The Environmental Protection Agency is evaluating whether to allow continued use of Glyphosate. Nebraska Farm Bureau told the agency it’s one tool farmers need to keep in the toolbox.
August 30, 2019
Office of Pesticide Programs
U.S. Environmental Protection Agency
1200 Pennsylvania Ave. N.W.
Washington, DC 20460-0001
RE: Docket ID No. D: EPA-HQ-OPP-2009-0361-2340: Glyphosate Proposed Interim Registration Review Decision
Dear Sir or Madam:
On behalf of the nearly 60,000 member families of the Nebraska Farm Bureau (NEFB), I would like to offer these comments to the Environmental Protection Agency (EPA) in connection with the above-referenced docket, which pertains to EPA’s Proposed Interim Registration Review Decision for glyphosate. As a crop protection product with decades of data backing its effectiveness and safety, NEFB strongly supports the reregistration of this vital product.
NEFB is Nebraska’s largest farm and ranch organization and is in the unique position of representing all sectors of Nebraska agriculture. From cattle and hog producers to corn, soybean and sugar beet farmers, NEFB’s membership is comprised of farmers and ranchers that grow and raise everything that is produced within the state of Nebraska. As such, many of our members utilize these products in their operations. Any decision by EPA to restrict or eliminate their availability, particularly the availability of glyphosate, would directly and negatively affect thousands of our members, increasing their costs of production, potentially reducing yields, and harming their profitability. NEFB strongly supports the continued use of glyphosate and urges the agency not to prohibit or restrict its availability and use.
According to estimates made by NEFB utilizing data from the U.S. Department of Agriculture (USDA), glyphosate was applied to 8.16 million acres of corn in Nebraska and 5.24 million acres of soybeans in 2018. This represents 85 percent of our state’s planted corn acres and 92 percent of our planted soybean acres. The loss of glyphosate would present a significant challenge to farmers of these crops by reducing crop quality and reducing farm productivity and profitability.
In addition, making glyphosate unavailable would unquestionably compromise the rapid growth of conservation-based no-till soil practices. The 2017 Census of Agriculture revealed no-till farming in Nebraska as a preferred conservation management practice in 2017 at 10.25 million acres, up nearly 1 million acres since 2012. No-till conservation is enabled by the use of glyphosate, and these practices help to conserve soil, preserve and increase nutrients, improve water quality, trap excess carbon in the soil, and reduce greenhouse gas emissions. Without access to effective weed management tools, farmers would be limited in their abilities to improve soil health and continue being good stewards of the land.
Glyphosate is a widely adopted crop protection tool for farmers across many crops and growing systems. We firmly support the agency’s assessment that glyphosate is a beneficial tool for American agriculture. The loss of this crop protection tool could prove devastating for Nebraska agriculture and thus Nebraska’s economy as a whole. We urge the agency to continue their thoughtful and fair evaluation of its importance to farmers and thank you for your consideration of these comments.
Stephen D. Nelson