UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D

.C

. 20460 

## DEC 202013

MEMORANDUM
SUBJECT: BEAD Response to Atrazine Public Comments 

### FROM: Bill Phillips, II, Ph.D., Agronomist

# /J#~ Biological Analysis Branch

# 151

# \ I l \ 

# rG Derek Berwald, Ph.D., Economist 

# ,fV VV\._

# \Y(J Economic Analysis Branch Elizabeth Hill, Economist Economic Analysis Branch OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION



### THRU: Sepehr Haddad, Environmental Protection Specialist

## ~ 1

## ~ Science Information and Analysis Branch

## ~

# r Biological and Economic**An lys·**  ivision (7503P) Arnet Jones, Chief

# ~ Biological Analysis Branch Biological andEconomic Analysis Divi (7503P) Timothy Kiely, Chief

# ~,;f Economic Analysis Branch 

# J Diann Sims, Chief Science Information and Analysis Branch Biological and Economic Analysis Division (7503P) 

### TO: Kaitlin Keller, Chemical Review Manager Risk Management and Implementation BranchIII Pesticide Re-evaluation Division (7508P) 

### PRODUCT REVIEWPANEL: November 20,2013

1The Environmental Protection Agency (Agency) is implementing the registrationreview programpursuant to Section 3(g) ofthe Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and will review each registered pesticide every 15 years to determine whether it continues to meetthe FIFRA standard for registration. Changes in science, public policy, and pesticide use practices occur over time. Theregistrationreviewprogram is intended to make sure that, as the ability to assess risk evolves and as policies and practices change, all registered pesticides continue to meetthe statutory standard. The public phase ofregistration reviewbegins whenthe initial docket is opened for each case. Information on this program is provided on the Agency's website. (EPA 2012) Registrationreviewmay consist ofa review ofavailable information on a pesticide, risk assessments, and, potentially, risk management. The Biologic and Economic Analysis Division's (BEAD) role is to provide relevant use and usage information for risk assessments and to conduct benefit/impact assessments to inform risk management. In the case of agricultural uses, these impacts could include changes in yield, inthe quality ofproduce, and/or the cost ofproducing the commodity that affect producers' income and, potentially, could affect consumers through the supply and price ofcommodities. On June 26, 2013 the federal docket (HQ-OPP-2013-0266) for the registrationreview ofthe active ingredient atrazine was opened to the public to receive comments regarding all preliminary work for this herbicide, the docket subsequently closed on August 26, 2013. This 60 day commentperiod provided the public the opportunity to submit comments about the work that has been completed up to the June docket opening. The Agency received comments with some ofthese comments being focused on the benefits ofatrazine as well as the alternatives to using atrazine. Inthis document BEAD is responding to the comments that were submitted to the atrazine docket. Since many ofthe comments addressed the same concerns, BEAD has summarized the comments and presented the responses inthis documentrather thanresponding to each comment individually. EPA thanks the public for comments providedto the atrazine docket during the public comment period. Informationprovidedto the docket and any additional information submitted bythe public regarding the agronomic, weed science and/or economicrelevance ofatrazine could be useful in future alternatives and/or benefits analysis.
Comments and Responses Economic impacts
o Comments include:
• Minimizing the amount ofchemical applied improves profit margins on farms. EPA-HQ-OPP-2013-0266-0061 (Illinois Com Growers Association)
2• Research shows that the use ofatrazine boosts comyields by 5.5 bushels peracre, at a significantly lowercostthan otherherbicides. EPA-HQOPP-2013-0266-0078 (Kansas Com Growers Association)
• Atrazine helps increase yield potential throughbetter weed control and at a low costto fanners. Despite intensive research by weed scientists to find alternatives to Atrazine, it continues to be one ofthe best low-rate products available to fanners at a reasonable cost. EPA-HQ-OPP-2013- 0266-0300 (Kentucky Com Growers Association)
• It [atrazine] is a low costtreatment. EPA-HQ-OPP-2013-0266-0019 (Maryland Grain Producers Association)
• Ifunable to utilize atrazine in their operation, the costto fanners could be inthe millions ofdollars when losses to yield, reduction to ease to stewardship and increased herbicide costs are calculated. Weeds are one ofthe largest yield thieves in field crops. Lack ofweed control due to herbicide resistance and effective product availability is an ever increasing cost and concern for fanners. EPA-HQ-OPP-2013-0266-0020 (Missouri Com Growers Association)
• U.S. fanners have relied on atrazine for cost-effective, broadleafweed control in com. EPA-HQ-OPP-2013-0266-0074 (National Com Growers Association)
• Atrazine helps to increase yields throughbetter weed control at a costthat is notprohibitive to fanners. EPA-HQ-OPP-2013-0266-0060 (Andy Thompson, Ohio State Rep)
• At a time when grainprices are dropping and the cost to produce that grain is skyrocketing, maintaining the ability to use important and reasonably priced products like atrazine and simazine cannot be stressed enough. EPA-HQ-OPP-2013-0266-0068 (Ohio Comand Wheat)
• Atrazine helps increase yields through betterweed control, and at a low cost to fanners. Despite intensive research by weed scientists to identify atrazine alternatives, low rates ofatrazine inherbicide programs continue to produce yield benefits at a reasonable cost. EPA-HQ-OPP-2013-0266- 0085 (Oregon Farm Bureau)

3o Response
• EPA will take these comments into consideration ifan impact/benefits assessment is conducted for atrazine. There are over 200 published studies analyzing howthe absence ofatrazine would be reflected in corn and sorghum producers' budgets (Fawcett, 2006). Some studies (WI DOA, 2011; Ackerman, 2007; EPA, 2002; and Coursey, 2007; Fawcett, 2006) conclude that growers may face an increase in the cost per acre and/or a decline inyields when switching from atrazine to alternative herbicides. However, economic impacts vary widely across studies. More current analyses would be necessary, as pesticide prices fluctuate regularly and are influenced by a variety offactors. Commenters are always encouragedto share withthe EPA Office ofPesticide Programs any current data or studies--especiallypeer-reviewed studies-that address the economic benefits ofatrazine.
o References: Ackerman FA. 2007. The Economics ofAtrazine. International Journal of Occupational Environmental Health. 13: 441-449. Coursey D. 2007. Illinois Without Atrazine: Who Pays? Online: http://www.ilfb.org/uploads/files/Atrazine_Final_Report_02-27-07 _13072.pdf. Accessed March 21,2012. Fawcett RS. 2006. Two Decades ofAtrazine Yield Benefits Research. Triazine Network, 2006. Online: http://www.ksgrains.com/triazine/. Accessed March 21, 2012. U.S. Environmental ProtectionAgency. 2002. Assessment ofPotential Mitigation Measures for Atrazine. Biological and Economic Analysis Division, Office ofPesticide Programs. Wisconsin Department ofAgriculture (WI DOA). 2011. Final Report onthe 2010 Survey ofWeed Management Practices in Wisconsin's Atrazine Prohibition Areas.

4Use and Usage o Comment (EPA-HQ-OPP-2013-0266-0299)
• Syngenta states that they are working withthe other atrazine technical registrants to make a table to be provided to EPA that lists current atrazine uses, products and formulation types. The table will include clarification for some uses as discussed at the Atrazine Focus Meeting.
• There are a number ofdiscrepancies onthe EPA provided table. Syngenta will be addressing these onthe Use Table (matrix) as mentioned above to beprovided to EPA.
• Syngenta states that emulsifiable concentrate is incorrectly listed as a formulation type for atrazine.
• Some Syngenta suspension concentrate formulations are incorrectly identified by EPA as emulsifiable concentrates. Corrections to formulation type will be included onthe atrazine use table beingprepared

o Response
• Since Syngenta is working withthe other atrazine technical registrants to make a table to be provided to EPA that lists current atrazine uses, products and formulation types, and the table will include clarification for some uses as discussed at the atrazine Focus Meeting, once EPA receives the information we will incorporate all necessary changes as appropriate. EPA thanks Syngenta and othertechnical registrants for the information.

Weed Control and Agronomics I. Importance ofatrazine in weed management
o Comments
• Atrazine has beenproven effective for over 50 years.
• Atrazine has been used effectivelyto control weeds in com, sorghum and sugar cane production.
• Atrazine has been used effectively to control weeds in nonagricultural areas such as forest tree establishment and turfgrass. 5• Atrazine is a significanttool for a farmer to control weeds.
• Atrazine controls a broad spectrum ofweed species over a long period of time.
• Atrazine controls problematic weeds such as Palmer amaranth and waterhemp.
• There is no alternative to atrazine.
• There are alternative pestmanagementpractices and less toxic pesticides that canbe used as alternatives to atrazine.
• Integrated pest management and organic production are examples of alternativesto atrazine use.
o Response
• The EPA is aware that atrazine has been used for many decades to control a broad spectrum ofweeds in agricultural crops such as com, sorghum, and sugarcane as well as innonagricultural crops such as forest tree establishment and turfgrass. It is understood that there is no single herbicide that has all ofthe characteristics ofatrazine. The EPA is also aware that no single herbicide isrequired under all conditions and that atrazine may not be needed under certain circumstances where combinations ofherbicides and/or alternative practices may be sufficient to control weeds. II. Additional benefits ofatrazine
o Comments
• Atrazine is important in aiding in increased crop yields.
• Atrazine is important inmaintainingreduced and no tillage cropping systems.
• By supporting no tillage agriculture atrazine allows for a reduction in soil, nutrient and pesticides in runoff.
• Atrazine is an effective tool in managing resistant weeds bybeing an additional mechanism ofaction in an herbicide combination and/or rotation.
• Atrazine has a broad window ofapplication timing. 6• Sorghum has very few herbicides and atrazine is a very importanttool in a crop with a limited number ofavailable herbicides.
o Response
• The EPA is aware that the agricultural industry considers atrazine to be a significanttool in reducing weed populations, thus resulting in increasing crop yield, while also supporting no-tillage practices and resistance managementpractices. The EPA is also aware that atrazine has a broad windowofapplication timing and can be used in a number ofcrops that have a limited number ofherbicides available, such as sorghum and sugarcane. III. Managing atrazine inthe environment?
o Comments
• Growers have been inthe forefront ofatrazine stewardship.
• Atrazine is efficacious at lower rates.
• The efficacy ofherbicide mixtures is enhanced withthe addition of atrazine.
• Technologies such as GPS and variable rate application make for safer and better control ofthe herbicide
. • Many states work with farmers on BMPs to better steward atrazine.
o Response
• The EPA appreciates the fact that growers and applicators have worked to make atrazine use rates lower overtime while still maintaining efficacious weed control. In addition, the EPA understands thatthe use ofatrazine in some herbicide mixtures canenhance control above that ofthe individual active ingredients
. The move toward the use oftechnology such as GPS and variable rate technology are importantto the EPA's understanding of the use ofthis herbicide. Information onprojects with states and other entities regarding BMP and other stewardship projects will be important for the EPAto know about moving forward in conducting analyses such as alternative assessments orbenefits analysis thatmay beneeded for registrationreview.

7Summarized Weed Control and Agronomic Comment Docket Number EPA-HQ-OPP-2013-0013 EPA-HQ-OPP-2013-0017 EPA-HQ-OPP-2013-0018 EPA-HQ-OPP-2013-0019 EPA-HQ-OPP-2013-0020 EPA-HQ-OPP-2013-0025 EPA-HQ-OPP-2013-0060 EPA-HQ-OPP-2013-0061 EPA-HQ-OPP-2013-0062 EPA-HQ-OPP-2013-0065 EPA-HQ-OPP-2013-0066 EPA-HQ-OPP-2013-0067 EPA-HQ-OPP-2013-0068 EPA-HQ-OPP-2013-0069 EPA-HQ-OPP-2013-0070 EPA-HQ-OPP-2013-0071 EPA-HQ-OPP-2013-0072 EPA-HQ-OPP-2013-0073 EPA-HQ-OPP-2013-0074 EPA-HQ-OPP-2013-0075 EPA-HQ-OPP-2013-0077 EPA-HQ-OPP-2013-0078 EPA-HQ-OPP-2013-0085 EPA-HQ-OPP-2013-0299 EPA-HQ-OPP-2013-0300

References Commenter South Dakota Com Growers Association Chemical Industry Council ofAmerica Iowa Farm BureauFederation Maryland Grain Producers Association Missouri Com Growers Association American Farm Bureau Federation Andy Thompson, Ohio State Representative, 95th District Illinois Com Growers Association Hawaii Agriculture Research Center National Farmers Union Texas Seed Trade Association Illinois Farm Bureau Ohio Com & Wheat Growers Association Nebraska Com Growers Association Illinois Soybean Association Michigan Farm Bureau HC&S Beyond Pesticides National Com Growers Association Oregonians ForFood & Shelter Kansas Grain Sorghum Producers Association Kansas Com Growers Association Oregon Farm Bureau Syngenta Crop Protection Kentucky Com Growers' Association

EPA 2012, Pesticides: Registration Reviewhttp://www.epa.gov/oppsrrdl/registration_review/

8