May 19, 2017
U.S. Environmental Protection Agency Docket Center (EPA/DC) (28221T)
1200 Pennsylvania Ave. NW.
Washington, DC 20460–0001
RE: Comments on Docket ID No. EPA–HQ–OPP–2011–0183; Pesticides; Certification of Pesticide Applicators Rule; Extension of Effective Date
The National Cotton Council (NCC) is the central organization of the United States cotton industry. Its members include growers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from California to Virginia. U.S. cotton producers cultivate between 9 and 12 million acres of cotton with production averaging 12 to 18 million 480-lb bales annually. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 125,000 workers and produce direct business revenue of more than $21 billion. Annual cotton production is valued at more than $5.5 billion at the farm gate, the point at which the producer markets the crop. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 280,000 workers with economic activity of almost $100 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed, and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.
Currently the effective date of the revised Certification of Pesticide Applicators rule (also known as the Certification and Training rule or C&T rule) is May 22, 2017. Upon further review, the Environmental Protection Agency (EPA) determined that the effective date of the revised C&T rule should be extended until May 22, 2018. EPA is taking this action to give recently arrived Agency officials the opportunity to conduct a substantive review of the revised rule.
The NCC agrees with EPA that the effective date should be extended. Some state agencies have informed us that they are not ready to implement this rule and that they have issues with some points of the rule that they have asked EPA to address. Furthermore, with U.S. agriculture heading into its growing season, this is not the time to try to implement an expansive new rule. These two situations justify the decision to extend this rule’s comment period.
The NCC thanks EPA for proposing this extension and for the opportunity to comment. If you have any questions, please don’t hesitate to contact me at 202-745-7805.
Senior Scientist, Regulatory and Environmental Issues
National Cotton Council