November 9, 2020
Diane Gelburd, Ph.D.
Deputy Chief for Science and Technology
USDA Natural Resource Conservation Service
Room 5113, South Building
1400 Independence Avenue, SW, Washington, DC 20250
Via Federal Rulemaking Portal
RE: USDA’s Agricultural Innovation Agenda, Docket No. USDA-2020-0008
The National Cotton Council (NCC) appreciates this opportunity to provide input on the most innovative technologies, practices, and management tools that can be readily deployed through one or more USDA programs. The NCC commends the Department in continuing its efforts to develop and implement its Agricultural Innovation Agenda (AIA) as it aligns with U.S. agricultural industry efforts to accomplish similar goals through coalitions, such as the row crop commodity initiative, Field to Market and through the U.S. cotton industry’s own initiative, the U.S. Cotton Trust Protocol, all focused on the continuous improvement of agriculture’s sustainability record.
The NCC is the central organization of the United States cotton industry. Its members include growers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehouses, and textile manufacturers. 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 $6.0 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 $75 billion.
The NCC provided comments earlier this year on objectives and opportunities leading to research goals that will facilitate production breakthroughs and will enable U.S. agriculture to meet the goals of increasing production by 40 percent by 2050 while cutting its environmental footprint in half as part of USDA’s Agricultural Innovation Agenda [Docket No. 2020-0003]. However, this request is specific to assist the Department in identifying the best “ready to go” technologies, practices and management approaches in support of the AIA goals.
The NCC recommends the Department consider a system, commercially referred to as VIPR, that detects and removes plastic contaminants from seed cotton prior to entering the gin stand where cotton fiber is separated from cottonseed.
For a number of years, plastic contamination has been a concern of the U.S. cotton industry. However, in the past four years, plastic material used to wrap round cotton modules formed by the latest harvesting technology has been identified as greatly increasing the amount of plastic contamination found in cotton bales from the U.S. and other cotton growing regions utilizing this harvesting machinery. Plastic contamination has become a very large threat to the U.S. cotton industry. According to the USDA Agricultural Marketing Service, Cotton Classing Offices, the number of “classer calls” for plastic contamination has risen to the point that a new classer remark specifically for plastic is now utilized. Additionally, many commercial purchasing contracts and marketing pools refuse to accept cotton with plastic contamination classing remarks, thus relegating those bales to “below grade” (BG) status.
Researchers at the USDA/ARS Cotton Production and Processing Research Unit in Lubbock, Texas developed (with assistance from ARS colleagues from the Southwestern Cotton Ginning Research Laboratory in Las Cruces, New Mexico) a low-cost system that identifies and removes plastic and other contaminants in harvested cotton before being ginned. This system, commercially known as VIPR (Visual Inspection and Plastic Removal), utilizes imaging sensors from the cell phone industry combined with low-cost embedded microcontrollers to identify contaminants. When a contaminant is detected, a compressed air nozzle system blows the contaminant out of the cotton. Commercial testing shows that the system can operate with detection/removal efficiency of more than 90%. This technology was developed, tested, and successfully transferred to a commercial partner with plans to market the system for the 2021 harvest season. However, research in collaboration with the commercial partner continues to refine certain aspects of the system as part of ARS National Program 306, Project numbers 3096-21410-008-00D and 3050-41000-009-00D.
The VIPR system is a unique approach to solving a very real and costly post-harvest issue for the U.S. cotton industry. The system is readily retrofitted to existing ginning machinery, and it has been trialed commercially and has shown to be 90% effective in removing plastic contamination.
We urge the Department to provide the necessary support to ARS and its commercial partner to complete refinement of this system so that timely commercial adoption can be achieved. The VIPR system has the potential to significantly reduce market discounts for thousands of bales (nominal 500 LBS each) of U.S. cotton fiber and to eliminate the waste of otherwise high grading fiber. The system is compatible with existing machinery, it is relatively simple in installation and operation, and with USDA/ARS’ research and technology transfer capabilities, it can be hastened to commercial adoption by the 2021 harvest season.
Thank you for this opportunity to provide comments on USDA’s efforts to continue to assist U.S. agriculture in meeting future challenges and the needs of its customers.
Sincerely,
Gary M. Adams
President and CEO
National Cotton Council