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Virtual Public Meeting - GE Cotton & Soybeans Resistant to Dicamba 09-11-2014
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VIRTUAL PUBLIC MEETING
GE COTTON & SOYBEANS RESISTANT TO DICAMBA
Conducted by Richard George and Joanne Serrels
Thursday, September 11, 2014
5:00 p.m.

U.S. Department of Agriculture
Animal and Plant Health Inspection Service
4700 River Road
Riverdale, Maryland 20737
(301) 851-2236

Reported by:

Karlene Campbell, CCR
Capital Reporting Company

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2

P R O C E E D I N G S
MR. GEORGE:

My name is Richard George.

3

I'm the communications branch chief at

4

Biotechnology Regulatory Services or BRS, a part

5

of APHIS, the Animal and Plant Health Inspection

6

Service, an agency of the U.S. Department of

7

Agriculture.

8

environmental protection specialist at BRS.

9

Joining me is Joanne Serrels,

MS. SERRELS:

We welcome you to this

10

virtual meeting being held to receive public

11

comments on the Monsanto Company's soybean

12

genetically engineered to be resistant to dicamba

13

and cotton resistant to dicamba and glufosinate.

14

We value your input and are pleased that you

15

joined us today either to make a public comment or

16

listen to the comments of others.

17

MR. GEORGE:

The purpose of this meeting

18

is to solicit your comments on a draft

19

Environmental Impact Statement for petitions for

20

nonregulated status for herbicide resistant,

21

genetically engineered plants.

22

focuses on petitions from Monsanto for soybean

The draft EIS

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genetically engineered to be resistant to dicamba

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and cotton resistant to dicamba and glufosinate.

3

For more information on these plants, go

4

to www.aphis.usda.gov/aphisvirtualmeetings, all

5

one word.

6

www.aphis.usda.gov/aphisvirtualmeetings.

7

site contains background information and also

8

links to other documents and Web sites.

9

That's
This

In the past we have traveled around the

10

country to conduct meetings where interested

11

parties can make public comments on our various

12

regulatory actions.

13

online virtual meeting to allow more people the

14

opportunity to comment.

15

Today we are holding this

MS. SERRELS:

We will be taking only

16

spoken comments today.

17

written comment instead of a spoken one, you can

18

do so by going to www.regulations.gov through

19

September 25.

20

and this will take you to the pages where you can

21

make your comment.

22

If you prefer to make a

Enter "dicamba" in the search box,

The public comment period ends on

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September 25.

You can go to regulations.gov

2

anytime up until that date to leave a written

3

public comment or you can make a spoken comment

4

here in our meeting, which will go until 8:00 p.m.

5

Eastern time.

6

comment will become part of the public record.

7

transcript of your public comment will be posted

8

to the Web site within the next three weeks.

9

Today we are here to receive your input only, not

Whether spoken or written, your

10

to answer questions about the draft EIS.

11

background information, please go to

12

www.aphis.usda.gov/aphisvirtualmeetings.

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MR. GEORGE:

A

For

If you would like to make a

14

public comment today, on your telephone keypad,

15

please press one and then zero.

16

then respond to you and let you know when it is

17

your turn to speak.

18

comments to three minutes or less.

19

that when it is your turn to speak, that you

20

identify yourself, and please say and spell your

21

name so that our court reporter has a good chance

22

of spelling it correctly in the transcript.

The operator will

We ask that you keep your
We also ask

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Written transcripts of this meeting will be

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available within three weeks at

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www.aphis.usda.gov/aphisvirtualmeetings.

4

MS. SERRELS:

The statements received

5

during the public comment period, whether spoken

6

today or submitted in writing to regulations.gov,

7

will be considered in the development of the final

8

Environmental Impact Statement associated with the

9

petitions for nonregulated status from Monsanto

10

for soybean genetically engineered to be resistant

11

to dicamba and cotton resistant to dicamba and

12

glufosinate.

13

APHIS will then carefully consider all

14

public comments submitted during the comment

15

period before finalizing the draft EIS and then

16

making its final decision regarding the regulatory

17

status of these GE plants.

18

comments today because they will help us ensure

19

that relevant issues are considered as we prepare

20

the final Environmental Impact Statement.

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MR. GEORGE:

We welcome your

If you would like to make a

public comment today, again, on your telephone

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keypad, please press one and then zero.

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operator will then respond and let you know when

3

it is your turn to speak.

4

to -- with that, we are ready to hear from our

5

first commenter.

6
7
8

With that, we are ready

Do we have someone?

MR. MCCLENDON:
McClendon.

The

Yes.

This is Larry

Am I live?

MR. GEORGE:

You are live, Larry.

If you

9

would please say and spell your name slowly and

10

clearly so we can get the spelling right in the

11

record, please.

12

MR. MCCLENDON:

My name is Larry

13

McClendon, L-A-R-R-Y, M-C-C-L-E-N-D-O-N.

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fourth-generation cotton farmer.

15

farmed in Eastern Arkansas most of my life.

16

grow from five to ten thousand acres of cotton

17

each year.

18

trait under the regulatory review this year on my

19

farm, approximately 2500 acres.

20

I'm a

I have lived and
And I

I grew the dicamba-tolerant cotton

I would like to share my experience

21

firsthand because not many people, and

22

particularly farmers have been able to see this.

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I would also like to say that I fully support the

2

option to deregulate the dicamba-tolerant cotton

3

and soybeans.

4

a lot of confidence that growers need new weed

5

management technologies.

6

becomes more prevalent as it is on my farm, we

7

need additional tools at our disposal to fight

8

them.

9

Again, as a farmer, I can say with

As weed resistance

And dicamba tolerance, it works very well.
I have significant Palmer pigweed, weed

10

pressure on my farm.

11

of action in dicamba to control it, which is very

12

important.

13

additional mode of action, but it also expands the

14

dicamba weed control window from burndown and

15

planting to in-crop applications.

16

I have the additional mode

This system will not only provide an

With regards to concerns about off-site

17

movement, I believe that growers have experience

18

with various cropping systems and are in a good

19

position to prevent or minimize drift.

20

label instructions very closely.

21

regular training, and we invest in modern

22

technology that enables to minimize drift.

We follow

We go through

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Newer dicamba formulations along with

2

application requirements that accompany this

3

system can make it possible for all types of

4

growers to coexist and prosper.

5

with the performance of this system on my farm

6

this year.

7

tools such as dicamba-tolerant technologies is

8

important to me as a grower.

9

I'm very happy

Again, access to new weed management

I would urge USDA to pursue in a timely

10

fashion towards full deregulation of

11

dicamba-tolerant technologies.

12

thank you today for my comments, my ability to

13

speak and my -- just considering my thoughts here.

14

Thank you.

I would like to

15

MR. GEORGE:

16

We have another commenter ready.

17

go ahead and give us name, spell it, please, and

18

let us know if you're affiliated with any

19

organization.

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MR. SMITH:

Thank you for your comment.
Please

Steve Smith, S-T-E-V-E,

21

S-M-I-T-H.

I'm affiliated with the Save Our Crops

22

Coalition.

We appreciate -- we appreciate the

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chance to participate in this meeting today.

2

I would like to say that we have submitted written

3

comments already.

4

verbal comments as well.

5

And

But I would like to make these

We at Save Our Crops Coalition have grave

6

concerns about the off-target applications that

7

will be hitting the entire crop-growing areas,

8

particularly in the Midwest once this technology

9

is released, if it is released.

Some of the

10

problems that we found with the EIS that we would

11

like to have your continued research into would be

12

that there is no definition of what a nonvolatile

13

with any metric, nonvolatile dicamba formulation

14

is.

15

And it just says other than the DMA

16

formulations, which leads to the belief that it

17

will be used with DGA formulation.

18

do we consider the DGA formulations nonvolatile.

19

They may be less volatile than the old DMA

20

formulations, but they are known to be volatile.

21

And it is backed up by much practical experience

22

in university research that that's the case.

And in no way

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The question will become, what is an

2

acceptable level of volatility?

3

that this level is not acceptable as there will be

4

crop injury widespread with its use.

5

believe that in the EIS it was felt that due to

6

the -- that the pricing of the materials would not

7

be a problem.

8

the least volatile materials might not be the ones

9

that would be used.

10

And we believe

We also

But due to pricing, we believe that

In other words, the DMA formulations will

11

be tempting for growers to use in replacement of

12

the DGA or the brand of products that Monsanto

13

might be releasing with.

14

that volatility products will be used at the

15

minimum, we believe, is not accurate because the

16

least volatile products will be the more

17

expensive.

18

So that any indication

We also want to point out that the use of

19

this product will be primarily later -- our

20

concerns is primarily use in the later of growing

21

season once acceptable crops are already leafed

22

out and that the environmental temperatures are

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going to be higher, which lead to more volatility.
And we also would like for APHIS to

3

recommend to EPA imposing similar label

4

restrictions as Dow has voluntarily done with

5

their new Enlist product.

6

restrictions are reasonable and would add a lot to

7

the structural safety of the use of this material.

8

Then finally, just as a comment of

9

We believe that those

something -- we know that USDA and APHIS can

10

formulate about the actual use of the chemistry

11

and the safety of it.

12

and APHIS has a role to play in maintaining good

13

rural acrimony.

14

all the off-site, off-target movements will lead

15

to problems among neighbors that sit on -- sit

16

together on church boards, school boards.

17

prospect of suing your neighbor to recover losses

18

is not good for rural acrimony.

19
20

But we do believe that USDA

And we believe that potential for

And the

So with that, I appreciate the chance to
speak and look forward to your decisions.

21

MR. GEORGE:

Thank you, Steve.

22

The next commenter would like to go,

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please.

2

spell it for us, please.

3

Just remember to give us your name and

MR. MURPHY:

Hi, this is Danny Murphy,

4

D-A-N-N-Y, M-U-R-P-H-Y.

5

farmer from Mississippi.

6

speak in favor of deregulation of dicamba.

7

think it is certainly important for industry to

8

continue to adopt new chemicals and new

9

technology.

10

I'm a soybean and corn
And I would like to
I

Unfortunately, on my farm that I no

11

longer have -- that I don't have resistant weeds

12

yet or glyphosate-resistant weeds.

13

in my county, and I know that they are coming.

14

And I have been able to reduce having them or not

15

having them today because I have used multiple

16

modes of action.

17

But they are

And I think this new dicamba technology

18

would be important in giving me that opportunity

19

to continue to broaden the base of chemicals I use

20

and to delay that resistance even further.

21

think it is important that we move forward with

22

this.

And I

As we delay, then it is more likely that I

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will have resistance in the future.

2

like to be able to delay that so that it doesn't

3

inhibit the crops unable to grow or what I'm able

4

to do.

5

And I would

I think that farmers are able to apply

6

this chemical.

I don't think the application

7

to -- recommendations are -- will be difficult for

8

farmers to do, I think, if we understand drift and

9

how to reduce that, how to use the right tips, how

10

to look at the wind speed.

So I think it is a

11

process that farmers can comply and will comply.

12

I know that we will need to be careful using this.

13

But again, I think it is something that we can

14

easily meet and be able to use this technology.

15

So I think that we do need to move

16

forward with this deregulation and give farmers an

17

opportunity to use this technology.

18

the neighbors that do have resistant weeds, it's

19

really an opportunity for them to be able to

20

control those weeds.

21
22

I know with

Again, I thank you for the opportunity to
comment, and I look forward to being able to use

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this technology in the future.

2

MR. GEORGE:

3

We are getting notes.

Thank you.

Thank you, Danny.
So we need to

4

speak up a little bit here in the room.

5

will try to remember to do that.

6

everyone can hear okay.

7

comment.

8
9

And we

So I'm hoping

And our next is ready to

So please go ahead.
MR. YODER:

Yes, thank you.

Fred Yoder, F-R-E-D, Y-O-D-E-R.

My name is

I'm a

10

fourth-generation farmer here from Central Ohio.

11

We raise corn, soybeans and wheat.

12

for over 40 years, and I have used dicamba in my

13

cornfields for over 40 years.

14

it, and I know there is a right way and a wrong

15

way to use these chemicals.

16

Been farming

I'm well aware of

We have to avoid drift, and we have to

17

figure out ways to be cognizant of our nature's

18

crops.

19

new neighbors.

20

formulation that's going to be available to use if

21

this dicamba-resistant variety gets released.

22

I think that's really good.

And we have done that.

We all have to be

So I'm very excited about the new

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I disagree with one thing one of the

2

other commenter said.

3

of using this particular product in burndowns

4

because we have learned when we get ready to plant

5

the crops, we have been using things like 2,4-D

6

and having to wait a week and then go ahead and

7

plant the corns or the beans and the -- the

8

soybeans and the stubble from after a week's worth

9

of letting it cook.

10

I really see the advantage

To me, with the different times of the

11

climate changes that we have experienced and the

12

weather pattern that we have endured as far as big

13

rains and dry spells, I think that's the real

14

advantage of the farmers going to have a chance to

15

use this new technology.

16

We all have learned in the past that we

17

can overuse things.

The way you bounce back from

18

a resistance that develops -- and by the way, I

19

have seen resistant weeds develop for the last 40

20

years.

21

are talking about glyphosate resistance.

22

lots of other weeds that are resistant to many

This is not something new just because we
There is

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other chemistries as well.

2

that the way you deal with resistant weeds is

3

multiple modes of action.

4

it.

5

But we have learned

That's the way you do

We can use other -- we have used other

6

chemistries like atrazine, which show there is 50

7

to 60 weeds already resistant too.

8

it with something else, you still get a multiple

9

mode of action.

But by mixing

And that's the way you control

10

resistance.

So this is some of the -- this is a

11

new product we need to keep ahead of the

12

resistance of weeds that are developing.

13

Again, I have used dicamba for many, many

14

years, and I'm excited about the new formulation,

15

which is much lower in off-target movement with

16

our new sprayers.

17

going to have a fine time using this.

18

greatly appreciate and urge the deregulation of

19

dicamba-resistant soybeans.

20

time.

And being good stewards, we are
So I would

I thank you for your

21

MR. GEORGE:

Thank you, Fred.

22

And I think we have another commenter

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ready to speak.

If you would, please, go ahead.

2

Is there a commenter ready to speak, please?

3

Prompted if you are.

4

MR. CROMLEY:

5

MR. GEORGE:

6

MR. CROMLEY:

Yes, I'm ready.
Please go ahead.
Thank you.

My name is Lee

7

Cromley, L-E-E, C-R-O-M-L-E-Y.

I am a

8

fifth-generation farmer living in Bulloch County,

9

Georgia.

My brother and I have farmed together

10

for over 30 years, farming several thousand acres

11

of cotton and peanuts during that time.

12

In my 30 years or 30 years plus now of

13

farming, I have seen unbelievable advances in

14

technology and research in the agricultural

15

industry.

16

not be able to survive the economic and

17

environmental pressures that we have seen over the

18

last three decades.

19

Without these advances, we simply would

Research and technology is what keeps us

20

going, what keeps us surviving.

Because I believe

21

that dicamba-tolerant crop for the next big

22

advances in a long line of important technologies,

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I fully support the option to deregulate

2

dicamba-tolerant soybeans and cotton without

3

restriction as recommended by the draft

4

Environmental Impact Statement.

5

and similar technology will help us maintain

6

healthy yields and ensure stable supply of very

7

valuable crops just bypass with the consumers

8

around the world.

9

Access to this

As a Georgia farmer, I can assure you

10

that our growers need new weed management

11

technologies with prudent weed control over a

12

broad spectrum of weeds, likely Roundup Ready

13

technologies.

14

prevalent on my farm, we have become more and more

15

limited in our options to effectively fight our

16

broad spectrum of weeds.

17

As weed resistance becomes more

Weed science tells us that the best way

18

to address weed resistance besides good management

19

practices is using a variety of weed control

20

tools.

21

an additional mode of action while expanding the

22

dicamba weed control window that we so desperately

The dicamba-tolerant system will provide

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need.
One other very important point I would

3

like to discuss relates to our dedication to

4

sustainability and our desire to reduce our

5

environmental footprint.

6

technologies will enable growers to continue to be

7

good stewards of our land.

8

crops have made conservation tillage widely

9

accepted in Georgia.

10

I believe that these

Glyphosate-tolerant

This has been the greatest advance in

11

sustainable farming practices since the --

12

preservation of the topsoil, reduce fuel use and

13

better water conservation are just a few of the

14

benefits of conservation tillage.

15

it along the last few decades.

16

I stay away, as a lot of growers should, from

17

conservation tillage because of the difficulty

18

controlling weeds.

19

will help us better manage weed resistance so we

20

can continue this very important sustainable

21

practice.

22

But I have seen

That's years.

And

The added dicamba tolerance

With regards to the concerns about

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dicamba off-site movement, I believe our growers

2

are experienced enough with various cropping

3

systems and are in good position to prevent or

4

minimize drift.

5

our area.

6

those types of things available to us, we will be

7

able to manage the drifts.

Education has been real strong in

Training is very long.

We believe with

8

Access to new weed management tools such

9

as dicamba-tolerant technologies is important to

10

me as a farmer.

So I just urge USDA in a timely

11

fashion to move forward for deregulation of

12

dicamba-tolerant technologies.

13

your time and considering my comments.

I thank you for

14

MR. GEORGE:

15

And we have another commenter ready to

16

comment.

So please go ahead.

17

MS. REED:

18

MR. GEORGE:

19

Thank you, Lee.

Hello, can you hear me?
Yes, we can.

Please go

ahead.

20

MS. REED:

Great.

Okay.

This is Genna

21

Reed, G-E-N-N-A, R-E-E-D.

22

representing Food and Water Watch, a nonprofit

And I'm here

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consumer advocacy group that supports safe,

2

accessible and affordable food for consumers and

3

fair access to markets for farmers.

4

Food and Water Watch has provided the

5

USDA our comments on the notice of intent to

6

prepare an Environmental Impact Statement from

7

Monsanto's dicamba-tolerant soybean and cotton

8

varieties last July.

9

numerous concerns about the impacts of

In our comments we brought

10

dicamba-tolerant crops and the increased use of

11

dicamba.

12

Most notably are the impact the drift

13

will have on specialty crop, organic and non-GMO

14

farms and the unintended environmental impact

15

associated with more dicamba use.

16

submitted a letter asking the USDA to extend this

17

comment period, and we hope you will honor that

18

request.

We also

19

Since then Food and Water Watch with

20

partnership with Organic Farmers' Agency for

21

Relationship Marketing, OFARM, conducted a survey

22

of organic grain producers on preventative

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measures that they use to avoid GMO contamination

2

and their financial losses associated with that

3

contamination.

4

Besides GMO contamination, many of the

5

responding farmers wrote that they were also

6

experiencing financial losses associated with

7

chemical drifts from nearby farms.

8

mentioned that a neighbor's spray drift killed 10

9

acres' worth of feed corn one year.

One farmer

Another

10

wrote, quote, My only problem comes from drift

11

when commercial chemical sprayers spray on a windy

12

day and the spray drifts across the road, a buffer

13

strip to kill my alfalfa or other crops.

14

the company and complained, but they have never

15

compensated me for my loss.

16

I called

And regarding dicamba specifically, one

17

farmer wrote, quote, I'm more concerned with spray

18

drifts, especially with the effort to release

19

resistant soybeans.

20

that chemical can be, not only to organic farmers,

21

but all farmers and homeowners, unquote.

22

Everyone knows how volatile

Even Roundup, considered to be less

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1

harmful and less prone to drift than 2,4-D and

2

dicamba, has been a huge problem for organic

3

growers.

4

last 16 years, I have had three instances where

5

spray drift have affected my field.

6

times it was Roundup.

7

I have had to start the three-year transition

8

process for organic certification all over.

9

Not only has spray drift negatively

One farmer wrote that, quote, In the

All three

It has totaled $65,000, and

10

affected relationships between neighbors, but it

11

has resulted in organic farmers being forced to

12

take some areas of their farm out of organic

13

production completely.

14

The USDA's EIS predicts that dicamba use

15

will increase up to 88 folds and 14 folds for

16

soybean and cotton respectively compared to

17

current practice.

18

pesticide use, farmers will become more complacent

19

with the applications on crop; and farmers with

20

nearby nontolerant crops will pay the price.

21
22

Without stricter controls over

I understand that the USDA does not have
authority over pesticide registration and the use,

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1

but allowing these crops to become widespread on

2

agricultural land knowing these implications will

3

be enabling the irresponsible use of these

4

chemicals and doing a huge disservice to U.S.

5

agriculture in the long run.

6

Recently a meta-analysis on 2,4-D and

7

dicamba done by researchers at Penn State

8

University found that cotton is extremely

9

sensitive to dicamba, especially in the flowering

10

stage.

11

cotton will not be affected by dicamba,

12

nontransgenic varieties can be damaged in a number

13

of ways through off-target movement from ground

14

spraying, if herbicides is applied in windy

15

conditions, if dicamba is sprayed in high

16

temperature condition.

17

Although dicamba-tolerant soybean and

Also residues are hard to remove from

18

farm equipment and could be applied to susceptible

19

crops unintentionally.

20

is used abundantly, herbicide residues can

21

actually accumulate in the air and return to both

22

transgenic and nontransgenic fields in the form of

And in areas where dicamba

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1
2

precipitation.
And because dicamba affects broadleaf

3

plants, quote, nontarget exposures may therefore

4

lead to a net reduction in the functional

5

diversity and floral resources provided by

6

seminatural habitats, unquote.

7

Penn State University study on the effects of

8

dicamba drift on plants and arthropods.

9

Scientists found a decline in forb cover in field

This is from a

10

edge plots with only 1 percent of the field

11

application rate of dicamba and declines in three

12

insect species:

13

and potato leaf hopper.

14

pea aphids, spotted alfalfa aphid

There are clearly gaps in scientific

15

knowledge on the response of wild plants and plant

16

communities to low-dose exposures, especially in

17

realistic field settings.

18

evidence available regarding the direct and the

19

indirect effect of herbicides on arthropods.

20

And this is also from the study:

21

most herbicides do not appear to be directly toxic

22

to arthropods, herbicides do affect plant nutrient

There is incomplete

Quote, While

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1

levels and hormone pathways used in defense, both

2

of which may influence plant susceptibility to

3

herbivores.

4

The USDA --

5

MR. GEORGE:

If you can finish your

6

thought, please.

7

have a number of people that are waiting.

8

we reach a point where everyone has spoken and we

9

have more time, we will invite you to continue and

10

But if

elaborate on your comment.

11
12

And I will mention that we do

MS. REED:

Okay.

This is the last

sentence.

13

MR. GEORGE:

14

MS. REED:

Okay.
We just hope that the USDA to

15

do this kind of research on plant and insect

16

communities and biodiversity in general before

17

approving this dicamba-tolerant system.

18

urge the USDA to deny approval of Monsanto's

19

dicamba-tolerant varieties.

20

MR. GEORGE:

21

And we have another commenter ready to

22

begin.

So we

Thank you.

Thank you, Genna.

Please say and spell your name for us, and

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1

let's have your comment, please.

2

commenter, are you there?

3
4

MR. TIFFANY:

Hello.

Hello,

Okay.

This is

Bruce Tiffany, B-R-U-C-E, T-I-F-F-A-N-Y.

5

MR. GEORGE:

6

MR. TIFFANY:

Go ahead, Bruce.
Okay.

I'm a

7

fourth-generation farmer in the Redwood Falls,

8

Minnesota, area.

9

sweet corn, cattle and sheep.

I have raised soybeans, corn,
I have grown

10

dicamba-resistant soybeans under permit now for

11

three years and fully support the deregulation of

12

this trait.

13

system is effective, economical, safe for the

14

operator and environmentally responsible.

15

My experience is the weed control

I also believe the technology will be

16

effective for a long time because we have numerous

17

corn chemistries available so we can reserve the

18

dicamba for soybean weed control.

19

different modes of action will delay any

20

resistance of the weed population.

21

another soybean weed control tool is apparent with

22

increased newly difficult-to-control weeds showing

All of these

The need for

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1

up here.

2

Weed such as tall waterhemp and Venice

3

mallow can be controlled with dicamba.

4

these weeds are small-seated types that flourish

5

under a reduced tillage system.

6

improve water quality, soil health and reduce fuel

7

usage, most farmers are reducing their tillage,

8

thereby setting up a more favorable environment

9

for these small-seated weeds.

10

A lot of

In an effort to

Compared to the 1970s and the present, we

11

have gotten much more efficient at using our

12

inputs in crop production.

13

we have not been wasting labor, fuel, fertility,

14

water and sunlight on growing weeds.

15

for the environment and good for the price of

16

food.

17

Part of the reason is

This is good

However, nature is always evolving and

18

changing the rules of the game, and using the best

19

tools and technology available will ensure its

20

safe and sustainable food system.

21

a global society and have a responsibility to use

22

our resources wisely.

We also live in

I have traveled a fair

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1

amount and met and seen people all over the world

2

that rely on us to provide protein for their diet.

3

I have met buyers of Midwest U.S.

4

soybeans to be used for direct human consumption,

5

animal feed and fish feed.

6

people that get their dietary protein on the other

7

side of the world because we do our job correctly

8

here.

9

to us here and have fewer tons of soybeans on the

There are millions of

If we fail to use all the tools available

10

market at a price they can afford, then we have

11

failed to live up to our responsibility.

12

in the U.S. and other developed countries won't

13

starve.

14

be the ones left with a lower protein diet.

15

We here

The people in developing countries will

I base my management decisions for my

16

farm not only on the present circumstances, but I

17

also consider whether the people farming this land

18

before me and after me would be pleased with my

19

choices.

20

one tool -- one of those tools they would endorse

21

because this technology helps us deliver a vital,

22

sustainable and safe product to the public.

I believe dicamba-tolerant soybeans are

Thank

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1

you for your time.

2

MR. GEORGE:

3

And we have another commenter ready to

4
5

comment.

Thank you, Bruce.

So please go ahead.
MR. COWAN:

Yes.

This is Wade Cowan,

6

W-A-D-E, C-O-W-A-N, from Brownfield, Texas, where

7

I farm several crops, including peanuts, cotton,

8

soybeans, grain, sorghum and vegetables.

9

also represent the American Soybean Association as

10
11

And I

first vice president.
I was calling in today to support the

12

deregulation of the dicamba soybeans and the

13

dicamba glufosinate cotton in that they will both

14

help us in our operation to do a better job of

15

keeping the rotation that we have kept on our farm

16

for over 150 years.

17

As we go into the 21st century here, we

18

need more and more tools to make sure that we can

19

farm effectively and economically.

20

operation we have used dicamba since the 1970s and

21

have been able to do so safely and efficiently on

22

directed crops and as a burndown right next to

On our

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1

crops.

2

We have done this and done it with very little,

3

ever, if any, damage to any off-site crop or

4

the -- a nontarget crop.

5

So people recognize it's very susceptible.

As we go forward and as you listen to the

6

comments, I would also assert that when we have

7

off-site applications, you do have drift

8

volatility.

9

Texas, those disputes are handled amicably between

Many times in the high plains of West

10

the farmer and his neighbor because they

11

communicate with each other and they know the

12

problems.

13

court.

14

And they are quite often handled out of

I would just like to encourage you to

15

deregulate both the dicamba soybeans and the

16

dicamba glufosinate cotton so that we can have

17

these extra tools in our toolbox.

18

the needs of consumer not only in the United

19

States, in the world, that we are able to do it in

20

a highly efficient and sustainable way and prevent

21

the spread of weeds that are resistant to

22

different herbicides.

And as we meet

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1

I thank you for listening to my comment,

2

and I, once again, would hope to deregulate these

3

two systems.

4

MR. GEORGE:

5

And we do have another commenter ready to

6

comment.

7

Thank you, Wade.

Please go ahead.
MR. GAESSER:

This is Ray Gaesser, R-A-Y,

8

G-A-E-S-S-E-R.

My family and I grow soybeans and

9

corn in Southwest Iowa.

I also am currently

10

serving as president of the American Soybean

11

Association and both represent our farm and also

12

the association.

13

I would really like to speak in support

14

of deregulation of dicamba-tolerant soybeans and

15

cotton, you know, as farmers need and should have

16

choices to address weed-resistant issues.

17

are beginning to see weed-resistant issues on our

18

farm.

19

technology are important not only to us, but our

20

fellow soybean farmers around the country.

21

need -- as farmers we need multiple modes of

22

action, including dicamba-tolerant soybeans and

And we

So those new traits and these new

So we

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1

cotton to address those weed-resistant issues.

2

The new formulations of dicamba

3

substantially reduce volatility.

And farmers are

4

capable and are experienced using dicamba.

5

farm we have used dicamba within our crop --

6

cropping system for decades and have real personal

7

experience with that.

8

formulations that are out there and the new

9

technology that we have in our equipment, we are

On our

And with the new

10

even more capable of eliminating and reducing

11

off-target movement.

12

So with that, I would urge USDA to

13

regulate without restriction both dicamba-tolerant

14

soybean and dicamba- and glufosinate-tolerant

15

cotton.

16

opportunity to comment.

And I really thank you for the

17

MR. GEORGE:

Thank you, Ray.

18

We have another comment in the queue at

19

the moment.

If you're on the phone and you would

20

like to make a comment, please press one and then

21

zero on your touch-tone phone.

22

that -- if you would like to make a comment, we

And we will see

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1

will open the phone line for you and be glad to

2

take your comment.

3

And it looks like we have a commenter.

4

If you would like to make your comment, please go

5

ahead.

6

MR. VLIEGER:

Yes, this is Howard

7

Vlieger, H-O-W-A-R-D, V-L-I-E-G-E-R.

8

Northwest Iowa, and I am also a crop and livestock

9

nutrition advisor, working with diverse family

10

I farm in

farms all across the United States.

11

I am encouraging the USDA to step back

12

and take time to further analyze the dicamba

13

soybean and cotton system as well as the 2,4-D

14

crops.

15

part to rely predominantly on the chemical

16

industry and chemical use for weed control in crop

17

production.

It has not and will not ever be

18

successful.

And if USDA is incapable of

19

interpreting history that has proven this, they

20

are unbelievably shortsighted.

21
22

It is extremely shortsighted on USDA's

The 2,4-D and dicamba crops are going to
increase the amount of toxins that we are putting

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1

in our environment.

2

own USDA ARS research scientists that have already

3

manifested significant ill effects of

4

glyphosate-based herbicides in the soil, in the

5

environment and to crops.

6

this approach of weed control by herbicide is

7

ill-sighted and shortsighted.

8
9

USDA has research from their

And to further add to

There are effective means and mechanisms
of cover and breaking model crop cycles and

10

implementation of truly advanced natural

11

biological crop production systems that are vastly

12

reducing the weed pressure in fields of all types

13

of all crops.

14

the direction and the guidance of the chemical

15

industry and the genetically engineered industry

16

in how they are directing the crop production in

17

our country.

And USDA needs to quit following

18

We already have significant and growing

19

levels of glyphosate residue in virtually every

20

crop that is being produced in our country that is

21

inflecting significant harm on both livestock and

22

the human population.

USDA needs to be

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1

responsible and quit carrying water to the biotech

2

and chemical industry.

3

Thank you for listening to my comments.

4

And I urge USDA to say no until proper

5

environmental impact studies have been conducted

6

on the full adverse effects of this technology.

7

Thank you.

8

MR. GEORGE:

Thank you, Howard.

9

We have no another commenter in the

10

queue.

11

would like to make a comment, please press one and

12

then zero on your touch-tone phone; and we will

13

know you want to comment.

14

If you are on the phone listening in and

MS. ISHII-EITEMAN:

We will open your line.
Hello, am I on?

15

Hello?

16

M-A-R-C-I-A, I-S-H-I-I - E-I-T-E-M-A-N.

17

Pesticide Action Network.

18

express concerns with the dicamba-resistant cotton

19

and soybean system.

20

Hi, this is Marcia Ishii-Eiteman,
I am from

And I am calling to

As been mentioned previously and is, in

21

fact, reported in your own USDA's draft

22

Environmental Impact Statement, the agency, based

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1

on industry studies themselves, predict an 88-fold

2

increase in the use of dicamba compared with

3

current practice.

4

volatile, can drift for miles.

5

formulation of new formulations that are intended

6

to be less volatile aside, we also know from many

7

years of experience that spray drift as well as

8

volatilization drift happens and can devastate

9

vulnerable crops and also affect adjacent

10

And we know it is highly
Questions of

ecosystems and entire landscapes.

11

The other thing that's particularly

12

important here is that dicamba is 75 times more

13

toxic to plant life than the glyphosate in

14

Roundup.

15

with the extensive increase in dicamba use will

16

create situations that we really have not

17

experienced before.

And as a result, the -- combining that

18

We recognize and respect farmers who have

19

been using dicamba over the years, their attempts

20

to limit off-target movement.

21

intentions aside, off-target movement does happen.

22

Some of it is just inevitable.

We know that best

You have got to

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1

call in the sprayer.

2

appointment.

3

next chance of rescheduling it is just not going

4

to be very convenient when you're trying to manage

5

your entire farm.

6

as wind conditions change.

7

You have got to make an

The wind picks up.

You know, the

So sprays go ahead with -- even

The problem with how very toxic this is

8

to other plants is that it puts specialty crop

9

growers at extreme risk.

Grapes, tomatoes, beans,

10

wheat, corn, peanuts, fruit trees and all the

11

nonresistant corn, cotton and soybeans out there

12

are extremely sensitive to dicamba.

13

concerned that this expected surge in dicamba use

14

and coupled with the drift damage is very likely

15

to set back farmers' efforts.

16

We are very

It can cause -- and we have heard farmers

17

reporting cases of drift that have wiped out their

18

crops and are causing some to be on the verge of

19

abandoning their farms.

20

farmers' efforts to diversify their farm at a time

21

where with climate change, with increasing

22

environmental stresses, with droughts and floods,

It would also set back

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1

the importance of diversifying farm landscapes is

2

very high at this point in order to both have a

3

healthy, environmentally sustainable farm and to

4

have a diversity of crops.

5

diversify their farms, introduce perennials that

6

can help with soil health and erosion and creating

7

pollinator-friendly habitat, these are all goals

8

that are increasingly raised up on farmers'

9

agendas.

10

So farmers' efforts to

And as we look toward the future of

11

really building a sustainable farming system,

12

these are the kinds of shifts that we are seeing

13

farmers trying to take and wanting to take to

14

deregulate and put into the mix the

15

dicamba-resistant crops right on the heels of --

16

because it looks like its the 2,4-D resistant

17

crops come onto the market, is really going to be

18

a serious setback to these efforts of farmers to

19

diversify and those farmers who are already

20

growing crops and trying to make a living, make a

21

business, keep their communities going with

22

their -- especially with their fruit and vegetable

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production.

2

So we would urge USDA to refrain from

3

deregulating the dicamba-resistant cotton and

4

soybean seeds.

5

proactive position towards prioritize a search in

6

and extension of less chemical intensive,

7

integrated weed management practices to support

8

our commodity growers with those less chemical

9

intensive, less damaging to a neighboring farmer's

10
11

We would rather see USDA take a

tugi.
There is cutting-edge research coming out

12

of Penn State, out of Ohio State, out of many

13

places on successful integrated weed management

14

that does rely on these kinds of chemistries, but

15

that includes instead Integro cultivation, crop

16

rotation, cover cropping in combination with soil

17

building practices and limited tillage, which

18

really the state-of-the-art science that is coming

19

out on that now is showing us that limited tillage

20

systems can actually have both higher

21

productivity, comparable profits and really

22

improve soil health and prevent some of these soil

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1

erosion problems that have been raised in the past

2

within -- that are definitely a problem with a

3

much more aggressive tillage.

4

So there are a number of alternatives.

5

We do not need to go this way.

USDA has a

6

responsibility and a broader agency mandate to

7

keep in mind the bigger picture for all of our

8

farmers and take steps to protect the economic

9

success and well-being of our specialty crop

10

growers as well as support the vibrancy and

11

healthy environment of rural communities.

12

If we lose these farmers, both the

13

specialty crop growers or even commodity growers

14

that are trying to diversity their farms, organic

15

farmers, conventional farmers, if we lose those,

16

we are just going to see the further economic

17

erosion and demise of our already stressed rural

18

communities.

19

USDA would not want to see and would join us in

20

really wanting to take steps to protect the -- and

21

strengthen and rebuild our rural communities

22

rather than introduce technologies that could

And that is something that I am sure

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1
2

really have the opposite effect.
So I thank you for your time and

3

consideration.

4

from deregulating these 2,4-D and

5

dicamba-resistant crop technologies and to instead

6

lead double efforts to provide commodity growers

7

with cutting-edge research and extension of less

8

chemical intensive, ecological, integrated weed

9

management practices.

10

We really urge USDA to refrain

MR. REDICK:

Thanks very much.
I'm counsel to corn and

11

soybean growers and a former president of the

12

Council For Agricultural Science and Technology

13

and a current board member.

14

clear to me that we need these crops to prevent

15

weed resistance becoming a real problem.

16

for spray drifts, as an attorney for growers, I

17

can agree with Wade, who mentioned these are often

18

resolved amicably.

19

And it is pretty

And as

Also it shouldn't deny organic growers

20

certification to have drifts.

And if the

21

certifier is denying, the problem is with the

22

certifier and not with the drifts.

It should not

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1

deny certification of the organic program.

2

you can hear me.

If not, I'm not sure what to do.

3

(Brief pause.)

4

MR. GEORGE:

Thomas Redick, are you

6

MR. MILLER:

Who did you ask for?

7

MR. GEORGE:

Thomas Redick.

8

OPERATOR:

5

9

I hope

there?

Okay.

Ladies and gentlemen,

if you want to make a comment, please press one

10

and then zero.

11

queue, and we will take you in the queue as we

12

were doing before.

13

patience on bearing with us with our technical

14

difficulties.

15

and you're on.

16

And then you will be placed in the

Again, we appreciate your

But again, we are back on the air
Okay.

MR. GEORGE:

We had a commenter who was

17

in the process of commenting.

18

would like to please continue, I didn't quite get

19

your name.

20

Redick.

21
22

If that commenter

I think it was either Tom or Don

He's gone.
So is there another person who would like

to comment, please go ahead.

And we apologize for

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1
2
3
4

the technical problems here.
MR. MILLER:

But please go ahead.

Are we ready to take other

comments or is this just a question-only spot?
MR. GEORGE:

5

make comments.

6

please go ahead.

No.

This is the time to

And if you have a comment to make,

7

MR. MILLER:

Yes, I have a comment.

8

MR. GEORGE:

Please go ahead, give us

9
10
11

your name and spell your name, please, and give us
your comment.
MR. MILLER:

Victor Miller, V-I-C-T-O-R,

12

M-I-L-L-E-R.

13

opportunity to express my support for the

14

deregulation of dicamba-tolerant soybeans and

15

cotton without restriction as was recommended by

16

the draft Environmental Impact Statement on

17

dicamba-tolerant technologies.

18

And I want to thank you for the

As I stated, my name is Vic Miller.

I

19

have been growing corn and soybeans in Oelwein,

20

Iowa, for 41 years.

21

farmers as past chairman of the U.S. Grains

22

Council, an organization that develops export

I also have served our U.S.

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1

markets for U.S. barley, corn, sorghum and their

2

processed products.

3

firsthand about the importance of meeting the

4

growing demand for these products in the global

5

marketplace.

6

This is where I learned

As I have previously commented, the use

7

of dicamba is not new.

It has been used by

8

farmers for over 40 years in the U.S. and

9

continues to be effective on major broadleaf

10

weeds.

11

very successfully on more than 250 million acres,

12

including corn, wheat, pasture and rangeland as

13

well as other cropland.

14

and municipal parks are also among the many users.

15

Over the past ten years, it has been used

Homeowners, golf courses

The equipment, the knowledge and the

16

desire to use the product in a responsible manner

17

by the agricultural community already exists.

18

intention is to leave a safe, wholesome

19

environment for my children and grandchildren as

20

they are the most valued things in my life.

21

that end, I have upgraded my sprayers to

22

accommodate this technology, as have most of the

My

To

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1
2

agricultural producers in my area.
We are also well aware of sensitive

3

crops, many of which we grow in our community.

4

are all licensed and go through rigorous

5

educational courses yearly to be better stewards

6

of the land.

7

modes of action to limit the problem of herbicide

8

resistance.

9

addition to today's available weed control options

10
11

We

Growers across the U.S. need more

Dicamba tolerance would be a valuable

to maximize yield potential.
No till and reduced tillage are very

12

important conservation measures in my operation.

13

If weed resistance increases without additional

14

modes of action in new products to control that

15

resistance, then I will be forced to increase

16

tillage, which will have a very negative impact on

17

those conservation measures not only for me, but

18

for most of my counterparts as well.

19

technology, I am left with few viable alternatives

20

to control weeds in my field, resulting in poor

21

yields, which means I produce less on these acres.

22

Without this

This means I get paid less for my crop, I

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1

deliver fewer beans to my local elevator; and this

2

cascade of impact carries on down the line.

3

elevator has fewer beans and more weed seeds or

4

foreign material that end up at the local crush

5

plants.

6

and so is the bean quality reduced that is made

7

into animal feed, soybean oil, biodiesel and food

8

ingredients, just to name a few.

9

these things either end up used domestically in

10

many applications or sold to foreign buyers for

11

their use in the international market.

12

The

Those plants have reduced profitability

And ultimately,

Now, not only has my profitability been

13

impacted, but very possibly hungry people around

14

the world will find their livelihood more tenuous.

15

Having the ability to incorporate dicamba-tolerant

16

soybeans into my weed management program allows me

17

to reduce the dependence that I have on ALS and

18

PPO herbicides.

19

program for weed resistance management while

20

preserving the value of glyphosate, a herbicide

21

that is still very effective on my farm.

22

And it would offer a proactive

In closing, restricting the use or

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1

denying access to these new technologies would

2

have a negative effect on U.S. farm operations.

3

It would reduce weed control capabilities,

4

increase costs, reduce farm returns, impact the

5

U.S. producers' ability to meet foreign market

6

demand and unfortunately reverse conservation

7

tillage adoption.

8

and I urge you to fully deregulate it.

9

thank you for taking these comments.

We all need this technology,
And I

10

MR. GEORGE:

Thank you, Victor.

11

And I want to apologize to all for our

12

technical issues, which we appear to have ironed

13

out now.

14

the Washington area here just before 6:00.

15

may have had something to do with it.

16

know.

17

There is a major storm that went through
That

We don't

So thank you for your patience.
And I'm understanding we have one person

18

in the queue who would like to make a comment.

19

So, commenter, please go ahead.

20

MR. BROTEN:

Can you hear me?

21

MR. GEORGE:

Yes, we can.

22

Hello?

Please give us

your name and spell your name and then your

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comment, please.
MR. BROTEN:

Okay.

My name is Jim

3

Broten, J-I-M, Broten, B, like in boy, R-O-T-E-N.

4

I would like to thank you for the chance to

5

comment today.

6

here in North Dakota with my wife Pat and my son.

7

We operate a farm in North Dakota, producing corn,

8

soybeans and wheat as well as barley, canola,

9

feeds, sunflowers, some potatoes and livestock,

10

I am a third-generation farmer up

beef livestock.

11

I have been involved in agriculture all

12

my life and put my first crop in in 1964, and a

13

past chairman of the U.S. Grains Council, past

14

chairman of North Dakota Barley Council, a member

15

of the North Dakota Grain Growers Association,

16

past president of North Dakota Crop Improvement

17

Association and is very active in regional

18

community affairs and the university affairs.

19

I fully support the option to deregulate

20

dicamba-tolerant soybeans and cotton, MON 87708

21

and MON 88701, with all restriction as recommended

22

by the draft Environmental Impact Statement on

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1

dicamba-tolerant technologies.

2

comments previously that supported deregulating

3

the technologies that are worth repeating it as

4

USDA considers its final regulatory actions

5

regarding these technologies because they will

6

impact my future and that of my friends and family

7

and state.

8
9

I had made

Weed control issues are as challenging as
they have ever been.

Waterhemp, kochia,

10

lambsquarter and common ragweed continue to

11

compete with our crops further, water, sun and

12

yields.

13

weeds could decrease our land value and our farm

14

yield and our livelihood.

15

protect our yields, we need new tools; and the use

16

of dicamba in soybeans would provide excellent

17

additional mode of action to add to our limited

18

and valuable tool set.

19

If left without effective control, these

To fight these weeds to

Using dicamba and dicamba-tolerant

20

cropping system can be a proactive measure to use

21

on my farm.

22

dicamba-tolerant crop system, weeds will become

Without weed management tools such as

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1

more difficult to control; and there will be

2

greater selection for glyphosate resistance and

3

PPO resistance, one of the other effective

4

herbicide tools we have.

5

together with other effective mode of action such

6

as glyphosate with dicamba-tolerant soybeans will

7

protect not only glyphosate, but PPO herbicide and

8

even newer herbicide such as the bleachers for

9

sure, fells, mesotrione that are commonly used --

10
11

Dicamba, which when used

which are commonly used in soybean production.
We also compete in the global marketplace

12

for the crops we harvest.

13

approve or causes further delay in this new tool,

14

it will financially harm my farming operation and

15

restrict my ability to compete against growers in

16

other parts of the world who are able to use these

17

technologies such as these to control weeds and

18

protect yield.

19

If USDA does not

I urge the USDA to do their part of

20

approval of dicamba-tolerant crops without delay

21

or any restrictions as recommended in the draft

22

Environmental Impact Statement so that U.S.

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1

farmers may have access to important new

2

advancements in farming that allow farmers such as

3

me and my son and my grandson to have tools we

4

need to continue fighting weeds, raising

5

vulnerable crops and be able to pass our operation

6

onto the fifth and sixth generation.

7

I have a grandson named Brady Fulton, who

8

is already at three years old actively interested

9

in farming.

His mother said it must be in the

10

genes because he isn't old enough to understand

11

farming.

12

We need all the tools that can be made available

13

to us to continue our farming.

14

much.

And his dad, his granddad just laughed.

Thank you very

Submitted by Jim Broten.

15

MR. GEORGE:

Thank you, Jim.

16

Looking at our list, we have no one who

17

is in the queue at the moment.

I will remind you

18

to just press one and then zero on your telephone

19

keypad if you would like to make a comment.

20

will see that, and we will open your mike and be

21

glad to take your comment.

22

commented and would like to elaborate on your

We

If you already

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1

comment, we have time for that.

2

your extended comment, if you will.

3

And so we welcome

So having said that, we are going to take

4

a short break.

5

we will be coming back on every few minutes just

6

to check in.

7

that anyone would like to make a comment, just hit

8

one, then zero.

9

take that comment.

10

patience.

You should hear some music.

And

And in the meantime, at any time

We will see that, and we will
But thank you for your

We will be back in a few minutes.

11

(Brief pause.)

12

MR. GEORGE:

We still have no one in the

13

queue to comment.

14

invite anyone who may be on the phone listening in

15

to please, if you would like to make a comment or

16

elaborate on a previous comment, you're welcomed

17

to do so.

18

phone, and we will see that; and we will be able

19

to receive your comment.

20

So I just wanted to once again

Press one, then zero on your touch-tone

So having said that, I don't see any such

21

commenter in the queue.

22

again.

So we will break away

We will come back every few minutes.

In

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the meantime, you can break in at any time and let

2

us know that you would like to make a comment; and

3

we will be happy to take that comment.

4

be back in a few.

So we will

Thanks so much.

5

(Brief pause.)

6

MR. GEORGE:

Okay.

We have a commenter

7

on the line.

8

name, spell your name and go ahead, we will be

9

glad to take your comment.

10

So, commenter, if you would say your

Apparently, our commenter dropped off.

11

In that case, we will take another pause.

12

listening in who cares to make a comment, press

13

one, then zero on your telephone keypad.

14

see that and be glad to take your comment.

15

We will

We have a commenter who has just entered

16

the queue.

17

please.

18

Anyone

If you would make your comment,

Commenter, are you there, please?

19

possible that your phone may be on mute?

20

Commenter, we are not hearing a comment.

21

are not hearing a comment.

22

trying to comment, we are not hearing it.

I'm sorry.

Is it

So we
If you're
Perhaps

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1

you hit one, then zero again if we missed it

2

somehow.

3

There is still no commenter on the queue.

4

So we will take another pause, but we will be

5

happy to break in at any time.

6

like to make a comment, press one, then zero.

7

Thanks so much.

So if you would

We will be back in a few minutes.

8

(Brief pause.)

9

MR. GEORGE:

So we seem to have a

10

commenter on the line.

11

your comment.

12

your name for us, please.

13

with a particular group and go ahead and make your

14

comment, please.

15
16
17
18
19
20

If you would say your name, spell

MR. PETERSEN:
Petersen.

So we are ready to take

Let us know if you're

Okay.

My name is Kyle

I'm a crop farmer from Minnesota.

MR. GEORGE:

Go ahead, Kyle.

Would you

spell your name for us, please, Kyle.
MR. PETERSEN:

Absolutely.

Kyle,

K-Y-L-E, P-E-T-E-R-S-E-N.

21

MR. GEORGE:

22

MR. PETERSEN:

Thank you.
Okay.

Go ahead.

My name is Kyle

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1

Petersen.

2

farming near Murdock, Minnesota, my entire life.

3

My wife Paula and I have two sons, Brett, age 18;

4

Hunter, age 15.

5

our family farming operation consists of sugar

6

beets, corn, soybeans, sweet corn, peas and

7

alfalfa.

8
9

I'm 47 years old and have been crop

Crops currently being raised in

I was asked to join the dicamba advisory
council for the last two years, comprised of

10

academics, industry growers and commodity

11

organizations that worked with Monsanto to offer

12

input on the development and commercialization of

13

the Roundup Ready Xtend cropping system.

14

calling in today to offer my support for the

15

option to deregulate dicamba-tolerant soybeans and

16

cotton, MON 87708 and MON 88701, without

17

restriction as recommended by the draft

18

Environmental Impact Statement on dicamba-tolerant

19

technologies.

20

I am

One of the greatest challenges as a

21

farmer is with controlling weeds.

I know that

22

growers need weed management technologies with

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1

proven control of a broad spectrum of weeds like

2

the new Xtend technology.

3

becomes more prevalent, we feel that the arsenal

4

of tools at our disposal is limited to effectively

5

prevent and manage weed resistance.

As weed resistance

6

Our Minnesota weed control experts tell

7

us that the best way to address weed resistance

8

besides good management practices is using a

9

variety of weed management tools.

The

10

dicamba-tolerant system will provide an additional

11

mode of action while expanding the dicamba weed

12

control window from burndown in planting to

13

in-crop applications.

14

We currently use Roundup Ready sugar

15

beets but need to add additional modes of action.

16

The added dicamba tolerance will help us better

17

manage weed resistance so we can preserve and

18

maintain the value of our land.

19

but the use of dicamba as part of the Roundup

20

Ready Xtend crop system will help us preserve the

21

value of existing pre- and post-emergent

22

herbicides, which continue to bring significant

Not only that,

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1

value.

2

a wide variety of vegetables.

3

In Minnesota we produce many crops such as

With regard to concerns about dicamba

4

off-site movement, I believe growers have

5

experience with various cropping systems and are

6

in a good position to prevent or minimize drift.

7

We follow label instructions very closely, go

8

through regular training and invest in modern

9

technology that enable us to minimize drift.

10

I have personally seen the new dicamba

11

formulations in field trials, and the potential

12

for drift and volatility have been significantly

13

reduced.

14

best management practices can make it possible for

15

all types of growers to coexist and prosper.

Newer dicamba formulations along with

16

Access to new weed management tools such

17

as dicamba-tolerant technologies is important to

18

me as a farmer.

19

timely fashion toward full deregulation of

20

dicamba-tolerant technologies.

21

will be harmful to U.S. agriculture.

22

for reviewing and considering my comments.

I urge USDA to proceed in a

Further delays
Thank you

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1

Respectfully yours, Kyle Petersen.

2

MR. GEORGE:

Thank you, Kyle.

3

MR. PETERSEN:

4

MR. GEORGE:

You're very welcome.
As we look at our list,

5

there is no one else waiting to comment.

6

once again, we will invite anyone on the phone who

7

would like to comment to please press one, then

8

zero on your telephone keypad.

9

that you would like to comment and be glad to take

10
11

And so

And we will see

your comment.
Seeing that there are none at the moment,

12

we will take a break, pause for a bit.

And we

13

will be checking back in every few minutes.

14

you all for your patience, and we will see you in

15

a few minutes.

Thank

Thanks.

16

(Brief pause.)

17

MR. GEORGE:

And we are back.

Looking at

18

our list, we still don't have anyone in our queue

19

to make a comment.

20

comment, again, I invite you to do so by pressing

21

one, then zero on your touch-tone phone.

22

will pause a second here to see if anyone takes me

If you would like to make a

And we

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1

up on that.

2

will take another pause and let you know we will

3

be here till 8:00 and happy to take any comments

4

right up until that time.

5

And it seems that no one has.

We

So having said that, I also would invite

6

those who may have commented already and who might

7

like to elaborate on their comments, you certainly

8

have the opportunity to do so.

9

there was a gentleman whose name I think was Don

And in particular,

10

Braddock or something that sounds like that.

11

never quite got it because we lost him.

12

when we had our technical problems.

13

invite you to please let us know that you would

14

like to finish your comment.

15

you to go ahead and take that.

16

We

That's

We would

We would like for

So having said that, I don't see any

17

commenters in the queue.

So we will take another

18

pause, and we will check back in every five

19

minutes or so.

Thanks so much.

20

(Brief pause.)

21

MR. GEORGE:

22

go ahead with your comment.

Spell your name, please, and

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1

MR. JONES:

Yes.

My name is John Jones.

2

I'm a third-generation farmer who is -- I have

3

been farming since 1982 on a family farm.

4

in the Lubbock area, which is in the panhandle

5

area of Texas.

6

cotton, 2000 acres of wheat, and we have a

7

cow-calf operation.

8

irrigation.

9

have limited irrigation, center pivot irrigations.

10

We are

I farm approximately 2000 acres of

We are under limited

Mostly I'm a dryland farmer.

But we

The last three years have been really

11

rough on us.

12

for the last three years.

13

year we have had more rainfall, and it has really

14

helped our bottom line.

15

We pretty much have record drought
But fortunately, this

A part of my life is my family, and I am

16

blessed with a beautiful wife and a beautiful

17

daughter.

18

University here at Lubbock.

19

graduating in December.

20

college-aged students, you realize what the

21

tuition has done over the years.

22

going to finish in December.

She is a senior this year at Texas Tech
Hopefully she will be

And if you all have

So hoping she is

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1

Thank you all for this opportunity just

2

to visit with you.

3

deregulate dicamba-tolerant soybeans and cotton

4

without restriction as recommended by the draft

5

Environmental Impact Statement on dicamba-tolerant

6

technologies.

7

that as a Texas farmer, cotton farmer, that we as

8

growers need weed management technologies with a

9

proven efficiency over broad spectrum of weeds

10

I fully support the option to

And I can tell you with confidence

like these two Monsanto products, 87708 and 87701.

11

Particularly this year as weed resistance

12

has become more prevalent, we just feel like that

13

we need more in our arsenal of tools that we can

14

use to effectively prevent and manage our weed

15

resistance, the weeds that we have.

16

especially with our increased rainfall, we have

17

already witnessed a rapid increase in herbicide

18

resistance, Palmer pigweed, careless weed or

19

pigweed here in West Texas.

20

us it is the best way to address weed resistance

21

in addition to good management practices.

22

This year

And weed science tell

It is usually a variety and using a

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1

variety of -- dicamba-tolerant system, we feel

2

like we are providing additional mode of action.

3

While expanding the dicamba, we control window

4

from burndowns and also planting in minimum crop,

5

no-till crop applications.

6

Water and soil conservation are the two

7

most key components for our area for West Texas

8

farmers.

9

sustainability of my farm, and I believe that

I'm very concerned with the

10

dicamba-tolerant technologies will enable growers

11

to continue to be good stewards of the land.

12

Compared with -- to some weed control programs,

13

this system may result in few herbicide

14

applications.

15

Glyphosate-tolerant crops make no tillage

16

cultivation possible.

This has been a tremendous

17

advance in sustainable farming practices, thanks

18

to the prevention of erosion, topsoil erosion,

19

reduced fuel emissions and better water

20

conservation.

21

help us better manage these resistant weeds so

22

that we can preserve the value of our land.

The added dicamba tolerance would

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I know and I realize that some

2

individuals, some are very concerned about

3

off-site movement or herbicide drift.

4

believe that growers, that we have the experience

5

with various cropping systems; and we are in a

6

good position to prevent and minimize drift.

7

do our best.

8

closely.

9

we do our best to invest in modern technology.

And I

We do follow label instructions very

We participate in regular training, and

10

It's simply just new spray, spray tips,

11

maintaining our equipment to minimize drift.

12

We

Newer dicamba formations along with

13

better management practices can make it possible

14

for all types of growers to coexist and prosper.

15

I feel it is very important to let farmers have

16

access to new weed management tools such as

17

dicamba-tolerant technology, and I would urge the

18

USDA to proceed in a timely fashion towards full

19

deregulation of dicamba-tolerant cotton and

20

soybeans.

21

opportunity to share with you all this evening and

22

thank you for reviewing and considering my

And I really do appreciate just the

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1

comments.

Thank you very much.

2

MR. GEORGE:

Thank you, John.

3

So looking at our queue, we have no other

4

commenters at the moment.

So I will invite anyone

5

who may be listening in who would like to make a

6

comment to please press one, then zero.

7

that none are in the current queue, we will break

8

away now for a few moments.

9

few minutes.

Seeing

We will be back in a

We will be here until 8:00 Eastern

10

time.

And so we welcome your comments on the

11

draft EIS for dicamba-tolerant cotton and soybean.

12

We will be back in a few.

13

(Brief pause.)

14

MR. GEORGE:

Okay.

Thanks so much.

We are back, and we

15

have no one waiting in line to make a comment on

16

the draft EIS.

17

listening in who might want to make a comment to

18

do so, though we will remind you that we will be

19

here till 8:00 Eastern time to take your comment.

20

So if you would like to make a comment, press one,

21

then zero on your phone.

22

and we will invite you to comment at that time.

However, we invite anyone who is

And we will see that,

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1

However, not seeing anyone in the queue,

2

we are going to pause again.

3

every four or five minutes or so just to check in

4

and let you know we are here and that we are ready

5

to take comments.

6

few minutes.

Thanks so much.

7

(Brief pause.)

8

MR. GEORGE:

9

We will come back

See you in a

And we are back.

This is

the public comment meeting on a draft EIS for

10

dicamba-tolerant cotton and soybeans.

11

being with us.

12

comment if you care to by pushing one, then zero

13

on your touch-tone phone.

14

queue at the moment.

15

will be here till 8:00 tonight, which is about 12

16

or 13 minutes from now.

17

you have a comment you would like to make, please

18

do so.

19

Thanks for

And I would encourage folks to

We have no one in the

I will remind you that we

So we encourage you if

And I don't see anyone in the queue, and

20

so we will break away.

But we keep our eyes on

21

this computer screen.

22

then zero, we will know you want to make a

And so if you press one,

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1

comment.

We will come right back on to listen to

2

that comment.

3

going to pause once again, and we will be back in

4

a few minutes.

So thanks so much.

And we are

Thanks.

5

(Brief pause.)

6

MR. GEORGE:

7

about five minutes of 8:00.

8

remind folks if you would like to make a comment,

9

we are going to be here for five more minutes.

And we are back.

And I just want to

10

And we would welcome your comments.

11

one, then zero on your keypad.

12

that, and we will open your mike.

13

And it is

Just press

And we will see

So being that there is no one there, I

14

will remind you that if you would like to make a

15

comment by going to regulations.gov, you can make

16

a written comment there through September 25.

17

Just go to regulations.gov and put "dicamba" in

18

the search box.

19

make your comment.

20

It will take you to the docket to

And seeing that there is no one in the

21

queue, we are going to break away again.

And we

22

will come back at 8:00 just to say farewell.

But

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if you would like to make a comment, please let us

2

know.

Thanks so much.

3

(Brief pause.)

4

MR. GEORGE:

Back in a few.

I do have one commenter in

5

the queue.

6

name, spell your name and give us your comment,

7

please.

8
9

So commenter, if you would say your

MR. SMITH:
commented before.

This is Steve Smith.
S-T-E-V-E, S-M-I-T-H.

I
I just

10

wanted to do just a quick follow-up to a couple of

11

comments that had been made that farmers are good

12

at minimizing drift.

13

minimizing drift if the conditions are right.

14

we are very concerned that the cumulative effects

15

of 130, 140 million acres of dicamba floating

16

around is going to make that very difficult.

17

Farmers are good at
And

And also the comment that quite often

18

these cases are handled out of court when there is

19

damage, that may be true.

20

not good enough if you're the victim of an

21

off-target movement that wipes out your specialty

22

crop.

But quite often it is

So I just wanted to make those follow-up

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1

comments from others that were made, and I

2

appreciate the opportunity.

3

MR. GEORGE:

4

And if there are other folks who would

Thank you.

Thank you, Steve.

5

like to make a comment, we just have a couple

6

minutes left.

7

and then zero on your telephone keypad.

8

seeing none, we shall take a pause and we will be

9

back at exactly 8:00 to say good night.

10

Please let us know by pressing one
And

Be right

back.

11

(Brief pause.)

12

MR. GEORGE:

I would like to thank

13

everyone who participated today in our virtual

14

meeting.

15

will be available on our Web site,

16

www.aphis.usda.gov/aphisvirtualmeetings within a

17

couple of days.

18

survey there.

19

survey.

20

better in the future.

21
22

The PowerPoint of this virtual meeting

We will also post a link to a
Please click on it and complete the

It will help us make these meetings

MS. SERRELS:

Please keep in mind that

our public comment period is open until September

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1

25.

2

meeting, you can still comment up until that date

3

at regulations.gov and by entering "dicamba" in

4

the search box.

5

While this is the only virtual public comment

MR. GEORGE:

Thanks again for joining us.

6

This concludes our virtual public comment meeting.

7

Thanks everybody.

8

(Whereupon, at 8:00 p.m., the proceedings

9

were concluded.)

10
11

* * * * *

12
13
14
15
16
17
18
19
20
21
22

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1
2

CERTIFICATE OF NOTARY PUBLIC
I, KARLENE CAMPBELL, the officer before whom

3

the foregoing meeting was taken, do hereby certify

4

that the meeting was taken by me in stenotype and

5

thereafter reduced to typewriting under my

6

direction; that said meeting is a true record of

7

the proceedings; that I am neither counsel for,

8

related to, nor employed by any of the parties to

9

the action in which this meeting was taken; and

10

further, that I am not a relative or employee of

11

any counsel or attorney employed by the parties

12

hereto, nor financially or otherwise interested in

13

the outcome of this action.

14
15

______________________________
KARLENE CAMPBELL
Notary Public in and for the
State of Maryland

16
17
18

My commission expires:

19

April 10, 2015

20
21
22

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Virtual Public Meeting - GE Cotton & Soybeans Resistant to Dicamba 09-11-2014
Page 1
$
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Page 2
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besides 18:18 22:4
57:8

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Page 3
best 18:17 28:18
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3:14,17,21,22

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controlled 28:3
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corns 15:7
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costs 48:4
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