NCC’s Comments Support Glyphosate

October 4, 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-2016-0385

The National Cotton Council (NCC) appreciates this opportunity to provide comments on the herbicide, glyphosate.  This product has become increasingly important to U.S. cotton production.  The NCC strongly supports the re-registration of glyphosate.

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 10 and 14 million acres of cotton.  Annual cotton production, averaging approximately 16 to 20 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 230,000 workers and produce direct business revenue of more than $27 billion.  Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 420,000 workers with economic activity well in excess of $120 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.

Effective weed management is one of many critical components of successful cotton production.  Weeds play a major role in reducing cotton yields by an average of 30 %. Weeds are very efficient users of resources, competing with the crop for space, sunlight, nutrients, and moisture; they may release toxic compounds and also provide shelter and food for insect pests and plant pathogens. Weeds also may interfere with harvesting of cotton and can reduce lint quality because of trash or staining.  Control of weeds is essential to maximize yields and to produce a higher quality fiber.

Due to differences in plant growth, cotton requires better, more effective and timely weed control than many other crops.  Cotton is especially sensitive to weed competition because it grows relatively slowly in the early developmental stages and does not reach full ground shade until eight or more weeks after germination.

Because of the impact of weeds on cotton production and their ever-present nature, U.S. cotton farmers have increasingly utilized glyphosate and rapidly adopted glyphosate-tolerant transgenic cotton varieties.  In 2015, 94% of U.S. cotton acreage were planted with herbicide tolerant and/or insect resistant cotton varieties.[1]  Herbicide tolerant cotton has revolutionized cotton production and significantly reduced farming’s environmental footprint by enabling producers to apply herbicides, such as glyphosate, that are more environmentally benign.  During its 30 plus years of use, data has been accumulated from hundreds of toxicological and environmental studies.  The overwhelming consensus of regulatory agencies and scientific organizations such as the U.S. Environmental Protection Agency (EPA), Health Canada, the European Commission, and the World Health Organization is that glyphosate used according to label directions poses no unreasonable risk to humans, wildlife, or the environment.  In its own Reregistration Eligibility Decision, EPA concluded that glyphosate is of relatively low oral and dermal acute toxicity, poses minimal human dietary risk, is not expected to pose undue risk to workers/applicators, adsorbs strongly to soil and is readily degraded by soil microbes, and has minimal effects on birds, mammals, fish, and invertebrates.

The rapid adoption of this technology in just ten years demonstrates not only the safety of this product but also the benefits of the technology to commercial cotton growers.  The following chart provides the latest cotton acreage estimates for 2015¹, by state, and the percentage of planted cotton acres containing herbicide tolerant traits (burndown, over-the-top, etc.):

*Calculated using all biotech minus insect resistant only.

As environmental stewards, producers have both an economic and environmental incentive to use and preserve best available technologies.  For example, since the commercialization of glyphosate-tolerant cotton, growers have widely adopted agronomic practices of reduced tillage (no-till and strip-till) farming.  Soil conservation saves approximately 1 billion tons of soil per year in the U.S. and 306 million gallons of tractor fuel and its related emissions.  According to Cotton Incorporated researchers, conservation tillage practices as adopted in the U.S. from 1996-2004 have an effect on carbon dioxide reduction that is equivalent to removing 27,111 cars from the road.  The Environmental Impact Quotient (EIQ) developed at Cornell University can be used as a robust measure of the environmental impact of technologies, as it incorporates key toxicity and environmental exposure data related to individual products.  The EIQ has decreased by 17% in the U.S., largely due to advances in genetically modified cotton as it relates to pesticide use reduction along with air, water, and soil conservation; at the same time, yields have increased 25% from 1994-2004.[2]

Thank you again for this opportunity to provide comments in support of this important crop protectant tool.  The NCC looks forward to working further with you in your review of glyphosate and is pleased to provide additional data and information as needed.

Respectfully submitted,

Reece Langley
VP – Washington Operations