July 6, 2017
Environmental Protection Agency Docket Center (EPA/DC), (28221T)
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
Mr. Garland Waleko
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave. NW,
Washington, DC 20460–0001
Re: Docket ID No. EPA-HQ-OPP-2012-0167-0053
Dear Mr. Waleko:
The National Cotton Council (NCC) appreciates the opportunity to provide the following comments related to the importance of the pyrethroid pesticides as critical means for completion of Integrated Pest Management (IPM) programs in cotton production.
The NCC is the central organization of the United States cotton industry. Its members include growers, 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 California to Virginia. U.S. cotton producers cultivate between 9 and 12 million acres of cotton with production averaging 12 to 18 million 480-lb bales annually. 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. Annual cotton production is valued at more than $5.5 billion at the farm gate, the point at which the producer markets the crop. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 280,000 workers with economic activity of almost $100 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.
The NCC supports the evaluation of crop protection products to insure protection of human health and our ecosystem based on sound field relevant science. Unfortunately, the NCC has concerns that EPA is inferring harm beyond the scope of scientific data. The NCC urges EPA to return to the historic path of reliance on credible scientific data reflective of field practices. The current ecological risk assessment released by EPA is known to be overly conservative and not reflective of actual field use levels. EPA is strongly urged to refine the risk assessment based on the best science available and in a manner that will accurately reflect real world scenarios rather than extremely conservative assumptions. In particular, it is our understanding that EPA has failed to represent the scientific evidence of pyrethroid solubility in water, thus over exaggerating ecological impacts. Further, EPA has failed to account for restrictions already present on current use labels, which again over exaggerates impacts.
The NCC is extremely concerned that EPA continues to rely on a water model that often computes results that have no agreement with real world data. It is imperative that EPA recognize the multiple contradictions between the EPA water model and real world monitoring data as evidence that the model is failing to represent real world scenarios.
The pyrethroid group has a long history of safe use and has proven to be a critical tool in integrated pest management programs for crop production. The NCC urges EPA to recognize that the limited number of crop protection products currently available places a producer in a vulnerable position for massive crop losses and development of pest resistance. Products such as the pyrethroids are critical rotational products for long term preservation of multiple insect modes of action. The EPA’s decisions must reflect real world use and the multiple mitigating factors/restrictions already applicable to use of pyrethroids.
The pyrethroid chemistry has long served as a vital component in cotton IPM programs of the U.S. The overall use of the pyrethroids in U.S. cotton has decreased since the introduction of the BT cottons in the mid-1990’s, but continues to serve a vital role in both IPM and Integrated Resistance Management (IRM). It has long been understood that some Lepidopterous species were less susceptible to the BT trait, and pyrethroid applications play a vital role in control of those species and preservation of the susceptibility to BT cotton. Additionally, cotton producers have realized through experience that the pyrethroid chemistry cannot be utilized all season because of resistance development, but that the chemistry is vital as an alternate mode of action to achieve overall IPM objectives. Additionally, the pyrethroid chemistry has a particular fit in situations where multiple pests are present requiring either a broad spectrum product or multiple applications of different products. The loss of the pyrethroids will result in fewer modes of action, more applications of those few modes of action, and increased selection for resistance to the few modes of action remaining available to producers.
The NCC further urges EPA to recognize that the multiple pending registration decisions should not be considered as alternatives until the EPA has verified their continued registration. The NCC is concerned that the EPA’s recent process requiring years of review has deviated from sound science and realistic use in a manner more similar to the “precautionary principle” in violation of FIFRA. The NCC also is concerned that the EPA’s recent activity threatens the producer’s ability to protect crops from pest losses, while contending that alternatives exist when, in fact, those alternatives are under threat of cancellation or massive restrictions as well. Again, the NCC urges EPA to return to representing real field use of products and scientific data for risk assessment of the practiced use.
The NCC appreciates favorable consideration of these comments.
National Cotton Council