July 24, 2017
Ms. Susan Bartow
Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460
RE: Docket ID Number EPA-HQ-OPP-2012-0161-0090, Pesticide Registration Review; Aldicarb
Dear Ms. Bartow:
The National Cotton Council (NCC) appreciates the opportunity to comment on the proposed interim registration decision for aldicarb. The NCC continues to urge the Environmental Protection Agency (EPA) to recognize the historical safe labeled use of this product and its benefit to the cotton industry, particularly for control of nematodes.
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 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 has read the interim decision and regrets that the Agency feels the need to discontinue the T-band application which has served the cotton industry well for many years. However, we appreciate that the EPA identified mitigation measures that meet the criteria for registration approval of the product. The cotton industry continues to recognize, especially in fields with high nematode population, the lack of alternatives for aldicarb. We appreciate the EPA’s registration review and proposed continued registration with new safety mitigation measures to ensure public safety and appropriate environmental mitigations.
Thank you again for the opportunity to comment on the proposed interim registration decision for aldicarb.
Senior Scientist, Regulatory and Environmental Issues
National Cotton Council