COTTON'S AGENDA

Managing Regulatory Issues

The National Cotton Council steadfastly oversees all of U.S. cotton’s regulatory challenges.

Where has the NCC been active recently?

There are contentious Clean Water Act permitting issues. We worked for passage of H.R. 872, which would amend the Federal Insecticide, Fungicide & Rodenticide Act and the Clean Water Act (CWA) to exempt pesticide applications from CWA permits, and we asked each Cotton Belt senator to support the bill. On another water issue, the NCC signed onto a letter with 40 other organizations to EPA and the Corps of Engineers insisting they should be doing rulemaking instead of guidance regarding the determination of whether a waterway, water body or wetland is protected by the CWA. The agencies already have acknowledged that the number of water bodies found subject to CWA jurisdiction would increase significantly under such “guidance.”

On a third clean water issue, the NCC is surveying members regarding current problems they may be encountering with the Spill Prevention, Control and Countermeasure (SPCC) program rule, which is aimed at preventing oil spills into U.S. waters. Earlier, Reps. Rick Crawford (R-AR) and Stephen Fincher (R-TN) sent a letter with more than 100 Representatives’ signatures asking EPA Administrator Jackson to extend a Nov. 10, 2011, deadline for affected producers and ginners who would have to submit a SPCC plan.

What other regulatory issues loom?

Among the many other issues NCC is involved with include: 1) arguing that EPA’s current coarse particulate standards are overly protective, and there is no additional data that would support a more stringent standard, 2) supporting legislation that ensures agriculture’s GPS tools are not compromised by other broadband operations, 3) submitting detailed comments expressing agriculture’s concerns with the Department of Transportation’s proposed guidance on the applicability of its regulations to operators of farm equipment and off-road agricultural equipment, 4) submitting comments to a March Federal Register notice in support of a registration request from Ag Logic LCC for a generic aldicarb – a product that would serve as a key early season insect and nematode control after Temik production was discontinued and 5) seeking to keep the U.S. raw cotton export pipeline open to Turkey by making the case that cotton fiber is not a living organism and therefore should not be subject to Turkey’s new regulation of imports regarding genetically engineered crops.

These are but a few of the regulatory challenges. If there are reductions in agriculture’s safety net in the upcoming 2012 farm law, U.S. cotton producers will understandably need to be even more efficient and productive. That’s another arena in which the NCC has been very proactive in helping our member producers – with programs ranging from the Producer Information Exchange to weed resistance education. The NCC will continue to advance education, but it is imperative that we maintain an effective presence in the regulatory process so our industry members are not unduly hampered and their world marketplace competitiveness undermined.

Mark Lange is president and chief executive officer for the National Cotton Council of America. He and other NCC leaders contribute columns on this Cotton Farming page.