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May 27 , 2014
Mr. Michael Walsh Environmental Protection Agency (EPA) Office of Pesticide Programs Biopesticides and Pollution Prevention Division (7511P) / Registration Division (7505P) 1200 Pennsylvania Ave. NW Washington, D.C. 20460

- 0001 Dear Mr. Walsh : We, the undersigned institutional investors, representing $47 b illion in assets under management and led b y the Interfaith Center on Corporate Responsibility (ICCR) , are writing to express our concerns about the use of 2,4

- dichlorophenoxya cetic acid (2,4

- D) on new genetically engineered (GE) corn , cotton and soy bean crops designed to survive repeated spray ing of the herbicide. We are disappointed b y the recent news of the Agency’s proposed decision to approve this new v ersion of 2,4

- D. **We ask that, under the proposed new use registrations for 2,4 -**  **D -**  **resistant crops, EPA incorporate widely accepted estimates for significantly increased use and**  **altered use patterns of 2,4 -**  **D.** As investors, we are conscious of the long

- term risks associated with these products and believe it is prudent to await thorough assessment before releasing these products to the market. Without adequate understanding of the environmental consequences and health impacts of the 2,4

- D resistant crops and subsequent increase in herbicide use , we cannot be sure that our companies are sufficientl y considering potential risks of these products to human health and the environment . As a regulator responsible for understanding the effects of herbicide use on humans and the environment , the U.S. Environmental Protection Agency (EPA) must carefully consider its role in determining the use, sale, and labeling of 2,4

- D and make a thorough and accurate assessment of the potential impacts. The EPA has reported that 2,4

- D is the seventh largest source of dioxins in the U nited S tates
. 2,4

- D is a toxic herbicide associated with serious health risks. The 2,4

- D resistant crops will also, like their predecessors, lead to much greater use of even more dangerous chemicals, the development of more herbicide

- resistant weeds, destruction and genetic contamination of neighboring crops, and severe economic impacts on other farmers. As shareholders, we engage seed and chemical companies, including Dow AgroSciences, about risks and impacts related to herbicide utilization with its seed products on human health and the environment. Deregulation of Dow’s 2,4

- D resistant crops will drive up use of 2,4

- D, an antiquated and dangerous herbicide known to drift beyond target crops. Shareh olders are aware that Dow’s Enlist Duo system utilizes a less volatile form of 2,4

- D, however this does not2

mitigate its inherentl y dangerous characteristics linked to causing cancer, Parkinson’s disease, endocrine disruption, and reproductive problems in humans. We ask that as you consider Dow’s 2,4

- D New Use Registration Applications for the new uses of 2,4

- D choline salt that will be associated with the new 2,4

- D resistant crops, you consider the mounting evidence about the risks of increased and compounded 2,4

- D use . We join more than half a million individuals and organizations, including medical doctors and public health scientists, farmers, food and health experts, consumers, environmental organizations and many others in calling on you to undertake a thorough assessment and complete your findings prior to undertaking any regulatory changes. Noted agricultural scientist Charles Benbrook projects that widespread planting of Dow’s Enlist corn alone could trigger as much as a 25

- fold increase in use of 2,4

- D, from an estimated 4.2 million pounds at present to over 100 million pounds by 2019. The consequent increase of the use of further herbicide resistant crops is troubling for ecos ys tems and water supplies . As a result, Monsanto and other firms that manufacture pesticide s are focusing the bulk of their Research and D evelopment on new crops eng ineered with resistances to even more herbicides. Monsanto is awaiting approval of so ybean s eeds that are resistant to dicamba and gl yphosate, with triple herbicide resistant cor n and cotton in the pipeline. The instructions that the seed companies provide to end

- users is dependent on the findings of the EPA. Your role in setting the conditions for the herbicide’s use and placement in the labeling instructions that a user must follow are critical for protecting the health of farmers and the environment. We encourage you to use caution and restraint when establishing these instructions. Further, the MSDS sheet for Enlist Duo is alarming:

 **Environmental precautions:** Prevent from entering into soil, ditches, s ewers, waterway s and/or groundwater.  **Personal precautions, protective equipment and emergency procedures:** Is olate area. Keep unnecessary

and unprotected personnel from entering the area.  **Potential Health Effects (extracted from listing)** o **Eye Contact:** May

c ause moderate eye irritation. May cause slight corneal injury

. o **Skin Contact:** Brief contact may cause slight skin irritation with local redness. May cause drying and flaking of the skin. o **Skin Absorption:** Prolonged skin contact is unlikely to result in abs orption of harmful amounts. o **Skin Sensitization:** Has demonstrated the potential for contact allergy in mice. o **Inhalation:** No adverse effects are anticipated from single exposure to mist. Based on the available data, narcotic effects were not observed. Base d on the available data, respiratory irritation was not observed. o **Ingestion:** Lo w toxicity if swallowed. Small amounts swallowed incidentally as a result of normal handling operations are not likely to cause injury ; however, swallowing larger amounts may c ause injury

. o **Effects of Repeated Exposure:** For similar active ingredient(s). 2,4

- Dichlorophenox ya cetic acid. In animals, effects have been reported on the3 following organs: Gastrointestinal tract. Kidney . Liver. Muscles. Observations in animals include: Gastrointestinal irritation. Vomiting. For the minor component(s): In rare cases, repeated excessive exposure to propylene gl yc ol may cause central nervous s ys tem effects. o **Birth Defects/Developmental Effects:** For similar active ingredient(s). Has been toxic to the fetus in laboratory animals at doses toxic to the mother. How can deregulation of 2,4

- D corn , cotton and soy align with EPA’s announced proposed changes to the agricultural Worker Protection Standard (WPS) to increase protections from pesticide exposure for the nation's 2 million agricultural workers and their families and EPA’s commitment to Environmental Justi ce? Farmers are deeply

concerned that Dow’s Enlist corn , cotton and so y system will threaten their crops. 2,4

- D is known to drift

— directl y and through volatilization

— which poses a very real threat to rural economies and farmers growing crops not engineered to withstand application of these potent chemicals. 2,4

- D drift is already responsible for more episodes of crop injury than any other herbicide, and its vastly increased use promises still more damage to non - 2,4

- D resistant crops like so ybeans, cott on, vegetables and fruit. This chemical is used because Roundup Ready GE crops have caused an epidemic of gl yphosate

resistant weeds, so another herbicide is needed. Monsanto's RoundUp Ready seed line is responsible for a dramatic rise in gly phosate

- resi stant “superweeds,” which have afflicted millions of acres of farmland across the Midwest and South. Dow is promoting GE 2,4

- D corn , cotton and soy

as the solution to gly

phosate (the ingredient in Roundup) resistant weeds, but GE crop s ys tems caused the g ly phosate resistant weeds in the first place. Additionally , Enlist Duo also utilizes gly

phosate. **We ask that, under the proposed new use registrations for 2,4 -** **D -**  **resistant crops, EPA incorporate widely accepted estimates for significantly increased use and**  **altered use patterns of 2,4**  **- D**  **.** Sincerel y, Ellen Kennedy Manager, Environment, Water and Climate Change **Calvert Investments** Luan Steinhilber Director of Shareholder Advocacy **Miller/Howard Investments, Inc.**
Kathleen Coll **CHE Trinity Health** William Stoddart Founder and Principal **Northfork Financial** Shelley Alpern Director of Social Research &Shareholder Advocacy **Clean Yield Asset Management** Julie N.W. Goodridge President &CEO **NorthStar Asset Management, Inc.**4

James A Frazin President/CEO **Communitas Financial Management** Judy Byron Director **Northwest Coalition for Responsible Investment**  Sally Ann Brickner Coordinator of Justice, Peace and Ecology **Cong regation**  **of**

**S isters**  **of St. Agnes** Catherine Cartier President **Progressive Asset Management**  Margaret Weber Corporate Responsibility Director **Congregation of St. Basil** JoMarie Chrosniak, HM Coordinator **Region VI Coalition for Responsible Investment** Jo ellen Sbrissa, CSJ SRI Representative **Congregation of St. Joseph** Steve Zielinski SRI Consultant **Servants of the Paraclete** Susan Vickers VP Community Health **Dignity Health** Ruth Kuhn, SC Chair

- Corporate Responsibility Committee **S isters of Charity of Cincinnati**  Steve Zielinski SRI Consultant **Diocese of Springfield, IL**  Margaret O'Brien, SC Congregation Treasurer **Sisters of Charity of New York** Steve Zielinski SRI Consultant **Dominican Sisters** Sister Barbara Aires Coordinator of Corporate Responsibility **Sisters of Charity of Saint El izabeth**  Linda Hincken Chief Financial O

fficer **Dominican Sisters of Amityville** Sister Patricia Daly, OP Corporate Responsibility Representative **Sisters of St. Dominic of Caldwell NJ** Valerie Heinonen Director, Shareholder Advocacy **Dominican Sisters of Hope** Toni Palamar Province Business Administrator **Sisters of the Good Shepherd -**  **Province of NY** Sr. Donna Graham OSF Director, JPIC Office **Franciscan Friars (OFM), St. John the Baptist Province**  Steve Zielinski SRI Consultant **Sisters of the Presentation**
Lura Mack Director **General Council of the Adrian Dominican Sisters**  Mary Lardner Social Justice Committee Chair **Social Justice Committee at UUCSR**
Leslie Samuelrich President **Green Century Capital Management** Lars M Lewander C hief E xecutive O

fficer **Spring Water Asset Management** 5

Nadira Narine Program Director, Strategic Initiatives **Interfaith Center on Corporate Responsibility** Theodore Casparian Educator **Sustainable Investing 4 All** Cathy Rowan Corporate Responsibility Coordinator **Maryknoll Sisters** Susan Baker Vice President, Shareholder Advocacy & Corporate Engagement **Trillium Asset Management** Marcela Pinilla Director, Shareholder Advocacy **Mercy Investment Services** Valerie Heinonen Director, Shareholder Advocacy **Ursuline Sisters of Tildonk** Barbara Jennings Coordinator **Midwest Coalition for Responsible Investment** Sonia Kowal Director of Socially Responsible Investing **Zevin Asset Management, LLC**