SECTION: IN THE NEWS

LENGTH: 2342 words

HEADLINE: PREPARED TESTIMONY OF
DOUG WILSON
ILLINOIS CORN GROWERS ASSOCIATION
NATIONAL CORN GROWERS ASSOCIATION
BEFORE THE HOUSE AGRICULTURE COMMITTEE
DEPARTMENT OPERATIONS, NUTRITION AND FORESTRY SUBCOMMITTEE

BODY:

 
Thank you. My name is Doug Wilson. I am a farmer in North Central Illinois and I raise corn, soybeans, high oil corn, and hybrid seed corn. And had it not been for a generous rain last week, I would have appeared much more nervous today as my planter would have been sitting still while my neighbors were planting corn. I am president of the Illinois Corn Growers Association and am a former National Corn Growers director. One other involvement I would like to mention is being President of the Illinois Council on Best Management Practices (CBMP). Illinois CBMP is a board of agricultural organizations and businesses working to assist watersheds on water quality issues and sharing information with both agricultural and non-agricultural interests.
The NCGA represents more than 30,000 corn farmers in 48 states. Farmers need a variety of crop protection products to be successful in their farming operations. These products allow for a healthier crop, providing a higher yield due to protection from pests and weeds. NCGA supported the Food Quality Protection Act (FQPA) when the law was passed in 1996, and we remain committed to the law. We agree with the fundamental goals of the law, including safeguards for children and the establishment of a uniform public health standard. We feel that review of pesticides using reliable data, as stipulated in the law, will ensure the public health. However, farmers remain concerned about the lack of a defined process for the implementation of FQPA.
In working to more clearly articulate our concerns regarding FQPA implementation, farmers, farm and food groups, pest management and manufacturing organizations formed the Implementation Working Group (IWG). The IWG's "Framework for Implementing the FQPA" or "Road Map" document provides a series of workable recommendations for implementing the law. This document represents the consensus of a variety of affected parties as to how we believe FQPA can be implemented fairly and effectively. Based on the provision of the Road Map, IWG has prepared comments during the open comment period of several of the science policy papers and will continue to do so.
NCGA is also involved in the FQPA Tolerance Reassessment Advisory Committee (TRAC) created by the EPA and USDA, with Jim Czub, a farmer and member of NCGA's Board of Directors, as a participant. We support the TRAC and look forward to continuing to participate in the process. However, we see this as just one step in the implementation process. This advisory committee does not replace the need for sufficient information to U.S. farmers from EPA and USDA on the implementation process and valid scientific data behind tolerance reassessment and registration decisions.
NCGA would like to thank the members of this committee for your continued oversight of the FQPA implementation. Corn growers are very encouraged by the role of USDA in the FQPA implementation process and the achievements that have been made over the last year. However, we remain concerned that the USDA does not have sufficient financial resources or staff to continue providing the needed support to farmers throughout the implementation process. NCGA and the Illinois Corn Growers Association have been working very closely with the University of Illinois in the various programs relating to FQPA. Primarily, our focus has been on the need for accurate information on pesticide use patterns. The University of Illinois has submitted a "Corn Matrix Response" to the EPA, using data generated for the corn crop profiles in the EPA's crop matrix format. Much more of this work needs to continue in various areas of the country on corn and other commodities. Land grant universities need to be actively engaged in this process.
USDA also needs to be prepared to handle its increased role in risk assessment review, which we believe is a key role of USDA during the implementation of FQPA. We support the necessary resources for this process to continue. Also, the new programs being developed by USDA to develop broader participation and programs and to assist in the collection of data and disseminate of information are very important. We appreciate EPA's working on making several science policy papers available for public review and the work that has taken place in the agency as a result of the TRAC. However, there are still issues that need to be resolved. We remain concerned about how EPA is using its resources. While we understand the new requirements under FQPA substantially changed the way pesticides were regulated, the reassessment of existing tolerances cannot overshadow the importance of new product registration. The agency has not allocated sufficient funds to ensure that new product registration continues in a timely manner. Currently, the EPA expects 13 out of the 40 pending new product applications will be reviewed in fiscal year 1999. Thirty- three percent is not sufficient in light of the continued changes in agriculture.
When new products are made available to growers, their adoption is not immediate.
These products must have sufficient time on the market for before growers know and understand their efficacy and application methods. The mere "Washington" identification of a product as a replacement for another product is not always sufficient. There are regional variances in application and efficacy that need to be taken into account, not just the fact that the products are labeled to eradicate the same pest.
New products need to be introduced to the market in timely fashion to allow an orderly transition. There is also an important economic impact to having new products available at the same time that existing products are being reassessed and that is simply the price of the products. The price of existing products is most likely less than new products, but the sheer fact that these products are on the market allows some measure of cost containment. This applies for both traditional crop protection tools and biotechnology products.
Another element dictating the need for a variety of crop protection tools and methods is pest resistance. The most common production method employed is the traditional corn/soybean rotation to limit the corn root worm and other pest pressures. Unfortunately, in areas of Illinois and Indiana, we are seeing a root worm that is beginning to adapt and lay eggs in soybean fields instead of corn fields so that eggs hatch into rotated corn fields the following spring. This is already happening in Congressman Ewing's 15th congressional district, where I live, and in areas east and southeast of there. Without an effective crop protection product to control the root worm, yields could be cut by 25 percent and the remaining plants will not stand as well and could result in additional losses. As this adaptation continues to spread, the use of various crop protection products is even more critical to successful crop production. In regions with irrigated corn, crop rotation is often not an effective option and pesticides are even more vital for corn production. Use of these same crop protection products is also critical for seed corn production fields that will provide the seed for the following year's crop. In addition, crop protection products are often used in concert with conservation tillage to preserve the soil.
Farmers must contend with many factors, including choice of crop, seed technologies and products, soil, climate and rainfall, and historical weed and pest pressure in the field.

The same elements influence my decisions on pre-emergent and post- emergent application of crop protection products. Growers seldom use the maximum amount of application or the maximum rates because of cost alone. Safety and optimum yield are considered at length before application of any pesticide.
Corn growers have a great deal at stake during the entire reassessment process under FQPA. The policies developed now will set the stage for future actions and reassessments. This is not just an organophosphate issue or a herbicide issue, but applies to all areas equally and should be regarded in such a manner. The reassessment decisions on the first third of products should not be made without sufficient data and a defined process in place. The EPA must have a clearly defined process in place prior to making reassessment decisions under FQPA. As a result of the TRAC meetings, the science policies that indicate EPA's actions are being made available for public comment. This process of public input must continue and these policies must be clearly defined and reviewed prior to final reassessment decisions by the agency. The clarification of these policies is necessary to define a process for the reassessment of all tolerances under FQPA.
Due to the large crop acreage of corn, NCGA is not only concerned about health effects portion of the reassessment decisions, but also about EPA's use of lower tier or unrefined data in determining environmental fate and ecotoxicology. As well, the information on actual pesticide use patterns and data must be taken into account when calculating these assessments. If the EPA calculates environmental risk assessments using unrefined or inaccurate data, unnecessary losses in crop protection products will result. It is vital that sound science, actual pesticide use patterns and accurate information on formulations and application methods be used in all areas of pesticide reassessment. Often with corn products, there is a great deal of scientific information regarding these products and most accurate and higher level of refined data must be used.
As changes are made in product availability and/or product use through the adoption of risk mitigation measures, growers must be given appropriate transition time. As with new product availability, any mitigation measures or alteration ing practices must be given time for adoption. Changes cannot be expected immediately. Any mitigation measures that may require equipment changes, or similar significant changes in farming practices, but be weid with significant economic concern and be provided sufficient transition time.
As a part of our effort to articulate some of our existing concerns with FQPA implementation, NCGA and the ICGA have been working very closely with Representative LaHood on this issue. We support H.R. 1334, the FQPA Implementation Act of 1999, and its goals of sound implementation of FQPA through the use of data when making decisions, sufficient public input during FQPA implementation and analysis of the resources and priorities of EPA and USDA. Another important provision in this legislation is an analysis of the competitive strength of U.S. agricultural commodity sectors in the international marketplace.
Congressman LaHood's bill will assure consideration of sound science before suspending the use of a pesticide and will consider the overall public interest before taking such action. Corn growers feel that Rep. LaHood's bill is right on target because it addresses "implementation" of FQPA. FQPA can work if it is implemented correctly.
If corn growers are not provided sufficient options for crop protection, U.S. corn production will be at a competitive disadvantage. U.S. corn growers rely upon the latest technologies for all aspects of our farm business, and we evaluate current and new technologies constantly to choose the best products for our operations. Currently, the United States leads the world in corn production. NCGA strongly supports the 1996 Federal Agricultural Improvement and Reform Act's shift from supply management farm programs to a market-oriented farm economy. The FAIR Act allows me the flexibility to grow crops that make sense for my land in terms of conservation, production and economics. But to make these decisions, we need to have a regulatory process that supports product choice based on sound science and realistic agronomic practices.
NCGA monitors the corn production of other countries, including our closest low cost competitor, Argentina. If other countries can produce and transport corn at lower costs than the United States, we have the potential to lose our export markets and may suffer domestic market disruption. The U.S. government must help assist the U.S. farmer to remain competitive in the world market and not restrict our competitiveness through unnecessary and unreasonable regulation.
Keeping farm input costs in check is essential if we are to remain competitive in both domestic and international markets. Current low corn prices and weak export demand drive home the importance of this issue. If corn farmers have reduced options for crop protection the prices of these products will undoubtedly rise. If prices become cost prohibitive, corn farmers will be limited in our ability to produce food for the world.
One of the basic precepts of the FAIR Act was the "balance sheet"- reduced farm program payments offset by a more flexible farm program and other efforts such as tax reform, increased export assistance and regulatory relief. But the manner in which FQPA is being implemented is inconsistent with that balance sheet concept. Mr. Chairman, members of the Committee, I would encourage you to keep that balance sheet in mind as you exercise your oversight authority in this process.
Mr. Chairman, I want to thank you for holding this oversight hearing today and providing this forum for agriculture to voice our concerns over the implementation of the Food Quality Protection Act. NCGA will continue to work with EPA and USDA and through public forums to ensure the impacts of this law on production agriculture are fully taken into account. We need transparency during the implementation of the law and the use of reliable information. We need to consider how this law effects agriculture, changes in farming practices, actual pesticide use and the need for new products. Provided that these things happen, we believe that FQPA can succeed in meeting the goals set by Congress.
END


LOAD-DATE: April 24, 1999