    Triazine Network

PO Box 446   Garnett, KS  66032 

785-448-6922

jwhite@ksgrains.com

Statement of Jere White, Executive Director

Kansas Corn Growers Association

Kansas Grain Sorghum Producers Association

Before the EPA FIFRA Scientific Advisory Panel on Atrazine

December 4, 2007

Mr. Chairman, members of the committee, my name is Jere White. I am the
executive director of the Kansas Corn Growers Association and Kansas
Grain Sorghum Producers Association and also serve as chairman of the
Triazine Network.  My expenses to be here are covered by Kansas farmers.
The Triazine Network was formed in 1995 as a response by thousands of
growers of over 30 commodities and from over forty states, to provide
input to the US EPA special review of the triazine herbicides. Our
objective is to ensure that EPA has and utilizes the best science.
That's why we participate in events such as this one today. I have
participated in every SAP concerning atrazine since the beginning of the
Special Review in 1994. Network membership encompasses farm groups from
border to border and sea to sea. The executive committee is composed of
farm organizations from Kansas, Missouri, Florida, California and
Hawaii. We're a very diverse group focused on a single outcome; a
science based review of atrazine.  

Atrazine has been the foundation of our weed control programs since the
1950s. It has been around for a long time and we know this product well.
Even today, its use is associated with the best yields and many best
practices like conservation tillage.  We know how to steward atrazine in
a way that provides safety for ourselves and the environment in which we
farm and live. We do not take concerns of harm to humans or the
environment from the use of atrazine lightly. But the value to
agriculture and to society is great and the science must be sound. We
believe the scientific evidence shows atrazine to be both safe for the
environment and effective for weed control and that is the best kind of
tool that farmers can have.

There are a few specific observations that I would like to share with
the committee today. First, states need a finalized guidance document to
implement a science based Aquatic Life Criteria. The CASM model has
provided EPA with a tool, but certainly a numeric trigger based on
lessons learned from recent monitoring using the conservative and
protective CASM model would be more acceptable to states without the
resources to implement their own CASM approach. Lacking such final
guidance document, states are left to default criteria not based in
science, or in many cases, no standard at all. With proper standards in
place, an additional level of protection can be assured through other
programs that are well connected to EPA, including the implementation of
TMDL programs at the watershed level when appropriate.

In addition, we have considerable concerns regarding the real world
application of monitoring results from intermittent streams that are not
supportive of aquatic life as well as artificially pushing numbers into
a model to show an effect that is simply not logical. Pushing macrophyte
populations significantly up on January 1 defies common sense. These
weed like plants would not be present in the Midwest small stream
aquatic ecosystems at any significant level during that time regardless
of the presence of atrazine or any other herbicide. But in fact, we know
that atrazine levels are not elevated at that time of year. In addition,
we know that the highest readings of atrazine in intermittent streams
occur simultaneously with high levels of runoff and the accompanying
turbidity. Photosynthesis at that time is being inhibited regardless of
the impact of any herbicide toxicity. Also, typically, these
intermittent streams dry down several times during the summer,
effectively eliminating aquatic ecosystem survivorship. That is not to
say that farmers should ignore their ability to minimize the loss of
atrazine or any other product they use on their fields. It just makes
good agronomic sense to do so. The bottom line is atrazine helps farmers
adopt practices like conservation tillage that keeps more soil on the
field and minimize nutrient losses. And that is a bigger issue in every
watershed that I have ever worked in over the past twenty years than the
presence of herbicides. 

We believe that the Agency has a good model in place and with the
implementation of suggested corrections should conclude that additional
monitoring, beyond that which is already being done at the state and
national level, is not required.

On behalf of the Triazine Network and the growers and commodities we
represent, thank you for this opportunity to present. We will be happy
to take any questions at the appropriate time.

Typical intermittent stream segment, SE Kansas

