NCC Comments Regarding Monarch Butterfly Proposal

NCC filed a comment letter in response to EPA’s request to identify risk management options to protect monarch butterflies.

Published: August 21, 2015
Updated: August 21, 2015

August 21, 2015 

Mr. Jack Housenger, Director
Office of Pesticide Programs
Environmental Protection Agency Docket Center
1200 Pennsylvania Ave. NW

Washington, DC 20460-0001

RE: Docket No. EPA-HQ-OPP-2015-0389 Risk Management Approach to Identifying Options for Protecting the Monarch Butterfly

The National Cotton Council (NCC) appreciates the opportunity to provide the following comments in response to the Environmental Protection Agency's (EPA) Federal Register notice EPA-HQ-OPP-2015-0389 Risk Management Approach to Identifying Options for Protecting the Monarch Butterfly.

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. Annual cotton production 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. The industry and its suppliers, together with the cotton product manufacturers, account for approximately 200,000 jobs and generate total annual economic activity in excess of $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.We recognize the dilemma facing the monarch butterfly and believe that action should be taken to address the declining population. As you work toward establishing conservation methods for milkweed, it is important to have our industry involved in the conversation to collaborate on this issue.

Input from agricultural organizations is essential to ensure the practicality of the measures suggested, as well as to ensure buy-in from land owners. The agricultural community is willing to work with the EPA to develop solutions that can benefit everyone by restoring the monarch population and assuring that our farmland remains productive.

It is important to note that agricultural practices are not the only issue confronting monarch butterflies. Experts who study the species say there are a number of factors that may contribute to fewer monarchs migrating from the U.S. to Mexico in any given time period. These factors include predation, pathogens, parasites, logging of overwintering sites in Mexico, weather events (freezing temperatures and drought) and climate change. We are committed to working together with the EPA and public and private organizations to develop viable solutions that do not limit our farmers' use of current and future agricultural technologies necessary for human food and fiber production.

Our growers protect the land on which they produce crops and live. Innovations like herbicide tolerant crops have allowed our farmers to control weeds with less pesticide applications and fewer trips through the field, thus reducing environmental footprints. Removing herbicides and placing unnecessary restrictions could have negative consequences that will be detrimental to the protection of butterflies and crop yields. It is imperative that any regulatory action developed to protect milkweed must be compatible with the weed management needs on a farm. Farmland and butterflies can coexist. We must work together to find solutions that benefit all stakeholders without placing undue burdens on agricultural stakeholders alone.

As you move forward through this process, please look at national agriculture organizations, such as ours, to join these important conversations.

Again, the NCC appreciates this opportunity to provide comments regarding Risk Management Approach to Identifying Options for Protecting the Monarch Butterfly, and looks forward to participating in meaningful dialog to ensure preservation of monarchs and agricultural production.Please do not hesitate to contact us with any questions or concerns.


Reece Langley
Vice President, Washington Operations