Hundreds of Farmers Tell EPA to Scrap Endangered Species Herbicide Strategy - DTN The Progressive Farmer

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"However, we are greatly concerned the herbicide strategy as proposed would significantly undermine producer access to herbicides and their important production and environmental benefits."

One of the major concerns for ASA farmers is they say the proposed strategy is too prescriptive on implementing conservation practices that could benefit endangered species.

"Most of the runoff reduction practices EPA offers are not suitable for certain regions or crop types, leaving many producers simply unable to comply," the letter said.

"For individual producers with sufficient compliance options, the practices proposed can be very costly and might require the annual investment of millions of dollars across hundreds or thousands of their acres to continue using herbicides."

Also, in comments to the agency, Iowa Secretary of Agriculture Mike Naig said he was concerned about the EPA mandating certain conservation practices as a remedy.

The state of Iowa has come under scrutiny in the past decade for implementing a statewide voluntary conservation plan to address nutrients runoff from farms.

Naig said that program has been successful because it is voluntary.

"Iowa has seen tremendous interest and participation in our conservation programs, which are voluntary, non-regulatory, and which are proven to be successful at reducing the amount of nutrients that ultimately make their way into the Gulf of Mexico -- a goal we share with the EPA," Naig said in the letter.

"I fear that this new regulatory approach will have a chilling effect on the positive relationship and trust that we have built with Iowa farmers. We do not want to lose the momentum and progress that we have built at a time when we are scaling up and accelerating our state efforts to get more practices on the ground."

Naig asked the agency to consider the economic effects he said the plan could have on agriculture in particular and in rural areas in general.

"Impacted stakeholders are likely to see significant costs both monetarily and in terms of time required to comply with the new regulations," Naig said in the letter.

"EPA should conduct an economic analysis to determine these costs and better understand how this decision will impact applicators and regulatory officials tasked with enforcing the changes."

Otis Howe, executive director of the Arkansas Crop Protection Association, told the agency the strategy would "impose huge regulatory burdens on nearly every herbicide user" in his state.

In a comment letter to the EPA, Howe said many Arkansas producers could "simply not be able to comply with the proposal, while others would face significant cost increases" on their farms.

Howe said his association believes the biggest problem with the proposal has to do with endangered species themselves.

"Very little data or knowledge of their actual locations or presence of their habitat exists," he said.

"This strategy would be much more effective if we had a better grasp on the locations of endangered species, then effects on those specific locations could be minimized."

Like other commenters, Howe called the strategy "incredibly complex" and that it would be difficult for individual producers to determine if certain lands are under regulation or what exactly compliance obligations would be.

"Many of the exemptions EPA proposes are not practical and will apply to few agricultural lands, leaving most under regulation even if herbicide use at those sites does not pose a genuine risk to endangered species," he said in the letter.

"Broad-brush regulation does not work for everyone. This herbicide strategy does not account for variability based on farm location."

Doug Miyamoto, director of the Wyoming Department of Agriculture, said in a letter to the agency that the strategy raises many concerns for farmers and ranchers in the West.

In particular, he said states like Wyoming have concern that the strategy will lead to more weeds and increased wildfire risks and added burdens to farmers who use both public and private lands for livestock grazing.

"Cheatgrass outcompetes almost all native habitat if not treated on a landscape level," Miyamoto said in a letter to the agency.

"Not only does cheatgrass outcompete native flora, it also creates the opportunity for devastating fires and the spread of annual invasive species to occur. Herbicide treatments for cheatgrass and other annual invasive grasses is a necessary tool used by livestock producers to reestablish native rangelands and habitat. The framework restricts opportunities to treat and thus encourages the spread of annual invasive grasses, which will in turn reduce habitat for all wildlife."

Robyn Stewart, an Extension agent at the University of Georgia, said the strategy suffers from a lack of information about species' locations.

Without accurate maps, she said, the strategy would harm agriculture while not necessarily protecting species.

"Therefore, in order to protect both listed species and our family farms," Stewart wrote in comments, "identifying the exact locations of listed species, habitats and agriculture fields potentially treated with a pesticide allows for a scientific determination of the exact locations of 'sensitive sites' where protections may be needed. Currently, the process of using outdated range maps or maps based on historical habitat/populations is flawed and unacceptable."

Stewart said the University of Georgia and the U.S. Fish and Wildlife Service have developed a protocol to identify where species' habitats and farm fields overlap.

"Georgia's ESA pilot program research documents that to protect two salamander species from Enlist Duo, mitigation measures should be considered on less than 3,526 field acres," Stewart said.

"The current restriction for Enlist Duo prevents its use on 951,557 acres, a restriction lacking scientific merit. When considering the potential impacts to agriculture and the livelihoods that depend on the ability to use pesticides on their farms to protect their yields, it is critical that accurate, scientifically sound information is used to determine where restrictions are needed and where they are not.

"The current loss of both family farms and agricultural land is highly alarming when considering our nation's security and the need to feed and clothe a growing world's population. Overly aggressive regulations lacking scientific merit will not further steward pesticides."