Remaining Concerns

In a recent letter to EPA, the presidents of the California, Idaho, Oregon and Washington Farm Bureaus have joined together to express their concerns about EPA’s current approach to the NMFS recommendations. These four agricultural leaders called EPA's plan “unreasonable and unworkable,” pointing out that it will impose significant new constraints on farming operations throughout the West Coast without the necessary scientific information to justify this action.

Dow AgroSciences continues to try to work with EPA toward a resolution that is protective of both endangered salmon and continued crop production in the Western U.S. – even as we continue to press for legal review of the NMFS proposal on which EPA’s currently problematic implementation plan is based. For instance:

• We believe that EPA needs to redefine the waters to be affected by these new restrictions so that the intended buffer zones apply to actual salmonid habitat. Unless this habitat is better defined, the new restrictions will apply to every ditch, drain, canal and irrigation furrow bearing water with some potential to reach salmon habitat, leading to an essential prohibition of use of these three products in large areas of the Pacific Northwest with more than 112 million acres – including some of the most valuable and productive farm and forestry land in the U.S. – being affected. Resolving this definitional issue is of critical importance to agriculture, since the regulatory decisions made on these three products are now setting a precedent for decision-making on 34 more pesticide active ingredients over the next few years.

• We also believe that it is imperative that EPA develop a transparent process for implementing these new restrictions with the full involvement of state authorities and registrants – and with input from the growers who actually use the products and whose competitiveness and livelihoods the overly broad application of these restrictions may be placing at risk. 

Pesticides are a necessity of modern food and fiber production. Arbitrarily restricting access to these important tools without valid data-driven scientific assessments demonstrating clear benefit to the environment offers no assurance of protection for salmon and steelhead. Such restrictions can, however, lead to reduced food supply and quality and increased food cost. They can also significantly impair the ability of American farmers to compete with growers overseas and cause tremendous financial risk and damage to their livelihood and the sustainability of their operations. Clearly, all parties have a stake in these important, precedent-setting decisions, and all parties – including agriculture – ought to have an opportunity to provide input on how they should be resolved.

Read a one-page summary of the issue.