Ms. Tracy Perry 
Pesticide Re-Evaluation Division (7508P) 
Office of Pesticide Programs 
Environmental Protection Agency 
1200 Pennsylvania Ave. NW 
Washington, DC 20460-0001 

via regulations.gov: EPA-HQ-OPP-2021-0575 

Re: EPA’s Draft Endangered Species Act Biological Evaluations for the Registration Review of Clothianidin, Imidacloprid, and Thiamethoxam; EPA-HQ-OPP-2021-0575 

Dear Ms. Perry: 

Established in 1933, CropLife America (CLA) represents the developers, manufacturers, formulators, and distributors of pesticides and plant science solutions for agriculture and pest management in the United States. CLA represents the interests of its registrant member companies by, among other things, monitoring legislation, federal agency regulations and actions, and litigation that impact the crop protection and pest control industries and participating in such actions when appropriate. CLA’s member companies produce, sell, and distribute virtually all the crop protection and biotechnology products used by American farmers. 

CropLife America (CLA) appreciates the opportunity to comment on the Draft Endangered Species Act (ESA) Biological Evaluations of Clothianidin, Imidacloprid, and Thiamethoxam (the Draft Neonic BEs) produced by the Environmental Protection Agency’s (EPA or the Agency). Our comments, provided below, contain an Executive Summary, Policy Considerations, Technical Comments, and Conclusions. Should you have any questions or comments, please feel free to contact me at mbasu@croplifeamerica.org or (202) 296-1585. 

Read the full comments signed by CropLife America.