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AMERICAN FARM BUREAU FEDERATION" 800 Maryland Avs. SW \ 1000W \ Wa&hrsgton, DC 8024 ph, 282.408 3800 f, 202.408.3802 www.fb.o rg January 5, 2016 U.S. Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460-0001 RE: Docket ID No. EPA-HQ-OPP-2015-0653 RIN: Not Assigned Dear Sir or Madam: American Farm Bureau Federation (AFBF), the nation's largest general farm organization, represents farmers and ranchers in all fifty states and Puerto Rico. They are engaged in the production of literally hundreds of commodities and specialty crops. On their behalf, we are submitting these comments to the above-referenced docket, in which EPA proposes to revoke all tolerances for chlorpyrifos. AFBF strongly opposes the agency's proposed action and requests that these comments be considered by EPA as it considers a final decision on this matter. As a prefatory matter, AFBF wishes to state that it has previously submitted comments to the agency when it issued its preliminary human health risk assessment on chlorpyrifos; those comments were dated October 6, 2011 and December 31, 2013. We incorporate those comments by reference herein and ask that they be included for consideration in the docket. We also wish to express our concern and disappointment that EPA's proposal appears to be a retreat from its statutory obligation that, when evaluating pesticides for registration, it balances the risk of those active ingredients against their benefits to farmers specifically, and to the public generally, when they do not pose an unreasonable risk to health or the environment. In the case of chlorpyrifos, a compound that has been widely used for decades, we believe its efficacy and safety when used as directed are amply demonstrated not just in the literature but in the experience of the agricultural sector. To underscore this fact, it may be helpful to emphasize the widespread use of the product. As we pointed out to EPA previously, there are more than 50 different crops in more than 98 countries that rely on chlorpyrifos products to help defend against crop failure from a wide array of insect pests. In the United States alone, there are a number of widely-grown crops that depend extensively on chlorpyrifos and growers need the current list of tolerances to be maintained for these crops and for any processed fraction or food tolerance, animal feed tolerance and animal commodity tolerance (such as, but not limited to milk, meat, eggs) that would be associated with the use on these crop(s). Specifically, we note these particular uses: Alfalfa Chlropyrifos is widely used and highly effective against the most important insect pests of alfalfa. These pests include alfalfa weevil, leafhoppers, aphids and Lepidoptera pests. Use rates in the Midwest and Plains, which represent 60 percent of the total alfalfa area, are 0.75 pounds of active ingredient per acre (lb a.i./A) for alfalfa weevil and 0.50 lb a.i./A for leafhoppers. Rates in Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00057101-00001 the West and Southern U.S. (nearly 35 percent of the total alfalfa area) range from 0.5 to 1.0 lb a.i./A. Citrus Products containing chlorpyrifos are widely used in citrus for control of scale, mealybug, citrus rust mite, various Lepidoptera larvae and ants. Since the introduction of the Asian citrus psylla to the continental U.S. in 1998, chlorpyrifos has become one of the most widely used insecticides to control this pest. The Asian citrus psylla is present in Florida and Texas and recently has also been found in San Diego and Imperial Counties in California, according to the California Department of Food and Agriculture. The typical use rate in Florida is 2.5 lb a.i./A. In California, use rates vary by pest: 3 to 6 lb a.i./A for California red scale and citricola scale, and 2 to 4 lb a.i./A for ants. Soybeans Chlorpyrifos is effective in treating a number of Arthropod pests in soybeans, including soybean aphid, bean leaf beetle, caterpillars, grasshoppers, leafhopper, two-spotted mites and others. Use of chlorpyrifos has grown significantly in the last few years in soybeans as a result of the increased presence of the soybean aphid in the Midwest and the Great and North Plains areas that represent the largest soybean producing area in the U.S. (80 percent of the total soybean producing area). Use rates in the Midwest and the Great and North Plains are 0.25 to 0.5 lb a.i./A and 0.5 to 1.0 lb a.i. in the Southeast. Tree Nuts - Almonds, Hazelnuts, Pecans and Walnuts Chlorpyrifos is used as a foliar treatment and as a dormant or delayed dormant spray on almonds to control peach twig borer, navel orangeworm and San Jose scale. Walnut scale, codling moth and walnut husk fly are effectively controlled with foliar applications of a liquid chlorpyrifos formulation. Dormant or delayed dormant applications in combination with dormant oil are effective against walnut scale. The use rate of chlorpyrifos for almonds and walnuts is 2.0 lb a.i./A. Pecan insect pests controlled with chlorpyrifos include black pecan aphid, hickory shuckworm, Phylloxera, pecan nut casebearer, spittlebugs and yellow aphid complex. Rates to control these insect pests in pecans vary from 0.5 to 1.0 lb a.i./A. These are not the only sectors where a loss of chlorpyrifos would have a large impact. Other examples include: Hundreds of thousands of acres of grass seed production depend on chlorpyrifos to control a wide variety of pests (e.g., aphids, crane fly, cutworms and others). According to the Oregon Seed Council, in Oregon alone grass seed contributes approximately $1 billion of economic activity to the state and the loss of chlorpyrifos would have a significant impact on that agricultural activity. For vegetable crops, chlorpyrifos represents a critical tool in farmers' efforts to control insect damage,1 1Please see comments submitted to the docket by the Pacific Northwest Vegetable Growers Association, as well as the Michigan Farm Bureau, the latter o f which is a member o f AFBF Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00057101-00002  For mint oil production, the Mint Industry Research Council estimates that inability to utilize chlorpyrifos could present growers with an economic loss of over $5 million.2 We have attached a more extensive list as Table 1, which is appended to these remarks. The U S. Department of Agriculture, in response to an inquiry by AFBF, noted that chlorpyrifos has been a part of growers' integrated pest management (IPM) programs for approximately 50 years and is used to control a wide array of primary and secondary pests in over 75 cropping systems. Were chlorpyrifos to be eliminated or severely restricted, the impact to farmers would be significant in terms of reduced efficacy of pest management programs, increased costs to growers switching to more expensive, more frequently applied and less effective alternatives, disruption to current and historical IPM programs across these cropping systems and potentially substantial losses due to reduced crop yield. According to USDA, in some systems lack of effective alternatives targeting control of primary pests, such as root maggot in sugar beets, presents serious concern of economic damage if the pest is left uncontrolled. It is quite clear that the agency's proposal, should it be made effective, would represent a crippling loss to American agriculture, reaching likely into tens of millions of dollars and affecting the livelihood of farmers across the country. We do not believe a reasonable assessment of the evidence can lead to any other conclusion. At the same time, AFBF is greatly disturbed that the agency appears to be proceeding in this manner based on modeling assessments that are highly questionable and linking its reasoning to epidemiological studies that are not transparent and do not accurately represent the risk of chlorpyrifos. In doing so, AFBF believes EPA has stepped well beyond its statutory authority and is reaching conclusions not justified either by the science or the law. We also di sagree with the agency's conclusion that a revocation of tolerances will not have an impact on a significant number of small farms. The agency conducted only a national screen and although citing the potential for a higher level of impact in some regions, dismissed any regional effect as not significant. The screen also focused only on primary pests and whether an alternative product might be available. As discussed in these comments, there are multiple reasons a farmer may rely on chlorpyrifos. We strongly counsel the agency not to pursue this proposal. Sincerely, Dale Moore Executive Director, Public Policy American Farm Bureau Federation 2 See comments previously submitted to the docket by the Mint Industry Research Council. Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00057101-00003 Table 1 Master Label Alfalfa Asparagus Beets (table, sugar) Cole crops Carrots Citrus, Nectarine Clover Corn (all) Cotton Cranberry Cucumber Fig Fruit and Nut trees Ginseng Grapes Legume vegetables (beans, peas) Mint - Peppermint, Spearmint Onions Peanut Peppers Pineapple Apple, Cherries, Peach, Pear, Plum, Prune Pumpkin Radish Rutabaga Sorghum (grain) Soybeans Strawberries Sunflower Corn (all) Sweet potatoes Tobacco Turnip Tree Nuts - Almonds, Flazelnuts, Pecans, Walnuts Wheat, Triticale On Master label as DAS use YES YES YES - Sugarbeets YES YES YES YES YES YES NO YES YES YES YES YES YES YES YES YES YES YES YEs YES YES YES YES YES YES YES YES YES YES YES Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00057101-00004