June 10, 2016
Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
One Potomac Yard (South Building)
2777 S. Crystal Drive
Arlington, VA 22202
RE: Docket No. EPA-HQ-OPP-2015-0746
The National Cotton Council (NCC) appreciates the opportunity to provide the following comments regarding the Environmental Protection Agency’s (EPA) notice of registration review of fluometuron. The NCC strongly urges EPA to maintain the current section 3 label uses of fluometuron for cotton. The NCC appreciates EPA’s recognition that this product provides cotton producers with a management option for the control of weeds (particularly palmer amaranth) that have evolved resistance to glyphosate and/or ALS herbicides. The NCC urges EPA to recognize the critical value this product provides on those acres where it is most needed. Producers must have access to herbicides with different modes of action in order to manage current resistant weed populations and deter evolution of additional resistant weed species. The NCC urges EPA to maintain producer engagement during the registration review of fluometuron.
The NCC is the central organization of the United States cotton industry. Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from Virginia to California. The NCC represents producers who cultivate between 9 and 12 million acres of cotton. Annual cotton production, averaging approximately 12 to 18 million 480-lb bales, is valued at more than $5 billion at the farm gate. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 125,000 workers and produce direct business revenue of more than $21 billion. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 375,000 workers with economic activity well in excess of $75 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed, and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.
Fluometuron has been safely used as a herbicide in cotton for over 40 years. The NCC understands EPA must conduct a registration review of products every 15 years, but NCC is not aware of any new data, developments, or concerns related to fluometuron. The NCC encourages EPA to conduct a timely registration review that will not disrupt the use of this important weed control product. Again, the NCC appreciates the opportunity to comment on EPA’s notice of registration review of fluometuron.
Respectfully submitted,
Reece Langley
VP – Washington Operations