September 25, 2014


United States Department of Agriculture
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238


Re: Docket ID No. APHIS-2013- 0043—Draft Environmental Impact Statement: Monsanto Petition (10-188-01p and 12-185-01p) for Determination of Non-regulated Status for Dicamba-Resistant Soybean and Cotton Varieties


To Whom It May Concern:


Pennsylvania Farm Bureau (PFB) is pleased to offer comments in support of the USDA’s recommendation, contained in the above-referenced draft Environmental Impact Statement (EIS) on dicamba-tolerant technologies, to deregulate dicamba-tolerant soybeans and cotton (MON 87708 and MON 88701) without restriction.


PFB is a general farm organization, made up of more than 59,780 members. Since 1950, PFB has provided support, advocacy and informational and professional services for agriculture and farm families. Our organization includes 54 local organizations (County Farm Bureaus) that actively operate in 64 of Pennsylvania’s 67 counties.


Pennsylvania’s agricultural economy is diverse and complex with respect to the size and types of operations present, and the composition of PFB’s membership reflects these factors. Agriculture is the largest single industry in our state, and its continued growth and strength is dependent, in significant part, on the availability of the most up-to-date scientific and technological innovations. One such innovation is the development of dicamba-tolerant soybeans, which would provide farmers with another option in promoting weed control and lessening the incidence of weed resistance to certain herbicides.


Synthetic auxin herbicides, which include dicamba, have been used on crops in the United States for decades and continue to be effective on broadleaf weeds. The herbicides have undergone rigorous human health and environmental safety risk reviews conducted by the Environmental Protection Agency (EPA). Dicamba-tolerant soybeans would provide farmers with improved opportunity to eliminate soybean crops’ competition for nutrients in the soil. Deregulating this technology would give America’s farmers the ability to kill weeds that have developed chemical resistance, while safely preserving the food, feed and fuel crop at the same time.


While soybean production accounts for a greater proportion of total agricultural output in other states (primarily in the Midwest) than it does in Pennsylvania, our farmers planted approximately 540,000 acres in 2013. This scale of production allows Pennsylvania farmers not only to meet the needs of the state’s livestock producers, but to also maintain a ready source of soybeans for export, and multiple-mode-of-action weed management and tools are essential to achieve these two outcomes. With farmers in Pennsylvania and across the United States facing challenges related to weather patterns, national agricultural policy, and foreign and domestic product demand pressures, deregulation of dicamba-tolerant technologies would constitute a significant, immediately useful advancement in mitigating some of the uncertainties implicit in agriculture.






PFB appreciates USDA’s efforts to streamline the responsible deregulation of biotech crops with EPA and FDA and to ensure access to needed cropping technologies while the concerns of food, feed, and seed integrity. Pennsylvania’s farmers and pesticide applicators (who are required under state law to be licensed) are very familiar with dicamba and consider it a reliable and effective herbicide for use in corn, wheat, pastures and other labeled uses. Their experience with a wide variety of crops and production systems makes these licensed applicators sophisticated adopters and stewards of new technology such as dicamba-tolerant soybeans.


In order for American agriculture to maintain and build upon its world leadership position, farmers must have access to timely, science-tested products and methodologies that increase output while protecting the environment and enhancing crop diversity. In that vein, PFB member families support science-based deregulation of plant biotechnology. Thank you for the opportunity to provide comments.




Grant Gulibon
Director, Regulatory Affairs