $ 46.2 $ 48.0 $ 45.7 $ 47.2 19.8%

Source: USDA Agricultural Statistics, 2003. 169 An economic loss of 20% of gross revenue would be sufficient to eliminate net farm income, 170 which is on average about 20% of gross revenue. A yield loss of 20% results in economic loss of 171 20% or more of gross revenue. 172 Since net farm income is a little less than 50% of net revenue, an economic loss that is 50% of 173 net revenue would be sufficient to eliminate net farm income. 174 b. Retrospective Analysis 175 In addition, a retrospective analysis was done on past emergency exemptions and the results are 176 shown in Figure 1 in Section IIIC. To qualify as a SEL under a direct use ( without subjective 177 judgement) of the revenue variation approach, the losses caused by the emergency must result in the 178 expected net revenue being equal to or less than the minimum net revenue over the last 5 years. 179 According to the retrospective analysis: 180 ( 1) Tiers 1 and 2. The average and median economic losses that would have qualified 181 as a SEL under the current method ( i. e. calculated thresholds of losses) were 182 about 18% and 15% of gross revenue, respectively. 183 ( 2) Tier 3. The median economic loss that would have qualified as a SEL under the 184 current method was about 51% of net revenue. 185 Since the first 2 tiers are screening thresholds, these thresholds were rounded up to 20% to be a 186 little more stringent, with the idea being that if they did not pass Tiers 1 or 2, they could qualify with 187 Tier 3. Tier 3 compares losses to net revenue ( gross revenue minus operating costs). 188 6 c. Neutral to Likelihood of a SEL 189 The proposed approach is not expected to significantly change the likelihood of an application 190 qualifying for a SEL. That is, approximately the same number of emergency requests that qualified 191 for a SEL using the current revenue variation approach, would have qualified using the proposed 192 loss based ( tiered) approach, although there would be differences in individual cases. That is, some 193 cases would have qualified for a SEL under the proposed method that did not qualify under the 194 current method and visa versa with the total number qualifying being the about the same with both 195 methods. See Section IIIE, Comparison of Findings. EPA believes that the differences in which 196 cases qualify would be more equitable and consistent under the proposed method. 197 E. Statutory and Regulatory Requirements: 198 1. Statutory Provisions: FIFRA, Section 18 199 FIFRA generally prohibits the sale and distribution of any pesticide product, unless it has been 200 registered by EPA in accordance with section 3. One exception to this general prohibition is section 201 18 of FIFRA, which gives the Administrator of EPA broad authority to exempt any Federal or State 202 agency from any provision of FIFRA if the Administrator determines that emergency conditions exist 203 which require such exemption. 204 2. Regulatory Provisions: 40 CFR, Part 166 205 Regulations governing such FIFRA section 18 emergency exemptions are codified in 40 CFR 206 part 166. Generally, these regulations allow a Federal or State agency to apply for an exemption to 207 allow a use of a pesticide that is not registered when such use is necessary to alleviate an emergency 208 condition. A State, as defined by FIFRA section 2( aa), means a State, the District of Columbia, the 209 Commonwealth of Puerto Rico, the Virgin Islands, Guam, the Trust Territory of the Pacific Islands 210 and American Samoa. The regulations set forth information requirements, procedures, and standards 211 for EPA's approval or denial of such exemptions. 212 II. Methodology of Economic Analysis 213 A. Purpose of EA ( economic analysis) 214 The purpose of this EA is to evaluate the costs and benefits of the proposed rule change. The 215 EA: 216 1. Compares findings ( both the overall likelihood of a finding and the findings for individual 217 cases) to determine if there would be an impact with substantially different conclusions 218 under more flexible data requirements, given changes in guidance for evaluating SEL. The 219 analysis indicates that there would be virtually no impact in the overall likelihood of a 220 finding of SEL, and that small differences in findings for individual cases would be more 221 equitable. 222 7 2. To estimate the cost savings of the rule as a result of : 223 a. More flexible data requirements for determining SEL ( significant economic loss). 224 b. Reduced data requirements for re certification of emergency conditions. 225 B. Significant Economic Loss ( SEL) 226 1. SEL Database. The first step in this analysis was to populate a database of SEL findings 227 under different approaches. EPA developed a SEL spreadsheet template that determines 228 SEL findings under both the current and proposed methods, as well as what the analyst 229 concluded. This SEL spreadsheet was used to analyze many of the exemption requests 230 since 2000 and to populate the SEL database used for this analysis. 231 2. Cost Savings Analysis. 232 a. Number of cases qualifying. With the SEL database EPA determined the number of 233 cases which would have qualified as a SEL under each Tier. Then, EPA assumed the 234 same proportion would qualify in the future. A significant economic loss ( SEL) is 235 defined as a loss that would pass any one of the following tiers: 236 Tier 1  Yield loss $ 20%. Significant cost savings for both states and EPA. 237 Tier 2  Economic loss as a percent of gross revenue $ 20%. This tier also covers 238 quality losses and cost increases. Economic loss is defined as loss in revenue from 239 yield and quality losses plus increased costs as a result of the emergency, such as 240 increased pest control or harvesting costs. This tier would also save resources because 241 production costs other than cost increases are not required. 242 Tier 3  Economic loss as a percent of net revenue $ 50%. This tier also considers the 243 impact on net revenue. This tier has the same numerator, economic loss as Tier 2, but 244 compares that economic loss to a different denominator, net revenue. Net revenue is 245 defined as gross revenue minus operating costs. This tier should still save some 246 resources since historical data are not required. However, operating cost information 247 needs to be more documented than has often been the case in the past, when states 248 have not clearly defined the costs included in the submitted data. Therefore, BEAD 249 assumes that the resource requirements would be comparable to the revenue variation 250 method. 251 b. Cost saving per case. Using ICRs ( information collection requests) and expert opinion 252 from scientists in EPA, the agency estimated the savings. 253 c. Estimate cost impacts. The agency can estimate the total cost savings by multiplying 254 the number of cases qualifying for a SEL per year under Tiers 1 and 2 by the cost 255 savings per case for each respective tier, i. e.: 256 3 ( cost savings for Tiers 1 & 2 requests) X ( number of cases qualifying for Tiers 1 & 2) 257 This calculation may overestimate the cost savings, since states may choose to submit 258 more data than would be necessary in case EPA does not concur with their loss 259 estimates. That is, states claiming yield losses in excess of 20% may still decide to 260 8 submit price and production cost data in case EPA's evaluation suggests that yield 261 losses will be less severe. This calculation also assumes that there will be no savings 262 under Tier 3, although more flexible data requirements may mean that applicants will 263 be able to provide adequate baseline data more easily than under the revenue variation 264 method. 265 3. Comparison of SEL Findings. The database can also be used to compare findings with 266 respect to the likelihood of a SEL finding and the findings in individual cases. The database 267 provides what the findings: 268 a. Would be with a direct use ( without judgement) of revenue variation method, 269 b. Would have been with the proposed loss based approach given data submitted under 270 the current methodology, and 271 c. What they actually were determined to be by the analyst. 272 C. Re certification 273 To estimate the potential cost savings EPA estimated the: 274 1. Number of section 18s that would have been eligible for re certification. EPA assumes that 275 75% of repeat requests would have been eligible, and that the same proportion will be 276 eligible in the future. 277 2. Resources required by the state and EPA for a full application & review compared to a 278 review with re certification. 279 III. Results of the Analysis of Proposed Method for Determining SEL 280 A. Summary of exemption requests. See Table 2 below. 281 Table 2. Summary of emergency exemption requests received by EPA annually, and the 282 numbers of requests used in the Economic Assessment for the section 18 proposed rule. 283 Set of exemption requests 284 Average Annual Number Comments Total exemption requests received/ year 285 541 Includes all specific, quarantine, public health, and crisis exemption requests Number of specific exemption requests 286 received/ year 287 500 The proposed process revisions only apply to specific exemptions.

Number of specific exemption requests 288 received/ year for which bio/ econ analysis is 289 done 290 95 The Biological and Economic Analysis Division ( BEAD) does not do analysis when the emergency is not SEL type, when BEAD's conclusion for one state applies to others for same emergency in same year, or for many repeat requests. Set of exemption requests Average Annual Number Comments 1 BEAD is the Biological and Economic Analysis Division of the Office of Pesticide Programs of EPA. BEAD does the biological and economic reviews and analyses of emergency exemption requests to determine if there is an emergency condition and if the emergency condition would lead to a SEL.

9 Number of specific exemption requests 291 received/ year for which bio/ econ analysis is 292 done, AND for which we have complete 293 data to do comparative analysis of revenue 294 variation and loss based methods 295 45 BEAD keeps a database in which analysts record certain data from the application, the results of the revenue variation method, and the analyst's SEL conclusion. However, in some cases the data is incomplete.

Number of specific exemption requests 296 received/ year for which bio/ econ analysis is 297 done, AND for which we have complete 298 data to do comparative analysis of revenue 299 variation and loss based methods, AND for 300 which we have the analyst's SEL 301 conclusion available in the database 302 26 In some cases, the BEAD database is complete, except for the conclusion on SEL.

NOTE: average annual numbers are based on four year averages for FY2000 FY2003. Each set of 303 exemption requests is a subset of the set( s) described in the row( s) above it. 304 B. Dataset 305 1. Number of Applications Received for specific exemptions from 2000 through 2003 306 averaged about 500 annually. This average is assumed to be the likely number of 307 applications to be received in the future. ( EPA, 2003b) The proposed rule only applies to 308 specific exemption requests. 309 2. Number of Applications Reviewed for SEL by BEAD1 from 2000 through 2003 averaged 310 about 95 annually for specific exemptions only. This average is assumed to be the likely 311 number of applications to be reviewed by BEAD for SEL in the future. A BEAD review 312 for SEL was conducted on less than one fifth of the applications received. Many requests 313 are not reviewed by BEAD for SEL for various reasons such as repeat requests, low risk, 314 and similar conditions to granted requests from another state. ( EPA, 2003a) 315 3. SEL Database 316 a. As explained above, this database derived from SEL spreadsheet templates, was used 317 to estimate the likelihood of an application qualifying for a SEL 318 ( 1) as recommended by the analyst using the current method, including the analyst's 319 judgement, 320 10 ( 2) under a direct use of the revenue variation method without the analyst's 321 judgement or conclusion, and 322 ( 3) under the loss based method, given data submitted under the current 323 methodology. 324 b. The SEL database contains information from 181 ( 45 per year) SEL spreadsheets 325 compiled in the course of the BEAD review covering almost one half of the 378 ( 95 326 per year) requests reviewed for SEL by BEAD from 2000 through 2003. SEL 327 spreadsheets were not necessarily utilized nor complete for each review for a number 328 of reasons including: 329 ( 1) Incomplete data submitted by the applicant. 330 ( 2) Determination by the biologist that there was not an emergency condition. 331 ( 3) Withdrawal of request by the applicant. 332 ( 4) The revenue variation methodology was not appropriate for the situation. 333 c. Of the 181 ( 45 per year) observations, the analyst's recommendation is known for 103 334 ( 26 per year) observations because of incomplete data in the SEL database. Some 335 requests in the database were determined to be routine or non urgent situations. 336 However, these data may be used to calculate what losses would be required to be 337 significant even if a SEL was not determined. 338 4. Specific exemption requests eligible for self certification are estimated to be about 247 per 339 year ( 75% of an average of 329 repeat exemption requests per year). ( EPA, 2005 ) 340 5. ICR ( Information Collection Request). The ICR for emergency exemptions was used to 341 estimate the resources required to apply for an emergency exemption and for EPA to 342 review these requests. ( EPA, 2000) 343 C. Losses Qualifying as a SEL under the Revenue Variation Method. 344 To qualify as a SEL under the revenue variation method, the loss should cause expected net 345 revenue as a result of the emergency to fall below the minimum net revenue over a period of 5 years. 346 This loss threshold is calculated as a percent of gross revenue as follows: 347 baseline net revenue  minimum revenue over past 5 years 348 baseline gross revenue 349 The chart below presents the frequency distribution of the losses as a percent of gross revenue 350 that would have resulted in the expected net revenue being equal to the minimum net revenue for the 351 181 analyses available for observation from the period 2000 2003. 352 Figure 1. Frequency Distribution of Minimum Losses Qualifying as SEL. 353 11 0 5% 5 10% 10 15% 15 20% 20 25% 25 30% 30 35% 35 40% 40 45% 45 50% 50 55% 55 60%

Economic Loss as a % of Gross Revenue 0 10 20 30 40 50 in each 5% interval Number of Observations Frequency Distribution of the Minimum Losses that Qualify as Significant with 5 Year Revenue Variation Method This frequency distribution demonstrates the perverse nature of the current method of 354 determining SEL. Out of the 181 observations, the following number ( and percent) of requests 355 could have qualified as having a SEL under a direct interpretation ( without judgement) of the revenue 356 variation method with the following losses as a percent of gross revenue: 357 1. 12 ( 7% of 181) requests with a loss of 5%. 358 2. 45 ( 25%) requests with a loss of 10%. 359 3. 91 ( 50%  the median) requests would have qualified with a loss of 15.3%. The other 90 360 would have required losses ranging between 15.3 % and 60% to qualify with a SEL. 361 4. 117 ( 65%) requests with a loss of 20%. The other 64 ( 181 117 or 35%) requests would 362 have required losses ranging between 20% and 60% to qualify with a SEL. 363 5. 3 ( 2%) requests would have required a loss of 50% or more to qualify as having a SEL 364 under a direct interpretation of the revenue variation ( current) method. 365 6. Conclusion. A consistent standard of loss ( as the proposed loss based method) that would 366 qualify as a SEL would be more equitable. 367 7. Average. The average calculated loss threshold under the current variation method was 368 about 18% of gross revenue. The average was higher than the median of 15% because of 369 the skewed distribution. The calculated loss threshold is the minimum loss required to 370 qualify as a SEL. 371 2 Results may be slightly different under more flexible data requirements since the historical data used for this analysis may not be representative of situation growers face. For example, under the current method average historical price was generally used as a baseline, while proposed method may use other information to determine the price most likely to be received by growers.

12 D. Cost Savings as a Result of Changing Data Requirements for Determining SEL 372 1. Requests Passing Each Tier with a Finding of a SEL. Table 3 below shows the percent and 373 number of requests that would have qualified for a SEL under the proposed loss based 374 method, given data submitted under the current methodology2. 375 a. About 55% would qualify for Tier 1 and would not require economic data nor an 376 economic review. 377 b. Another 10% that would not qualify for Tier 1 would qualify for Tier 2 and not 378 require production cost data. 379 c. Another 15% would qualify only for Tier 3, for which we assume no savings compared 380 to the current method. 381 d. No savings are assumed for requests not qualifying for any tier. 382 e. EPA receives about 500 specific exemption requests per year. Of these about 95 are 383 reviewed for SEL. Therefore, the annual applicant savings are based on 500 requests 384 submitted, while the annual EPA savings are based 95 applications reviewed for SEL. 385 Table 3. Requests Likely to Pass Each Tier Using the Loss based Method 386 Tier 387 Threshold Required Data & Analysis Requests likely to pass tier*

% Total* Bio/ Econ*

Tier 1 388 $ 20% yield loss Yield loss 55% 276 52 Tier 2, but not 389 Tier 1 390 Loss $ 20% gross revenue Yield loss + prices, cost changes & gross revenue 10.5% 53 10 Tier 3, but not 391 Tiers 1 & 2 392 Loss $ 50% of net revenue All of the above + operating cost & net revenue 15.5% 77 15 Requests passing any tier 393 81% 406 77 Requests not passing any tier 394 19% 94 18 Total requests per year ( Average 2000 03) 395 100% 500 95 Numbers may not exactly add, due to rounding 396 * While the average number of requests per year is 500, about 95 are reviewed for SEL. The percentages passing each 397 tier are based on 181 observations ( 2000 03) where EPA had data on past analyses of SEL. These percentages are 398 applied to all 500 applications ( total) for estimating annual applicant savings, but only to the 95 applications in which a 399 biological and economic review ( Bio/ Econ) was done to determine SEL when estimating annual EPA savings. 400 13 2. Cost Savings for the Applicants ( States). The table below estimates the application cost 401 savings that are likely to occur as a result of changing to the loss based method. 402 a. The ICR ( EPA, 2000) estimates that it takes about 99 hours to apply for an emergency 403 exemption at a cost of $ 54 per hour or over $ 5000 per application. Of this 99 hours, 404 an estimated 74 hours is spent processing, compiling, reviewing, and providing all the 405 requested data, including efficacy and risk data. EPA assumes that about 25% of the 406 time providing all of the data is required to provide the economic data under the 407 current method. If the application qualifies for a SEL in Tier 1, the economic data 408 would not be required, thus saving almost 19 hours or almost $ 1000 per application. 409 For 276 applications that are likely to qualify under Tier 1, the savings would be 410 almost $ 276,000. 411 b. If an applicant qualifies for a SEL under Tier 2, but not under Tier 1, limited 412 economic data is required. EPA assumes that this limited data would require about 413 half of the time required for economic data under the current method. Therefore, the 414 savings would be about 12.5% of the time required to provide all data under the 415 current method   about 9 hours or $ 500 per application. With about 53 applications 416 that are likely to qualify for a SEL in Tier 2, but not Tier 1, and that would provide 417 limited economic data, the savings would be almost $ 26,500. 418 c. While the data required under Tier 3 may be less than required under the current 419 method, EPA makes the conservative assumption that there would be no savings. 420 Often an applicant may provide historical data to establish a baseline from which to 421 calculate the loss. Also, no savings are assumed for requests with no finding of SEL. 422 d. EPA estimates the total annual savings to the applicants to be almost 5,600 hours or 423 over $ 300,000. 424 Table 4. Cost Savings for Applicants from Proposed Loss based Method 425 Applicant 426 Current Cost Savings as a Result of Qualifying for a SEL Under:

Application Data * Tier 1 Tier 2 Total Savings Avg wage rate 427 $ 54 per hour % savings 428 25% 12.5%

Hour/ application 429 99 74 18.5 9.25 Applications/ year 430 500 500 276 53 329 Hours per year 431 49,500 37,000 5,106 490 5,596 $ per application 432 $ 5,346 $ 3,996 $ 999 $ 500 Total $ per year 433 $ 2,673,000 $ 1,998,000 $ 275,724 $ 26,474 $ 302,198 Numbers may not exactly add, due to rounding 434 * The estimate of the time and cost required to process, compile, review, and provide data. 435 3 Based on TAIS ( Time Accounting Information System) of OPP ( Office of Pesticide Programs), the time spent for the biologic and economic review is slightly over 25% of the time reported by all of OPP in processing emergency exemptions. ( EPA, 2003c)

14 3. Cost Savings for EPA. The table below estimates the review cost savings that are likely to 436 occur as a result of changing to the loss based method. 437 a. The ICR ( EPA, 2000) estimates that it takes about 108 hours for EPA to review an 438 emergency exemption. Of this 108 hours, it takes about 28 hours to review the 439 biological and economic data in order to determine if there is an emergency condition 440 and a SEL3. Most of the time is spent by the biologist in reviewing the emergency 441 condition. EPA assumes that 25% of the 28 hours ( about 7 hours) is spent by the 442 economist in the determination of SEL under the current method. At a cost of $ 67.25 443 per hour the biologic and economic review costs almost $ 1900 per application, with 444 the economic analysis costing about $ 470. 445 b. If the application qualifies for a SEL in Tier 1, the economist review would not be 446 required, thus saving about 7 hours or about $ 470 per application or about $ 24,500 447 annually for 52 applications ( of the 95 applications reviewed for SEL) likely to qualify 448 for a SEL in Tier 1. 449 c. If an applicant qualifies for a SEL under Tier 2, a limited economic review would be 450 required. EPA estimates that this limited review would save about 40% of the normal 451 time to do a full economic analysis or 10% ( 40% x 25%) of the time required for the 452 biologic and economic review under the current method with a savings of almost $ 190 453 per application or almost $ 1,900 for 10 applications that are likely to qualify for a SEL 454 in Tier 2. 455 d. EPA makes the conservative assumption that there would be no savings in the review 456 of Tier 3, including those requests with no finding of SEL. 457 e. EPA estimates the total annual savings of the biologic and economic review to be 458 almost 400 hours or about $ 26,000. 459 Table 5. Cost Savings for EPA from Proposed Loss based Method 460 EPA 461 Current Cost Savings as a Result of Qualifying for a SEL Under: Total Savings EPA Bio/ Econ Tier 1 Tier 2 Avg wage rate 462 $ 67.25 per hour Savings 463 25% 10%

Hours/ application 464 108 28 7 2.8 # of applications 465 95 95 52 10 62 Total hours 466 10,206 2,646 364 28 392 $ per application 467 $ 7,263 $ 1,883 $ 471 $ 188 Total $ per year 468 $ 686,354 $ 177,944 $ 24,479 $ 1,883 $ 26,362 4 Using data submitted under the present approach may result in some bias if average values for yield and prices are used to represent typical conditions. Under revised data requirements, states could submit data that better represents typical conditions if historical averages are inappropriate.

15 4. Total Saving. EPA estimates the total potential savings for the states and EPA combined to 469 be about a third of a million dollars as a result of changing data requirements and using the 470 loss based method for determining SEL. 471 E. Comparison of Findings 472 1. Likelihood of a SEL Finding 473 The table below compares the number and percent of findings under a direct use ( without 474 judgement) of the current and proposed methods, and what the analyst actually concluded using 475 judgement. 476 a. The analyst found a SEL a higher percentage of time ( 83%) than a direct use of the 477 revenue variation method would indicate ( 72%). The higher findings of a SEL by the 478 analyst were mainly the result of the analyst eliminating outliers where past revenues 479 were very low due to unusual conditions. Such outliers distort typical conditions and 480 the loss as a result of the emergency condition would have to be overly large to qualify 481 for a SEL. By eliminating the outliers, the historical data is more indicative of normal 482 conditions and the calculated threshold needed to qualify as a SEL is more realistic. 483 b. The percent of time the loss qualified as a SEL under the loss based method ( given 484 that the data were submitted under the present methodology) was closer to what the 485 analysts found than what a direct use of the revenue variation method found. Since the 486 loss based method is less affected by outliers in the historical data4, it is less dependent 487 on subjective decisions of the analyst. 488 Table 6. Comparison of Findings 489 Finding 490 Number and Likelihood of a Finding Current Method Proposed Method Actual by Analyst* Revenue Variation* Loss based SEL 491 86 ( 83%) 131 ( 72%) 147 ( 81%)

No SEL 492 17 ( 17%) 50 ( 28%) 34 ( 19%)

Total Observations* 493 2000 03 494 103 181 181 * Out of 181 observations, the actual finding by the analyst is known in 103 cases. The actual findings of SEL by the 495 analyst exceeds what the current revenue variation method would have found without judgement. The analyst uses 496 judgement to eliminate outliers in annual revenue data that distort the findings of SEL. 497 16 2. Cross Agreement of Findings 498 The table below shows the percent of time that the findings of a SEL agreed with each other 499 under the following: 500 a. What a direct use of the revenue variation method would have determined. 501 b. What the analyst actually determined. 502 c. What the loss based method would have determined. 503 This table below is based on 103 observations where the recommendation of the analyst was 504 known. The results show a high degree of agreement between the various methods. 505 Table 7. Cross Agreement of Findings 506 Cross Agreement of Findings 507 based on 103 observations 2000 03* 508 % Agreement SEL no SEL total Analyst with Revenue Variation Method 509 76% 14% 90%

Analyst with Loss based Method 510 82% 6% 88%

Revenue Variation Method with Loss based Method 511 76% 6% 82%

Analyst with Revenue Variation & Loss based Methods 512 74% 6% 80% * Out of 181 observations, the finding of the analyst is known in 103 cases. 513 3. Conclusions of comparisons. The two tables above demonstrate that changing from the 514 current method to the proposed loss based method would: 515 a. Not cause a significant change in the overall likelihood of a SEL finding as compared 516 to the current revenue variation method as modified by analyst judgement such as 517 eliminating outliers. The analyst made a finding of SEL in 83% of the cases studied, 518 while the loss based method would have found a SEL in 81% of cases. 519 b. Result in some different findings in individual cases. The analyst and the loss based 520 method arrived at different conclusions 12% of the time. In a few cases the analyst 521 found a SEL with a yield loss and economic loss as a percent of gross revenue of less 522 than 20% because these losses were sufficient to cause the net revenue to fall below 523 the lowest net revenue of the past 5 years. In other cases, the analyst did not find a 524 SEL with a yield loss greater than 20% because these losses were not sufficient to 525 cause the net revenue to fall below the lowest net revenue of the past 5 years. In some 526 cases there was not good data on the expected yield loss, so a judgement was made 527 whether or not the expected loss would exceed the minimum loss needed to qualify as 528 significant with the revenue variation method. 529 17 IV. Results of Analysis of Re certification 530 A. Applicant ( States) Savings 531 The table below estimates the likely savings to the applicants from re certification. The 532 calculations are similar to the cost savings analysis of the loss based method for determining SEL. If 533 an applicant re certifies, data will not be required, thus saving the 74 hours that the ICR estimates is 534 needed to provide the data, thus saving about $ 4000 per application. EPA estimates that about 75% 535 of an average of 329 repeat applications per year may qualify for re certification resulting in a total 536 savings to the applicants of almost $ 1 million per year. 537 Table 8. Cost Savings to Applicants from Re certification 538 Applicant 539 Current Cost Savings from Re certification Average wage rate 540 $ 54 per hour Hours per application 541 99 74 75%

Number of applications 542 500 247 Total hours 543 49,500 18,278 $ per application 544 $ 5,346 $ 3,996 Total $ per year 545 $ 2,673,000 $ 987,012 B. EPA Savings 546 The table below estimates the likely savings to EPA from re certification. Since many repeat 547 requests that would have qualified for re certification are currently not as thoroughly reviewed as new 548 requests, the EPA savings would not be as great as the applicants'. EPA estimates ( conservatively 549 low) that it would save about 10% of the average time it currently takes to review an application. 550 According to the ICR it takes about 108 hours to review an application, thus savings for EPA would 551 be almost 11 hours or over $ 700 per application, with a total annual savings of almost 2700 hours or 552 about $ 180,000. 553 Table 9. Cost Savings to EPA from Re certification 554 EPA 555 Current Average Cost Savings from Re certification Average wage rate 556 $ 67.25 per hour Hours per application 557 108 11 10%

Number of applications 558 500 247 Total hours 559 54,000 2,668 $ per application 560 $ 7,263 $ 726 Total $ per year 561 $ 3,631,500 $ 179,396 18 C. Total Savings from Re certification. EPA estimates the annual combined savings for the 562 applicants and EPA from re certification to be almost $ 1.2 million. 563 V. Combined Savings 564 The savings from re certification and the loss based method for determining SEL are 565 summarized in the table below: 566 Table 10. Summary of Cost Savings 567 Savings 568 Loss based Method Re certification Total Applicants 569 $ 0.30 million $ 0.99 million $ 1.29 million EPA 570 $ 0.03 million $ 0.18 million $ 0.21 million Total 571 $ 0.33 million $ 1.17 million $ 1.50 million By provision. The total savings from the loss based method are about a third of a million 572 dollars, and from re certification are almost $ 1.2 million for a grand total of about $ 1.5 million. 573 By entities. The total savings to the applicant and EPA are about $ 1.3 million and $ 210,000, 574 respectively, for a grand total of about $ 1.5 million. 575 VI. Information Collection Request ( ICR) 576 This economic analysis is based on the ICR for emergency exemptions ( EPA, 2000). The 577 provisions of the proposed rule only reduce the paperwork burdens as estimated in this economic 578 analysis. Therefore, the current ICR is still valid and provides an estimate of the paperwork burden 579 for those applications that would not benefit from the proposed rule. For the applicants that benefit 580 from the proposed rule, the burden will be reduced. The applicants that benefit include: 581 1. Those qualifying for self certification 582 2. Those applicants who can show a SEL in Tiers 1 or 2 of the loss based method. 583 In those applications where the applicant burden is reduced, EPA's burden is also reduced. 584 19 VII. Limitations of Analysis 585 A. Total Savings. The savings for the loss based method and re certification were each estimated 586 as if the other were not going to be implemented, i. e., the number of applications would benefit 587 from the savings of the loss based method would be slightly less as a result of economic data and 588 analysis not being required because of re certification. Also, the savings from re certification 589 were based on the current method. Since the loss based method would usually require less time 590 to prepare, the savings from re certification would be slightly less for the applicant. However, 591 this double counting of savings is likely to be small because repeat applications benefitting from 592 re certification are not likely to be the same applications that would benefit from the loss based 593 method. 594 B. Average Savings. This analysis was based on average hours and costs required to prepare and 595 review applications. However, such costs vary widely. The costs to prepare and review a first 596 time application for an emergency exemption are likely to be higher. Since these first time 597 applications are more likely to benefit from the savings of the loss based method for determining 598 SEL, the savings from the loss based method are likely to be underestimated. On the other 599 hand, the costs for preparing repeat applications are likely to be less. Since repeat applications 600 are more likely to benefit from the savings of re certification, the savings from re certification 601 are likely to be over estimated for the applicants. Since EPA has no basis to differentiate the 602 costs of first time vs. repeat applications, it did not fully attempt to do so, except that EPA 603 assumed a conservatively low savings for EPA for re certification. These under and over 604 estimates are likely to offset each other somewhat. 605 C. Unrealized Savings. Some applicants that qualify for Tier 1 or 2 of the loss based method may 606 not realize their potential savings because they might provide additional data in case they do not 607 pass those tiers. Similarly, some applicants that would qualify for re certification may not take 608 advantage of it. However, EPA has no basis to estimate these unrealized savings. Instead, EPA 609 has estimated the potential saving applicants could realize if they chose to do so. 610 D. Time Savings. The hours that would be saved under the various scenarios ( Tier 1, Tier 2, re 611 certification) were mostly assumed. In making these assumptions, EPA has tried to be 612 conservative toward underestimating the savings. Several factors were used to help make some 613 of these assumptions. For example, the 74 hours required to provide data is the basis of the 614 savings for re certification. Other savings are possible from other parts of the application that 615 are likely be simpler, but were not estimated. Therefore, the savings from re certification may be 616 underestimated. However, repeat applications are likely to be less costly, thus offsetting this 617 underestimation. 618 E. Conclusions. In spite of these limitations, the conclusions are valid. There should be substantial 619 savings from re certification and from changing data requirements for determining SEL. 620 Increasing flexibility in the data requirements in conjunction with changing the methodology for 621 determining SEL will also increase fairness, openness and objectivity. 622 20 VIII. Conclusions 623 A. Benefits 624 1. Cost Savings. EPA estimates substantial cost savings to applicants and some savings to 625 EPA from the proposed loss based method for determining SEL and re certification. EPA 626 estimates savings of about $ 1.3 million to the applicants and over $ 200,000 to EPA . 627 Different assumptions in the analysis would change the magnitude of the savings estimates, 628 but would not change the conclusion that there will be cost savings. 629 2. Transparency, Consistency, and Equity. EPA believes that the determination of SEL under 630 the loss based method will be more consistent and transparent. Currently, differences in 631 variations in revenue result in differences in the magnitude of the losses that would qualify 632 as SEL. To avoid extremes in inequities, analysts use judgement; however, such judgement 633 is not consistent nor transparent. By reducing judgement the loss based method is more 634 transparent. With established thresholds for SEL, the loss based method is also more 635 consistent and equitable. EPA believes decision making will be improved under the 636 proposed method. 637 3. Timeliness. Reduced analysis by EPA means more timely decisions on emergency 638 exemptions. 639 B. Impacts. There are no costs associated with the proposed rule, only cost savings. With respect 640 to the proposed loss based method, our analysis shows that the overall likelihood of a finding of 641 SEL would not be changed. However, in individual cases, the proposed method would result in 642 different findings of SEL in about 12% of the requests. As discussed above, EPA believes that 643 these different findings would be better since they would be more transparent, consistent, 644 equitable, and timely. 645 IX. References 646 BLS, 2003. Bureau of Labor Statistics. http:// data. bls. gov/ cgi bin/ surveymost 647 EPA, 2000. Information Collection Request, Emergency Exemptions. 648 EPA, 2003a. Data from the Biological and Economic Analysis Division, Office of Pesticide 649 Programs. 650 EPA, 2003b. Data from the Registration Division, Office of Pesticide Programs. 651 EPA, 2003c. Time Accounting Information System, Office of Pesticide Programs. 652 OPM, 2003. Office of Personnel Management. http:// www. opm. gov/ oca/ 03tables/ indexGS. asp 653 USDA, 2003. Agricultural Statistics  2003 654 EPA, 2005. Data from the Registration Division, Office of Pesticide Programs. 655


[Federal Register Volume 76, Number 197 (Wednesday, October 12, 2011)]
[Notices]
[Page 63334]
[FR Doc No: 2011-26386]

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SECURITIES AND EXCHANGE COMMISSION

Sunshine Act Meeting

    Notice is hereby given, pursuant to the provisions of the
Government in the Sunshine Act, Public Law 94-409, that the Securities
and Exchange Commission will hold a Closed Meeting on Thursday, October
13, 2011 at 3:30 p.m.
    Commissioners, Counsel to the Commissioners, the Secretary to the
Commission, and recording secretaries will attend the Closed Meeting.
Certain staff members who have an interest in the matters also may be
present.
    The General Counsel of the Commission, or his designee, has
certified that, in his opinion, one or more of the exemptions set forth
in 5 U.S.C. 552b(c)(3), (5), (7), 9(B) and (10) and 17 CFR
200.402(a)(3), (5), (7), 9(ii) and (10), permit consideration of the
scheduled matters at the Closed Meeting.
    Commissioner Walter, as duty officer, voted to consider the items
listed for the Closed Meeting in a closed session.
    The subject matter of the Closed Meeting scheduled for Thursday,
October 13, 2011 will be:
    Institution and settlement of injunctive actions;
    Institution and settlement of administrative proceedings;
    Adjudicatory matters; and
    Other matters relating to enforcement proceedings.
    At times, changes in Commission priorities require alterations in
the scheduling of meeting items.
    For further information and to ascertain what, if any, matters have
been added, deleted or postponed, please contact:
    The Office of the Secretary at<PHONE_NUMBER>.

    October 6, 2011.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011-26386 Filed 10-7-11; 11:15 am]
BILLING CODE 8011-01-P


[Federal Register: January 9, 2006 (Volume 71, Number 5)]
[Notices]
[Page 1420-1421]
[DOCID:fr09ja06-26]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. CP05-410-001]

Northern Natural Gas Company; Notice of Amendment of Application

December 29, 2005.
    Take notice that on December 23, 2005 Northern Natural Gas Company
(Northern), 1111 South 103rd Street, Omaha, Nebraska 68124, filed with
the Federal Energy Regulatory Commission an application under section 7
of the Natural Gas Act (NGA) to amend its original application pending
Commission approval in Docket No. CP05-410-000, all as more fully set
forth in the application which is on file with the Commission and open
to public inspection. This filing may be also viewed on the Web at
http://www.ferc.gov using the ``eLibrary'' link. Enter the docket

number excluding the last three digits in the docket number field to
access the document. For assistance, call<PHONE_NUMBER> or TTY, (202)
208-3676.
    Northern states it is amending its original application requesting
authorization to install the water handling facilities to increase the
storage capacity at its Redfield Storage Field in Dallas County, Iowa,
pursuant to section 7 of the NGA. This amendment is in addition to the
authorization requested in the original application filed September 2,
2005.
    Any questions regarding this amendment should be directed to
Michael T. Loeffler, Director of Certificates for Northern, 1111 South
103rd Street, Omaha, Nebraska 68124,<PHONE_NUMBER> or Bret Fritch,
Senior Regulatory Analyst, at<PHONE_NUMBER>.
    There are two ways to become involved in the Commission's review of
this project. First, any person wishing to obtain legal status by
becoming a party to the proceedings for this project should, on or
before the comment date stated below, file with the Federal Energy
Regulatory Commission, 888 First Street, NE., Washington, DC 20426, a
motion to intervene in accordance with the requirements of the
Commission's Rules of Practice and Procedure (18 CFR 385.214 or
385.211) and the Regulations under the NGA (18 CFR 157.10). A person
obtaining party status will be placed on the service list maintained by
the Secretary of the Commission and will receive copies of all
documents filed by the applicant and by all other parties. A party must
submit 14 copies of filings made with the Commission and must mail a
copy to the applicant and to every other party in the proceeding. Only
parties to the proceeding can ask for court review of Commission orders
in the proceeding.
    However, a person does not have to intervene in order to have
comments considered. The second way to participate is by filing with
the Secretary of the Commission, as soon as possible, an original and
two copies of comments in support of or in opposition to this project.
The Commission will consider these comments in determining the
appropriate action to be taken, but the filing of a comment alone will
not serve to make the filer a party to the proceeding. The Commission's
rules require that persons filing comments in opposition to the project
provide copies of their protests only to the party or parties directly
involved in the protest.
    Persons who wish to comment only on the environmental review of
this project should submit an original and two copies of their comments
to the Secretary of the Commission. Environmental commenters will be
placed on the Commission's environmental mailing list, will receive
copies of the environmental documents, and will be notified of meetings
associated with the Commission's environmental review process.
Environmental commenters will not be

required to serve copies of filed documents on all other parties.
However, the non-party commenters will not receive copies of all
documents filed by other parties or issued by the Commission (except
for the mailing of environmental documents issued by the Commission)
and will not have the right to seek court review of the Commission's
final order.
    Comments, protests and interventions may be filed electronically
via the Internet in lieu of paper. See 18 CFR 385.2001(a)(1)(iii) and
the instructions on the Commission's Web site under the ``e-Filing''
link.
    Comment Date: January 5, 2006.

Magalie R. Salas,
Secretary.
 [FR Doc. E6-54 Filed 1-6-06; 8:45 am]

BILLING CODE 6717-01-P


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Water Models

Exposure 		Modeling Public Meeting (EMPM) Information and Products

Minutes of the September 30, 2003 Exposure Modeling Public Meeting

Minutes of the September 30, 2003 Exposure Modeling Public Meeting

CM2

Rm 1126

1921 Jeff. Davis Hwy.

Arlington, VA

On this Page

Attendees

Welcome and Introduction

Old Action Items

Brief Updates

Next Meeting

Action Items

Attendees

Name	Association

Michael Barrett	 OPP/EFED

Dirk Young	OPP/EFED

Betsy Behl	OPP/EFED

William Eckel	OPP/EFED

Ron Parker	OPP/EFED

Mark Corbin	OPP/EFED

Lucy Shanaman	OPP/EFED

Cheryl Sutton	OPP/EFED

Faruque Khan	OPP/EFED

Mohammed Rahman	OPP/EFED

Jim Lin	OPP/EFED

Nelson Thurman	OPP/EFED

Donna Randall	OPP/EFED

Karen McCormack	OPP/EFED

Christine Hartless	OPP/EFED

James Hetrick	OPP/EFED

Norm Birchfield	OPP/EFED

David Miller	OPP/HED

Paul Whatling	Cheminova

Russell Jones	Bayer

Dean Scott	BNA Daily Env Report

Piyush Singh	Valent

Neil Shah	Inside Washington

Brent Solomon	Valent

Mary Nett	WQC

Wenlin Chen	Syngenta

Paul Hendley	Syngenta

Scott Jackson	BASF

Elise McCoy	FMC

Uwe Wanner	Crompton

Larry Burns	NERL/Athens

Mark Cheplick	Waterborne

Joe Bagdon	USDA - NRCS

Amanda Harrah	Toxcel LLC

Maria Ball	Waterborne

Kevin Armbrust	MS State/MSCL

Ric Lopez	EPA/ORD

Anne Neal	EPA/ORD

Anne Pitchford	APA/ORD/NERL

Jim Cowles	Wash State Ag

Cathleen Hapemen	USDA/ARS

Charlie Crawford	USGS

Susan H. Youngren	Burgrean and Campell

Skip Vecchia	USGS

T.S. Ramanarayan	Bayer

Stuart Cohen	Turf Envir. Services

James Breithaupt	OPP/EFED

Top of page

Welcome and Introduction

Michael Barrett (OPP/EFED) opened the meeting and welcomed the group.

Top of page

Old Action Items

Russell Jones (Bayer) to circulate reference to Piacenza journal with details of the conference proceedings - done

Don Wauchope (USDA) to circulate an Excel spreadsheet of combined databases when
available - still outstanding

Michael Barrett (OPP/EFED) to consider adding a progress update on the EPA fate database - to be covered at a future meeting.

Dave Jones' group to report on progress on Rice Tier 1 Model at next meeting - Jim Breithaupt to cover in his presentation today.

Ron Parker to check on availability of National Dunne Overland Flow data on USGS web site - Charlie Crawford released this GIS coverage.

Michael Barrett to add an agenda item to review background to WARP together with initial results from the CWS's for next time (and invite Charlie Crawford) - see later presentations.

Paul Hendley to circulate outcome of SDTF meeting on June 11 via list server - see later update.

Instructions for accessing and installing the latest version of EXPRESS were made available at the end of the meeting after some people had left.  These will be posted on the Website and a note sent to alert people of their availability - This is not currently an EPA official model (Please see below).  While a direct link is not currently provided on the EMWG webpage, a ftp link to a developmental version (close to a Beta Version) can be obtained from Marty Williams or Mark Cheplick at Waterborne Environmental:

http://www.waterborne-env.com/modeling/model_topic_przm.html

EFED to post PL4 on Web site - done.

EFED will consider adding agenda item on Tier 2 Groundwater needs and conceptual model for September EMWG meeting - moved to January agenda.

Russell Jones offered to coordinate presentation of the soils types/setting where PRZM works and why and whether there are any other viable alternative models for the other soils. EFED to consider adding to agenda - done.

Michael Barrett will schedule progress reports on EFED research programs at next EMWG meeting - possible January item.

Michael Barrett will circulate PGW database templates from last meeting and arrange for a discussion topic at the September meeting - moved to future.

Don Wauchope will post the ACS symposium  on soil dissipation (Spring 2004) on the
FIFRA-EMWG Web site - not done yet.

Bill Eckel will give update on half-life calculation policy for pesticide exposure models - see later update.

All are recommended to pass information on the algal inhibition technology on to others that they work with who might be interested in herbicide and syngergism screens - done.

Jerry Hannan to post synergism talk on Web site - not done.

Thuy Nguyen to post QA/QC presentation on Web site- not done yet.

It would be useful to get an update on the spatial approach for defining ponds and watershed sizes that EPA's intern is developing - see later presentation.

Jim Carleton may want to share the pond area/watershed ratio for the example HUC to see if there is useful information that can be drawn from the area comparison data sets - not yet.

EPA to post Gail Thelin's presentation after rechecked by USGS on the Web site - The material is still interim, interested parties should contact Gail directly for more information on her presentation: <a href="mailto:gpthelin<EMAIL_ADDRESS>.

EPA to check on availability of an orchard spray drift study run in concert with Mexico in the mid to late 90's - no data available.

Dave Valcore and Andrew Hewitt to supply  copies of their presentations to EPA for posting on the Web site - done.

Gerry Laniak to make his slides available via the Web - not done yet.

Top of page

Brief Updates

Update on New Half-life Calculations Policy - Bill Eckel  (Hand-out)

Development of this policy is a continuation of the Input Parameter Guidance for EFED aquatic modeling efforts.  The goal is to harmonize first and second tier risk assessment half-life calculations among EPA reviewers and contractors.  This proposed policy has been drafted and discussed in the technology teams but has not been approved by management.  After the policy is approved, it was agreed that the details should be presented at an upcoming EMWG meeting along with the findings of the FOCUS kinetics group.

In his presentation, Bill Eckel mentioned that:

Although our models use first-order kinetics, EFED recognizes that first-	order may not be appropriate for all situations  As a result, we have tried to find 	the most general method for best first-order fit to data sets.

The proposed policy allows either traditional log-linear regression or non-	linear exponential decay analysis without data weighing; all data must be included 	in the regression.

This approach avoids over-estimation of half-lives caused by use of log 	linear regression on data sets that are non-linear in log space.

The reviewer must decide which residues (e.g., bound residues) to include as 	parent based on appropriateness of extraction efforts.

Fit is determined informally by comparing computed intercept, half-life, and 	3 x half-life to empirical initial concentration, DT50 and DT90, respectively; the 	method that best fits the empirical data is chosen.

Chemical concentrations that do not decline below detection and past a 	certain time in the experiment, and are not well-fit by the chosen rate constant, 	are reported for use in other parts of the risk assessment.

Questions

Q.  Is this policy linked to the FOCUS kinetics workgroup outputs?

A.  Yes, but at a low level.

Q.  What happens if the policy process results in half-life estimates that continue to be unrealistic?

A.  If an arguable case exists for continuing fitting approaches, this may be acceptable provided there are supporting facts.

Q.  When will this policy be approved by management?

A.  If should be within three months.  After it is approved, we will circulate details and include a discussion at the next meeting.

SCI-GROW - Michael Barrett

A new version of SCI-GROW on the EMWG Web site is a Windows version.  It was designed to replicate the code of the existing version and should replicate the model output exactly.  Further changes to improve simulations will not be made until the EFED groundwater group (tech team subgroup) has agreed on a direction for the Tier 2 groundwater model development program.

EU Modeling Issues - Russell Jones

There have not been any  significant changes in the surface water and groundwater scenarios.  There is a new version of PERL which can be downloaded from their Web site.  The Landscape and Mitigation group and a new groundwater group is looking at risk assessments and scenarios.  They  should be finished early next year.  The Kinetics group will meet in December and the first draft report is being reviewed by the group.  Draft reports should be available soon.

PRZM-EXAMS/EXPRESS - Larry Burns/Mark Cheplick

The most recent version of PRZM-EXAMS is on the CEAM Web site.  Mark Cheplick reported
that there are three versions of PRZM with significant use worldwide:

PRZM 3.12.1 - primary user CEAM

PRZM 3.12 - primary user OPP

PRZM 3.24 - primary user the European Union

Syngenta recently funded investigation of a revision of code to take into account variable adsorption/desorption.  Mark has programmed test versions with a drain tile routine into PRZM and some turf thatch routines.

Currently the following versions are available on the CEAM web pages:

PRZM 3.12.1 (released 8/03) at
http://www.epa.gov/ceampubl/gwater/przm3/index.htm

EXAMS 2.98.04 (released April 2003) at
http://www.epa.gov/ceampubl/swater/exams/index.htm

The most recent information on the OPP Models is on the web at:

http://www.epa.gov/oppefed1/models/water/index.htm

The following versions are being used by OPP:

PRZM version 3.12 (dated May 24, 2001); not directly available on the web but a link is provided to Dr. Lawrence Burns' email to request this model.

EXAMS 2.98.04 (released April 2003).

The Input Guidance document on the web is outdated and does not currently reflect the current version of EXAMS (it also does not have the correct current version for SCI-GROW):

http://www.epa.gov/oppefed1/models/water/input_guidance2_28_02.htm

EPA/OPP is in the process of funding the development of a users manual for EXPRESS (the test version of EXPRESS currently has capabilities for running any of the three versions of PRZM in current use worldwide as well as running EXAMS 2.98.04).  Paul Hendley announced that an industry group will also be performing a review of EXPRESS.ORD is developing an implementation plan

PE4V01.pl, a PRZM-EXAMS user shell designed to automate most of the process for single
scenario runs, is currently being used in EPA by OPP (See extensive discussion on the QA/QC process for this in the minutes for earlier EMWG meetings).

Rice Tier 1 Model - Jim Breithaupt

Jim Breithaupt was asked to do some incremental refinements of  the rice model.  He is using redox numbers and is incorporating some aerobic soil degradation and water degradation information.    The interim policy for initial estimation of upper bound exposure levels from the rice use is being improved but is still considered pre-Tier 1.  Also, better crop time lines are being used.

Spray Drift Task Force - Norm Birchfield

Norm Birchfield reported on a recent meeting between the Spray Drift Task Force (SDTF) and senior EPA people including lawyers on the AgDRIFT model.  Several issues are still in play:

data compensation may be an issue if the use of the model were to take the 	place of spray drift data; risk managers are working on this issue with support 	from EFED;

license agreement and transparency - many EPA people are still not 	comfortable with the license agreement; EPA prefers to make the model and code more 	freely available;

future ownership of the model and how will improvements be entered; and

the need to define which version of the model will be used; EPA does not 	think that version control is a pressing issue at this point since the model is not 	in common use.

Paul Hendley reported that version 2.08 compiles all the changes made since version 2.04 and includes full documentation of those changes.  The SDTF wants this version to be approved and then renumbered as version 2.10.  The version 2.10 would then form the basis for future development and agreement.  Norm Birchfield stated most AgDRIFT modeling is presently conducted with version 2.01 because this is the last version created under the EPA-USDA-SDTF CRADA.  Later versions have not been reviewed by the Agency.  Later versions, however, do not appear to be substantially different from 2.01.  EPA feels issues 1-3 are more important at the moment.

PLUS and CARES - Scott Jackson and Paul Hendley

Scott Jackson indicated that there is nothing new on PLUS.  For CARES, they are looking at how to move daily water values into CARES.  This needs development of PLUS and a daily surface water model.  An industry  sub work group of CARES

has produced a white paper on how to move the data.  Using different methodologies, you can get daily output and link with CARES.  Betsy Behl asked to have regular updates on this CARES/modeling interface topic at future EMWG meetings.

EFED Groundwater Team - Betsy Behl

Betsy Behl reported on the progress of the groundwater team and efforts to link with other groups outside OPP.  The team has reviewed the open literature and the FIFRA Enviromental Modeling Taskforce (a group which previous evaluated PRZM leaching performance using OPP-required Prospective Ground-Water Monitoring Studies to support pesticide registrations) output and will produce a report by December.  The next action will be to identify models and data sets and make recommendations about Tier 2 models.  Betsy Behl is hoping to report on their progress at the January meeting.

EFED Fate Database - Michael Barrett

Don Wauchope is going ahead with his interim database and needs to circulate his spreadsheet version.  Mah Shamim and Larry Liu will try to present their progress at the next meeting.

Performance of PRZM - Russell Jones

Russell Jones gave a presentation that will be attached to the minutes.  Larry Burn had asked after his presentation whether a more theoretical based approach that relates to sorption and degradation would be helpful.  Russell Jones replied that he supported a theoretical approach when information is available, but an empirical approach can also be used for laboratory measurements of aged sorption.

FOCUS - Approach to Foliar Washoff and Dissipation in Surface Water Calculations - Piyush Singh

Piyush Singh's presented an update on how FOCUS looks at foliar washoff and dissipation for surface water calculation.  His presentation will be posted with the minutes.    It was pointed out that there are differences in the way FOCUS and EPA handle these issues.  EPA participants confirmed the importance of selecting the right chemical application method (CAM) appropriate for a particular use pattern.  Betsy Behl agreed that this topic should be discussed at the next EMWG meeting.

Landscape Investigations for Pesticide Studies (LIPS) - Small Water Body (SWB) Study - Donna Randall, Ann Pitchford and Las Vegas ORD Team.

Donna Randall explained that ORD is helping with the development of the Tier II Refined Risk Assessment model (PRZM/VVM).   ORD is using a RS/GIS approach to develop national, regional and scenario specific values for watershed size to pond volume.  Anne Pitchford reported that after the Mid-Atlantic monitoring program (1999 - 2004) , they will be monitoring between 100-150 small scale water bodies in the Midwest from 2001 - 2007 in collaboration with USGS and others.  In the future, they would like to monitor water bodies in  California (2002 - 2008)

Anne Pitchford described the Indiana pilot program that will be operational from 2003 - 2006.  The objective of this pilot study is to develop statistical distributions for model parameters to drive EXAMS.  The goal of the broad scale analysis is to assess large populations of surface water bodies (SWB's) using RS/GIS.  Then they will conduct surface water (SW) specific analyses to sample representative SWB's followed  by measurements of  diurnal, weekly, and monthly temporal changes in small water bodies (to be done at local universities through STAR grants).

The goal is to look at combining data from the National Wetlands Inventory with National Agricultural Statistics Service annual data at sites where SSURGO data exists along with previous National Water Quality Assessment (NAWQA) monitoring data from the US Geological Survey.  Given these criteria, they looked at the White River basin in Indiana.  They will be sampling four 8 digit HUC's using at least two levels of remote sensing resolution.  The objective is to identify the criteria needed for full census.  The four regions that were selected  represent a range of topographic relief and land-cover techniques.  The plan will result in an RS inspection of 10 - 12% of the basin.

During her presentation, Ann showed examples of 15 m Landsat thematic data and compared this with 30 m TM and 5 m CASI data.  In an earlier study, they looked at 5 m data to identify ponds in a flat area.  They used a 100 m buffer zone around each pond initially, but they may use LIDAR next season to better define small watersheds around static water bodies.

For the pilot study, they will identify 20-30 SWB's using RS/GIS (based on RS determined criteria to be agreed with OPP) and will visit each site for one day and evaluate the sampling method.  They will evaluate the runoff area and key pond parameters for EXAMS in sediment and water column.  The next steps include developing a peer-reviewed Research and Quality Assurance Plan.  The pilot program will run in the Summer of 2004 and then the final (full) study will occur in the Summer of 2005-2006.

WARP - Ron Parker

Ron Parker provided an update on WARP.

EFED has received Dunne overland flow model estimates for WARP were received from USGS
(for 6300 drinking water watersheds). Delineation of watersheds was difficult (problems with QA/QC), and there are plans to correct some of the data.  Christine Hartless announced that additional verification will be done, and they are finalizing a GIS tool to do this faster. Ron Parker then gave a brief background on WARP.  He explained that after the Food Quality Protection Act (FQPA) was passed, there was a need perform upper level refinements and estimate population-weighted concentration values for drinking water across the US. USGS had a regression model SPARROW which related concentration in surface water to characteristics of watersheds.  This model was originally used to evaluate nitrates.  EPA asked USGS to use the model to look at atrazine, and it worked well. This national-scale regression model methodology was presented to FIFRA SAP meetings at different stages of development on three occasions.  Then after the second SAP meeting, USGS suggested to EPA that the WARP model be used in place of SPARROW.  WARP has been developed from patterns observed in NAWQA monitored pesticide concentration data and provides predictive capabilities by performing a regression against predictors of watersheds that consist of widely available hydrologic, soil, and weather data.  WARP is a compilation of eight regression equations that provides 5th - 95th percentiles.

Variography and Kriging - Jim Hetrick/Jim Wolf

Using 1994-2000 Heidelberg data (Maumee River data only), they demonstrated the differences in time course for different chemicals (atrazine, acetochlor, chlorpyrifos).  Tools included GEO-EAS and Geostatistical Software Library.    Jim Hetrick discussed a variogram approach to analyzing temporal data ( days 100 - 275 for each year).  As an example, he showed the atrazine data from the reservoir monitoring program that showed a range of about four days.  He takes a data set, identifies missing data and uses temporal structure (nearest neighbor approach) to re-estimate data sets in a Monte Carlo approach.  This approach requires a normal distribution so monitoring data sets require  transformation (natural log transforms and normal score).  This technique may be limited by violation of stationarity; also needs to be aware of trends in periodicity and systematic annual effects.

Initial runs for atrazine were done as untransformed but later results used normal score transformed data for atrazine and acetochlor and had a range of about 20 days.  No temporal relationships were determined for chlorpyrifos.  For some years, kriging approaches were useful but for others they were not.  This approach permits temporal correlation and estimates missing values.  However, the approach depends on the quality of the monitoring and does not recognize the underlying transport variables.  The approach will tend to underestimate high occurrence frequency events, and the time series is noisy.

They performed a stochastic simulation analysis of the six years mean time series for atrazine and the 1995 data for acetochlor.  Atrazine simulations looked good for imaging the time series, but acetochlor predictions were less useful.  More work will be required.  They are looking to reevaluate this approach with other data sets and to incorporate other variables such as rainfall distribution and flow rate into co-kriging.

WARP and Climatic Time Series - Charlie Crawford/Skip Vecchia

A set of 1800 watersheds should be delineated by the end of the year.  The remainder will be available after QA/QC.

They used percentiles generated from annual WARP to transform raw concentrations to
approximate normality.  Then they linked with climatic data to explain seasonal variation in transformed concentrations.  Next they developed a time series model for generating residuals from the climatic model on a daily time step and finally reversed the WARP-transformation to obtain generated daily data.

Transformation to achieve approximate normality was achieved based on WARP generated
percentiles for 114 model validation stations.  They examined three methods: 3-parameter log-normal transformation, alternative transformation 1 and alternative transformation 2.  The 3-parameter log normal transformation provided a good fit for high percentiles but was a poor fit for lower percentiles.  Alternative 2, which shows S-shaped behavior, was better for lower percentiles.  Then they interpolated and areally averaged temperature and precipitation data on a monthly basis for each basin.  The monthly climatic data were used to model variation in the transformed concentrations for the model calibration stations (one model); station sin west was excluded because of data paucity.  A non-linear regression was performed; censored concentrations were handled using maximum likelihood (Tobit regression).  Low precipitation went with low values (concentration).  A model was developed to link atrazine data with temperature and precipitation using a seasonal temperature factor (61% atrazine variability was not explained).

No significant seasonality was found between station groups.  Variogram analyses suggested that noise was due to measurement error plus signal was related to drainage area and usage.  Final model fitted fairly well for atrazine and metolachlor.   Metribuzin had a highly censored data set which tended to amplify the variability.

Conclusions

seasonal variability in herbicide concentrations can be reproduced well 	using available monthly temperature and precipitation data

use of more accurate precipitation data may also help

easier to predict the annual mean rather that peak values; limits on upper 	bound predictions

the proposed model only works well with <15% censored data sets

obstacles remain given high censoring rates

Questions

Q.  Can this tool be used for predictions?

A.  Yes, this is the ultimate objective.

Q.  Would flow be a better variable?

A.  Flow may be a better explanatory variable for concentrations than precipitation, but flow is usually not available at most locations where you want to predict.

Q.  Is there an upper bound or can the predicted data exceed the measured?

A.  Yes, it can.  In some examples, simulated values were higher; no upper bounds

One issue is how to handle tails of distribution - extrapolation (extend relationships into tail).

EUFRAM Project - T.S. Ramanarayanan

Ingrid Sunzenauer provided a set of slides that describes the 2001 EUPRA workshop.  Ingrid Sunzenauer serves as EPA's link to the EUFRAM program and is on the EUFRAM steering committee.    EUFRAM has three parts: framework document (guidance, case studies), end-user testing, and strategic network.

T.S. Ramanarayanan presented Andy Hart's slides on the EUFRAM program.  These slides will be posted on the EMWG Web site.   The ECOFRAM report serves as a starting point and data guidance for EUFRAM.

Hybrid Model for Upper Tier FQPA Drinking Water Exposure Assessments - Ron
Parker

The hybrid model approach is being developed by Ron Parker and George Sabbagh. This option for calculating daily pesticide concentration values combines the nine percentiles of the distribution of concentration values at each the drinking water intake sites calculated by the WARP model with daily values calculated by the pesticide fate and transport models now used by OPP. The hybrid assessment is done by performing simulations using both types of models at the same or nearby and then combining the output results. The main advantages of this procedure over other options are

incorporation of application date(s) to provide the time factor needed
	for cumulative assessments

capability to simulate daily concentration values of  pesticide parent 	compound along with correctly timed degradates the for cumulative assessments and

capability to better estimate pesticide concentration values at the upper 	end of the distribution (above the 95th percentile) which are not estimated by the 	WARP model and are a function of the environmental fate properties of the chemical.

 This approach requires input data for each type of model and involves several steps. For the example presented, both PRZM/EXAMS and SWAT simulations were run for multiple years at sites near to the WARP site and the daily EEC's are sorted and ranked for each year. Then concentration values for multiple years were generated from variations of the 9 WARP percentiles by using the mean and standard error of the WARP estimates.  Finally, values for each percentile were randomly generated for each year and a new set of daily EEC's was recalculated. This approach uses daily ratios of parent to degradate to generate sets of daily data for parent plus degradates.

To estimate higher percentiles than can be done by WARP, this approach calculates the ratio of 99.7th %ile values (annual maximum day) from PRZM/EXAMS to 95th percentile from
PRZM/EXAMS for each year - this ratio is then applied to the WARP 95th percentile to estimate a WARP 99.7th %ile.  In the example presented, this approach did better for parent atrazine than for the degradate desethyl atrazine. This may be due to the fact that a flow component was not included in the PRZM/EXAMS simulation. Of the three approaches described, this one appears to be the most attractive for handling cumulative assessments of multiple active ingredients and degradates and for estimating of peak annual values.

The result of the hybrid is multiple years of daily values for multiple chemicals including degradates at all US surface water intake locations for use in population-weighted cumulative/aggregate FQPA drinking water assessments.

Top of page

Next Meeting

The next proposed meeting date is January 8th with the 7th or 6th as alternative dates.  Michael Barrett will confirm availability of Rm 1126 and circulate the final date ASAP.

Top of page

Action Items

Everyone will review old action items and complete before next meeting, particularly posting of presentations to Web site (Thuy Nguyen, Jerry Hannan, Don Wauchope, Gail, Gerry Laniak).

EFED will consider adding Tier 2 groundwater needs and conceptual model to January
meeting agenda.

Mark Cheplick will post details of suggested code changes in PRZM and slides showing impact of changes on the list server.

Michael Barrett or the new EMWG chair (new chairs are currently being elected for the Water Quality Technical Team in EPA-OPP Environmental Fate & Effects Division, one of the new WQTT chairs will be slated to take over the chair of EMWG) will schedule progress reports on the EFED research programs at the next meeting.

Don Wauchope will circulate an Excel spreadsheet of combined databases when available - end of the month.

Don Wauchope to post notice of ACS symposium on soil dissipation on Web site.

Ron Parker to update FIFRA EMWG on progress of the FAO comparative model at the next meeting.

EFED will consider  presenting a demo of  the fate database at the next meeting.

After management approval, Michael Barrett or the new EMWG chair will add a discussion of the kinetics policy to the agenda of the next meeting.

Industry representatives to present the findings of the FOCUS kinetics group at the same meeting.

All speakers to provide copies of their presentations to Michael Barrett for posting on Web site.

EPA to consider adding a presentation on internal work on foliar degradation, washoff and extraction factors as well as chemical application method factors for PRZM.

EPA to examine PLUS and CARES; industry to provide regular updates on
CARES/modeling interface topics at future meetings.

Michael Barrett to check availability or meeting room for next meeting and circulate final date on list server.

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