WASHINGTON, June 8, 2016 - A proposal to allow in-crop
application of dicamba on cotton and soybeans genetically engineered to be
resistant to the herbicide has sparked lively debate among farmers, farm and
food safety groups.
In comments submitted to EPA, soybean and cotton growers
almost uniformly supported the proposed registration, which would allow
post-emergent dicamba use on Monsanto’s Roundup Ready 2 Xtend soybeans and its
Bollgard II Roundup Ready cotton. The Center for Food Safety and some specialty
growers were highly critical of the proposal, however.
Dicamba is currently registered for use on preplant and
pre-harvest soybeans and on preplant and postharvest cotton. The proposed use
would add post-emergence (over-the-top) applications to dicamba-tolerant cotton
and soybean crops.
“The demand to use dicamba in combination with
dicamba-tolerant soybeans is urgent,” said
American Soybean Association President Richard Wilkins. “The weed
resistance issues farmers are facing are grave. We urge (EPA) to make this new
weed-control tool available on the quickest possible timeline.”
In proposing
the new uses for the registration, EPA said that resistance to glyphosate,
the most widely used herbicide in the world, “is having severe economic
consequences in soybean and cotton production.”
“EPA finds that when the proposed mitigation measures are
applied, the risks that may remain are minimal, if they exist at all, while the
benefits are potentially great,” the agency said.
But growers questioned two of those mitigation measures in
particular: around-the-field buffer zones of 110 to 220 feet, depending on the
amount of dicamba used, and a prohibition on tank-mixing with other herbicides.
“The current size of buffer zones does not consider that
farms, like many in Georgia, may be small and irregularly shaped,” said
Tommy Gray, director of the Plant Industry Division in Georgia’s Department
of Agriculture. “Requiring so much of our farmers' limited space will lead to
loss in profit and production.”
And Reece Langley, vice president of Washington operations
for the National Cotton Council, said
that “if EPA is encouraging a different herbicide to be mixed and applied to
these massive buffers on all sides of the field, it would seem EPA has lost
touch with agricultural practices.”
Cotton, he said, “is often planted on raised or ‘hipped’
beds in order to allow furrow irrigation and/or proper drainage with minimum
soil loss. Trips across the field afterwards (are) based on the direction of
the hipped rows. As such, the beginning and ends of the rows included in the
buffer could only receive a different treatment by traveling over the entire field.”
Dale Moore, executive director of public policy at the
American Farm Bureau Federation, said the
around-the-field buffers “might well raise questions of using conventional
tillage or hand weeding in the buffer area to fight hard-to-control weeds. Resistance
that develops in this buffer area could limit the overall value of weed
resistance management and conservation tillage.”
As for tank-mixing, the ASA’s Wilkins said, “Tank-mixing
herbicides with different modes of action is a common practice. The proposed
restriction is impractical, is counter to good herbicide resistance management
practices, and is counter to environmental stewardship.”
Disallowing
tank mixes will “(increase) the need to make more passes over the field,
resulting in greater CO2 emissions, soil compaction and crop damage while also
requiring greater time and costs incurred by farmers,” said Iowa Soybean
Association President Wayne Fredericks.
On the other
end of the spectrum, the Center for Food Safety (CFS) also criticized the buffer zones,
calling them “unrealistic.”
“EPA does not analyze how often applicators are likely to
spray when wind speeds are greater than allowed, when weather conditions are
unpredictable, or how often rain events occur when not forecast,” CFS said.
The center also said the tank-mix restriction does not go
far enough. “Other types of pesticides, such as insecticides and fungicides,
could also interact synergistically in the formulation and are not included in
the tank-mixing restriction,” CFS said.
EPA did not adequately consider the effects of the proposal
on endangered species or migratory birds, as required by the Endangered Species
Act and Migratory Bird Treaty Act, CFS said. In addition to violating those
laws, CFS said EPA’s proposal violates the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) because it focused almost entirely on the benefits of
the proposal and ignored the risks.
Another group, the Save
Our Crops Coalition, emphasized the potential for damage to off-site crops
from spray drift.
“The
introduction of dicamba-tolerant crops will cause an explosion in the use of
dicamba,” said the group, which petitioned EPA in its comments to classify
dicamba as a restricted-use pesticide.
The group, “a grassroots
coalition of farm interests organized for the specific purpose of preventing
injury to non-target plants from exposure to 2,4-D and dicamba,” cited
research by Ohio State’s Department of Horticulture and Crop Science that used
simulations to demonstrate that “applications of dicamba at levels as low as
1/300th of the soybean field rate caused statistically significant losses of
tomato crops.”
Scott
Rice and his son, tomato growers in Indiana, also opposed the registration
changes, saying that their tomato crop “is highly
susceptible to any amount of drift from dicamba.”
“We are particularly concerned about soybean
growers using older and more volatile formulations of dicamba due to the
current depressed economics in the Corn/Soybean Belt, even though this would be
off-label,”
they said. “We understand the need to fight resistant weeds
in the Corn Belt. We are also corn and soybean producers. However, we must not
do this at the expense of our existing specialty crop production in the
Midwest.”
Monsanto has also submitted
comments, said spokesman Kyel Richard. They were not yet available on the EPA
docket and Richard did not make them available, but said the company’s Dicamba Advisory Council has been working with
stakeholders from a variety of fields.
“As the
dicamba-tolerant system moves closer to launch, Monsanto and other stakeholders
will work to provide information, resources, tools, and best management
practices necessary to ensure responsible usage of the product, which will
ultimately provide benefits to all parties,” the company said.
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