December 22, 2015
Environmental Protection Agency Docket Center (EPA/DC), (28221T)
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
Ms. Kelly Ballard, Pesticide Re-Evaluation Division (7508P)
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave. NW,
Washington, DC 20460–0001
Re: Docket ID No. EPA–HQ–OPP–2013-0409.
Dear Ms. Ballard:
In response to the Environmental Protection Agency’s September 25, 2015 Federal Register notice opening a public comment period on EPA’s draft human health and ecological risk assessments for the registration review of a group of 35 different pesticides known as sulfonylureas and other identified chemicals, the National Cotton Council (NCC) appreciates the opportunity to provide the following comments related to the importance of the herbicide trifloxysulfuron-sodium as a weed management product.
The NCC is the central organization of the United States cotton industry. Its members include producers, 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 Virginia to California. The NCC represents producers who cultivate between 10 and 14 million acres of cotton. Annual cotton production, averaging approximately 16 to 20 million 480-lb bales, is valued at more than $5 billion at the farm gate. 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 230,000 workers and produce direct business revenue of more than $27 billion. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 420,000 workers with economic activity well in excess of $120 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.
Trifloxysulfuron-sodium is labeled for use in cotton production as a post emerge overtop (once cotton reaches at least 5 true leaves) herbicide to control annual broadleaf weeds. It is a sulfonylurea herbicides whose mode of action (MOA) is generally referred to as an Acetolactate Synthase (ALS) inhibitor. Although some plant species are known to be resistant to ALS chemistry, the chemistry continues to play a vital role in better management strategies that do not solely rely on one MOA, but rotate or combine MOAs in order to effectively control the multitude of weed species present and minimize further resistance evolution of weed populations.
While use of trifloxysulfuron-sodium may not appear large, the importance of retaining multiple MOAs and products that fit niche uses in weed management is very important for sustainable cotton production. Additionally, the use and value of this herbicide has increased in recent years as producers have altered weed management programs to control glyphosate resistant weeds. Trifloxysulfuron has played a more vital role in recent years for control of morning glory, sicklepod, and nutsedge, particularly in the southeastern cotton states. The NCC urges EPA to include the value of resistance management needs and niche uses in the assessment of trifloxysulfuron and retain this product as a viable option as cotton producers identify herbicide products that fit the necessary weed management needs of their farm.
VP – Washington Operations