July 24, 2017
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-2009-0846 & EPA-HQ-OPP-2012-0663, Registration Reviews: Boric Acid/Sodium Salts, Clethodim, Diquat Dibromide, Ethephon, Fenitrothion, Hexazinone, Hymexazol, Methoxyfenozide, Pronamide, and Trimedlure
The National Cotton Council (NCC) appreciates the opportunity to comment on the proposed interim registration decision for methoxyfenozide. 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 sporadic pest outbreaks and conventional cotton production.
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 appreciates the recognition of the relatively high selectivity this product has for pest control thereby minimizing disruption of beneficial insect populations. The product does provide a unique fit into many IPM programs as well as resistance management programs and is efficacious to many damaging caterpillar pests of cotton.
The NCC does not agree with the EPA’s proposed label change in appendix B, row 1, specifying insect pest and site “only.” The NCC understands the intent as do the users, but the biological reality is that no one can be certain that no other susceptible species are present in a field infested with damaging insects. The previous label adequately covers the Agency’s intent without language that essentially forces non-compliance due to basic biological facts. Additionally, NCC is concerned the language would prevent 2(ee) options if such need were to arise. The NCC urges EPA to refrain from the proposed label change in appendix B, row 1.
Thank you again for the opportunity to support the proposed interim registration decision for methoxyfenozide.
Senior Scientist, Regulatory and Environmental Issues
National Cotton Council