October 17, 2022

Cathryn Britton
Branch Chief, Pesticide Re-Evaluation Division
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001

Melanie Biscoe
Pesticide Re-Evaluation Division
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001

Dear Ms. Britton and Ms. Biscoe:

Pennsylvania Farm Bureau (PFB) is pleased to offer its comments on the EPA’s revised human health and draft ecological risk assessments for the registration review of dicamba (Document #EPA-HQ-OPP-2016-0223).

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.

Dicamba is a valuable resource for Pennsylvania farmers, and it is vital that it remain available as an option for weed control. Its unique product chemistry allows growers diversity in applications, which can result in fewer herbicides needed. The continued use of this post-emergent product is critical for Pennsylvania’s agricultural industry, and efforts to further restrict herbicide options available to farmers will have a negative effect on crop yields.

PFB urges EPA to continue to base decision-making on the use and registration of dicamba on sound, peer-reviewed scientific research. We appreciate the opportunity to provide comments on this crucial issue.

Sincerely,

Grant R. Gulibon
Environmental Specialist