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JenREES 9/26/22

Atrazine Comment Period: I’m blessed to work with both conventional and organic farmers and learn from them on various tools used in their operations to combat pests. For conventional farmers, one tool that’s been available for over 60 years is atrazine, which is used for weed control on over 2/3 of U.S. corn and sorghum acres. In listening to farmers, this latest atrazine comment period has been confusing, because EPA just re-registered atrazine for use in Sept. 2020 and confirmed the decision to use 15 parts per billion (ppb) aquatic level of concern. This level was based on a large amount of peer-reviewed scientific research and documentation which were in consensus that that 15 ppb level of concern was considered safe for aquatic environments.

The confusing part to those who were sharing was ‘why this change if it was recently re-registered?’. In Aug. 2021, EPA reopened the decision in response to a court case and published proposed revisions in 2022 which would lower the aquatic level of concern to 3.4 ppb. Re-opening a previously confirmed decision in such a short time-frame doesn’t typically occur. The proposed 3.4 ppb level of concern also doesn’t agree with the large body of scientific evidence that was reviewed to make the 2020 decision. It calls into question the scientific validity of this proposed ruling.

In the proposed ruling, in order to apply atrazine, mitigation strategies would need adopting by farmers based on land quality. Some of these listed include: No pre-emergence applications; Atrazine application prohibited when soils are saturated; Atrazine application prohibited when rain is forecasted during application or for 48 hours after application; Aerial application prohibited; Application rate reduced to 2.0 lbs of atrazine on sorghum, field corn and sweet corn in a year; Inclusion of a picklist to mitigate runoff and leaching based on factors of the field (soil, crop, slope, weather, etc.) and predicted atrazine contamination in watershed field is located in; and Record-keeping requirements. The docket of EPA’s proposed revisions is available on Regulations.gov.

The public comment period to these proposed revisions ends on October 7, 2022. The public comment period allows for anyone to provide their feedback on the changes to inform the EPA of knowledge gaps, considerations or concerns that the public would like addressed.

The following are some suggestions before making any public comments on any topics one feels strongly about: Define your objectives for the comment at the beginning; Use specific situations to strengthen your points; Include positive and negative feedback; Use precise and respectful language to state your concerns, identified gaps of knowledge, or additional considerations; Avoid grammatical errors and spelling errors; Include scientific data when applicable; Avoid opinions or undocumented observations; Use an active voice, not passive; Include solutions or specific changes to the language of the docket; Read the docket fully before writing a comment; and Avoid wordy sentences or dense text blocks.

National Corn Growers Association has a prewritten template that can be viewed on its website, and for those who wish to submit a comment through the group, see the following site: https://ncga.com/take-action/become-an-advocate/take-action.

Beef Quality Assurance (BQA) and BQA transport training will be held Oct. 5th from 10 a.m.-Noon at the Fairgrounds in Geneva. You can RSVP at https://bqa.unl.edu/training-events.

Crop Insurance Workshop will be held Oct. 19 at the Heartland Event Center in Grand Island. Register at: https://cvent.me/R5qeL3 or 402-472-4923.

Central Nebraska Regenerative Ag Conference featuring Gabe Brown will be held Nov. 18 at the Tassel Performing Arts Center in Holdrege, NE from 1-4:30 p.m. Pre-register at: 308-995-8133.

Dr. Kohl will be at Farmers and Ranchers College in Bruning at the Opera House on Dec. 8th.



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