


May 27, 2014


Mr. Michael Walsh
Environmental Protection Agency (EPA)
Office of Pesticide Programs
Biopesticides and Pollution Prevention Division (7511P) / Registration Division (7505P)
1200 Pennsylvania Ave. NW
Washington, D.C. 20460-0001

Dear Mr. Walsh: 

We, the undersigned institutional investors, representing $47 billion in assets under management and led by the Interfaith Center on Corporate Responsibility (ICCR), are writing to express our concerns about the use of 2,4-dichlorophenoxyacetic acid (2,4-D) on new genetically engineered (GE) corn, cotton and soybean crops designed to survive repeated spraying of the herbicide.  We are disappointed by the recent news of the Agency's proposed decision to approve this new version of 2,4-D. We ask that, under the proposed new use registrations for 2,4-D-resistant crops, EPA incorporate widely accepted estimates for significantly increased use and altered use patterns of 2,4-D.

As investors, we are conscious of the long-term risks associated with these products and believe it is prudent to await thorough assessment before releasing these products to the market.  Without adequate understanding of the environmental consequences and health impacts of the 2,4-D resistant crops and subsequent increase in herbicide use, we cannot be sure that our companies are sufficiently considering potential risks of these products to human health and the environment.  As a regulator responsible for understanding the effects of herbicide use on humans and the environment, the U.S. Environmental Protection Agency (EPA) must carefully consider its role in determining the use, sale, and labeling of 2,4-D and make a thorough and accurate assessment of the potential impacts. 

The EPA has reported that 2,4-D is the seventh largest source of dioxins in the United States.  2,4-D is a toxic herbicide associated with serious health risks. The 2,4-D resistant crops will also, like their predecessors, lead to much greater use of even more dangerous chemicals, the development of more herbicide-resistant weeds, destruction and genetic contamination of neighboring crops, and severe economic impacts on other farmers. 

As shareholders, we engage seed and chemical companies, including Dow AgroSciences, about risks and impacts related to herbicide utilization with its seed products on human health and the environment. Deregulation of Dow's 2,4-D resistant crops will drive up use of 2,4-D, an antiquated and dangerous herbicide known to drift beyond target crops. Shareholders are aware that Dow's Enlist Duo system utilizes a less volatile form of 2,4-D, however this does not mitigate its inherently dangerous characteristics linked to causing cancer, Parkinson's disease, endocrine disruption, and reproductive problems in humans.

We ask that as you consider Dow's 2,4-D New Use Registration Applications for the new uses of 2,4-D choline salt that will be associated with the new 2,4-D resistant crops, you consider the mounting evidence about the risks of increased and compounded 2,4-D use. We  join more than half a million individuals and organizations, including medical doctors and public health scientists, farmers, food and health experts, consumers, environmental organizations and many others in calling on you to undertake a thorough assessment and complete your findings prior to undertaking any regulatory changes.  

Noted agricultural scientist Charles Benbrook projects that widespread planting of Dow's Enlist corn alone could trigger as much as a 25-fold increase in use of 2,4-D, from an estimated 4.2 million pounds at present to over 100 million pounds by 2019.  The consequent increase of the use of further herbicide resistant crops is troubling for ecosystems and water supplies.  As a result, Monsanto and other firms that manufacture pesticides are focusing the bulk of their Research and Development on new crops engineered with resistances to even more herbicides. Monsanto is awaiting approval of soybean seeds that are resistant to dicamba and glyphosate, with triple herbicide resistant corn and cotton in the pipeline.

The instructions that the seed companies provide to end-users is dependent on the findings of the EPA. Your role in setting the conditions for the herbicide's use and placement in the labeling instructions that a user must follow are critical for protecting the health of farmers and the environment. We encourage you to use caution and restraint when establishing these instructions. 

Further, the MSDS sheet for Enlist Duo is alarming:  

   * Environmental precautions: Prevent from entering into soil, ditches, sewers, waterways and/or groundwater. 
   * Personal precautions, protective equipment and emergency procedures: Isolate area. Keep unnecessary and unprotected personnel from entering the area.
   * Potential Health Effects (extracted from listing)
         o Eye Contact: May cause moderate eye irritation. May cause slight corneal injury. 
         o Skin Contact: Brief contact may cause slight skin irritation with local redness. May cause drying and flaking of the skin. 
         o Skin Absorption: Prolonged skin contact is unlikely to result in absorption of harmful amounts. 
         o Skin Sensitization: Has demonstrated the potential for contact allergy in mice. 
         o Inhalation: No adverse effects are anticipated from single exposure to mist. Based on the available data, narcotic effects were not observed. Based on the available data, respiratory irritation was not observed. 
         o Ingestion: Low toxicity if swallowed. Small amounts swallowed incidentally as a result of normal handling operations are not likely to cause injury; however, swallowing larger amounts may cause injury.
         o Effects of Repeated Exposure: For similar active ingredient(s). 2,4-Dichlorophenoxyacetic acid. In animals, effects have been reported on the following organs: Gastrointestinal tract. Kidney. Liver. Muscles. Observations in animals include: Gastrointestinal irritation. Vomiting. For the minor component(s): In rare cases, repeated excessive exposure to propylene glycol may cause central nervous system effects. 
         o Birth Defects/Developmental Effects: For similar active ingredient(s). Has been toxic to the fetus in laboratory animals at doses toxic to the mother.
            
How can deregulation of 2,4-D corn, cotton and soy align with EPA's announced proposed changes to the agricultural Worker Protection Standard (WPS) to increase protections from pesticide exposure for the nation's 2 million agricultural workers and their families and EPA's commitment to Environmental Justice?

Farmers are deeply concerned that Dow's Enlist corn, cotton and soy system will threaten their crops. 2,4-D is known to drift  --  directly and through volatilization  --  which poses a very real threat to rural economies and farmers growing crops not engineered to withstand application of these potent chemicals. 2,4-D drift is already responsible for more episodes of crop injury than any other herbicide, and its vastly increased use promises still more damage to non-2,4-D resistant crops like soybeans, cotton, vegetables and fruit. 

This chemical is used because Roundup Ready GE crops have caused an epidemic of glyphosate-resistant weeds, so another herbicide is needed. Monsanto's RoundUp Ready seed line is responsible for a dramatic rise in glyphosate-resistant "superweeds," which have afflicted millions of acres of farmland across the Midwest and South.  Dow is promoting GE 2,4-D corn, cotton and soy as the solution to glyphosate (the ingredient in Roundup) resistant weeds, but GE crop systems caused the glyphosate resistant weeds in the first place. Additionally, Enlist Duo also utilizes glyphosate.

We ask that, under the proposed new use registrations for 2,4-D-resistant crops, EPA incorporate widely accepted estimates for significantly increased use and altered use patterns of 2,4-D. 

Sincerely, 	

Ellen Kennedy
Manager, Environment, Water and Climate Change
Calvert Investments
Luan Steinhilber
Director of Shareholder Advocacy
Miller/Howard Investments, Inc.


Kathleen Coll
CHE Trinity Health
William Stoddart
Founder and Principal
Northfork Financial


Shelley Alpern	
Director of Social Research & Shareholder Advocacy	
Clean Yield Asset Management
Julie N.W. Goodridge
President & CEO
NorthStar Asset Management, Inc.




James A Frazin
President/CEO
Communitas Financial Management
Judy Byron
Director
Northwest Coalition for Responsible Investment


Sally Ann Brickner
Coordinator of Justice, Peace and Ecology	
Congregation of Sisters of St. Agnes
Catherine Cartier
President
Progressive Asset Management


Margaret Weber
Corporate Responsibility Director
Congregation of St. Basil
Jo Marie Chrosniak, HM
Coordinator 
Region VI Coalition for Responsible Investment


Joellen Sbrissa, CSJ	
SRI Representative
Congregation of St. Joseph
Steve Zielinski
SRI Consultant
Servants of the Paraclete


Susan Vickers	
VP Community Health	
Dignity Health
Ruth Kuhn, SC
Chair - Corporate Responsibility Committee	
Sisters of Charity of Cincinnati


Steve Zielinski	
SRI Consultant	
Diocese of Springfield, IL
Margaret O'Brien, SC
Congregation Treasurer
Sisters of Charity of New York


Steve Zielinski	
SRI Consultant
Dominican Sisters
Sister Barbara Aires
Coordinator of Corporate Responsibility
Sisters of Charity of Saint Elizabeth


Linda Hincken	
Chief Financial Officer
Dominican Sisters of Amityville
Sister Patricia Daly, OP
Corporate Responsibility Representative	
Sisters of St. Dominic of Caldwell NJ


Valerie Heinonen
Director, Shareholder Advocacy
Dominican Sisters of Hope
Toni Palamar
Province Business Administrator
Sisters of the Good Shepherd-Province of NY


Sr. Donna Graham
OSF Director, JPIC Office
Franciscan Friars (OFM), St. John the Baptist Province
Steve Zielinski	
SRI Consultant	
Sisters of the Presentation


Lura Mack
Director
General Council of the Adrian Dominican Sisters
Mary Lardner
Social Justice Committee Chair
Social Justice Committee at UUCSR


Leslie Samuelrich 
President	
Green Century Capital Management
Lars M Lewander	
Chief Executive Officer	
Spring Water Asset Management



Nadira Narine
Program Director, Strategic Initiatives
Interfaith Center on Corporate Responsibility

Theodore Casparian
Educator
Sustainable Investing 4 All


Cathy Rowan
Corporate Responsibility Coordinator
Maryknoll Sisters
Susan Baker
Vice President, Shareholder Advocacy & Corporate Engagement
Trillium Asset Management


Marcela Pinilla
Director, Shareholder Advocacy	
Mercy Investment Services
Valerie Heinonen
Director, Shareholder Advocacy
Ursuline Sisters of Tildonk


Barbara Jennings
Coordinator
Midwest Coalition for Responsible Investment
Sonia Kowal
Director of Socially Responsible Investing
Zevin Asset Management, LLC


