Testimony of Doug Wilson on behalf of the Illinois Corn Growers
Association and the National Corn Growers Association before the
Subcommittee on Department Operations, Nutrition and Forestry U.S.
House of Representatives Committee on Agriculture April 22, 1999
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 in farming 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 weighted 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.
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