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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