The National Cotton Council continues to work with Congress and the Administration to ensure farmers are not further burdened by over-reaching regulations.
Any concerns conveyed recently to Congress?
Those testifying at a recent House Agri-culture Committee subcommittee hearing agreed there were a number of factors driving up production costs, including increased prices for inputs, machinery and new technologies. The witnesses also agreed that another factor was the dramatic increase in the number of regulations and policies put in place by federal agencies, especially EPA. They explained that crop protection businesses that support American agriculture recently have seen serious deviations from the regular order, transparency and scientific integrity of EPA’s risk assessment-based pesticide review process.
The witnesses urged Congress and stakeholders to work with government agencies, including EPA, to ensure that no policies are enacted that would prevent farmers and ranchers from economically producing food and fiber. They also emphasized that due to the rising costs and the recent collapse in net farm income, farmers and ranchers will need every tool available to help minimize their production costs. The witnesses’ testimonies are at http://1.usa.gov/1VBYrH6.
What input did the NCC provide?
A key action was the NCC’s follow-up statement to be submitted to the record of that subcommittee’s hearing. In general, the NCC pointed to concerns with EPA’s: 1) approval process of crop protection products, 2) registration and re-registration process for pesticides and 3) new pesticide applicator certification rule. Other regulatory concerns noted were updated Worker Protection Standards, the Food and Drug Administration’s animal food safety rule, and the additional permits required under the new Clean Water Rule through the National Pollutant Discharge System.
The statement, at http://www.cotton.org/issues/2016/procost.cfm, highlighted various products/chemistries and how EPA’s actions are affecting their availability. The focus was on: Enlist Duo technology, dicamba and 2, 4-D product registration/labels, chlorpyrifos, imidacloprid, organophosphates, sulfonylureas, and sulfoxaflor. For example, we urged the EPA to consider the weight of evidence that does not support the agency’s inclusion of new risk safety factors in its review of all organophosphate pesticides. EPA also was urged to recognize these pesticides’ benefits – such as providing producers with effective insect resistance management options.
Another example of our concern with EPA’s procedures occurred shortly after we submitted the hearing statement of record. We joined with 38 other organizations on a letter to EPA expressing deep distress about the EPA’s opening of only a 60-day comment period for the stakeholder community to provide meaningful input on the draft biological evaluations of chlorpyrifos, diazinon and malathion. These three organophosphates are critical tools for a wide array of commodities, specialty crops and public health uses throughout the United States. The letter emphasized that a 60-day comment period was totally inadequate given the thousands of pages in each review and that there is missing data, lack of proper citations, significant internal errors and discrepancies as well as the failure to fully present key information.
Gary Adams is president/chief executive officer of the National Cotton Council of America. He and other NCC leaders contribute columns on this Cotton Farming magazine page.