WASHINGTON, DC, Sept. 21, 2012 –- After recently reaching agreement with Dow AgroSciences on the use and approval of 2, 4-D tolerant crops, the Save Our Crops Coalition (SOCC) signaled today that it wants to restrict and slow down approvals for similar synthetic auxin resistant technology from Monsanto and BASF, the dicamba resistant cropping system. 

The SOCC called for the Environmental Protection Agency (EPA) to submit itself to National Environmental Policy Act (NEPA) procedures, and prepare an environmental impact statement (EIS) that considers herbicide use within the dicamba tolerant cropping system.

Yet, critics of the call for an environmental impact statement argue that EPA is exempt from completing such an assessment. According to documents on the EPA’s web site:

Courts also consistently have recognized that EPA procedures or environmental reviews under enabling legislation are functionally equivalent to the NEPA process and thus exempt from the procedural requirements in NEPA.

However, EPA has a policy that allows the agency to voluntarily submit itself to NEPA procedures where NEPA analysis would be beneficial. SOCC believes it has a strong basis, under that EPA policy, for EPA's voluntary submission.

Among the criteria that EPA considers in making a determination to submit itself voluntarily to NEPA procedures are “the potential for using an EA or EIS to comprehensively address largescale ecological impacts, particularly cumulative effects” and “the potential for improved coordination with other federal agencies taking related actions.” SOCC believes that the preparation of an environmental impact statement that comprehensively considers the environmental effects of herbicide use within the dicamba tolerant cropping system would prove beneficial to EPA to fit both criteria. 


BASF Industry Affairs Manager Daniel Pepitone said that his firm is “evaluating this and the earlier SOCC announcement,” but that government agencies already have "a strong and robust process in place to evaluate these products appropriately." 

The public submitted more than 300 comments to USDA’s Animal and Plant Inspection Service (APHIS) for Monsanto’s dicamba resistant soybean before the deadline closed on Sept. 11.  When commercialized, the dicamba tolerance trait will be combined with Monsanto’s Roundup Ready 2 Yield® to form Roundup Ready® 2 Xtend Soybeans. According to the company, this technology is designed to provide greater flexibility, simplicity and crop safety in controlling tough weeds and maximize yield opportunity. This will be the first consideration from APHIS regarding nonregulated status for a plant developed to be tolerant to the dicamba herbicide. 

“Millions of farmers look forward to the potential that dicamba tolerant crop technology offers as an additional tool in their weed management toolbox,” said Monsanto public affairs specialist Janice Person. “We have kept the success of all farmers in mind, involving sensitive crops and others, as we’ve developed the system.”

In their letter to Secretary Tom Vilsack last month, 10 national agricultural groups insisted the industry developed the new herbicide tolerant cropping system to incorporate stewardship measures that promote compatibility with other crops.  The groups believe that requiring a full EIS is not necessary. 

“We remain concerned about efforts to deny valuable tools to U.S. farmers by requiring costly and unwarranted environmental reviews of agricultural biotechnology,” the letter stated.

“Concerns about off-target movement of dicamba when applied in-season to dicamba-tolerant soybeans have been addressed by the petitioner through new product formulation as well as stewardship measures and education to be undertaken,” said American Soybean Association (ASA) President Steve Wellman, who also commented that dicamba has been used to manage weeds in crop production for sixty years.

SOCC opposes Monsanto and BASF's efforts to register the new use of dicamba on dicamba tolerant crops, and also requested EPA withhold registrations “until effective measures are in place to mitigate the effects of non-target plant damage.”

The coalition claimed in its comment to EPA that without more mitigation measures, the registration of dicamba on dicamba tolerant crops would increase the risk of adverse effects on the environment.

"Dicamba is one of the nation’s most dangerous herbicides for non-target crop damage,” said SOCC Chairman Steve Smith. “Monsanto and BASF have not offered sensitive crop growers effective measures to protect against non-target crop damage.”

SOCC and Dow AgroSciences reached an agreement about Dow’s 2,4-D tolerant crops  this month. A joint statement indicated that Dow will request an amendment to its label pending before EPA to include more statements assuring stewardship of herbicide applications near sensitive crops. SOCC stated it will change its comments to USDA and EPA to the extent they challenge Dow’s new seed and herbicide product applications for approval to be commercialized as part of the Enlist™ Weed Control System.

“Dow AgroSciences has worked with SOCC to deliver solutions to the problems of growers,” Smith said. “We hope Monsanto and BASF will step to the plate and do the same.”

Currently, SOCC’s mission has two objectives for the dicamba new use registration process: that the crops are used in a “responsible manner,” and that Monsanto use the lowest volatility formulations on dicamba tolerant crops.

SOCC said “additional restrictions” on the use of dicamba are necessary to “protect against drift and volatilization damage to non-target plants.”

Peterson maintained that EPA and USDA already have extensive evaluation procedures in place, and that Monsanto will not authorize the use of “higher volatility herbicide products” containing the active ingredients dimethylamine salt (DMA) of dicamba or dicamba acid in the Roundup Ready Xtend Crop System.

She added that Monsanto will use “clear and specific label and license requirements” regarding the use and application of new products. 

“This approach will be based on scientific research and data that determine the best ways to minimize risk of off-site movement,” Peterson said. 


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