                                       
                                August 17, 2023

Environmental Protection Agency
1200 Pennsylvania Ave. NW 
Washington, DC 20460

RE: FIFRA Scientific Advisory Panel White Paper: Examination of the Microcosm/Mesocosm Studies for Evaluating the Effects of Atrazine on Aquatic Plant Communities   
EPA Docket: EPA-HQ-OPP-2023-0154 

To whom it may concern:

Introduction

My name is Brian Breaux and I serve as the Commodity and Public Policy Managing Director for the Louisiana Farm Bureau Federation, Louisiana's largest agricultural organization with a membership of 145,000 members. 

Let me begin by letting the Panel know that we support the EPA White Paper evaluation of the 11 mesocosm and microcosm studies.  Our comments are to highlight what is at stake for our farmers. 

Corn, Sugarcane and Climate Smart Agricultural Practices 

According to USDA-NASS, Louisiana has 580,000 acres of corn and 505,000 acres of sugarcane in 2023. Florida has 440,000 acres and Texas has 31,000 acres of sugarcane. The fact is that the majority of corn and sugarcane acres rely heavily on Atrazine to maintain sustainable, climate-smart agricultural practices on their farms such as implementation of no-till and reduced tillage practices that reduces soil erosion and fuel consumption and increases soil health and carbon sequestration. 

Role of Atrazine in NRCS  -  Conservation Stewardship Program conservation plans 

Atrazine plays in a key role conservation stewardship.  For example, many of our producers in recent years have enrolled in the USDA-NRCS Conservation Stewardship Program (CSP) where they submitted a CSP conservation plan for their farm that was approved by NRCS. 

What is important to note is that once the NRCS approves your CSP conservation plan, you are under a 5-year NRCS contract to comply with your CSP conservation plan. 

The concern is that most CSP conservation plans rely on the longer residual period of weed control provided by Atrazine to eliminate a cycle of tillage as part of their CSP conservation plan. 

Therefore, any change in Atrazine availability or use rates could place farmers who are under 5 year CSP contracts in a position where they may be unable to comply with their CSP conservation plan causing them to violate the terms of their CSP contract.

Atrazine's Role in Conservation Tillage 

Sustainability and conservation practices are hugely important for our farmers with some buyers who refuse to buy commodities that cannot prove sustainable production practices.  Therefore, we need Atrazine for implementing in conservation tillage where it allows farmers an opportunity to reduce and sometimes eliminate cultivation under No-Till and Strip-Till Production Systems that reduces tillage and soil erosion while improving soil health.

Role of Atrazine in Reduced Tillage and Weed Control in Sugarcane

In addition to corn, Atrazine is important for sugarcane. The U.S. is the 5[th] largest producer of sugarcane in the world and 75% of the world's sugar comes from sugarcane.  Sugarcane is Louisiana's highest value agronomic crop where we produce sugarcane in a subtropical climate where weed pressure is severe.  Sugarcane after freeze goes through dormancy from November to March.  The problem is that weeds in the spring emerge before the emergence of sugarcane creating a longer period of weed pressure.  This is where Atrazine's longer period of weed control helps our farmers get ahead of early season weeds. 

Atrazine use patterns differ among sugarcane farmers, Florida commonly applies Atrazine for early post emergence control, others use Atrazine to provide pre-emergence control of broadleaf weeds such as morning glories at layby (last spring cultivation) in May, or following planting in August. 

In the northern portion of the Louisiana sugarcane belt, Auxin herbicide use (2,4-D, Dicamba and Picloram) is restricted from April 1st to September 15th each year.  Therefore, it is common for Atrazine or Atrazine in combination with Mesotrione to be used in the restricted area.

The Importance of this Scientific Advisory Panel 

The outcome of this Scientific Advisory Panel has a bearing on the future of corn, sugarcane and grain sorghum production in the US.  It is critical for sugarcane, which is a small acreage crop with very few weed management tools available.  

We cannot stress enough, the EPA's 2022 ultra-low proposed Concentration Equivalent Level of Concern (CE-LOC) for Atrazine of 3.4 parts per billion (ppb) was not based nor is it supported by good quality scientific studies and proper analysis. Based on EPA's current modeling approach, a CE-LOC of 3.4 ppb would translate to use rates around 1.25 lbs./acre/ of Atrazine per year or less in most watersheds in LA. For sugarcane, with LSU Ag Center recommended application rates from 2-4 lbs./acre per application, a CE-LOC that low would move use rates so low that Atrazine would no longer be effective, and we would lose Atrazine as a primary weed control tool. 

Therefore, we sincerely ask the members of the Panel to please focus on the good quality scientific studies which would lead to a more appropriate CE-LOC. We are confident that if sound science is used, an accurate and defensible CE-LOC will be determined. 


Thank you for your time and your consideration of our remarks.


                        Sincerely,

                        Brian Breaux
                        Commodity and Public Policy Managing Director   
                        Louisiana Farm Bureau Federation, Inc. 
