October 6, 2022
Alex Hazlehurst
Chemical Review Manager, Pesticide Re-Evaluation Division (7508P)
Office of Pesticide Programs
U. S. Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
Melanie Biscoe
Pesticide Re-Evaluation Division (7508P)
Office of Pesticide Programs
U.S. Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
Dear Mr. Hazlehurst and Ms. Biscoe:
Pennsylvania Farm Bureau (PFB) is pleased to offer its comments on the Agency’s document, “Proposed Revisions to the Atrazine Interim Registration Review Decision Memorandum, Case Number 0062 (Docket ID# EPA-HQ-OPP-2013-0266).”
PFB represents over 30,000 members engaged in all manner of agricultural activities, including the production and processing of crops; the production and processing of animals; the production and processing of forestry products; landscaping and horticultural services; agriculture-related support services; and food manufacturing. According to the 2021 report, The Economic Impact of Agriculture in Pennsylvania: 2021 Update, agriculture continues to be a leading contributor to the Commonwealth’s economy, contributing $1 of every $16 in gross state product, with every dollar of direct output generating $0.63 in additional economic activity. In addition, agriculture supports one out of every ten jobs in Pennsylvania and seven jobs per $1 million of output. In 2019 alone, the total direct and indirect economic impact of agriculture within Pennsylvania was an estimated $132.5 billion.
The herbicide atrazine has been used by farmers for nearly six decades for the efficient, effective, sustainable protection of corn, sorghum, sugar cane and a variety of additional crops from weeds. The benefits associated with atrazine help farmers continue to be “climate-smart” stewards of their land by assisting with carbon sequestration, as well as the use of conservation tillage and “no-till” practices that keep nutrients on the land and increase their efficient usage. Doing this improves the health of our soil, air, and water by reducing water runoff and soil erosion.
However, in issuing these proposed revisions, the Agency has departed from using reliable, science-based evidence to support decisions of this type, and has instead relied upon questionable science in doing so. Specifically, there are significant concerns about the interim decision’s reduction of the concentration equivalent level of concern (CE-LOC) from 15 parts per billion (ppb) to 3.4 ppb—a change that contradicts the conclusions of a decade-long, exhaustive scientific review that was concluded barely two years ago. If implemented, this reduction in the CE-LOC for atrazine would have far-ranging negative consequences for its usage and effectiveness, as would other mitigation measures in the proposed revisions.
Pennsylvania farmers, like their counterparts across the United States, cannot always simply use another product when another becomes less accessible or effective (whatever the reason for that diminished access or effectiveness), whether it be for ecological, economic, rotational, resistance, or numerous other purposes. Prohibition of atrazine, or restrictions of its use which would effectively prohibit it, would remove a valuable tool our farmers need for reliable weed reduction—an outcome that would have serious, negative implications for the volume and quality of agricultural production needed to feed, clothe, and fuel the American—and increasingly, the global—economy.
PFB recommends that the Agency abandon the interim decision’s reduction of the CE-LOC from 15 to 3.4 ppb. Doing so supports to the principle of using sound science to inform the Agency’s decision-making process and allows Pennsylvania farmers to continue their efforts to enhance the environment and climate with sustainable practices proven to accomplish both objectives—all while meeting the needs of consumers all around the world.
Sincerely,
Grant R. Gulibon
Environmental Specialist