July 24, 2017
Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW Washington, DC 20460
The National Cotton Council (NCC) appreciates the opportunity to comment on the Environmental Protection Agency’s (EPA) “Preliminary Aquatic Risk Assessment to Support the Registration Review of Imidacloprid.” The NCC urges EPA to refine the risk assessment based on use and real world monitoring data.
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 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.
The preliminary risk assessment of imidacloprid has identified concerns that deserve the inclusion of field data for refinement. The NCC has expressed before its concerns with the overestimates of EPA’s water models, and it again appears the models could be a contributing factor to the identified concern. The NCC strongly believes EPA should acknowledge higher tier studies and incorporate those into future assessments. The NCC believes that once EPA refines the assessment with field relevant monitoring data, the agency will reach prior determinations of no adverse effect. However, that must be based on real world practices and monitoring data that reflect current use before seeking mitigation for model based assumptions. The EPA has access to actual use data that should be given more credibility and weight than modeled assumptions.
Benefits of Neonic Uses
The NCC understands EPA has received a presentation from Dr. Jeff Gore, Research Entomologist at Mississippi State University, studying the insect control with and without neonics, and that the study reflects the fact that removing the neonics from the production system resulted in more foliar applications of older chemistries, overall increase in pesticide use, and a net loss of profit for the producer.
The importance of the neonic chemistries to the cotton industry cannot be overstated. The cotton industry, once plagued with boll weevil and tobacco budworm pests, has undertaken many measures to reduce overall pesticide use for control of these pests input, but those changes have shifted the pest complex toward piercing/sucking insects such as thrips, aphids, whiteflies, stinkbugs, and plant bugs. The neonic chemistries provide control of these pests with fewer applications, but producers must include rotations of mode of action for overall pest control and resistance management strategies, meaning that other chemistries are to be considered necessary, not alternatives.
The NCC conducted a recent survey of state extension entomologists regarding the cotton production use of the neonic chemistries. Approximately 82 percent of the cotton production utilizes treated seed, and this adoption is predominantly driven by thrips. Thrips have historically been recognized as a major pest of cotton plants emerging from the soil until the plants grow three to four nodes. Losses to thrips often vary because the effect extends beyond plant injury. Thrips injury often includes delaying growth and development, thereby extending the growing season, subjecting the crop to more pest pressure, and delaying harvest which often subjects the crop to adverse weather causing yield and quality losses. In some states with very high historical thrips pressure (eg. VA, GA, SC, NC) there has been a growing adoption of in-furrow neonic treatments, but at a national level the percentage is around 11 percent. At a national level, pre-bloom foliar applications are made to less than 46 percent of the cotton acreage, but equals the post bloom applications. The foliar uses vary tremendously between states due to certain pest pressures such as plant bugs in the Mid-south. Georgia and South Carolina report less than 5 percent foliar applications while Texas reports less than 20 percent use of foliar applications. Removing seed treatment considerations, the question was asked of the state entomologists to rate the importance (0=low, 3=critical) of in-furrow, foliar pre-bloom, and foliar during bloom. The national average was 2.18, 1.81, and 1.94 respectively. These entomologists quickly point out that tank mix applications with other modes of action are common in order to comply with resistance management strategies.
The consensus expressed among the entomologists is that no acceptable alternatives exist to replace the use of neonics in the IPM and resistance management strategies for their states. The loss of neonics will result in additional reliance on older chemistries, multiple applications, and risks to flare up other pest populations adding additional control measures.
The NCC thanks the EPA for the opportunity to provide comments on this registration review.
Senior Scientist, Regulatory and Environmental Issues
National Cotton Council