Monsanto Petitions (10-188-01p and

12-185-01p) for Determinations of 

Nonregulated Status for DicambaResistant Soybean and Cotton Varieties

Final Environmental Impact Statement

December 2014

Agency Contact:

Sid Abel

Biotechnology Regulatory Services

4700 River Road 

USDA, APHIS 

Riverdale, MD 20737 

Fax: (301) 734-6352

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This publication reports research involving pesticides. All uses of pesticides must be registered by appropriate State and/or Federal agencies 

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CAUTION: Pesticides can be injurious to humans, domestic animals, desirable plants, and fish and other wildlife—if they are not handled or 

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Executive Summary

The U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service 

(APHIS) received two requests (petitions) from Monsanto Company, St. Louis, MO (Monsanto) 

seeking determinations of nonregulated status for genetically engineered (GE) plant varieties 

referred to as MON 87708 soybean and MON 88701 cotton, that have been engineered to be 

resistant to the herbicide dicamba (Monsanto, 2012b; 2012a). These GE plant varieties are 

currently regulated by APHIS, and Monsanto requests that APHIS grant the petitions 

(Petition 10-188-01p for MON 87708 soybean and Petition 12-185-01p for MON 88701 cotton), 

so that these varieties can be grown without any APHIS regulatory oversight. Since these two 

GE plant varieties are currently under APHIS regulatory oversight, the Agency requires 

Monsanto to comply with a full range of safeguarding measures to ensure that these regulated 

GE plant varieties do not transfer or spread from their APHIS-approved outdoor planting sites. 

APHIS authorization is also required to move these regulated varieties interstate.

Once a developer of a GE plant has obtained sufficient information to conclude that its regulated 

GE plant is unlikely to cause injury, damage, or disease to plants or plant products (i.e., pose a 

plant pest risk), it may submit a petition to APHIS to no longer regulate the organism. This is 

referred to as seeking nonregulated status. If a petition for nonregulated status is approved by 

APHIS, permits or notifications are no longer required by the Agency to grow or ship the GE 

plant throughout the United States and its territories. If APHIS determines that nonregulated 

status is appropriate for one or both the Monsanto GE varieties, they will no longer be subject to 

any regulations pursuant to Part 340.

Regulatory Authority

APHIS regulates certain GE organisms under the authority of the PPA of 2000 as amended (7 

U.S.C. §§ 7701–7772), and by APHIS regulations codified in Title 7, part 340 of the U.S. Code 

of Federal Regulations (7 CFR part 340). The APHIS part 340 regulations govern a GE organism 

in the following circumstances: if it is a plant pest (such as certain microorganisms or insects that 

can cause injury or damage to plants); if it is created using an organism that is itself a plant pest; 

if APHIS does not have sufficient information to determine if the GE organism is or may be a 

plant pest.

Any party can petition APHIS for “nonregulated status” of a GE organism (that is, to discontinue 

regulating a GE organism that falls under its regulations) through the procedures described in 7 

CFR § 340.6. APHIS regulates such a GE organism until a request for nonregulated status is 

made. The agency then evaluates whether it meets the PPA definition of a plant pest, and it

concludes on the basis of scientific evidence that the GE organism is unlikely to pose a plant pest 

risk by determining that the potential for the GE organism to cause plant disease or damage is 

unlikely. The petitioner must provide data, including information obtained from confined field 

tests regulated by APHIS, to help inform Agency decisionmakers. APHIS analyzes the data from 

the petitioner, researches current scientific findings, and prepares a Plant Pest Risk Assessment 

(PPRA) that documents whether or not the GE organism is likely to cause disease or damage. If 

APHIS concludes that the GE organism does not pose plant pest risk, APHIS must then issue a 

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regulatory decision of non-regulated status, since the Agency does not have regulatory authority 

to regulate organisms that are not plant pests. When a determination of nonregulated status has 

been issued, the GE organism may be introduced into the environment without APHIS regulatory 

oversight under Part 340. In the case of the GE soybean and cotton varieties that are the subject 

of this environmental impact statement (EIS), if nonregulated status is determined to be 

appropriate for them, Monsanto will be allowed to sell the GE seeds to farmers, and growers will 

be able to grow, harvest, and move their crop into commerce for food and feed without any 

authorization from APHIS.

Two other agencies, the Federal Drug Administration (FDA) and the Environmental Protection 

Agency (EPA), provide oversight of GE plants. The relative roles of the USDA (through 

APHIS), the FDA, and the EPA are described by the “Coordinated Framework,” a 1986 policy 

statement from the Office of Science and Technology Policy that describes the comprehensive 

Federal policy for ensuring the safety of biotechnology research and products (US-OSTP, 1986).

The FDA’s regulation of GE plants is based upon its authority to regulate food safety under the 

Federal Food, Drug, and Cosmetic Act (FFDCA) 21 U.S.C. §§ 301 – 399. The FDA implements 

a voluntary consultation process to ensure that human food and animal feed safety issues or other 

regulatory issues, such as labeling, are resolved before commercial distribution of food derived 

from GE products.

The EPA regulates the use, sale, and labeling of pesticides pursuant to its authority under the 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 U.S.C. §§ 136–136y). EPA’s 

actions under FIFRA directly affect the production methods used on herbicide-resistant (HR) GE 

plants. An herbicide must first be “registered” by the EPA before it can be distributed or sold in 

the U.S. (7 U.S.C. §§ 136a(a),136j(a)(2)(F)). The EPA registration process starts with the 

herbicide manufacturer providing the EPA with information about the herbicide (7 U.S.C. § 

136a(c)(1)(C), (F)). The agency then evaluates the adverse effects it may have on humans and 

the environment in accordance with the proposed label. On the basis of this evaluation, the EPA 

then determines if it will allow use of the herbicide on a plant, and, if so, under what conditions 

and in what quantity. The EPA sets the conditions for herbicide use and places them in labeling 

instructions that a user must follow (See 7 U.S.C. 136j(a)(2)(G)). The EPA reevaluates all 

pesticides, which includes herbicides, every fifteen years (or shorter) to ensure they meet current 

standards for continued safe use (7 U.S.C.§ 136a(g)(1)(A)(iv)). Under FIFRA, the EPA also 

regulates plant-incorporated protectants (PIPs) which are pesticidal substances produced by 

plants and the genetic material necessary for the plant to produce the substance.

The varieties that are the subject of this EIS, MON 87708 soybean and MON 88701 cotton, are

both resistant to the herbicide dicamba. MON 88701 cotton is also resistant to the herbicide 

glufosinate. The EPA is currently reviewing proposed changes in the registered uses of dicamba 

on these soybean and cotton varieties. If approved by the EPA, these label changes will allow for 

the direct application of dicamba to MON 87708 soybean and MON 88701 cotton. Following the 

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EPA’s approval, dicamba herbicide products that could be used on MON 87708 soybean and 

MON 88701 cotton could include lower volatility dicamba formulations based on the 

diglycolamine (DGA) salt, as well as those based on the BAPMA1 salt. These proposed label 

changes were requested by Monsanto based on the standard that the new uses of this herbicide 

would not cause any unreasonable adverse environmental effects and a reasonable certainty of no 

harm to humans, so long as it was applied in accordance with its labeling instructions. Monsanto 

is not requesting any changes to the current EPA-approved uses for glufosinate for MON 88701 

cotton; thus, no new review of the label by the EPA is required. The EPA does not regulate 

MON 87708 soybean and MON 88701 cotton plants because these plants are not plant 

incorporated protectants. 

Purpose of MON 87708 Soybean and MON 88701 Cotton

Monsanto has developed these two GE plant varieties as alternatives to currently available GE 

herbicide-resistant (HR) soybean and cotton varieties (Monsanto, 2012a; 2012b). The primary 

purpose of MON 87708 soybean and MON 88701 cotton is to provide growers with additional 

and enhanced pre-emergence and in-crop weed management options in soybean and cotton 

cultivation to control a broad spectrum of broadleaf weeds, including glyphosate-resistant (GR)

broadleaf weed species. Each of these varieties has a trait that makes the plant resistant to 

dicamba, an active ingredient in many herbicide formulations. MON 87708 soybean and MON 

88701 cotton can be treated with dicamba after sprouting, killing competing weeds but not the 

developing soybean or cotton seedlings. MON 88701 cotton is also resistant to glufosinate, so 

both herbicides may be used on this cotton variety after planting. If MON 87708 soybean and 

MON 88701 cottonare no longer regulated they would also be available for cross-breeding with 

all other GE varieties that are no longer regulated by APHIS. For the technical details on these 

two GE plant cultivars, see the petitions submitted by Monsanto which are available on the 

APHIS website (USDA-APHIS, 2014f).

Purpose and Need for Agency Action

APHIS regulations require that APHIS make decisions on the petitions it receives for 

nonregulated status. The Agency can choose to approve a petition in whole or in part, or it can 

deny the petition. As previously mentioned, the APHIS decision is based on a PPRA for the GE 

plants that are the subject of the petition. Plant pest risks are those risks caused by plant pests 

that can cause injury, damage, or disease to plants or plant products. Consistent with the APHIS 

authority under the PPA, market acceptance of a product is not a plant pest risk.

The purpose of the petition process and the decisions made under the regulations is to protect 

plant health. Developers who can demonstrate through this process that their products do not 

cause plant pest risks can enter their products into commerce without restrictions. APHIS must 

make a decision that is consistent with the Agency’s statutory and regulatory authority.

1 N, N-Bis-(aminopropyl) methylamine

iii

 
In response to the receipt of the two Monsanto petitions, APHIS prepared PPRAs to assess the 

plant pest risk for each plant variety. In addition to the PPRAs, APHIS must also prepare an 

environmental analysis consistent with its obligations under the National Environmental Policy 

Act (NEPA). Under NEPA regulations, an agency conducts an environmental assessment (EA) 

to determine if a major federal agency action will cause significant environmental impacts (40 

CFR § 1501.4). If the agency concludes in its EA that its action will not significantly impact the 

environment, the agency issues a “Finding of No Significant Impact” (FONSI) and the agency 

can proceed with its proposed action without preparing a more thorough EIS. If the EA 

concludes that the proposed action may significantly affect the environment, the agency must 

prepare an EIS. However, an agency may determine that significant impacts are possible without 

formally preparing an EA and proceed to the preparation of an EIS. 

Public Involvement

APHIS sought comments for the petitions that are the subject of this EIS in a Federal Register

notice dated July 13, 2012, and February 27, 2013. Comments received for the petitions were 

influential, though not the sole basis, for the Agency’s decision to prepare this EIS. In reviewing 

the petitions for determinations of nonregulated status of crop cultivars genetically engineered to 

be resistant to various herbicides, APHIS has identified the potential selection of HR weeds as a 

potential environmental impact. As part of its scoping process to identify issues to address in this 

EIS, APHIS also published a Notice of Intent (NOI) to prepare an EIS and sought public input 

during a comment period (May 10 to July 17, 2013). Comments were submitted by individuals, 

academic researchers, non-government organizations, and industry representatives. The majority 

of comments submitted by non-government organizations and individuals were opposed to 

determinations of nonregulated status for the petitions. The majority of comments submitted by 

industry and academia supported determinations of nonregulated status for MON 87708 soybean 

and MON 88701 cotton. These comments are summarized in Appendix 2.

The draft EIS (DEIS) was made available for public comment for 45 days from August 11 

through September 25, 2014; the comment period was further extended to October 10, 2014. 

APHIS held a virtual public meeting on the DEIS on September 11, 2014. At the end of the 60-

day comment period (October 10, 2014), APHIS reviewed and evaluated all of the comments 

received. APHIS received 4,693 submissions to the EIS docket (APHIS 2013-0043) with the 

majority of commenters supporting determinations of nonregulated status for MON 87708 

soybean and MON 88701 cotton. A summary of public comments on the DEIS and responses to 

those comments are presented in Appendix 11. 

Alternatives Analyzed

In this EIS, APHIS considered four alternatives for its response to the two Monsanto petitions for 

nonregulated status. The four alternatives are: 1) continue to regulate MON 87708 soybean and 

MON 88701 cotton (i.e., no action); 2) approve the petitions for nonregulated status of MON 

87708 soybean and MON 88701 cotton; 3) approve the petition for nonregulated status for MON 

88701cotton only; and 4) approve the petition for nonregulated status for MON 87708 soybean

only. These alternatives are further described here and in Section 2.1.

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Alternative 1: No Action Alternative—Continuation as Regulated Articles

Under the No Action Alternative, APHIS would deny the two petitions because the two varieties 

that are the subject of the petitions would present a plant pest risk and would continue to be 

regulated by APHIS. Permits issued or notifications acknowledged by APHIS would still be 

required for the introduction of MON 87708 soybean and MON 88701 cotton, and measures to 

ensure physical and reproductive confinement would continue to be implemented. This 

alternative is not the Preferred Alternative because APHIS has concluded in its PPRAs that 

MON 87708 soybean and MON 88701 cotton are unlikely to pose plant pest risks (USDAAPHIS, 2014d; 2014e). Therefore, choosing this alternative would not be consistent with the

scientific evidence before the Agency regarding lack of plant pest risk and thus would not fully 

satisfy the purpose and need of making the required regulatory determination under the PPA and 

7 CFR part 340.6.

Alternative 2: Determination of Nonregulated Status of MON 87708 Soybean and MON 

88701 Cotton (Preferred Alternative)

Under this alternative, MON 87708 soybean and MON 88701cotton and their progeny would no 

longer be subject to APHIS biotechnology regulations (7 CFR part 340) as they have been 

determined unlikely to pose plant pest risks. Permits issued or notifications acknowledged by 

APHIS would no longer be required for introductions of these varieties. This alternative meets 

the purpose and need to respond appropriately to the petitions for nonregulated status (Monsanto, 

2012a; 2012b), the requirements in 7 CFR part 340, and the Agency’s regulatory authority under 

the plant pest provisions of the PPA, because APHIS has concluded in its PPRAs that these 

varieties are unlikely to pose plant pest risks (USDA-APHIS, 2014d; 2014e). Therefore, this is 

the Preferred Alternative because approving the petitions for nonregulated status for both

varieties is consistent with the scientific evidence before the Agency regarding lack of plant pest 

risk and would satisfy the purpose and need of making the required regulatory determination 

under the PPA and 7 CFR part 340.6.

Alternative 3: Approve the Petition for a Determination of Nonregulated Status Only for

MON 88701 Cotton Only

Under this alternative, only MON 88701 cotton and progeny derived from its cultivation would 

no longer be subject to APHIS biotechnology regulations (7 CFR part 340) as it has been 

determined unlikely to pose a plant pest risk. Permits issued or notifications acknowledged by 

APHIS would no longer be required for this cotton variety and its progeny. This alternative 

meets the purpose and need to respond appropriately to the petition for nonregulated status for 

MON 88701 cotton (Monsanto, 2012b), the requirements in 7 CFR part 340 and the Agency’s 

regulatory authority under the plant pest provisions of the PPA because APHIS has concluded in 

its PPRA that it is unlikely to pose a plant pest risk (USDA-APHIS, 2014e). Therefore, 

approving the petition for a determination of nonregulated status for MON 88701 cotton is 

consistent with the plant pest provisions of the PPA and the regulations codified in 7 CFR part 

340. However, because APHIS has concluded in its PPRA that MON 87708 soybean is also 

unlikely to pose a plant pest risk (USDA-APHIS, 2014d), choosing this alternative is 

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inconsistent with the scientific evidence before the agency regarding lack of plant pest risk and 

would not satisfy the purpose and need of making the required regulatory determination under 

the PPA and 7 CFR part 340.6. 

Alternative 4: Approve the Petition for a Determination of Nonregulated Status Only for

MON 87708 Soybean 

Under this alternative, only MON 87708 soybean and progeny derived from its cultivation would 

no longer be subject to the APHIS biotechnology regulations (7 CFR part 340) as it has been 

determined unlikely to pose a plant pest risk. Permits issued or notifications acknowledged by 

APHIS would no longer be required for its introduction and progeny derived from it. This 

alternative meets the purpose and need to respond appropriately to the petition for nonregulated 

status for MON 87708 soybean (Monsanto, 2012a), the requirements in 7 CFR part 340 and the 

Agency’s regulatory authority under the plant pest provisions of the PPA, because APHIS has 

concluded in its PPRA that it is unlikely to pose plant pest risk (USDA-APHIS, 2014d). 

Therefore, approving the petition for a determination of nonregulated status for MON 87708 

soybean is consistent with the plant pest provisions of the PPA and the regulations codified in 7 

CFR part 340. However, because APHIS has concluded in its PPRA that MON 88701cotton is 

also unlikely to pose plant a plant pest risk (USDA-APHIS, 2014e), choosing this alternative 

would be inconsistent with the scientific evidence before the agency regarding lack of plant pest 

risk and would not satisfy the purpose and need of making the required regulatory determination 

under the PPA and 7 CFR part 340.6.

Affected Environment

To determine the extent of the potential environmental impacts that could result from any APHIS

decision related to the regulation of MON 87708 soybean and MON 88701cotton, APHIS used 

information provided by the USDA National Agricultural Statistics Service (USDA-NASS) to 

identify those regions of the country where soybeans and cotton are grown. To describe the 

ecological features of soybean and cotton regions, APHIS compared these growing areas to maps 

that group regions having similar ecological attributes such as soil, landform, or major vegetation 

types (CEC, 2009). These regions are termed ecoregions and are identified as regions A through 

M in this EIS. To identify the types of land cover and crops grown in each region, APHIS 

analyzed information in the USDA-NASS online tool “Cropscape,” an information source that 

compiles these data from satellite imagery.

Potential Environmental Consequences of Alternatives

Environmental issues are assessed individually in Chapter 4 (Potential Environmental 

Consequences). As stated previously, APHIS has regulatory authority based on the plant pest

potential of MON 87708 soybean and MON 88701 cotton cultivars; the EPA has regulatory 

authority over pesticide products and uses, such as dicamba. The scope of this EIS analyzes the 

potential for direct and indirect impacts that might result from the cultivation and use of these 

GE crop varieties.

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The EPA regulates the use of herbicides under FIFRA and is making a separate decision which 

may or may not allow new uses of dicamba. While MON 87708 soybean and MON 88701 cotton

are engineered to resist damage from the application of dicamba, selection of a particular 

alternative by APHIS does not allow the new uses of dicamba on these soybean and cotton 

varieties. The EPA, in its registration process, is considering any direct and indirect impacts from 

the proposed new uses of dicamba on these varieties. The dicamba product proposed for 

registration for use for treating dicamba-resistant soybean and cotton is the M1691 herbicide

formulation (EPA Reg. No. 524-582) which is in the form of the diglycolamine salt of dicamba. 

APHIS will not duplicate the assessments prepared by the EPA. 

APHIS emphasizes that its decision to prepare an EIS in this case was discretionary. The 

agency’s decision was based on a perceived need for the level of thoroughness afforded by the 

EIS process because of the complexity of issues that needed to be addressed. These issues 

initially included the potential environmental impacts associated with the increased use of certain 

herbicides and possible selection for and spread of weeds resistant to the herbicide dicamba 

combined with resistance to other herbicides (multiple resistance). APHIS considers these in 

detail in Chapter 5 which considers potential cumulative impacts that may result if APHIS

recognizes nonregulated status for MON 87708 soybean and MON 88701 cotton, and if the EPA 

registers the proposed new uses of dicamba on these crop varieties.

APHIS determined that the direct impacts on the environment from the cultivation of MON 

87708 soybean and MON 88701 cotton would not differ from those caused by the cultivation of 

other soybean and cotton varieties, because these GE varieties are not agronomically different 

from non-GE soybean and cotton cultivars or other GE soybean or cotton cultivars that are no 

longer regulated by the Agency. These two GE plant varieties do not directly affect natural (e.g.,

soil, water, air) or biological (e.g., animal, insect, plant) resources. However, the agricultural

management practices (e.g., tillage practices) associated with their cultivation may indirectly 

impact natural and biological resources. For example, the need for tillage, which may adversely 

affect soil, water, and air quality, and greenhouse gas emissions, is likely to stabilize in 

conjunction with the weed management alternatives presented by the cultivation of MON 87708 

soybean and MON 88701 cotton.

Potential Cumulative Impacts

Chapter 5 of this EIS includes an environmental analysis of potential cumulative impacts, 

including how herbicide use may change, if APHIS approves the petitions for nonregulatory 

status of MON 87708 soybean and MON 88701 cotton and the EPA approves the proposed 

registration changes for dicamba. As part of its analysis, APHIS considered the potential effects 

of the development of dicamba-resistant weeds if the EPA approves the new dicamba uses on 

MON 87708 soybean and MON 88701 cotton. In particular, APHIS evaluated the impacts of 

dicamba-resistant weeds on the cultivation of crops, other than soybean and cotton, on which 

dicamba is used currently (see Appendix 4, Tables 4-8 and 4-12 for more details). 

The availability of dicamba-resistant soybean and cotton in conjunction with EPA’s approval of

the new uses of dicamba on these new varieties would result in growers who adopt the varieties 

vii
changing management practices. For instance, dicamba use may increase to levels greater than 

what might occur if these varieties were not available. Another anticipated change is that 

dicamba could be used over a wider part of the growing season. Both changes in management 

practices would be expected to increase the pressure for selection of dicamba-resistant weeds. 

Growers themselves can influence this selection pressure by the management practices they 

choose. For example, rotating crops, rotating types of herbicides, using cover crops, scouting for 

weeds and using mechanical tillage to prevent weeds from flowering, are just some of the 

practices that can be followed to reduce or delay the selection of HR weeds. Groups such as the 

Weed Science Society of America (WSSA), university extension agents, crop consultants, and 

industry representatives, have made a concerted effort to increase grower awareness of best 

management practices for managing the development of HR weeds (see Section 5.7.2 for a 

detailed review of this topic).

The EPA has noted the increasing problems and economic issues growers are facing from the 

emergence of HR weeds. In 2014, as part of the registration of Dow’s Enlist Duo (a 2,4-D 

choline salt and glyphosate premix), EPA imposed a new, robust set of requirements on the 

registrant. These requirements include extensive surveying and reporting to EPA, grower 

education and remediation plans. The registration will expire in six years, allowing EPA to 

revisit the issue of resistance. In the future, the agency intends to apply this approach to weed 

resistance management for all existing and new herbicides used on herbicide tolerant crops.

2

 

Therefore, APHIS expects the EPA to implement similar requirements, including an herbicide 

resistance management plan, as part of the registration of the M1691 dicamba formulation for 

application to MON 87708 soybean and MON 88701cotton. Additionally, APHIS assumes that 

growers will adhere to the EPA label requirements. 

Dicamba-resistant weeds might become more prevalent as a result of dicamba use on MON 

87708 soybean and MON 88701cotton if growers fail to diversify weed management practices in 

a comprehensive strategy (i.e., best management practices) to mitigate weed resistance 

development. As a result, growers of other crops that rely on dicamba for weed control might 

have to modify management practices to control additional weeds that become resistant to 

dicamba. These necessary management changes could increase the complexity and cost of weed 

management programs for some of these growers. Because the use of dicamba on MON 87708 

soybean and MON 88701 cotton does not require a single specific set of agronomic practices, the 

magnitude of the effects would depend on the adoption rates of various practices by growers.

In the cumulative impacts assessment, the selection pressure for dicamba-resistant weeds is 

expected to be greater under the Preferred Alternative, while the selection pressure for GR weeds 

is expected to be greater under the No Action Alternative. This is because the cropping systems 

that use dicamba potentially decrease grower reliance on glyphosate by including an additional 

type of herbicide in the weed management system. The continued emergence of GR weeds under 

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viii

 
the No Action Alternative will itself require modification of crop management practices to 

address these weeds.

Growers will likely continue to use glyphosate because it is still effective on hundreds of weed 

species. However, farmers are also expected to depend on additional chemical and non-chemical 

methods to control GR weeds. Changes in management practices are expected to include more 

use of non-glyphosate herbicides and adjustments to crop rotation and tillage practices (Owen et 

al., 2011). Use of herbicides that kill weeds by mechanisms (referred to as sites of action; see 

Appendix 3 for details) that differ from that of glyphosate are expected to increase as growers 

alter methods to manage GR weeds.

Selection for GR weeds is expected to continue under all the alternatives. Effects of this trend 

can be minimized if best management practices incorporating a diversity of weed control 

methods are used by growers. Areas where GR weeds are expected to remain a serious problem 

include the Southeast, Great Plains and Northern Crescent. Weed resistance to other nonglyphosate herbicides has also become prevalent in many regions (see Appendix 6 for more

details). For example, a total of 146 species worldwide show resistance to ALS inhibitors(Heap, 

2014d), including the five classes Imidazolinones, Pyrimidinylthiobenzoates, 

Sulfonylaminocarbonyltriazolinone, Sulfonylureas, and Triazolopyrimidines; ALS resistance in 

Palmer amaranth includes seventeen US reports and more will likely develop. As a result, 

herbicide options for weed management may become less attractive under the No Action 

Alternative and growers may be forced to return to more aggressive tillage systems to maintain 

productive soybean yields (Conley, 2013).

When considering cumulative impacts under the Preferred Alternative, APHIS assumed that the 

EPA approves the proposed new uses of dicamba on these crops and dicamba use is expected to 

increase relative to the No Action Alternative. However, increases in the use of other herbicide 

sites of action under the Preferred Alternative are expected to be less than under the No Action 

Alternative because dicamba is expected to be preferentially adopted if approved for use on these 

crops by EPA. The availability of inexpensive and effective herbicides may delay the adoption of 

non-chemical management strategies under the Preferred Alternative. Fewer growers would be 

expected to adopt aggressive tillage when herbicides remain both cost effective and efficacious 

for weed control. Selection of weeds resistant to glyphosate, and non-glyphosate herbicides will 

continue to occur under the Preferred Alternative. The selection pressure for HR weeds under the 

Preferred Alternative relative to the No Action Alternative will depend on the management 

practices chosen and cannot be predicted. Under the No Action Alternative, natural resources are 

expected to be negatively impacted by the continued trend of a return to more aggressive tillage 

practices. If conventional tillage continues to increases to control GR/HR weeds, several 

negative impacts are likely: reduced soil quality from increased erosion; reduced air quality from 

increased air particulates and increased exhaust emissions from farm equipment; reduced water 

quality from the release and mobilization of sediments, nutrients, and other chemicals into 

surface and groundwater; increased greenhouse gases from burning additional fossil fuels and 

releases of sequestered carbon from disrupted soil; and reduced biodiversity from habitat loss. 

The total acreage that may be impacted by such increases in tillage would be based on the extent 

of resistant weeds present in a field and the weed management strategy chosen by a grower. 

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Adoption of MON 87708 soybean and MON 88701 cotton and the new approved use of dicamba 

on these varieties can provide growers with an alternative broadleaf herbicide to supplement 

glyphosate, and provide multiple effective herbicides for specific weeds, which will both benefit

weed control plans. In some cases, these HR crops and the new use of dicamba on them will 

provide growers with an alternative to intensive tillage practices that may be used to manage HR 

weeds. However, the development of more resistant weed species to more types of herbicides 

could reduce the long-term use of dicamba and any associated benefits to natural resources. The 

magnitude of this impact is uncertain because of the difficulty of characterizing the variability of 

the decisions made by crop production managers and individual growers.

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Table of Contents

LIST OF FIGURES ..................................................................................................................XVII

LIST OF TABLES..................................................................................................................... XIX

LIST OF APPENDICES............................................................................................................ XXI

ACRONYMS AND ABBREVIATIONS.................................................................................XXII

1 PURPOSE AND NEED...........................................................................................................1

1.1 Introduction ...............................................................................................................1

1.2 APHIS Regulatory Authority ....................................................................................2

1.3 Requirement for This Document ...............................................................................2

1.4 Purpose of These Products ........................................................................................3

1.4.1 MON 87708 Soybean ................................................................................................4

1.4.2 MON 88701 Cotton ...................................................................................................5

1.5 Coordinated Regulatory Framework for Genetically-Engineered Organisms..........6

1.5.1 USDA-APHIS............................................................................................................6

1.5.2 Environmental Protection Agency.............................................................................7

1.5.3 Food and Drug Administration ..................................................................................8

1.6 Purpose and Need for this APHIS Action .................................................................8

1.7 Public Involvement....................................................................................................9

1.7.1 Public Comments for Petitions 10-188-01p and 12-185-01p ..................................10

1.7.2 Public Comment Period for Draft EIS.....................................................................10

1.7.3 Issues Considered in This EIS .................................................................................12

2 ALTERNATIVES..................................................................................................................13

2.1 Alternative Considered and Selected for Further Evaluation for This EIS .............13

2.1.1 Alternative 1: No Action Alternative - Continuation as Regulated Articles...........13

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Table of Contents

2.1.2 Alternative 2: Determination of Nonregulated Status of MON 87708 Soybean and 

MON 88701 Cotton (Preferred Alternative)...........................................................13

2.1.3 Alternative 3: Determination of Nonregulated Status for MON 88701 Cotton, 

Only .........................................................................................................................14

2.1.4 Alternative 4: Determination of Nonregulated Status for MON 87708 Soybean, 

Only .........................................................................................................................14

2.2 Alternatives Considered but Not Selected for Further Evaluation..........................14

2.2.1 Prohibit Any MON 87708 Soybean and MON 88701 Cotton from Being Released15

2.2.2 Approve the Petition(s) in Part ................................................................................15

2.2.3 Production/Geographical Restrictions to Isolate MON 87708 Soybean and MON 

88701 Cotton from Non-GE Soybean or Cotton .....................................................15

2.2.4 Requirement of Testing for MON 87708 Soybean and MON 88701 Cotton..........16

2.3 Comparison of Alternatives.....................................................................................16

3 AFFECTED ENVIRONMENT.............................................................................................24

3.1 U.S. Cotton and Soybean Economics......................................................................24

3.1.1 U.S. Cotton Economics............................................................................................24

3.1.2 U.S. Soybean Economics.........................................................................................27

3.2 U.S. Cotton and Soybean Production ......................................................................29

3.2.1 Major U.S. Cotton and Soybean Production Regions .............................................29

3.2.2 Ecoregions of the Affected Environment ................................................................29

3.3 Physical Environment..............................................................................................32

3.3.1 Physical Terrain and Climate...................................................................................32

3.3.2 Soil Resources..........................................................................................................38

3.3.3 Water Resources ......................................................................................................40

3.3.4 Air Quality ...............................................................................................................46

3.3.5 Climate Change........................................................................................................49

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3.3.6 Land Resources........................................................................................................52

3.4 Biological Resources...............................................................................................60

3.4.1 Animal Communities...............................................................................................60

3.4.2 Plant Communities...................................................................................................68

3.4.3 Microorganisms .......................................................................................................69

3.5 Agronomic Practices in Cotton and Soybean Production .......................................70

3.5.1 Tillage ......................................................................................................................71

3.5.2 Crop Rotation...........................................................................................................73

3.5.3 Agronomic Inputs ....................................................................................................77

3.5.4 Organic Cotton and Soybean Production.................................................................86

3.5.5 GE Cotton and Soybean...........................................................................................91

3.6 Health and Safety for Humans and Livestock .........................................................92

3.6.1 Worker Safety ..........................................................................................................94

3.6.2 Public Health............................................................................................................97

3.7 Cotton and Soybean Production as Related to the Affected Environment..............98

4 POTENTIAL ENVIRONMENTAL CONSEQUENCES ...................................................100

4.1 No Action Alternative ...........................................................................................100

4.1.1 Land Use and Acreage ...........................................................................................100

4.1.2 Socioeconomics .....................................................................................................103

4.1.3 Agronomic Practices in Cotton and Soybean Production......................................109

4.1.4 Health and Safety for Livestock and Humans .......................................................117

4.1.5 Animal Communities.............................................................................................119

4.1.6 Plant Communities.................................................................................................120

4.1.7 Soil Microorganisms..............................................................................................122

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4.1.8 Water......................................................................................................................123

4.1.9 Air Quality .............................................................................................................124

4.1.10 Climate Change......................................................................................................124

4.2 Preferred Alternative .............................................................................................124

4.2.1 Land Use ................................................................................................................125

4.2.2 Socioeconomics .....................................................................................................125

4.2.3 Agronomic Practices in Cotton and Soybean Production......................................126

4.2.4 Health and Safety for Livestock and Humans .......................................................128

4.2.5 Biological Resources .............................................................................................130

4.2.6 Physical Environment ............................................................................................132

4.3 Potential Environmental Consequences - Alternative 3........................................133

4.4 Potential Environmental Consequences - Alternative 4........................................133

5 CUMULATIVE IMPACTS.................................................................................................135

5.1 Cumulative Impacts Methodology ........................................................................136

5.2 Geographic Boundaries for the Analysis of Cumulative Effects ..........................136

5.3 Proposed New Dicamba Uses and EPA Risk Assessments ..................................136

5.4 No Action Alternative. Current Management Practices Considered in the Analysis 

of Cumulative Impacts ..........................................................................................138

5.5 Assumptions..........................................................................................................141

5.6 Preferred Alternative: Cumulative Impact ...........................................................142

5.6.1 Land Use and Acreage ...........................................................................................143

5.6.2 Agronomic Practices..............................................................................................143

5.6.3 Socioeconomics .....................................................................................................156

5.6.4 Health and Safety for Livestock and Humans .......................................................171

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5.6.5 Biological Resources .............................................................................................172

5.6.6 Physical Environment ............................................................................................193

5.7 Cumulative Impacts - Alternative 3.......................................................................194

5.7.1 Agronomic Practices..............................................................................................194

5.7.2 Health and Safety Aspects for Livestock and Humans..........................................195

5.7.3 Biological Resources .............................................................................................195

5.7.4 Physical Environment ............................................................................................195

5.8 Cumulative Impacts - Alternative 4.......................................................................196

5.8.1 Agronomic Practices..............................................................................................196

5.8.2 Health and Safety Aspects for Livestock and Humans..........................................196

5.8.3 Biological Resources .............................................................................................196

5.8.4 Physical Environment ............................................................................................197

6 OTHER IMPACTS AND MITIGATION MEASURES.....................................................198

6.1 Unavoidable Impacts.............................................................................................198

6.2 Short Term Versus Long Term Effects .................................................................198

6.3 Irreversible Resource Commitments.....................................................................198

6.4 Mitigation Measures..............................................................................................199

7 THREATENED AND ENDANGERED SPECIES ............................................................200

7.1 Requirements for Federal Agencies ......................................................................200

7.2 Potential Effects of MON 88701 Cotton and MON 87708 Soybean on TES .......201

7.2.1 Potential Effects of MON 88701 Cotton on TES Plant Species............................202

7.2.2 Potential Effects of MON 88701 Cotton on TES Animal Species........................205

7.2.3 Summary of Potential Effects of MON 88701 Cotton on TES Species................208

7.2.4 Potential Effects of MON 87708 Soybean on TES Plant Species.........................208

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7.2.5 Potential Effects of MON 87708 Soybean on TES Animal Species.....................210

7.2.6 Summary of Potential Effects of MON 87708 Soybean on TES...........................211

8 CONSIDERATION OF EXECUTIVE ORDERS, STANDARDS, AND TREATIES 

RELATING TO ENVIRONMENTAL IMPACTS ......................................................213

8.1 Executive Orders with Domestic Implications......................................................213

8.2 International Implications......................................................................................216

8.3 Compliance with Clean Water Act and Clean Air Act..........................................218

8.4 Impacts on Unique Characteristics of Geographic Areas......................................218

8.5 National Historic Preservation Act (NHPA) of 1966 as Amended .......................219

9 LIST OF PREPARERS........................................................................................................220

10 DISTRIBUTION LIST FOR THIS FEIS ............................................................................225

11 BIBLIOGRAPHY................................................................................................................227

12 INDEX 276

xvi
List of Figures

Figure 1. Upland Cotton 2012 Yield per Harvested Acre by County for Selected States............ 27

Figure 2. Soybeans 2012 Yield per Harvested Acre by County for Selected States. ................... 29

Figure 3. Major Soybean and Cotton Cultivation Regions in the United States. ......................... 30

Figure 4. Ecoregions of the Conterminous United States............................................................. 31

Figure 5. U.S. Croplands with High Erosion Rates. ..................................................................... 40

Figure 6. Examples of Cotton Irrigation Systems: A=furrow, B=drip method, C=low energy 

precision application. .................................................................................................................... 41

Figure 7. Irrigated Cotton Acreage in the United States in 2007.................................................. 42

Figure 8. Irrigated Soybean Acreage in the United States in 2007.............................................. 43

Figure 9. Cropping Patterns for Soybeans and Cotton in the United States................................. 75

Figure 10. States of the United States Reported to Have Populations of Dicamba-, 2,4-D-, and 

Glufosinate-Resistant Weeds........................................................................................................ 82

Figure 11. Cotton Water Use and Average Water Use Efficiency Compared to Other Crops, 

2003/2004. .................................................................................................................................... 84

Figure 12. A Recent Compilation of Drought Affected Areas in the United States..................... 85

Figure 13. Acres of Upland and Pima Cotton Planted and Harvested from 1993 to 2013......... 101

Figure 14. Acres of Soybeans Planted and Harvested from 1993 to 2013. ................................ 102

Figure 15. Domestic Mill Use and Exports of U.S. Upland Cotton with Projections Through 

2022............................................................................................................................................. 104

Figure 16. Projections of U.S. Soybean Domestic Use and Exports to 2023............................. 105

Figure 17. Projections of Global Cotton Exports to 2023. ......................................................... 106

Figure 18. Projections of Global Cotton Imports to 2023. ......................................................... 107

Figure 19. Projected U.S. Global Exports of Soybeans, Soybean Meal, and Soybean Oil. ....... 107

Figure 20. Projections of Global Soybean Exports to 2023........................................................ 108

Figure 21. Projections of Global Soybean Imports to 2023........................................................ 108

xvii
xviii
List of Tables

Table 1. Summary of Issues and of Potential Impacts of the Alternatives. .................................. 17

Table 2. Location of Major Cotton and Soybean Production Areas............................................. 32

Table 3. Dominant and Major Secondary Soil Types by Region. ................................................ 38

Table 4. Total Farm Diesel Fuel Consumption by Tillage Method.............................................. 48

Table 5. Comparison of NLCD 2006 Land Cover Groups with Classes in This Document........ 52

Table 6. Land Cover Composition by Region. ............................................................................. 54

Table 7. Major Cultivated Crops by Region in 20121. ................................................................. 57

Table 8. Major Arthropod Pests of Soybean................................................................................. 63

Table 9. Major Arthropod Pests of Cotton.................................................................................... 65

Table 10. Major Beneficial Arthropods in Soybean and Cotton .................................................. 67

Table 11. Commonly Used Insecticides for Cotton Pests............................................................. 78

Table 12. Summary of Trends in U.S. Cotton and Soybean Production, Resource Use and Impact 

from 1980-2011............................................................................................................ 99

Table 13. Tillage Practices by Crop, 2007.................................................................................. 110

Table 14. Comparison of Water Needs and Drought Sensitivity for Some Globally Important 

Crops........................................................................................................................................... 123

Table 15. Status of Import Approvals of MON 88701 Cotton in Key U.S. Cotton Export 

Markets....................................................................................................................... 126

Table 16. Status of Import Approvals of MON 87708 Soybean in Key U.S. Soybean Export 

Markets....................................................................................................................... 126

Table 17. Summary of Dicamba Use on U.S. Agricultural Crops.............................................. 139

Table 18. Acres and Percentages of Cotton Acres Treated with Non-Glyphosate Herbicides... 149

Table 19. Rotational Practices Following Soybean Production in the United States. ................ 154

Table 20. Rotational Practices Following Cotton Production in the United States.................... 155

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Table 21. Percent of Regional Cropland Devoted to Crops on which Dicamba is Used in Each 

EcoRegion. ................................................................................................................. 158

Table 22. Post-emergence Broadleaf Herbicides Commonly Used in Pastures and Rangeland. 160

Table 23. Changes in Dicamba Application to Crops 2006-2012. ............................................. 161

Table 24. Post-emergence Broadleaf Herbicides Currently Approved for Use in Wheat, Barley, 

Oats, and Rye. ............................................................................................................ 162

Table 25. Herbicides Available for Use on Fallow and for Burndown. ..................................... 165

Table 26. Post-emergence Broadleaf Herbicides Currently Available for Use on Sorghum. .... 167

Table 27. Known Weed Resistance in the Southern United States.1.......................................... 179

Table 28. Known Weed Resistance in the Midwestern United States........................................ 180

Table 29. Auxin-Resistant Weeds............................................................................................... 185

Table 30. Novel Proteins Associated with MON 87708 Soybean and MON 88701 Cotton...... 202

xx
List of Appendices

Appendix 1. USDA Notifications and States Approved for Environmental Releases of MON 

88701 Dicamba- and Glufosinate-Resistant Cotton and MON 87708 DicambaResistant Soybean 

Appendix 2. Summary of Public Comments 

Appendix 3. Weed Management and Herbicide Use

Appendix 4. Herbicide Use Trends and Predicted Dicamba Use on Dicamba-Resistant Soybean 

and Cotton

Appendix 5. Common Weeds in Cotton and Soybean

Appendix 6. Herbicide Resistance

Appendix 7. Off-Target Pesticide Movement

Appendix 8. EPA Assessment of Herbicides Used on MON 87708 Soybean and MON 88701 

Cotton

Appendix 9. Monsanto Tillage Report

Appendix 10. EPA Resistance Management Requirements for Registration of Dow 

Agrosciences Enlist DuoTM

Appendix 11. Response to Comments on the DEIS

xxi
Acronyms and Abbreviations

§ section

2,4-D 2,4-dichlorophenoxyacetic acid

ae acid equivalent

a.i. active ingredient

ALS acetolactate synthase

AMS Agricultural Marketing Service (USDA)

APHIS Animal and Plant Health Inspection Service (USDA)

AQI Air Quality Index

ARMS Agricultural Resource Management Survey

ARS Agricultural Research Service (USDA)

BMPs best management practices

BNF biotechnology notification file

BRS Biotechnology Regulatory Services (USDA)

Bt Bacillus thuringiensis

CBD Convention on Biological Diversity

CEC Canada-Mexico-U.S. Commission for Environmental Cooperation

CFR Code of Federal Regulations

DAS Dow AgroSciences

DCSA 3,6-dichlorosalicylic acid

DEIS Draft Environmental Impact Statement

DGA diglycolamine

DMA dimethylamine

DMO dicamba mono-oxygenase

DNA deoxyribonucleic acid

EA environmental assessment

EFED Environmental Fate and Effects Division (EPA)

EIS environmental impact statement

EPA U.S. Environmental Protection Agency

EPSPS 5-enolpyruvylshikimate-3-phosphate synthase

ER environmental report produced by the petitioner for nonregulated status

ERS Economic Research Service (USDA)

ESA Endangered Species Act

EO Executive Order

FDA U.S. Food and Drug Administration

FFDCA Federal Food, Drug, and Cosmetic Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

fl oz/A fluid ounces per acre

FQPA Food Quality Protection Act

FSANZ Food Standards Australia New Zealand

GE genetically engineered

GHG greenhouse gases

GR glyphosate resistant

xxii
HED Health Effects Division (EPA)

HPPD 4-hydroxyphenylpyruvate dioxygenase

HR herbicide resistant

HRAC Herbicide Resistance Action Committee 

IPCC Intergovernmental Panel on Climate Change

IPM Integrated Pest Management

IPPC International Plant Protection Convention

IWM integrated weed management

MGI mesotrione, glufosinate, isoxaflutole

MOA mode of action

MOU memorandum of understanding

MCPA (4-chloro-2-methylphenoxy) acetic acid/2-Methyl-4-

chlorophenoxyacetic acid

NASS National Agricultural Statistics Service (USDA)

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NLCD National Land Cover Dataset

NO2 nitrogen dioxide

NOI Notice of Intent

NOP National Organic Program

NPS nonpoint source

NRC National Research Council

NRCS Natural Resources Conservation Service

NTSR non-target site-specific resistance

OECD Organization for Economic Co-operation and Development

OPP Office of Pesticide Programs (EPA)

PAT phosphinothricin acetyltransferase

PM particulate matter

PM2.5 particulate matter with aerodynamic diameter of 2.5 micrometer or less

PM10 particulate matter with aerodynamic diameter of 10 micrometer or less 

POST postemergence in-crop use

PPA Plant Protection Act

PPE personal protective equipment

ppm parts per million

PPO protoporphyrinogen oxidase

PPRA plant pest risk assessment

PRA pest risk analysis

PRE pre-plant/pre-emergence application to the crop

PSII Photosystem II

SOA site of action

SOM soil organic matter

TES threatened and endangered species

Tg CO2 Eq teragrams of CO2 Equivalent

USDA U.S. Department of Agriculture

xxiii
USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

WSSA Weed Science Society of America

xxiv
1 PURPOSE AND NEED

This document is intended to ensure compliance with the National Environmental Policy Act 

(NEPA). NEPA requires agencies to prepare an environmental impact statement (EIS) to be 

included in “every recommendation or report on proposals for legislation and other major 

Federal actions significantly affecting the quality of the human environment” (42 U.S.C. 

§4332(2)(C)).

The United States Department of Agriculture (USDA) Animal and Plant Health Inspection 

Service (APHIS) is currently engaged in decisionmaking relevant to its statutory authority to 

regulate two genetically engineered (GE) varieties as potential plant pests. The Agency has 

determined that there are possible environmental impacts associated with whatever regulatory 

decision it renders. Therefore, this document has been prepared as part of this APHIS 

decisionmaking process.

1.1 Introduction

Summarized as “Protecting American Agriculture,” the mission of USDA APHIS3 is: “To 

protect the health and value of American agriculture and natural resources.” To achieve its 

mission, APHIS regulates plant and animal health. It integrates these regulatory functions to 

protect and promote United States domestic agricultural production, commodities, and trade in 

agricultural products in a manner that prevents or minimizes impacts on the environment.

To implement its plant protection mission, the Agency establishes policies and measures to 

prevent the introduction of plant pests into the United States. It also promotes management of 

those plants, animals, and microorganisms that currently occur within the U.S. and cause 

economic losses to U.S. agriculture, including commercial and non-commercial production of 

crops and ornamental plants. Its mission encompasses all practices and technologies that have the 

potential to impact plant pest risks, either by increasing or reducing them.

One practice overseen by the APHIS plant protection mission is the use of genetic engineering to 

modify plant agronomic properties. The Agency has regulatory authority to ensure that 

applications of genetic engineering technology are unlikely to pose a plant pest risk

Principles of biochemistry and molecular biology underlie the current understanding of genetic 

inheritance. The mechanisms involved provide the theoretical framework for modern 

biotechnology. Genetic engineering is one application of biotechnology. It enables the precise 

manipulation (insertion or deletion) of one or more selected genetic traits (genes) into the 

genome of an organism without sole dependence on the secual compatibility of traditional 

breeding (cross-breeding principles of classical Mendelian genetics of inheritance). As a result, 

modern biotechnology makes possible the transfer of highly specific, individual, beneficial 

3 For more details about the APHIS mission, visit http://www.aphis.usda.gov/about_aphis/

1

 
genetic traits between unrelated species. As part of its statutory and regulatory authority to 

regulate plant pests, APHIS must examine and determine that a certain GE (genetically 

engineered) organism or product, which is a plant pests or which there is reason to believe is a 

plant pest, is unlikely to pose a greater plant pest risk than the unmodified organism from which 

it was derived.

The APHIS regulatory authority (see Section 1.2 for a general summary) over GE organisms is 

limited to those with the potential to be plant pests. The Agency performs extensive, sciencebased analyses to evaluate the plant pest potential of each organism regulated for which a 

petition for nonregulated status has been submitted. Results are documented in a plant pest risk 

assessment (PPRA). If the conclusion of the PPRA is that a GE organism is unlikely to pose a 

plant pest risk, the Agency must determine that it does not regulate that organism as a plant pest.

Regardless of its decision (either not to regulate or continue regulating) for a particular article 

(i.e., organism) that has not been released previously into the environment, the Agency also 

assesses whether or not its decision is likely to cause an environmental impact(s), and if so, 

examines the environmental impacts of its determination to comply with regulations codified 

under NEPA. The results of the examination APHIS has performed, relevant to two new GE 

organisms it currently regulates, are the subject of this document.

1.2 APHIS Regulatory Authority

The Plant Protection Act of 2000 (PPA), as amended (7 U.S.C. §§ 7701–7772), provides the 

legal authorization for the APHIS plant protection mission. It authorizes the Agency to regulate 

the introduction of potential plant pests into the territorial boundaries of the U.S., and their 

interstate movement within U.S. boundaries by establishing quarantine, eradication and control 

programs. Implementing rules, regulations and guidelines for this enabling legislation (PPA) are 

codified in Title 7 of the U.S. Code of Federal Regulations (CFR). Rules that implement this 

authority specific to GE organisms have been published in 7 CFR part 340.

1.3 Requirement for This Document

When APHIS receives a petition for nonregulated status of an article currently regulated under

its PPA authority codified in 7 CFR part 340, the Agency is required to make a decision. As a 

Federal agency, APHIS must also comply with applicable U.S. environmental laws and 

regulations because a decision on a petition for nonregulated status, whether positive or negative, 

is a final Agency action that might cause environmental impact(s).

This document addresses both of these requirements relevant to decisionmaking for two petitions 

submitted by Monsanto Company, St. Louis, Missouri (henceforth referred to as Monsanto): 

APHIS Petition 10-188-01p for MON 87708 soybean (Monsanto, 2012a) and APHIS Petition 

12-185-01p for MON 88701 cotton (Monsanto, 2012b). Each petition seeks a determination of 

2
nonregulated status respectively for two new GE cultivars: a soybean and a cotton variety 

engineered for resistance4 to certain herbicides. Monsanto has presented data in these petitions to 

support its claims that each variety does not present a plant pest risk, so should not be regulated 

by APHIS under the PPA and 7 CFR part 340.

Both varieties described here are currently regulated under 7 CFR part 340. Interstate movement 

and field trials of each (MON 87708 soybean and MON 88701 cotton) were conducted under 

permits issued or notifications acknowledged by APHIS between 2005 and 2012. The field trials 

were conducted within selected growing areas in the U.S. (see Appendix 1 for a list of 

notifications and states approved for environmental releases for each of the petitions). Data from 

field trials of each variety are reported in the petitions (Monsanto, 2012a; 2012b) and analyzed in 

separate PPRAs prepared by APHIS (USDA-APHIS, 2014d; 2014e).

If APHIS makes a determination of nonregulated status for each of these GE varieties, they will 

cease to be subject to the PPA and regulations in 7 CFR part 340. If they are no longer regulated, 

non-regulated status will extend to crosses between these varieties and conventional (non-GE) 

cultivars, and other biotechnology-derived varieties classified previously by APHIS as not 

subject to regulation as plant pests under the PPA and 7 CFR part 340. Those not subject to 

regulation are those for which a petition for nonregulated status was submitted, and which were 

classified as nonregulated, and those for which a letter of inquiry was submitted and over which 

APHIS decided the agency had no jurisdiction.

1.4 Purpose of These Products

Monsanto has developed herbicide-resistant (HR) MON 87708 soybean that is tolerant to 

dicamba herbicide and MON 88701 cotton that is tolerant to dicamba and glufosinate. Dicamba 

provides effective control of more than 95 annual and biennial weed species, and suppression of 

over 100 perennial broadleaf and woody plant species. Dicamba is efficacious on broadleaf 

weeds that are difficult to control with glyphosate (e.g., common lambsquarters, hemp sesbania, 

morning glory species, nightshade, Pennsylvania smartweed, prickly sida, velvetleaf, waterhemp 

and wild buckwheat). Hard-to-control weeds generally require a higher treatment rate and/or 

more frequent applications at a smaller growth stage in order to consistently achieve 

commercially acceptable control. See the Roundup WeatherMax® label (U.S. EPA Reg. No. 524-

537) for a listing of these weeds.

4 “Resistance” is defined by the Herbicide Resistance Action Committee (HRAC) as the inherited ability of a plant

population to survive and reproduce following repeated exposure to a dose of herbicide normally lethal to the wild type 

(Herbicide-Resistance-Action-Committee, 2013)Resistance may be induced by genetic engineering or selection of variants

produced by tissue culture or mutagenesis (Herbicide-Resistance-Action-Committee, 2013)HRAC applies a different 

meaning to the term “tolerance,” defining it as the inherent ability of a plant to survive and reproduce after herbicide

treatment. Survival of a tolerant plant implies that there was no selection or genetic manipulation to make it tolerant; it is

naturally tolerant (Herbicide-Resistance-Action-Committee, 2013). These terms are sometimes used interchangeably. For 

this document, the term “herbicide resistance” has been used consistent with that of HRAC. It can be construed as 

synonymous with the term “herbicide tolerance” as used in the petitioner’s documents. HRAC (2013). Guideline to the 

management of herbicide resistance." http://www.hracglobal.com/Education/ManagementofHerbicideResistance.aspx

3

 
Dicamba also provides effective control of HR weeds, including GR weeds such as marestail, 

common ragweed, giant ragweed, palmer pigweed, and waterhemp. HR weeds are those listed on 

the International Survey of Resistant Weeds website (www.weedscience.org).

MON 87708 soybean and MON 88701 cotton would provide growers with alternatives to 

currently available GE HR soybean and cotton varieties (Monsanto, 2012a; 2012b). Most GE 

HR crops in the United States have historically included only a glyphosate-resistant (GR) trait 

for weed control. This has limited the diversity of herbicides used for weed management, and 

resulted in intense reliance on glyphosate. This has been accompanied by a corresponding 

increase in GR weeds that commonly occur in soybean, cotton, and other crops (USDAAPHIS, 2014d; 2014e). Each of these varieties (MON 87708 soybean and MON 88701 cotton) 

will increase weed-management options available to growers. These additional options for 

weed control and flexibility will provide more diverse strategies for growers to control HR 

weeds. More details about these new varieties follow.

1.4.1 MON 87708 Soybean

APHIS Petition 10-188-01p is for a GE soybean (Glycine max) variety designated as MON 

87708 soybean. It is engineered for increased resistance to the broadleaf herbicide dicamba (3,6-

dichloro-2-methoxybenzoic acid). MON 87708 soybean contains a gene from Stenotrophomonas 

maltophilia (an aerobic gram-negative bacillus that is found in soil, water and plants) that 

expresses a mono-oxygenase enzyme that rapidly demethylates dicamba rendering it inactive, 

thereby conferring resistance to dicamba. This dicamba mono-oxygenase (DMO) protein rapidly 

demethylates dicamba to the herbicidally inactive metabolite 3,6-dichlorosalicylic acid (DCSA), 

a known soybean, soil, and livestock metabolite of dicamba.

MON 87708 soybean offers growers an expanded use of dicamba in soybean production from 

the current preplant and preharvest labeled uses. MON 87708 dicamba-resistant soybean will 

allow growers to make pre-emergence applications up to crop emergence. Postemergence 

applications through the early reproductive (R1/R2) growth stages (R1/R2; beginning to full 

flowering) will also be allowed.

Monsanto has requested a registration from the EPA for the expanded use pattern of dicamba 

described here for MON 87708 soybean, an establishment of new tolerances for dicamba in 

soybean forage and hay and the inclusion of DCSA in the residue definitions for these

(Monsanto, 2012a). Modification of the current soybean seed 10 ppm tolerance is not being 

requested.

As indicated in Section 1.3, if MON 87708 soybean is no longer regulated, non-regulated status 

will extend to crosses between MON 87708 soybean and conventional (non-GE) soybean 

cultivars, and those GE soybean varieties no longer subject to regulation as plant pests under the 

PPA and 7 CFR part 340. Monsanto has indicated it intends to cross MON 87708 soybean with 

MON 89788 (Roundup Ready 2 Yield soybean) utilizing traditional breeding techniques, 

producing a soybean variety with resistance to both dicamba and glyphosate (Monsanto, 2012a).

4
1.4.2 MON 88701 Cotton

APHIS Petition 12-185-01p is for a GE cotton (Gossypium hirsutum) variety designated as event 

MON 88701 cotton that is engineered to express resistance to the herbicides dicamba and 

glufosinate. MON 88701 provides a wider dicamba window of application beyond the current 

preplant cotton uses and glufosinate application rates and timings that are equivalent to current 

commercial glufosinate-tolerant cotton. The combined effects of these two traits enable MON 

88701 cotton to outcompete weed species, which increases productivity of cotton fiber.

MON 88701 cotton contains a demethylase gene from Stenotrophomonas maltophilia that 

expresses a dicamba mono-oxygenase (DMO) protein to confer resistance to dicamba. The DMO 

protein rapidly demethylates dicamba to the herbicidally inactive metabolite DCSA. DCSA has 

previously been identified as a metabolite of dicamba in cotton, soybean, livestock, and soil

(Reeves and Weihrauch, 1979). DCSA, in addition to dicamba, is included in the current 10 ppm 

pesticide residue tolerance for soybean seed that supports the existing uses of dicamba on 

commercial soybean (40 CFR § 180.227). Even with the expanded use of dicamba on MON 

87708, compared to commercial soybean uses, the rapid metabolism of dicamba results in 

residues in dicamba-treated MON 87708 cotton seed, including the DCSA metabolite, that are 

well below the established 10 ppm tolerance, and therefore no modification to the existing 

soybean seed tolerance is needed. Consequently, Monsanto has requested of EPA only approval 

for the expanded use pattern of dicamba on MON 87708 cotton.

MON 88701 cotton will extend the application window beyond the current EPA preplant cotton 

uses of dicamba. If the EPA approves the new uses of dicamba on MON 88701 cotton

(Monsanto, 2014b), in-crop applications of dicamba would be allowed from preemergence to 

seven days preharvest. 

Monsanto has requested a registration from the EPA for the expanded uses of dicamba described 

here for MON 88701 cotton, an increase in the dicamba residue tolerance for cottonseed, the 

establishment of a tolerance for cotton gin by-products, and the inclusion of DCSA in the residue

definitions for both cottonseed and gin by-products. No other revisions to the dicamba pesticide 

residue tolerances are necessary, including those for animal products such as meat, eggs, and 

milk (Monsanto, 2012b). 

MON 88701 cotton also contains a bialaphos resistance (bar) gene from Streptomyces 

hygroscopicus that expresses the phosphinothricin N-acetyltransferase (PAT) protein to confer 

resistance to glufosinate. The PAT (bar1) protein acetylates the free amino group of glufosinate 

to produce non-herbicidal N-acetyl glufosinate. Glufosinate application rates and timings on 

MON 88701 cotton would be equivalent to the existing uses approved for glufosinate-resistant

cotton. Glufosinate applications for broad spectrum weed control would continue to be allowed 

from emergence through early bloom growth stage. Therefore, no changes in the existing 

glufosinate label will be requested by Monsanto. Monsanto is not seeking any changes in 

glufosinate residue tolerances.

5
As indicated in Section 1.3, if MON 88701 cotton is no longer regulated, non-regulated status 

will extend to crosses between MON 88701 cotton and conventional (non-GE) cotton cultivars, 

and those GE cotton varieties no longer subject to regulation as plant pests under the PPA and 7 

CFR part 340. Monsanto has indicated plans to stack MON 88701 cotton with Roundup Ready 

Flex Cotton and Bollgard II (MON 88913 and MON 15985) (Monsanto, 2013a). Roundup Ready 

Flex Cotton (MON 88913) is GE to exhibit resistance to glyphosate. Bollgard II (MON 15985) 

contains the Cry1Ac and Cry2Ab insecticidal proteins providing protection from feeding by a 

range of Lepidopteran species including: tobacco budworm (Heliothis virescens), pink bollworm 

(Pectinophora gossypiella), cotton bollworm (Helicoverpa zea), cabbage looper (Trichoplusia 

ni), saltmarsh caterpillar (Estigmene acrea), cotton leaf perforator (Bucculatrix thurbeiella), 

soybean looper (Pseudoplusia includens), beet armyworm (Spodoptera exigua), fall armyworm 

(Spodoptera frugiperda), yellowstriped armyworm (Spodoptera ornithogolli) and European corn 

borer (Ostrinia nubilalis) (Convention on Biological Diversity, 2014).

1.5 Coordinated Regulatory Framework for Genetically-Engineered Organisms

The U.S. government has regulated GE organisms since 1986 under a Federal policy statement

published in the Federal Register (51 FR 23302; 57 FR 22984) entitled “The Coordinated 

Framework for the Regulation of Biotechnology” (henceforth referred to here as the Coordinated 

Framework). The Coordinated Framework, published by the Office of Science and Technology 

Policy, describes the comprehensive Federal regulatory policy for ensuring the safety of 

biotechnology research and products. It also explains how Federal agencies will use existing 

Federal statutes to ensure public health and environmental safety, while maintaining regulatory 

flexibility to avoid impeding the growth of the biotechnology industry.

Three central guiding principles form the basis for the Coordinated Framework. Agencies:

1) should define those transgenic organisms subject to review to the extent permitted by

their respective statutory authorities;

2) are required to focus on the characteristics and risks of a biotechnology product, not the 

process by which it was created; and

3) are intended to exercise oversight of GE organisms when there is evidence of 

“unreasonable” risk.

The Coordinated Framework explains the regulatory roles and authorities for the three major 

agencies involved in regulating GE organisms: USDA APHIS, the EPA, and the U.S. Food and 

Drug Administration (FDA). A summary of each agency’s role follows.

1.5.1 USDA-APHIS

As noted in Section 1.2, the PPA authorizes APHIS to regulate, manage and control plant pests. 

The PPA includes regulatory authority over the introduction (i.e., importation, interstate 

movement, or release into the environment) of certain GE organisms and products. A GE 

6
organism is considered a regulated article if the donor organism, recipient organism, vector, or 

vector agent used in engineering the organism belongs to one of the taxa listed in the regulation 

(7 CFR part 340.2) and is also considered a plant pest. A GE organism is also regulated under 7 

CFR part 340, when APHIS has reason to believe that the GE organism may be a plant pest, or 

APHIS does not have sufficient information to determine if the GE organism is unlikely to pose

a plant pest risk. A GE organism is no longer subject to the plant pest provisions of the PPA or to 

the regulatory requirements of 7 CFR part 340, when APHIS determines that it is unlikely to 

pose a plant pest risk.

An individual may petition the Agency for a determination that a particular regulated article is 

unlikely to pose a plant pest risk, and should not be regulated under the plant pest provisions of 

the PPA or the regulations at 7 CFR part 340. Under §340.6(c)(4), the petitioner must provide 

information related to plant pest risk that the Agency can use to determine whether or not a 

regulated article is a plant pest risk. A GE organism or other regulated article is subject to the 

regulatory requirements of 7 CFR part 340 of the PPA until APHIS determines that it is unlikely 

to be a plant pest risk.

1.5.2 Environmental Protection Agency

The EPA is authorized under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 

U.S.C. 136 et seq.) to regulate the sale, distribution, and use of pesticides. Its authority includes 

herbicides and those that are expressed by an organism modified using techniques of modern 

biotechnology. The latter are classified by the EPA as plant-incorporated protectants. The EPA 

also regulates certain biological control organisms under the Toxic Substances Control Act (15 

U.S.C. 53 et seq.). Before planting a crop containing plant-incorporated protectants, an 

individual or company must seek an experimental use permit from EPA. Commercial production 

of crops containing plant-incorporated protectants for purposes of seed increase and sale requires 

a FIFRA Section 3 registration with the EPA.

Under FIFRA (7 U.S.C. 136 et seq.), the EPA requires registration of all pesticide products for 

all specific uses prior to distribution for sale. Before granting a registration, the EPA evaluates 

the following: toxicity of the ingredients of a pesticide product; the particular site or crop on 

which it is to be used; the amount, frequency, and timing of its use; storage and disposal 

requirements. Prior to registration for a new use for a new or previously registered pesticide, the 

EPA must determine through specified test protocols conducted by the applicant that the 

pesticide does not cause unreasonable adverse effects on humans, the environment, and nontarget species, when used in accordance with label instructions. The EPA is authorized under 

FIFRA to make these determinations on the basis of benefits exceeding associated risks of a 

pesticide. The EPA establishes restrictions that ensure that this test is met by approving specific 

language used on the pesticide label in accordance with 40 CFR part 158.

Once registered, a pesticide may only be legally used in accordance with directions and 

restrictions on its label. The purpose of the label is to provide clear directions for effective 

product performance, while minimizing risks to human health and the environment. The Food 

Quality Protection Act (FQPA) of 1996, (Pub. L. No. 104 – 170) amended FIFRA, requiring the 

7
EPA to implement periodic registration reviews of pesticides to ensure they are meeting current 

scientific and regulatory standards of safety and continue to have no unreasonable adverse 

effects (US-EPA, 2011d).

The EPA also sets tolerances (maximum residue levels) or establishes an exemption from the 

requirement for a tolerance, under the Federal Food, Drug, and Cosmetic Act (FFDCA). A 

tolerance is the amount of pesticide residue that can remain on or in food for human consumption 

or animal feed. Before establishing a pesticide tolerance, the EPA is required to reach a safety 

determination based on a finding of reasonable certainty of no harm under the FFDCA, as 

amended by the FQPA.

1.5.3 Food and Drug Administration

The FDA enforces pesticide tolerances set by EPA. The FDA also oversees market introduction 

of GE foods under the authority of the FFDCA (21 U.S.C. 301 et seq). The FDA published its 

policy statement concerning oversight for products derived from new plant varieties, including 

those derived from genetic engineering, on May 29, 1992 (57 FR 22984). Under this policy, the 

FDA implements a voluntary consultation process to ensure that human food and animal feed 

safety issues or other regulatory issues, such as labeling, are resolved before commercial 

distribution of food derived from GE products. This voluntary consultation process provides a 

way for developers to receive assistance from the FDA to comply with obligations under Federal 

food safety laws prior to marketing.

In June 2006, the FDA also published recommendations in “Guidance for Industry: 

Recommendations for the Early Food Safety Evaluation of New Non-Pesticidal Proteins 

Produced by New Plant Varieties Intended for Food Use” (US-FDA, 2014 (updated)). This 

establishes voluntary food safety evaluations for new non-pesticidal proteins produced by new 

plant varieties intended to be used as food, including GE plants. Early food safety evaluations 

help ensure that potential food safety issues related to a new protein in a new plant variety are 

addressed early in development. These evaluations are not intended as a replacement for a 

biotechnology consultation with the FDA, but the information may be used later in the 

biotechnology consultation.

1.6 Purpose and Need for this APHIS Action

APHIS is required to respond, consistent with its PPA authority and regulations at 7 CFR part 

340.6, to two petitions submitted by Monsanto. As noted previously in Section 1.3, each petition 

is for a different GE HR event: APHIS Petition 10-188-01p for MON 87708 soybean (Monsanto, 

2012a) and APHIS Petition 12-185-01p for MON 88701 cotton (Monsanto, 2012b).

In its submissions, the petitioner has provided information consistent with that described in 

§340.6(c)(4), which APHIS requires to inform it of the full range of biological and chemical 

properties of GE organisms, so the Agency can assess the plant pest risk(s) of each, and 

determine if they are unlikely to be a greater plant pest risk than the unmodified organisms from 

which they were derived. Therefore, APHIS must respond to the petitions from Monsanto that 

8
are the subject of this document. If the Agency determines that each GE-regulated article is 

unlikely to be a plant pest risk, it is no longer subject to the provisions of the PPA as 

implemented by the regulations of 7 CFR part 340.

As noted in Section 1.1, under the provisions of NEPA as amended (42 U.S.C. 4321 et seq), 

prior to implementation, Federal agencies must examine the potential impacts of proposed major 

actions that may significantly affect the quality of the human environment. In accordance with 

NEPA, regulations of the Council on Environmental Quality (CEQ) for implementing the 

procedural provisions of NEPA (40 CFR parts 1500-1508), USDA regulations implementing 

NEPA (7 CFR part 1 b), and the NEPA Implementing Procedures (7 CFR part 372) of APHIS, 

the Agency has considered how to properly examine the potential environmental impacts of its 

decisions for petitions for determination of nonregulated status.

For most petitions for a determination of nonregulated status of GE organisms that APHIS has 

evaluated previously, it has prepared an environmental assessment (EA) to provide the APHIS 

decisionmaker with a review and analysis that identifies whether there may be any significant 

environmental impacts. If the Agency makes a finding of no significant impact (FONSI), the 

NEPA process stops and a decision is issued. If significant environmental impacts are identified, 

the process continues with the preparation of an EIS before a determination is made.

For MON 87708 soybean and MON 88701 cotton, APHIS did not decide, a priori, to prepare an 

EIS based on the finding of significant environmental impact. Instead, as noted in the Notice of 

Intent to Prepare an EIS, the decision was discretionary on the part of APHIS based on public 

concerns about the potential environmental impacts associated with the increased use of certain 

herbicides and possible selection for and spread of weeds resistant to the herbicide dicamba 

alone or weeds resistant to dicamba and other herbicides with different modes of action (multiple 

resistance). Because of the likely socioeconomic impacts that would result in the event that 

dicamba-resistant weeds would be selected for from the potential increased use of dicamba, 

APHIS concluded these impacts were at minimum uncertain and perhaps significant in certain 

areas under certain conditions. Therefore, APHIS decided that, for the Monsanto varieties that 

are the subject of this analysis an EIS would be prepared to further analyze the potential for 

selection of dicamba-resistant weeds and other potential impacts that might occur from making 

determinations of nonregulated status for these varieties. This EIS limits its analysis of herbicide 

use to the potential cumulative impacts that may occur from the selection for herbicide resistant 

weeds and the changes in management practices that may result. This EIS provides Agency 

decisionmakers with a mechanism for examining the potential broad and cumulative impacts on 

the quality of the human environment that may result from determinations of nonregulated status. 

APHIS has prepared this EIS to be consistent with NEPA/CEQ regulations and USDA-APHIS 

NEPA-implementing regulations and procedures (7 CFR part 1 b, 7 CFR part 372, 40 CFR parts 

1500-1508).

1.7 Public Involvement

APHIS seeks public comment on petitions it receives that request a decision of non-regulatory 

status for GE organisms. When the Agency decides to prepare an EIS as part of its 

9
decisionmaking process for a petition, prior to preparation, it also seeks public comments as part 

of its advance scoping process. Details about the public involvement process for the petitions 

that are the subject of this document follow.

1.7.1 Public Comments for Petitions 10-188-01p and 12-185-01p

APHIS sought comments for the petitions that are the subject of the EIS in a Federal Register

notice dated July 13, 2012 and February 27, 2013. Comments received for the petitions were 

influential, though not the sole basis, for the Agency’s decision to prepare this DEIS. As part of 

its scoping process to identify issues to address in this EIS, APHIS also published a Notice of 

Intent (NOI) to prepare the EIS and sought public input during a comment period (May 10 to 

July 17, 2013).

Comments were submitted by individuals, academic researchers, non-government organizations, 

and industry representatives. The majority of comments submitted by non-government 

organizations and individuals were opposed to determinations of nonregulated status for the 

petitions. The majority of comments submitted by industry and academia supported 

determinations of nonregulation for MON 87708 soybean and MON 88701 cotton.

Issues most frequently cited in public comments on the petitions included the nature of 

agronomic inputs associated with these two new traits, potential impacts to plants from off-target 

herbicide drift, management of HR weeds, human health impacts of exposure to herbicides, and 

domestic and international economic impacts associated with the development and marketing of 

new HR products. A more detailed summary of these comments is provided in Appendix 2.

1.7.2 Public Comment Period for Draft EIS

APHIS issued the draft EIS (DEIS) for the petitions for a determination of nonregulated status 

for MON 87708 soybean and MON 88701 cotton and sought public comments on the DEIS 

through publication of a Notice of Availability (NOA) for the DEIS in the Federal Register on 

August 11, 2014 (79 FR 46799). The NOA explained how interested agencies, organizations, 

and individuals could access the DEIS for review and comment. The NOA also explained the 

process for submitting comments on the DEIS to APHIS. The DEIS was made available for 

public comment for 45 days from August 11 through September 25, 2014; the comment period 

was further extended to October 10, 2014. APHIS held a virtual public meeting on the DEIS on 

September 11, 2014. At the end of the 60-day comment period (October 10, 2014), APHIS 

reviewed and evaluated all of the comments received. APHIS received 4,710 comments on the

DEIS docket (APHIS 2013-0043). Of these, 3,716 supported and 941 opposed the use of MON 

87708 soybean and MON 88701 cotton. There was substantive information provided in public 

comments that was considered in the preparation of this final EIS. The Response to Comments 

that we have prepared addressing the comments received on the DEIS can be found in Appendix 

11. 

In general, the comments received fell into three broad categories. A brief summary follows, 

accompanied by the APHIS response to each:

10
1) Many commenters expressed the concern that natural and biological resources would be 

adversely impacted by the increased amounts of dicamba that would be used on soybean and 

cotton, if MON 87708 soybean and MON 88701 cotton were no longer regulated by APHIS.

The APHIS response is that the direct and indirect impacts of herbicide use are outside the scope 

of this EIS because the authority to regulate herbicide resides with the EPA under FIFRA and 

does not reside with USDA-APHIS. The USDA-APHIS authority comes from the PPA, which 

limits APHIS authority to the regulation of plant pests and noxious weeds. Under APHIS 

regulations (7 CFR part 340), the Agency can only consider plant pest risks when making a 

determination of nonregulated status. 

APHIS has no authority to regulate herbicide use or mitigate the impacts that may result from 

that use. The EPA registration process under FIFRA ensures that pesticides will be properly 

labeled, and that, if used in accordance with label specifications will meet the EPA’s safety 

standards of no unreasonable adverse effect on the environment and a reasonable certainty of no 

harm to humans. More details about the EPA regulatory responsibilities are provided in Section 

1.5.2. The risk assessment process used by the EPA is explained in Section 5.4.

2) Some commenters emphasized that growers need MON 87708 soybean and MON 88701 

cotton to manage GR weeds already present on many U.S. farms.

APHIS considers the impacts of GR weeds in the No Action Alternative (Section 4.1.3). APHIS

also considers possible cumulative impacts if it makes a determination to no longer 

regulate MON 87708 soybean and MON 88701 cotton, and the EPA makes a decision to allow 

the new registered uses of dicamba for these varieties in Chapter 5 of this EIS. 

3) Some commenters expressed concern that increased use of dicamba on MON 87708 soybean 

and MON 88701 cotton would promote selection of dicamba-resistant weeds.

APHIS notes that it has identified the possible selection of HR weeds resulting from the change 

in management practices associated with the adoption of MON 87708 soybean and MON 88701

cotton as a potential environmental impact. This impact is a cumulative impact (see Chapter 5)

because it would only result if APHIS approves the petitions to no longer regulate the GE 

varieties that are the subject of this EIS, and the EPA approves the proposed new uses of 

dicamba on them. However, APHIS notes that the potential for dicamba resistance already exists, 

and would continue to exist even if MON 87708 soybean and MON 88701 cotton are not 

approved because dicamba is currently registered for use on varieties of cotton and soybean 

already available, and several other major U.S. crops. This potential will be influenced not only 

by current uses of dicamba, but also the degree to which growers adopt the diversity of available 

alternative weed control methods as part of a coordinated system of best management practices. 

If dicamba-resistant weeds were to develop as a result of dicamba use on MON 87708 soybean 

and MON 88701 cotton coupled with a failure by growers to adopt best management practices, 

growers who rely on dicamba for weed control could face increased socioeconomic impacts. 

These impacts socioeconomic impacts associated with the increase in dicamba-resistant weeds

11
would not be a direct impact of the determination of nonregulated status, but from grower 

decisions, and for these users, may result in potentially more costly and restrictive weed control 

alternatives.

1.7.3 Issues Considered in This EIS 

The list of resource areas considered by APHIS in this document were identified in part from a 

review of: comments received for the petitions and the NOI; relevant concerns and issues cited in 

comments submitted by the public and various stakeholders in response to previous petitions and 

EAs for GE organisms; concerns identified in previous unrelated lawsuits. The following list 

includes the resource areas APHIS identified during this process, which are considered in this 

EIS:

• Land Use

• Domestic Use of Soybeans and Cotton

• Exports of Soybeans and Cotton

• Food and Feed Safety

• Worker Safety

• Animal and Plant Communities

• Biodiversity

• Soil Quality

• Water Quality

• Air Quality

• Climate Change

12
2 ALTERNATIVES

This document analyzes the potential environmental consequences of a determination of 

nonregulated status of MON 87708 soybean and MON 88701 cotton. In responding to the 

petitions, APHIS must assess the plant pest risks associated with MON 87708 soybean and MON 

88701 cotton. Based on its PPRAs (USDA-APHIS, 2014e; 2014d), APHIS has concluded that 

MON 87708 soybean and MON 88701 cotton are unlikely to pose plant pest risks. Following the 

conclusion of the plant pest risk analysis process, APHIS considered possible alternatives and 

selected those appropriate for further evaluation in this EIS. 

2.1 Alternative Considered and Selected for Further Evaluation for This EIS

APHIS evaluated four Alternatives in this EIS: 1) No Action Alternative; 2) determination of 

nonregulated status of MON 87708 soybean and MON 88701 cotton (Preferred Alternative); 3) 

determination of nonregulated status only for MON 88701 cotton; 4) determination of 

nonregulated status only for MON 87708 soybean. APHIS has assessed the potential for 

environmental impacts for each Alternative in the Environmental Consequences chapter of this 

document.

2.1.1 Alternative 1: No Action Alternative - Continuation as Regulated Articles

Under the No Action Alternative, APHIS would deny the two petitions (Monsanto, 2012a; 

2012b). MON 87708 soybean and MON 88701 cotton, and progeny derived from these event 

lines would continue to be regulated articles under the regulations at 7 CFR part 340. APHIS 

would still require permits or notifications for their introduction, and would continue to 

implement measures to ensure physical and reproductive confinement. APHIS could choose this 

Alternative if it determined that both of these cultivars were plant pests, or that there were 

insufficient data for APHIS to completely evaluate the potential plant pest risks associated with 

the unconfined cultivation of them. This Alternative is not the Preferred Alternative because 

APHIS evaluated the data and has concluded in its PPRAs that MON 87708 soybean and MON 

88701 cotton are unlikely to pose plant pest risks (USDA-APHIS, 2014e; 2014d). Therefore, 

choosing this Alternative would be inconsistent with the scientific evidence before the agency 

regarding plant pest risk, the purpose and need stated in the plant pest provisions of the PPA, and 

the regulations codified in 7 CFR part 340.

2.1.2 Alternative 2: Determination of Nonregulated Status of MON 87708 Soybean and MON 

88701 Cotton (Preferred Alternative)

Under this Alternative, MON 87708 soybean and MON 88701 cotton and progeny derived from 

their cultivation would no longer be subject to APHIS biotechnology regulations. APHIS would 

no longer require permits or notifications for introductions of these varieties because they are 

unlikely to pose plant pest risks (USDA-APHIS, 2014e; 2014d). Therefore, this is the Preferred 

Alternative because a determination of nonregulated status for both varieties, MON 87708 

soybean and MON 88701 cotton, would be consistent with the scientific evidence before the 

13
agency regarding plant pest risk, the purpose and need stated in the plant pest provisions of the 

PPA, and the regulations codified in 7 CFR part 340.

2.1.3 Alternative 3: Determination of Nonregulated Status for MON 88701 Cotton, Only

Under this Alternative, only MON 88701 cotton and progeny derived from its cultivation would 

no longer be subject to regulations. MON 87708 soybean would continue to be regulated as 

described under Alternative 1. APHIS would no longer require permits or notifications for 

introductions of MON 88701 cotton and progeny derived from this event because it is unlikely to 

pose a plant pest risk (USDA-APHIS, 2014e). APHIS would choose this Alternative if it 

determined that MON 87708 soybean was a plant pest itself or if available data were not 

sufficient to complete an evaluation of potential plant pest risks associated with the unconfined 

cultivation of MON 87708 soybean. However, APHIS has concluded as part of its plant pest risk 

assessment process that this variety is unlikely to pose a plant pest risk. Therefore, such a choice 

would be inconsistent with the scientific evidence before the agency regarding plant pest risk, the 

purpose and need of the plant pest provisions of the PPA, and the regulations codified in 7 CFR 

part 340.

2.1.4 Alternative 4: Determination of Nonregulated Status for MON 87708 Soybean, Only

Under this Alternative, only MON 87708 soybean, and progeny derived from its cultivation 

would no longer be subject to regulations. MON 88701 cotton would continue to be regulated as 

described under Alternative 1. APHIS would no longer require permits or notifications for 

introductions of MON 87708 soybean and progeny derived from this variety because it is 

unlikely that it poses a plant pest risk or increase existing ones (USDA-APHIS, 2014d). APHIS 

would choose this Alternative if it determined that MON 88701 cotton was a plant pest or if 

available data were not sufficient to complete an evaluation of potential plant pest risk from the 

unconfined cultivation of MON 88701 cotton. However, APHIS has concluded as part of its 

plant pest risk assessment process that this variety is unlikely to pose a plant pest risk. Therefore, 

such a choice would be inconsistent with the scientific evidence before the agency regarding 

plant pest risk, the purpose and need of the plant pest provisions of the PPA, and the regulations 

codified in 7 CFR part 340.

2.2 Alternatives Considered but Not Selected for Further Evaluation

APHIS assembled a list of alternatives considered for MON 87708 soybean and MON 88701 

cotton. The Agency evaluated these alternatives in accordance with its authority under the plant 

pest provisions of the PPA and the regulations at 7 CFR part 340. In this evaluation APHIS 

considered environmental safety, efficacy, and practicality to identify those alternatives the 

agency would further consider for MON 87708 soybean and MON 88701 cotton. Based on this 

evaluation, APHIS rejected several alternatives. These alternatives are described briefly below 

with the specific reasons for rejecting each.

14
2.2.1 Prohibit Any MON 87708 Soybean and MON 88701 Cotton from Being Released

In response to public comments that stated a preference that no GE organisms enter the 

marketplace, APHIS considered prohibiting the release of MON 87708 soybean and MON 

88701 cotton, including denial of any permits associated with field testing. APHIS determined 

that this Alternative is not appropriate because APHIS has concluded that MON 87708 soybean 

and MON 88701 cotton are unlikely to pose a plant pest risk (USDA-APHIS, 2014d; 2014e). 

Therefore, there is no scientific basis for prohibiting the release of these varieties under the 

regulations at 7 CFR part 340.

In enacting the PPA, Congress included findings in Section 402(4) that: “decisions affecting 

imports, exports, and interstate movement of products regulated under this title [i.e., the PPA] 

shall be based on sound science; ...”

On March 11, 2011, in a Memorandum for the Heads of Executive Departments and Agencies, 

the White House Emerging Technologies Interagency Policy Coordination Committee 

established principles consistent with Executive Order 13563 to guide agencies in the 

development and implementation of policies for oversight of emerging technologies such as 

genetic engineering that included the following guidance:

“Decisions should be based on the best reasonably obtainable scientific, technical, 

economic, and other information, within the boundaries of the authorities and mandates 

of each agency; ...”

Consistent with this guidance and based on the findings and scientific data evaluated for the 

PPRAs (USDA-APHIS, 2014a; 2014b), APHIS has concluded that MON 87708 soybean and 

MON 88701 cotton are unlikely to pose a plant pest risk. Therefore, there is no scientific basis 

for prohibiting the release of these varieties under the regulations at 7 CFR part 340.

2.2.2 Approve the Petition(s) in Part

The regulations at 7 CFR part 340.6(d)(3)(i) state that APHIS may “approve the petition in 

whole or in part.” However, APHIS has concluded that MON 87708 soybean and MON 88701 

cotton are unlikely to pose plant pest risks (USDA-APHIS, 2014e; 2014d), so there is no 

scientific basis for prohibiting the release of these varieties under the regulations at 7 CFR part 

340.

2.2.3 Production/Geographical Restrictions to Isolate MON 87708 Soybean and MON 88701 

Cotton from Non-GE Soybean or Cotton

In response to public concerns of gene movement between GE and non-GE plants, APHIS 

considered requiring isolation distances separating MON 87708 soybean and MON 88701 cotton 

from non-GE soybean or cotton production. However, because APHIS has concluded that MON 

87708 soybean and MON 88701 cotton are unlikely to pose plant pest risks (USDA-APHIS, 

2014a; 2014b), an alternative based on requiring isolation distances would be inconsistent with 

15
the Agency’s statutory authority under the plant pest provisions of the PPA and regulations in 7 

CFR part 340.

APHIS also considered geographically restricting the production of MON 87708 soybean and 

MON 88701 cotton based on the location of organic production systems of non-GE soybean and 

cotton, or production systems for GE-sensitive markets in response to public concerns regarding 

possible gene movement between GE and non-GE plants. However, as presented in the APHIS 

PPRA (USDA-APHIS, 2014a; 2014b), there are no geographic differences associated with any 

identifiable plant pest risks for MON 87708 soybean and MON 88701 cotton. This Alternative 

was not analyzed in detail because APHIS has concluded that MON 87708 soybean and MON 

88701 cotton are unlikely to pose plant pest risks in any geographic area. Therefore, there is no 

scientific basis for prohibiting the release of these varieties under the regulations at 7 CFR part 

340.

Individuals might choose, on their own, to geographically isolate their non-GE soybean or cotton

production systems from MON 87708 soybean and MON 88701 cotton, or to use isolation 

distances and other management practices to minimize gene movement between soybean and 

cotton fields. Information to assist growers in making informed management decisions to 

effectively isolate their crop varieties from other varieties (including MON 87708 soybean and 

MON 88701 cotton) is available from the American Organization of Seed Certifying Agencies 

(AOSCA, 2010).

2.2.4 Requirement of Testing for MON 87708 Soybean and MON 88701 Cotton

During the comment periods for other petitions for nonregulated status, some commenters 

requested that USDA require and provide testing for GE products in non-GE production systems. 

However, because APHIS has concluded that MON 87708 soybean and MON 88701 cotton are

unlikely to pose plant pest risks (USDA-APHIS, 2014a; 2014b), testing requirements are 

inconsistent with the plant pest provisions of the PPA, the regulations at 7 CFR part 340 and the 

biotechnology regulatory policies of the Coordinated Framework. Therefore, there is no 

scientific basis for prohibiting or regulating releases of these varieties under the regulations at 7 

CFR part 340.

2.3 Comparison of Alternatives

Table 1 includes a summary of the potential environmental consequences associated with 

selection of one of the Alternatives evaluated in this EIS. The environmental consequences 

assessment is presented in Chapter 4 of this EIS. The cumulative impacts are presented in 

Chapter 5.

16
Table 1. Summary of Issues and of Potential Impacts of the Alternatives.

Attribute/Measure Alternative 1: No Action

(Deny Both Petitions)

Alternative 2: Preferred

AlternativeDetermination of

Nonregulated Status for 

MON 87708 Soybean 

and MON 88701 Cotton

Alternative 3:

Determination of

Nonregulated Status for 

MON 88701 Cotton Only

Alternative 4:

Determination of

Nonregulated Status for 

MON 87708 Soybean

Only

Meets Purpose

and Need No Yes No No

Land Use Acreage of soybean 

plantings are anticipated to 

increase somewhat through 

2020 (USDA-OCE, 2013). 

Cotton plantings are 

anticipated to fluctuate as 

market prices change.

Locations of soybean and 

cotton production are not 

expected to change.

Acreage of plantings 

generally the same as 

Alternative 1.

The nonregulated varieties 

might replace other soybean 

or cotton varieties currently 

grown in the U.S.

Locations of production 

unchanged.

Acreage of plantings 

generally the same as 

Alternative 1.

The nonregulated cotton 

variety might replace other 

varieties currently grown in 

the U.S.

Locations of production 

unchanged.

Acreage of plantings 

generally the same as 

Alternative 1.

The nonregulated soybean 

variety might replace other 

varieties currently grown in 

the U.S.

Locations of production 

unchanged.

Economic Aspects The U.S. will continue to be 

an exporter of soybeans and 

cotton.

It is the responsibility of 

food and feed manufacturers 

to ensure that the products 

they market are safe and 

labeled properly.

The percentage of GE 

varieties in the market is not 

expected to change.

Monsanto has submitted or 

is planning to submit 

requests for regulatory 

approvals in the main export

markets for these varieties of 

soybean and cotton.

These traits and varieties are 

not substantially different 

from what is already in 

commerce.

Their presence in exported 

commodities will not affect 

trade differently than that of 

other currently approved GE 

traits in commerce. 

Monsanto has submitted or 

is planning to submit 

requests for regulatory 

approvals in the main export

markets for this variety of 

cotton.

This trait and variety is not 

substantially different from 

what is already in 

commerce. 

Its presence in exported 

commodities will not affect 

trade differently than that of 

other currently approved GE 

traits in commerce.

Monsanto has submitted or 

is planning to submit 

requests for regulatory 

approvals in the main export

markets for this variety of 

soybean.

This trait and variety is not 

substantially different from 

what is already in 

commerce. 

Its presence in exported 

commodities will not affect 

trade differently than that of 

other currently approved GE 

traits in commerce.

17
Attribute/Measure Alternative 1: No Action

(Deny Both Petitions)

Alternative 2: Preferred

AlternativeDetermination of

Nonregulated Status for 

MON 87708 Soybean 

and MON 88701 Cotton

Alternative 3:

Determination of

Nonregulated Status for 

MON 88701 Cotton Only

Alternative 4:

Determination of

Nonregulated Status for 

MON 87708 Soybean

Only

The percentage of GE 

varieties in the market is not 

expected to change.

The percentage of GE 

varieties in the market is not 

expected to change.

The percentage of GE 

varieties in the market is not 

expected to change.

Agronomic Practices Weeds resistant to 

glyphosate and other 

herbicides will continue to 

increase. As HR weeds 

become more prevalent, 

growers are expected to shift 

to more costly alternative

weed control measures or 

other herbicide-resistant 

crops that are economically 

viable. 

Conventional growers are 

likely to use additional 

herbicides and/or abandon 

conservation tillage practices

and return to more 

aggressive conventional 

tillage systems to maintain 

yields.

Use of dicamba in soybean 

and dicamba and glufosinate 

in cotton cropping systems is 

expected to increase, but 

dicamba use is contingent on 

EPA’s decision to approve 

the new uses of dicamba on 

these crop varietiesMore 

efficient weed control is 

expected to reduce the need 

for more aggressive tillage.

Conventional growers are 

likely to continue the use of

herbicides and retain or 

increase conservation tillage 

practices, if resistant weeds 

do not develop over time.

Use of dicamba and 

glufosinate in cotton is 

expected to increase, but 

dicamba use is contingent on 

EPA’s decision to approve 

the new use of dicamba on

this cotton variety.

More efficient weed control 

is expected to reduce the 

need for more aggressive 

tillage.More efficient weed 

control is expected to reduce 

the need for more aggressive 

tillage.

Conventional growers are 

likely to continue use of 

herbicides and retain or 

increase conservation tillage 

practices, if resistant weeds 

do not develop over time.

Use of dicamba in soybean 

is expected to increase, but 

this is contingent on EPA’s 

decision to approve the new 

use of dicamba on this 

soybean variety..

Conventional growers are 

likely to continue use of 

herbicides and retain or 

increase conservation tillage 

practices, if resistant weeds 

do not develop over time.

Organic Production 

Systems

Planting of organic soybeans

and cotton is not likely to

change .

Planting of organic soybeans

and cotton is not likely to 

change.

Planting of organic cotton is 

not likely to change.

Planting of organic soybeans

is not likely to change. 

Use of GE Crops: 

Herbicide and Resistant 

Planting of GE HR crops is 

likely to remain at current 

levels with adoption of GE 

Planting of GE HR crops is

likely to remain at current 

levels with adoption of GE 

Planting of GE HR crops is 

likely to remain at current 

levels with adoption of GE 

Planting of GE HR crops is 

likely to remain at current 

levels with adoption of GE 

18
Attribute/Measure Alternative 1: No Action

(Deny Both Petitions)

Alternative 2: Preferred

AlternativeDetermination of

Nonregulated Status for 

MON 87708 Soybean 

and MON 88701 Cotton

Alternative 3:

Determination of

Nonregulated Status for 

MON 88701 Cotton Only

Alternative 4:

Determination of

Nonregulated Status for 

MON 87708 Soybean

Only

Weed Aspects crops high. crops high. crops high. crops high. 

Human Health and 

Safety

Soybean and cotton varieties 

are associated with all the 

normal risks of agricultural 

production.

The EPA label use 

restrictions are designed to 

protect humans during 

herbicide use in soybean and 

cotton cropping systems to 

achieve a standard of a 

“reasonable certainty of no 

harm”.

These varieties do not 

present any additional risks 

to workers.

The revised EPA label use 

restrictions for soybean and 

cotton are designed to 

achieve the same level of 

human health and safety as 

those that currently exists for 

non-GE varieties.

This variety does not present 

any additional risks to 

workers.

The revised EPA label use 

restrictions for cotton are 

designed to achieve the same 

level of human health and 

safety as those that currently 

exists for non-GE varieties.

This variety does not present 

any additional risks to 

workers.

The revised EPA label use 

restrictions for soybean are 

designed to achieve the same 

level of human health and 

safety as those that currently 

exists for non-GE varieties.

Biological Diversity Cropping systems generally 

are not expected to change, 

so biodiversity in regions 

where soybean and cotton 

are produced will not 

change.

Herbicide use may decrease 

weed prevalence or modify 

the weed species complex in 

some regions. These changes 

could modify the species 

complex of organisms that 

rely on these weeds as a 

food source or habitat.

Crop biodiversity is not 

expected to change relative 

to the No Action Alternative

substantially. Use of these 

varieties will allow for stable

levels of conservation 

tillage, which will not 

decrease biodiversity and 

might increase it.

Use of these crops will 

likely not require increased

overall herbicide use, which 

will not reduce biodiversity 

and might increase it.

Selection pressure for 

dicamba and glufosinate 

Crop biodiversity is not 

expected to change relative 

to the No Action Alternative

substantially. Use of this 

cotton variety will allow for 

stable levels of conservation 

tillage, which will not 

decrease biodiversity and 

might increase it.

Use of this cotton variety 

will likely not require 

increased overall herbicide 

use, which will not reduce 

biodiversity and might 

increase it.

Selection pressure for 

Crop biodiversity is not 

expected to change realtive 

to the No Action Alternative

substantially. Use of this 

soybean variety will allow 

for stable levels of 

conservation tillage, which 

will not decrease 

biodiversity and might 

increase it.

Use of this soybean variety 

will likely not require

increased overall herbicide 

use, which will not reduce 

biodiversity and might 

increase it. 

19
Attribute/Measure Alternative 1: No Action

(Deny Both Petitions)

Alternative 2: Preferred

AlternativeDetermination of

Nonregulated Status for 

MON 87708 Soybean 

and MON 88701 Cotton

Alternative 3:

Determination of

Nonregulated Status for 

MON 88701 Cotton Only

Alternative 4:

Determination of

Nonregulated Status for 

MON 87708 Soybean

Only

resistance in weed 

populations may modify the 

weed species complex in 

some regions, which might

modify the species complex 

of organisms that rely on 

these weeds as a food source 

or habitat.

dicamba and glufosinate 

resistance in weed 

populations may modify the 

weed species complex in 

some regions, which might

modify the species complex 

of organisms that rely on 

these weeds as a food source 

or habitat.

Selection pressure for 

dicamba resistance in weed 

populations may modify the 

weed species complex in 

some regions, which might

modify the species complex 

of organisms that rely on 

these weeds as a food source 

or habitat.

Animal Communities Cultivated soybean and 

cotton currently provide 

limited food and habitat for 

wildlife in regular cropping 

situations.

Expected to be the same as 

Alternative 1 because 

toxicological studies and 

studies of allergenicity of the 

added traits did not reveal 

any impacts on animals.

Expected to be the same as 

Alternative 1 because 

toxicological studies and 

studies of allergenicity of the 

added trait did not reveal any 

impacts on animals.

Expected to be the same as 

Alternative 1 because 

toxicological studies and 

studies of allergenicity of the 

added trait did not reveal any 

impacts on animals.

Plant Communities / 

Weed Complexes

Currently cultivated soybean 

and cotton varieties are not 

potential plant pests because 

they do not compete with 

native plant species, so do 

not adversely impact natural 

plant communities.

Selection pressure for HR 

weed development will 

continue.

These varieties are not 

potential plant pests because 

they do not compete with 

native plant species and lack 

the potential to do so, so will 

not adversely impact natural 

plant communities.

Selection pressure to 

develop dicamba and 

glufosinate resistance in 

weed populations will 

increase, including the 

potential for development of 

weeds with multiple 

resistance to more than one 

This variety is not a 

potential plant pests because 

it does do not compete with 

native plant species and 

lacks the potential to do so, 

so will not adversely impact 

natural plant communities.

Selection pressure to 

develop dicamba and 

glufosinate resistance in 

weed populations will 

increase, including the 

potential for development of

weeds with multiple 

resistance to more than one 

This variety is not a potential 

plant pests because it does 

do not compete with native 

plant species and lacks the 

potential to do so, so will not 

adversely impact natural 

plant communities.

Selection pressure to 

develop dicamba resistance 

in weed populations will 

increase, including the 

potential for development of 

weeds with multiple 

resistance to more than one 

herbicide.

20
Attribute/Measure Alternative 1: No Action

(Deny Both Petitions)

Alternative 2: Preferred

AlternativeDetermination of

Nonregulated Status for 

MON 87708 Soybean 

and MON 88701 Cotton

Alternative 3:

Determination of

Nonregulated Status for 

MON 88701 Cotton Only

Alternative 4:

Determination of

Nonregulated Status for 

MON 87708 Soybean

Only

herbicide mode of action. herbicide.

Soil Quality Increased tillage to manage 

herbicide resistant weeds 

may occur in soybean and 

cotton cropping systems and 

cause decreased soil quality

from increased soil erosion.

New options to avoid tillage 

would be accompanied by 

decreased soil erosion.

These varieties are not 

expected to change the 

existing composition of soil 

microflora in cropping 

systems.

New options to avoid tillage 

would be accompanied by 

decreased soil erosion.

This variety is not expected 

to change the existing 

composition of soil 

microflora in cropping 

systems.

New options to avoid tillage

would be accompanied by 

decreased soil erosion.

This variety is not expected 

to change the existing 

composition of soil 

microflora in cropping 

systems.

Water Quality Increased tillage to manage 

HR weeds may occur in

soybean and cotton cropping 

systems. This could increase 

evaporative water loss and 

demand on water resources

for irrigation, and cause 

increased soil erosion 

accompanied by diminished 

water quality from 

sedimentation.

These varieties will support 

continued use of current 

conservation tillage practices 

in the short term. 

In the long term, 

development of more HR 

weeds may be accompanied 

by increased tillage with 

negative impacts (as 

described in the No Action 

Alternative).

This variety will support

continued use of current 

conservation tillage practices 

in the short term. 

In the long term, 

development of more HR 

weeds may be accompanied 

by increased tillage with 

negative impacts (as 

described in the No Action 

Alternative).

This variety will support

continued use of current 

conservation tillage practices 

in the short term. 

In the long term, 

development of more HR 

weeds may be accompanied 

by increased tillage with 

negative impacts (as 

described in the No Action 

Alternative).

Air Quality Increased tillage to manage 

HR weeds may occur in

soybean and cotton cropping 

systems. This could reduce 

air quality from increased air 

particulates and exhaust 

from farm equipment.

Increased use of herbicides

may occur to manage HR 

Use of these varieties is 

expected to stabilize current

tillage. This will be 

accompanied by a reduction 

in airborne particulates and 

exhaust emissions, which 

will increase air quality.

Overall use of herbicides 

will remain the same or be 

Use of this variety is 

expected to stabilize current

tillage. This will be 

accompanied by a reduction 

in airborne particulates and 

exhaust emissions, which 

will increase air quality.

Overall use of herbicides 

will remain the same or be 

Use of this variety is 

expected to stabilize current 

tillage. This will be 

accompanied by a reduction 

in airborne particulates and 

exhaust emissions, which 

will increase air quality.

Overall use of herbicides 

will remain the same or be 

21
Attribute/Measure Alternative 1: No Action

(Deny Both Petitions)

Alternative 2: Preferred

AlternativeDetermination of

Nonregulated Status for 

MON 87708 Soybean 

and MON 88701 Cotton

Alternative 3:

Determination of

Nonregulated Status for 

MON 88701 Cotton Only

Alternative 4:

Determination of

Nonregulated Status for 

MON 87708 Soybean

Only

weeds. This would increase 

drift from herbicides that 

would reduce air quality.

reduced by better 

management of HR weeds.

Drift from herbicides will 

remain the same or be 

reduced, resulting in no 

change or improved air 

quality.

reduced by better 

management of HR weeds. 

Drift from herbicides will 

remain the same or be 

reduced, resulting in no 

change or improved air 

quality.

reduced by better 

management of HR weeds.

Drift from herbicides will 

remain the same or be 

reduced, resulting in no 

change or improved air 

quality.

Climate Change Increased tillage to manage 

HR weeds may occur in

soybean and cotton cropping 

systems. This would 

Increase the release of 

GHGs (primarily CO2 and 

methane).

Use of these varieties is 

expected to stabilize current

conservation tillage. This 

will be accompanied by a 

reduction in the release of 

GHGs (primarily CO2 and 

methane).

Use of this variety is 

expected to stabilize current

conservation tillage. This 

will be accompanied by a 

reduction in the release of 

GHGs (primarily CO2 and 

methane).

Use of this variety is 

expected to stabilize current

conservation tillage. This 

will be accompanied by a 

reduction in the release of 

GHGs (primarily CO2 and 

methane).

Other U.S. Regulatory 

Approvals: 

FDA Consultations and 

EPA Registrations

Consultations with the FDA 

and changes to the EPA 

registrations would be 

unnecessary.

Monsanto completed 

consultations with the FDA 

for MON 87708 soybean on 

October 11, 2011 (BNF No. 

00125) and for MON 88701 

cotton on April 24, 2013 

(BNF No. 000135).

The EPA reregistration 

decision for dicamba was 

issued in 2006 (US-EPA, 

2006a). EPA concluded that 

dicamba and its metabolites 

were below the Agency’s 

level of concern for all 

registered uses of dicamba

Monsanto completed its 

consultation with FDA for 

MON 88701 cotton on April 

24, 2013 (BNF No. 000135).

The EPA reregistration 

decision for dicamba was 

issued in 2006 (US-EPA, 

2006a). The EPA concluded 

that dicamba and its 

metabolites were below the 

Agency’s level of concern 

for all registered uses of 

dicamba including cotton

(US-EPA, 2009b).

Monsanto completed its 

consultation with FDA for 

MON 87708 soybean on 

October 11, 2011 (BNF No. 

00125).

The EPA reregistration 

decision for dicamba was 

issued in 2006 (US-EPA, 

2006a). The EPA concluded 

that dicamba and its 

metabolites were below the 

Agency’s level of concern 

for all registered uses of 

dicamba including soybean 

22
Attribute/Measure Alternative 1: No Action

(Deny Both Petitions)

Alternative 2: Preferred

AlternativeDetermination of

Nonregulated Status for 

MON 87708 Soybean 

and MON 88701 Cotton

Alternative 3:

Determination of

Nonregulated Status for 

MON 88701 Cotton Only

Alternative 4:

Determination of

Nonregulated Status for 

MON 87708 Soybean

Only

including soybean and 

cotton (US-EPA, 2009b).

The EPA registration 

decision for glufosinate was 

issued in 2000 for crop use 

(US-EPA, 2008).

The EPA is currently 

evaluating the proposed new 

uses of dicamba for MON 

87708 soybean and MON 

88701 cotton.

The EPA registration 

decision for glufosinate was 

issued in 2000 for crop use 

(US-EPA, 2008).

The EPA is currently 

evaluating the proposed new 

uses of dicamba for MON 

87708 soybean and MON 

88701 cotton.

(US-EPA, 2009b).

The EPA registration 

decision for glufosinate was 

issued in 2000 for crop use 

(US-EPA, 2008).

The EPA is currently 

evaluating the proposed new 

uses of dicamba for MON 

87708 soybean and MON 

88701 cotton.

Applicable U.S. Laws Compliant Compliant Compliant Compliant

23
3 AFFECTED ENVIRONMENT

Cotton and soybean production regions of the conterminous U.S. may be affected by a 

determination of nonregulated status for MON 87701 cotton and MON 88708 soybean. This 

chapter includes a review of the prevailing conditions in the human environment in those 

regions. Background information about the economics and production practices associated with 

cotton and soybean production is provided followed by descriptions of twelve major components 

of the human environment and how they might be affected if MON 87701 cotton and/or MON 

88708 soybean were no longer regulated as plant pests.

Relevant components of the physical environment, biological resources, human health, animal 

feed, and socioeconomic resources are considered. They include soil, water and air quality, 

climate change, land cover and land uses, cotton and soybean production practices, animal 

communities, food and feed uses, worker safety and agricultural markets.

3.1 U.S. Cotton and Soybean Economics

The many and varied products derived from cotton and soybean are why these crops are 

important both domestically and as export commodities. This section describes some of the 

economics and production practices associated with these two crops.

3.1.1 U.S. Cotton Economics

Cotton (Gossypium spp.) is the world’s most widely grown textile fiber crop, accounting for over 

40% of fiber production in the world (Meyer et al., 2007). The major cotton by-products include 

an edible oil from seeds, as well as the use of chaff (hulls and linters), high-protein cake, and 

flour as livestock feed (OECD, 2008a). The most commonly cultivated species in the U.S. is 

upland cotton (G. hirsutum), comprising 97% of the cotton crop, ranging in 17 states from 

Virginia to California (USDA-NASS, 2014a). Upland cotton is also known as short staple cotton 

based on the relative length of the cotton fibers (Rude, 1984). The remainder is Pima (extra-long 

staple [ELS] or Egyptian) cotton (G. barbadense) cultivated in Arizona, California, New 

Mexico, and Texas (Pleasants and Wendell, 2005a; USDA-NASS, 2014a). The U.S. is the third 

largest producer of cotton after China and India (USDA-FAS, 2014).

Cotton is cultivated in tropical and subtropical zones (OECD, 2008a). It is a perennial plant 

cultivated as an annual (Smith and Cothren, 1999; Boyd et al., 2004b). It is geographically more 

limited than other major crops in the U.S. because its growth requires a minimum of 180 frostfree days per year (Rude, 1984; Smith and Cothren, 1999; OECD, 2008a).

Cotton is generally grown in deep arable soils with good drainage and a high moisture-retention 

capacity (OECD, 2008a). Ideal cotton production requires at least 500 millimeters (mm) rainfall 

during the growing season for non-irrigated upland crops. However, it is also grown as an 

irrigated crop, where careful timing of irrigation optimizes flowering and boll production 

(OECD, 2008a).

Good cotton management allows the plant to produce a high yield at a reasonable cost by 

channeling energy into harvestable seed cotton within the limitations imposed by soil, length of 

24
season, and production cost (Rude, 1984). Particularly in upland varieties, boll maturation is 

dominant over vegetative growth and formation of new flower buds (called “squares”), once the 

plant begins to set bolls. If too few of the ovules are fertilized, the fruit drops within 10 days of 

flowering. During the post-harvest ginning process, longer cotton lint fibers are separated from 

the harvested seed cotton. Unfertilized ovules within a fruit that fully develops remain as 

contaminants or “motes” within the lint. Shorter fuzz fibers (called linters) remain attached to the 

seed after ginning (Rude, 1984; Boyd et al., 2004b), and cottonseed oil processing begins with 

these materials.

The recent Agricultural Outlook Forum summarized recent economic aspects of cotton 

production (Johnson et al., 2014):

“U.S. all-cotton production in 2013/14 is estimated at 13.2 million bales, 24% lower than 

last season’s crop. Cotton planted acreage decreased 15% (nearly 2 million acres) in 

2013 as relative crop prices favored the planting of alternative crops. Cotton area this 

season was its lowest since 2009. Severe drought conditions continued for much of the 

Southwest in 2013, keeping U.S. abandonment near 25% for a second consecutive 

season, compared with the 10-year average of 14%. In 2013, the U.S. yield averaged 826 

pounds per harvested acre, below 2012’s record of 887 pounds but the second highest 

since 2007. Upland production is currently estimated at about 12.6 million bales—

approximately 4 million below 2012—with an average yield of 807 pounds per harvested 

acre, well below 2012’s 869-pound record. The extra-long staple (ELS) crop (also known 

as Pima cotton) also is estimated lower—at 636,000 bales—as smaller area and a lower 

yield reduced the crop to its smallest in three seasons.

“Compared with last season, 2013/14 upland cotton production was lower in each of the 

Cotton Belt regions. Production decreased in the Southwest as lower area more than 

offset a higher yield. With 2013 Southwest cotton plantings at 6 million acres, the region 

accounted for 59% of the total U.S. upland plantings and the largest since 1980. 

Southwest harvested area approached 3.4 million acres, below the 5-year average, as 

above-average abandonment --- 44% --- occurred for the third consecutive season. As a 

result, the Southwest upland crop reached 4.5 million bales in 2013/14, accounting for 

36% of upland production. “For the Southeast, planted acreage in 2013 was about 

unchanged at nearly 2.7 million acres. A yield of 811 pounds per harvested acre is 

considerably lower than 2012’s record yield of 1,033 pounds. The 2013/14 Southeast 

crop only approached 4.5 million bales, the lowest in three seasons. For the Delta, 2013 

planted area decreased to a record low of 1.2 million acres, 39% below 2012. Although a 

record yield of 1,085 pounds per harvested acre helped offset some of the area decline, 

the 2013/14 Delta crop of 2.7 million bales was the second lowest in three decades.

“In the West, 2013 upland area declined to 292,000 acres, the second lowest behind the 

2009 season. With an average yield of 1,470 pounds per harvested acre, upland 

production in the West decreased to 870,000 bales, one of the lowest on record. The ELS 

crop remains concentrated in the West, and with ELS production at 636,000 bales, total 

cotton production in the West region reached 1.5 million bales.”

25
U.S. Cotton Area, Abandonment, Yield, and Production

2009/10 2010/11 2011/12 2012/13 2013/14

Planted acres

(million acres) 9.2 11.0 14.7 12.3 10.4

Harvested 

acres

(million acres)

7.5 10.7 9.5 9.4 7.7

Abandonment 

rate (percent) 17.7 2.5 35.8 23.9 26.4

Yield

(lb/acre 

harvested)

777 812 790 887 826

Production

(millions of 

bales)

12.2 18.1 15.6 17.3 13.2

According to the 2007 Census of Agriculture, upland cotton was harvested in 631 U.S. counties 

or county equivalents (20%) (USDA-NASS, 2009d) (Figure 1). Production occurs in Alabama, 

Arizona, Arkansas, California, Florida, Georgia, Kansas, Kentucky, Louisiana, Mississippi, 

Missouri, New Mexico, North Carolina, South Carolina, Tennessee, Texas, and Virginia 

(USDA-NASS, 2009d). Five of these states (Texas, Georgia, Arkansas, North Carolina, and 

Mississippi) account for approximately 75% of the total U.S. crop (USDA-NASS, 2009d). 

Limited cotton production also occurs in Puerto Rico for breeding and as a seed crop (Monsanto, 

2004; Bayer, 2006). Naturalized or feral populations of cotton grow in Florida, Hawaii, Puerto 

Rico, and the Virgin Islands (Fryxell 1984; Bates, 1990; Coile and Garland, 2003; Wunderlin 

and Hansen, 2008; USDA-NRCS, 2012c).

26
Figure 1. Upland Cotton 2012 Yield per Harvested Acre by County for Selected States.

Source: (USDA-NASS, 2013i)

3.1.2 U.S. Soybean Economics

Soybean (Glycine max (L.) Merr.) is an economically important leguminous crop, providing oil 

and protein from processed seed. It is the most important oil-seed-producing crop in the world. It 

accounts for 58% of global oil-seed production (ASA, 2011). 

According to the 2007 Census of Agriculture, soybeans were harvested in 2,039 U.S. counties or 

county equivalents (66%) (USDA-NASS, 2009d). U.S. soybean production totaled 3.29 billion 

bushels in 2013, an increase of 8% from 2012. This is the third largest yield on record (USDANASS, 2014a). The average yield per acre is estimated at 43.3 bushels, which is 3.5 bushels 

more than the 2012 yield (USDA-NASS, 2014a). The harvested area of 85.9 million acres, 

although the fourth highest on record, was slightly less than 2012 acreage (USDA-NASS, 

2014a).

The value of U.S. soybean production for beans exceeded $43 billion in 2012 (USDA-NASS, 

2013f), which was 23% of the total value of field and miscellaneous crops in 2012. The U.S. 

heartland (Illinois, Indiana, Iowa, Kentucky, Minnesota, Missouri, and Ohio) accounted for more 

than 58% of the total U.S. crop value in 2012. There is substantial variation in yields and costs 

across soybean production regions.

Soybean exports in the form of bulk beans, meal, and oil are a major share of the total 

agricultural exports for the U.S., representing 16.1% of the total value of U.S. agricultural 

27
exports. Bulk soybeans accounted for $17.59 billion of the total U.S. agricultural exports ($136 

billion in 2011) (USDA-ERS, 2013c), ranking first among all agricultural commodities. Soybean 

meal ($3.2 billion) and soybean oil ($1.3 billion), ranked 11th and 22nd, respectively (USDAERS, 2012c). As a percentage of global exports, the U.S. accounted for 38% of bulk soybeans, 

13% of soybean meal, and 11% of soybean oil in 2011/12 (USDA-ERS, 2012c).

In 2011/12 soybean meal represented 67% of the protein meal produced worldwide, although 

soybean oil ranked behind palm oil in terms of worldwide vegetable oil production (USDA-ERS, 

2012c). In terms of consumption, soybeans yielded the largest share of protein meal consumed 

worldwide, mainly as animal feed. As a vegetable oil source, soybean oil consumption was 

second only to palm oil (USDA-FAS, 2013b).

In 2011/12, the U.S. was responsible for 35% of the world’s soybean production, 21% of world’s 

soybean meal production, and 21% of the world’s soybean oil production (USDA-FAS, 2013a). 

The U.S., China, Argentina, and Brazil are the major producers of bulk soybeans, soybean meal, 

and soybean oil (USDA-FAS, 2013a).

From 1990-2013, U.S. acreage planted with soybeans increased from 59 million to more than 77 

million acres (Figure 2). It is now the second most widely planted crop in the U.S. after corn. 

The increase in soybean acreage is related to strong prices, the absence of acreage set-aside 

programs, increased types of crop rotation strategies, and optimum soybean planting conditions. 

The top five soybean producing states (Iowa, Illinois, Minnesota, Indiana, and Nebraska) 

accounted for more than half of the total U.S. crop in 2012 (USDA-NASS, 2013f).

Soybeans yield both solid (meal) and liquid (oil) products. Soybean meal is high in protein and is 

used for products such as tofu, soymilk, meat replacements, and protein powder. It also provides 

a natural source of dietary fiber (USB, 2009). Nearly 98% of soybean meal produced in the U.S. 

is used as animal feed. Less than 2% is used to produce soybean flour and proteins for human 

consumption (Soyatech, 2011). Poultry consume more than 45% of domestic soybean meal 

(about 590 million bushels of the U.S. crop). Soybean oil is used increasingly to replace animal 

fats and oils in broiler diets (USB, 2011). Soybean can be the dominant component of livestock 

diets (e.g., about 66% of protein in poultry diets is derived from soybeans (Waldroup and Smith, 

2008)).

Other animals fed domestic soybean (by crop volumes consumed) include swine (26%), beef

cattle (12%), dairy cattle (9%), farm-raised fish (3%), and household pets (2%) (Soy Stats, 2010; 

USB, 2011). Soybean plant material is also used as forage, hay, and silage for livestock (Blount

et al., 2009). Specific varieties of soybean exist for grazing and hay, but the whole plant has 

feeding value (Weiderholt and Albrecht, 2003)Specific varieties of soybean exist for grazing and 

hay, but the whole plant has feeding value (Weiderholt and Albrecht, 2003).

Soybean liquids are used to produce salad and cooking oils, baking and frying fat, and 

margarine. Soybean oil is low in saturated fats, high in poly- and monounsaturated fats, and 

contains essential omega-3 fatty acids. Soybean oil comprises nearly 70% of the oils consumed 

in U.S. households (Soy Stats, 2010).

28
Figure 2. Soybeans 2012 Yield per Harvested Acre by County for Selected States. Source: (USDA-NASS, 2013h).

3.2 U.S. Cotton and Soybean Production

Most U.S. soybean acreage is located in the Midwest and along the east coast. Cotton is confined 

to the southern tier of the country. 

3.2.1 Major U.S. Cotton and Soybean Production Regions

Major cotton- and soybean-growing regions in the continental U.S are shown in Figure 1 and

Figure 2, respectively. Little or no cotton and/or soybean production occurs in Hawaii, Alaska, 

and the U.S. territories, so these regions are not included in the figures (Figure 1and Figure 2). 

The data in Figure 1 and Figure 2 were used to identify the criteria described in Section 3.2.2 and 

define the ecoregions of the affected environment (Figure 3). The primary locations of cotton 

and soybean cultivation within Regions A to M are described in Table 2. For each of these cotton 

or soybean producing regions, the corresponding Level I ecoregion is used to describe the

physical terrain and climate. These are broad descriptions based on the ecoregion’s 

characteristics, and demonstrate the wide range of soil types, land, and climatic features.

3.2.2 Ecoregions of the Affected Environment

The 13 regions (A-M) of the affected environment (Figure 3) reviewed in this document 

represent the principal U.S. cotton- and soybean-growing areas. The Regions (A-M; Figure 3) 

are based on the identification of contiguous groups of counties that exceed a threshold. The 

29
threshold used to determine if a county was included in a region was the number of cotton or 

soybean acres (USDA-NASS, 2009d) multiplied by a constant (100) and the percentage of total 

cropland in that county that the crop covers. If the result exceeded 100,000 and the county was 

contiguous with another county that exceeded the100-thousand threshold, then the county was 

included as part of the affected environment reviewed in this document. Idle cropland was

excluded from the calculations. 

Figure 3. Major Soybean and Cotton Cultivation Regions in the United States.

For example, if 20,000 acres of cotton were harvested in a county, and this represented 6% of the 

total cropland in that county, the index number is 120 thousand. If the county was contiguous 

with another county with an index exceeding 100 thousand, then the county was included as part 

of the affected environment reviewed in this document.

Using this method, over 90% of the total soybean and cotton acreage harvested in 2007 (USDANASS, 2009d) was included in the regions identified in Figure 3 and considered as part of the 

affected environment here.

The affected environment includes a number of ecological regions (ecoregions) defined by the 

EPA and the Canada-Mexico-U.S. Commission for Environmental Cooperation (CEC). 

Ecoregions are areas that are similar in type, quality, and quantity of environmental resources 

(CEC, 2009). The CEC uses a hierarchical system to classify ecoregions into three different 

levels. The broadest one is Level I. It divides North America into 15 ecological regions. These 

are subdivided into 50 Level II ecoregions that are then further subdivided into 182 Level III 

subregions. Each Level III subregion is defined by a variety of physical, biological, and human 

factors. These include location, climate, terrain, hydrology, vegetation, wildlife, and land use

30
associated with human activities. The U.S. EPA ecoregions correspond to the CEC Level III 

subregions. A map of the Level III subregions of the conterminous United States is shown in

Figure 4.

Figure 4. Ecoregions of the Conterminous United States. Source: (CEC, 2006)

Commercial cotton or soybean production occurs in the 13 regions (labeled A-M) of the affected 

environment in the conterminous U.S. Most are in Level I ecoregions (i.e., EPA/CEC 

Ecoregions 8 [Eastern Temperate Forests] and 9 [Great Plains]). Ecoregion 8 covers most of the 

eastern half of the conterminous U.S. and is distinguished by its moderate to mildly humid 

climate, diverse forest cover, and high density of human inhabitants, industry, and agriculture. 

Ecoregion 9 covers most of the central conterminous U.S. and is distinguished by its sub-humid 

to semiarid climate, grasslands with little topographic relief, high density of agriculture and 

much lower (than Ecoregion 8) density of human inhabitants. Ecoregion 9 is among the largest

farming and ranching areas in the world. 

For cotton, a small portion of the affected environment also occurs in Level I ecoregion 10 

(North American Deserts) and 11 (Mediterranean California). Although these two ecoregions 

combined account for only about 4% of total U.S. upland cotton cultivation, cotton production is 

locally important in both regions. Within the continental U.S., the regions of soybean and cotton 

31
cultivation are non-overlapping with the exceptions of the Mississippi River Valley and the 

Southeast (see Table 2; Figure 1 and Figure 2).

The general descriptions of the physical and biological environments for each region that follow 

are based on the CEC combined with U.S. EPA Level III descriptions for ecoregions. These are 

supplemented by the U.S. EPA Level IV descriptions, unless otherwise cited (US-EPA, 2010a; 

CEC, 2011).

3.3 Physical Environment 

The physical environment is defined for the purposes of this document as the location and 

physical terrain within each region, its soil and water resources, air quality, and climate. The 

locations of cotton and soybean cultivation within Regions A-M are described in Table 2.

3.3.1 Physical Terrain and Climate

For each of these cotton or soybean producing regions, the corresponding Level I ecoregion is 

used to describe the physical terrain and climate. These are broad descriptions based on the 

ecoregion characteristics that include soil type, land and climatic features.

Table 2. Location of Major Cotton and Soybean Production Areas.

Region CEC/EPA 

Ecoregion

Location of Soybean and 

Cotton Cultivation Area

(sq. miles)

Percent of U.S. 

Harvest1

Soybean Cotton

A 

(Mixed Wood 

Plains, central 

portion)

8.1.1/83 

8.1.3/60

Upstate NY 5,184 0.3% 0%

B

(Mixed Wood 

Plains, western 

portion)

8.1.4/51 

8.1.5/52 

8.1.6/56 

Northwestern IL

Northern IN

Northeastern IA

Central and southern MI

Central MN

Central and western WI

60,802 5.2% 0%

C 

(Central USA 

Plains; Erie 

8.2.1/53 

8.2.2/57 

8.2.3/54 

8.2.4/55

Northern and central IL

Eastern, central and 

northwestern IN

102,899 18.4% 0%

32
Region CEC/EPA 

Ecoregion

Location of Soybean and 

Cotton Cultivation Area

(sq. miles)

Percent of U.S. 

Harvest1

Soybean Cotton

Drift Plain) 8.1.10/61

8.4.3/70 

(northwestern)

Eastern MI

OH (most)

Northwestern PA

Southeastern WI

D

(Southeastern 

USA Plains, 

eastern and 

southern 

portion; 

Appalachian 

Forests, 

northeastern 

portion; 

Southeast USA 

Coastal Plains)

8.3.1/64

8.3.4/45

(east-central)

8.3.5/65 

(eastern, southcentral)

8.4.1/67 

(northern)

8.5.1/63

8.5.3/75 

(northwestern)

8.5.4/84 

(southern)

Southern AL

DE

Northwestern FL panhandle

Southern and east-central GA

MD (most)

Central and southwestern NJ

Eastern and central NC

Southeastern PA

Northeast to southwest SC

Eastern VA

133,875 5.4% 19.7%

E 

(Southeastern 

USA Plains, 

northwestern 

portion)

8.3.2/71 

8.3.3/72

8.4.5/40 

(northern, 

along 8.3.2 

border)

North-central AL

Western and southern IL

Southwestern IN

Southeastern edge IA

Central and western KY

Eastern edge and central MO

Southwestern edge OH

North-central and southcentral TN

97,017 9.4% 0.7%

33
Region CEC/EPA 

Ecoregion

Location of Soybean and 

Cotton Cultivation Area

(sq. miles)

Percent of U.S. 

Harvest1

Soybean Cotton

F

(Mississippi 

Alluvial Plains; 

Southeastern 

USA Plains, 

western 

portion)

8.3.5/65 

(northwestern)

8.3.6/74

8.3.7/35

(Red River 

only)

8.5.2/73

9.5.1/34 

(eastern)

Eastern and southwestern AR

Western KY

Northeastern, northwestern 

and central LA 

Western and northern MS

Southeastern MO

Western TN

78,430 11.7% 15.3%

G

(Temperate 

Prairies)

9.2.1/46

9.2.2/48

9.2.3/47

9.2.4/40

IA (most)

Eastern KS

Western and southern MN

Northern and western MO

Eastern NE

Eastern and north-central ND

Northeastern OK

Eastern SD

201,400 38.7% 0%

H

(West-Central 

Semi-Arid 

Prairies, 

eastern 

portion)

9.3.1/42 North-central NE (small area)

Central and south-central ND

Central SD

30,487 2.3% 0%

I

(South-Central 

Semi-Arid 

Prairies, 

northeastern 

9.4.2/27 

(northern)

9.4.4/28

Central KS

South-central NB

North-central OK

70,597 5.8% 0.2%

34
Region CEC/EPA 

Ecoregion

Location of Soybean and 

Cotton Cultivation Area

(sq. miles)

Percent of U.S. 

Harvest1

Soybean Cotton

portion)

J 

(South-Central 

Semi-Arid 

Prairies, southcentral 

portion)

9.4.1/25 

(southern)

9.4.2/27 

(southern) 

9.4.3/26 (southeastern)

Southwestern OK

Northwestern TX

63,765 0% 47.1%

K 

(Western Gulf 

Coastal Plain)

9.5.1/34 Central Gulf Coast of TX 22,863 0% 5.2%

L

Warm Deserts 

(central 

portion)

10.2.2/81

10.2.4/24 (AZ 

only)

Southwestern AZ 35,352 0% 1.5%

M

(Central 

California 

Valley)

11.1.2/7 

(southern)

San Joaquin Valley CA 10,270 0% 2.8%2

CEC = Canada-Mexico-E.S. Commission for Environmental Cooperation (CEC)

EPA = U.S. Environmental Protection Agency

1 Based on USDA-NASS CropScape land cover data for 2012 (USDA-NASS, 2013j). Upland cotton represented 

more than 97% of total cotton acreage harvested from 2007-2012 (USDA-NASS, 2009d; 2013g). 2 CropScape does not distinguish between upland and Pima cotton, so the percentage listed for Region M includes 

Pima cotton production. Pima cotton averaged 60% of the harvested cotton acreage in California (USDA-NASS, 

2013g). 90% of the harvested Pima cotton acreage in the U.S. came from California in 2007-2012.

Region A is characterized by level to rolling terrain and open valleys with a variety of deep 

glacial and marine deposits, and some bedrock outcrops. It has a mid-latitude humid continental 

climate marked by warm summers and cold, snowy winters with a mean annual temperature of 

5-9 degrees Celsius (°C). The frost-free period ranges from 130 to 200 days. Annual 

precipitation ranges from 720 mm to 1,200 mm. Locations that are in closer proximity to the 

Great Lakes experience a longer growing season, more winter cloudiness, and greater snowfall.

Region B is characterized by rolling plains formed by glacial outwash and deposits. Some are 

complex deposits of drift, rolling to hilly moraines, deeply dissected plateaus, lacustrine basins, 

35
and meltwater channels. It has a mid-latitude, humid continental climate, and winters with no dry 

season. The mean annual temperature ranges from 5-10°C with a frost-free period of 130-200 

days. Annual precipitation is 600-990 mm.

Region C is characterized by flat to rolling glacial plains, with some clay plains, outwash plains, 

sand dunes, and moraines, with areas of wetlands. The southeastern edge in Ohio was not 

covered by a glacier, so it has the form of a dissected plateau with some rugged hills. It has a 

mid-latitude, humid continental climate with mean annual temperatures of 7-13°C. The frost-free 

period ranges from 140-200 days. Annual precipitation is 700-1150 mm, increasing from north 

to south.

Region D is characterized by features, ranging from low rounded or irregular hills, ridges, 

irregular plains and rolling or open valleys in the north and west (CEC/EPA Ecoregions 8.3.1, 

8.3.4, northern 8.4.1), and flatter, rolling to smooth coastal plains to the south and east 

(CEC/EPA Ecoregions 8.3.5 and 8.5.1). It has a mild mid-latitude humid subtropical climate 

with hot humid summers and mild winters, except for the northern areas (CEC/EPA Ecoregions

8.3.1 and northern 8.4.1), which have severe mid-latitude climates or are transitional areas and 

have cold winters. Mean annual temperatures range from 8-19°C. The frost-free period ranges 

from 145-300 days, increasing from north to south and west to east. Annual precipitation ranges 

from 900-1650 mm, generally increasing from north to south and west to east.

Region E is characterized by wide, flat-bottomed terraced valleys, valley slopes, and river bluffs 

to the north and west (CEC/EPA Ecoregion 8.3.2), with dissected glacial till plains in Illinois and 

Indiana, and by a broader variety of landforms to the east and south (CEC/EPA Ecoregion 8.3.3), 

including gently sloping, rolling and irregular plains, dissected plateaus, and tablelands and open 

hills. The climate also varies from a severe mid-latitude humid continental climate with hot 

summers and cold winters in the north and west to a mild mid-latitude humid subtropical climate 

with hot summers and mild winters with no pronounced dry season in the south and east. Mean 

annual temperatures range from 10-16°C and the frost-free period ranges from 160-220 days. 

Annual precipitation ranges from 850-1470 mm, with noticeably more precipitation to the south 

and east.

Region F is characterized by a variety of landforms, from a mostly broad and flat alluvial plain 

with river floodplains, terraces, swales, levees, oxbow lakes, and back swamps to the west 

(CEC/EPA Ecoregions 8.5.2 and 8.3.7), to irregular plains with some gently rolling hills to the 

east (CEC/EPA Ecoregions 8.3.6 and northwestern 8.3.5). Thick deposits of sandy to clayey 

alluvium occur in the west, thick deposits of loess in the central part of the region, and finetextured clayey sand and some loess to the east and north. The region has a mild mid-latitude 

humid subtropical climate with hot and humid summers and mild winters. Mean annual 

temperatures range from 13°C in the north to 21°C in the south, while the frost-free ranges from 

200-300 days, but approaches 350 days near the Gulf of Mexico. Annual precipitation ranges 

from 1140 mm to 1650 mm, increasing from north to south, and is fairly evenly distributed 

throughout the year. 

Region G is characterized by flat to gently rolling glacial till plains with thick beds of lake 

sediments on top, and by hilly loess plains with thick layers of loess. The southernmost part of 

the region is topographically hillier than the rest. The region has a severe, mid-latitude, humid 

36
continental climate, with a milder humid subtropical climate in the southernmost area (CEC/EPA 

Ecoregion 9.2.4). It is marked by short warm summers and long cold winters with nearly 

continuous snow cover to the north, and by longer hot summers and cold to mild winters further 

south. The mean annual temperature ranges from 3°C in the north to 16°C in the south, and the 

frost-free period ranges from 90 to 225 days. Annual precipitation ranges from 400- 1145 mm, 

increasing from northwest to southeast, with most precipitation occurring during the growing 

season. 

Region H is characterized by rolling hills and gentle plains mantled almost entirely by moraine, 

outwash, and glaciolacustrine sediments. It has a dry, mid-latitude steppe climate with warm to 

hot summers and cold winters. The mean annual temperature ranges from 3°C in the north to 9°C 

in the south, and the frost-free period ranges from 100 to 160 days. Annual precipitation ranges 

from 250 mm to 550 mm.

Region I is primarily characterized by smooth and level to slightly irregular plains, with broad 

alluvial valleys and some hillier dissected plains in the central part of the region (CEC/EPA 

Ecoregion 9.4.2), rolling hills, and relatively narrow steep valleys to the east (CEC/EPA 

Ecoregion 9.4.4). The climate varies both north to south and west to east. The west has a midlatitude steppe climate while the east has a mid-latitude humid continental climate. Summers are 

hot and winters are cold in the north becoming milder moving south. Mean annual temperatures 

range from 10°C in the north to 15°C in the south, with 135 - 200 frost-free days. Annual 

precipitation ranges from 450 mm to 1000 mm and is much higher in the easternmost part of the 

region (CEC/EPA Ecoregion 9.4.4) than elsewhere. 

Region J is characterized by nearly level to irregular plains that are lightly to moderately 

dissected. It has a mild mid-latitude humid to dry steppe climate moving from east to west, 

marked by hot summers and mild winters. The mean annual temperature ranges from 13°C to 

18°C and the frost-free period is 190 to 260 days (USDA-NRCS, 2006b). Annual precipitation 

ranges from 300 to 660 mm, increasing from west to east (USDA-NRCS, 2006b).

Region K is characterized by flat to gently sloping coastal plains in the agricultural areas, with 

sediments of marine sand, silt, and clay. It has a mild, mid-latitude, humid subtropical climate 

marked by hot summers and mild winters. The mean annual temperature ranges from 20°C to 

25°C, with a frost-free period of 270 – 365 days. The mean annual precipitation ranges from 600 

mm to 1625 mm, increasing rapidly from southwest to northeast.

Region L is characterized by mountain ranges to the north, scattered low mountains, and alluvial 

fans and valleys. It has a dry, subtropical desert climate marked by hot summers and mild 

winters. The mean annual temperature ranges from 15°C to 23°C. The frost-free period ranges 

from 200 - 365 days, decreasing in length with increasing elevations. Mean annual precipitation 

ranges from 75 mm to 500 mm, with winter rainfall decreasing from west to east and summer 

rainfall decreasing from east to west. Evaporation rates are high.

Region M is characterized by flat fluvial plains filled with deep and well-drained loamy or 

clayey soils formed by deposits washed down from the surrounding mountains. It has a warm 

and mild Mediterranean climate, with long, hot dry summers and mild, slightly wet winters. The 

mean annual temperature ranges from 15°C to 20°C, with a frost-free period of 280 to 365 days, 

37
decreasing with increasing elevation and latitude. The mean annual precipitation ranges from 

125 mm in the south to 300 mm in the northern margins.

3.3.2 Soil Resources

Soils are an admixture of weathered minerals, organic matter, air and water. They are formed 

mainly by the weathering of rocks, the decaying of plant matter, and the deposition of materials 

such as chemical and biological fertilizers that are derived from other origins.

Particle size, texture and color are important attributes used to classify a soil type into one of 

twelve taxonomic orders. Properties such as organic matter content and degree of soil profile 

development are also used (Brady and Weil, 1996) to systematically classify soils according to 

relationships that define their character (USDA-NRCS, 1999b). Eight soil orders (Table 3) are 

predominant in areas where cotton and soybean are grown.

Table 3. Dominant and Major Secondary Soil Types by Region.

Soil Order Description Region

Alfisols A dark surface horizon mineral soil,

similar to mollisols however, lacking the 

same level of fertility and more acidic.

A, B, C, D, E, F, G, I, J, K,

M

Aridisols These soils are found in the arid regions 

of the US. Typically high in calcium, 

Magnesium, potassium and sodium. The 

soils have an alkaline pH.

J, L, M

Entisols This soil order is relatively un-weathered.

These soils have no diagnostic horizon 

development. Often found on floodplains, 

glacial outwash areas and other areas

receiving alluvial materials.

B, C, D, E, F, H, I, J, L, M

Histosols Dominated by organic soil materials, 

some consist of a thin layer of organic 

materials over a root-limiting layer or

fragmental materials; commonly called 

bogs, peats, mucks

B

Inceptisols Soils of the humid and sub humid region. 

Weathering has created minimal

diagnostic differentiation in the soil

column.

B, C, D, E, F, J

Mollisols Dark colored mineral soils developed

under grassland conditions. Rich in 

nutrients, very fertile. Associated with the 

corn belt.

B, C, E, G, H, I, J, M

Ultisols Highly weathered soils found in hot, D, E, F

38
Soil Order Description Region

moist regions. Typically acidic and low

in available nutrients.

Vertisols Soils having major amounts of expanding

clay content. Soils typically crack when 

dry and swell when wet.

F, G, H, J, K, M

Source: (USDA-NRCS, 1999b)

Soil properties are dynamic. Temperature, pH, soluble salts, amount of organic matter, the 

carbon-nitrogen ratio, numbers of microorganisms, and soil fauna all vary seasonally, and shifts 

in these parameters also occurs over broader extended periods (USDA-NRCS, 1999b). Soil 

texture and organic matter levels directly influence shear strength, nutrient holding capacity, and 

permeability (McCauley et al., 2005). Soil types also influence susceptibility to erosion by wind 

and water and the capacity to attenuate flooding (McCauley et al., 2005).

Soil erosion is a naturally occurring event and the erosion rates are relatively slow; however, 

human activity can greatly accelerate the rate of erosion. In general, wind and/or water erosion 

are important soil resource concerns along with wetness and maintenance of organic matter 

content in the U.S. cotton- and soybean-growing regions (USDA-FSA, 2010). Figure 5 is a map 

of erosion exceeding the soil loss tolerance rate on cropland in the United States (USDA-NRCS, 

2011). Excessively eroding cropland soils are concentrated in the Midwest and the Southern 

High Plains of Texas (Regions G and J). From 1980-2011, the reported total soil erosion in U.S. 

cotton production areas decreased by 42%, and decreased in soybean production areas by 28% 

(Field-to-Market, 2012). Conservation tillage and no-till practices reduce soil erosion, and the 

amount of reduction depends on the existing soil structure, making quantification of the impacts 

on soil erosion difficult (NRC, 2010a).

Cotton can be produced in a wide variety of soil types, provided sufficient nutrition and moisture 

is available throughout the growing season. In general, loam and clay loam soils are more 

productive where annual rainfall is less than 20 inches per year, because these soil types are able 

to store more water, in comparison to coarse-textured soils that provide better internal drainage 

and are more productive where rainfall exceeds 30 inches per year (Graneto et al., 2013). 

Soybean production is best suited to fertile, well-drained, medium-textured loam soils, yet they 

can also be grown in a wide range of soil types (National Soybean Research Laboratory; 

Berglund and Helms, 2003).

39
Figure 5. U.S. Croplands with High Erosion Rates.

Source: (USDA-NRCS, 2011)

3.3.3 Water Resources

Resources analyzed in this section include the quality and quantity of water in surface and 

groundwater. Impacts from human consumption, particularly water for irrigating agricultural 

production, are also reviewed.

Surface water in rivers, streams, creeks, lakes, and reservoirs provides water for drinking and 

bathing, irrigation, industrial, and recreational uses. About 66% of water used in the U.S. in 2005 

(about 410 billion gallons per day) was from fresh surface water sources (USDA-FSA, 2010).

Surface runoff from rain, snowmelt, or irrigation can affect water quality by depositing sediment, 

minerals, and contaminants into streams, rivers, lakes, wetlands, and coastal waters. The amount 

of surface runoff is influenced by meteorological factors (such as rainfall intensity and duration), 

and physical factors (such as vegetation, soil type, and topography).

Groundwater flows underground, substantially contributes water to streams and rivers, is stored 

in natural geologic formations called aquifers, and sustains ecosystems by releasing a constant 

supply of water. In 2005, groundwater contributed about 19% of the freshwater used in the U.S. 

(USDA-FSA, 2010). Approximately 47% of the U.S. population depends on groundwater for its 

drinking water supply (McCray, 2012). Both groundwater and surface water can be used for 

40
irrigation, which accounted for approximately 28% of withdrawals from fresh surface water 

sources (USDA-FSA, 2010).

Based on 2005 data, the largest use of groundwater in the U.S. is irrigation, representing 

approximately 67% of all the groundwater pumped each day (USDA-FSA, 2010; McCray, 

2012). More than 90% of the areas irrigated in Mississippi and Missouri used groundwater 

(USDA-FSA, 2010). Wells replenished from groundwater often are the only source of irrigation 

in many locations in the Great Plains (US-EPA, 2012a). Groundwater sources are especially 

important for irrigation in Arizona, Arkansas, California, Nebraska, and Texas, accounting for 

nearly 60% of total groundwater withdrawals for irrigation in 2005. In three of these states 

(Arkansas, Nebraska, and Texas) fresh groundwater accounted for 75% - 96% of all irrigation 

water. Irrigation maintains adequate moisture for a crop, so it contributes to agriculture by 

increasing yields per acre, and by making more acreage (i.e., dry lands) usable. Irrigation also 

moderates fluctuations in product and seed quality. This is because moisture requirements for 

most crops tend to vary during development, and an adequate water supply allows crop growth 

during critical periods of the growing cycle. In this way, irrigation can optimize both quality and 

yield (US-EPA, 2012a). A variety of irrigation technologies are available (Figure 6) (Cantrell, 

2006). Efficient irrigation can reduce runoff and deep percolation (leaching) losses (TAMU, 

2014). In addition to irrigation, water is used in agriculture for pesticide and fertilizer 

applications, crop cooling (e.g., light irrigation), and frost control (US-CDC, 2013).

Figure 6. Examples of Cotton Irrigation Systems: A=furrow, B=drip method, C=low 

energy precision application.

Source: (Cantrell, 2006)

Irrigation is especially important to cotton agriculture in the western U.S. and the Mississippi 

River Valley (Figure 7). Most irrigation in California (Region M) is used for alfalfa, cotton, 

orchards, and vegetables (USDA-NASS, 2009a). Nationally, less than 10% of soybean acres and 

approximately 40% of cotton acres are irrigated. However, soybean accounts for about 25% of 

irrigated acres in the eastern 31 states, particularly in the Mississippi River Valley (Region F) 

(USDA-NASS, 2009b; 2009c; Schaible and Aillery, 2012b). Cotton is heavily irrigated in 

California, Arizona, western Texas, Georgia, and the Mississippi River Valley (Regions D, F, J, 

L, and M). Soybean is heavily irrigated in central Nebraska (Region I) (USDA-NASS, 2007b; 

2007c) (Figure 8).

41
Figure 7. Irrigated Cotton Acreage in the United States in 2007.

Source: USDA National Agricultural Statistics Service Map # 07-M080 (USDA-NASS, 2007b).

42
Figure 8. Irrigated Soybean Acreage in the United States in 2007.

Source: USDA National Agricultural Statistics Service Map #07-M194 (USDA-NASS, 2007c).

Information from the U.S. Geological Survey (Konikow, 2013) is combined with the Level III 

and Level IV Ecoregion descriptions to further describe the water resources in the regions 

identified as the Affected Environment:

Region A contains perennial streams, Lake Ontario, the Finger Lakes and some smaller lakes, 

and abundant wetlands in some areas. 

Region B has many perennial streams, with wetlands and lakes more common in northern areas. 

The northern Mississippi River runs through the region and groundwater is abundant and is the 

major source of irrigation water in Minnesota and Wisconsin (USDA-FSA, 2010).

Region C has a low to medium density of perennial streams, which are often intermittent in the 

more southern portions of the region. Some areas have lakes and abundant groundwater, which 

serve as the major source of irrigation water in Illinois and Wisconsin, and wetlands are 

abundant in the east (CEC/EPA Ecoregion 8.1.10). Drainage has been greatly modified in 

CEC/EPA Ecoregions 8.2.2 and 8.2.3, and stream chemistry, turbidity, and habitat have been 

affected by agriculture.

43
Region D has a moderate to dense network of streams and rivers, with few natural lakes but 

some reservoirs to the north and numerous swamps and marshes to the south. The Roanoke, 

Savannah, and Susquehanna Rivers, among others, run through the region.

Region E has numerous perennial streams and rivers in CEC/EPA Ecoregion 8.3.2, with silt and 

sand dominating lowland channels while upland streams are rockier. There are both perennial 

and intermittent streams and numerous springs in CEC/EPA Ecoregion 8.3.3, with higher 

nutrient, alkalinity and hardness levels than the streams in CEC/EPA Ecoregion 8.3.2. In the 

Western Pennyroyal region of Kentucky and Tennessee there are also many sinkholes, ponds and 

well developed underground drainage such that soils are quick to dry. The Illinois, Missouri, 

Mississippi, Ohio, Tennessee and Wabash Rivers all run through the region. 

Region F is dominated by the Mississippi River and used to contain one of the largest 

continuous wetland systems in North America. However, extensive areas have now been 

modified by channelization and navigation and flood control engineering. The Red River also 

runs through the region, and oxbow lakes, backswamps, and ponds occur. To the east there is a 

moderate to dense network of perennial and intermittent streams and rivers, including the 

Tombigbee River, but few lakes. Groundwater from the Mississippi Alluvial Valley alluvial 

aquifer is the major source for irrigation water in this region (USDA-FSA, 2010). Water 

withdrawals from the aquifer greatly exceed recharge from surface waters (Konikow, 2013).

Region G has a low density of rivers and intermittent and perennial streams through most of the 

region, with a higher density and several large rivers in the south, including the Des Moines, 

Kansas, and Missouri Rivers. The Minnesota River and the Red River of the North are the major 

rivers in the north. Many streams and rivers have been channelized. Abundant temporary and 

seasonal wetlands occur in the north, creating favorable conditions for waterfowl nesting and 

migration, and a few large reservoirs occur to the south. Groundwater is highly mineralized in 

some areas and surface and groundwater contamination from fertilizer and pesticide applications 

as well as from concentrated livestock production is a regional issue in the central portions of 

this region (CEC/EPA Ecoregion 9.2.3).

Region H has mostly intermittent streams, with some perennial streams and larger rivers, most 

notably the Missouri River which runs along the western boundary of most of the region. In 

some areas a high concentration of semi-permanent and seasonal wetlands can be found.

Region I has mostly intermittent and ephemeral streams to the west and intermittent and 

perennial steams to the east. There are a few larger rivers (Arkansas, Platte, and Kansas and its 

tributaries) and some springs, but few lakes. The Ogallala Aquifer underlies large portions of the 

ecoregion and is the major source for irrigation water in this region (USDA-FSA, 2010). Water 

withdrawals from the aquifer greatly exceed recharge from surface waters (Konikow, 2013; 

Steward et al., 2013).

Region J has few to no streams. Surface water occurs in numerous ephemeral pools or playas 

which serve as recharge areas for the Ogallala Aquifer, which is essential for cultivated 

agriculture in the region. However, water withdrawals from the aquifer usually exceed recharge. 

44
Region K has intermittent and perennial streams, some of which are channelized. There are 

numerous wetlands in the eastern part of the region.

Region L has ephemeral and intermittent streams, with few surface waters other than the 

Colorado River, which has a mountainous, distant source. Some springs and a few reservoirs are 

present. Water resource use is intense, both from rivers and ground water.

Region M the San Joaquin flows through the region. Streams are mostly intermittent and dry 

during the summer months. The region has an extensive network of water diversions, 

channelization, and drainage, and irrigation water management is a priority (USDA-NRCS, 

2006d). Groundwater from the Central Valley Aquifer is a major source of irrigation water, 

though secondary to surface water for this purpose, and groundwater withdrawals exceed 

recharge rates (Konikow, 2013). Groundwater contamination from heavy use of agricultural 

chemicals is a concern. Water in lowland streams is often degraded by sediments and salts from 

agricultural irrigation and drainage and municipal and industrial waste discharges.

Water Quality

Natural features (i.e., the physical and chemical properties) of the land surrounding a water body 

have the greatest impact on quality. The topography, soil type, vegetative cover, minerals, and 

climate also influence water quality. Regions of the U.S. identified as part of the Affected 

Environment continue to experience diminished water quality. For example, in Region C, 

drainage has become greatly modified, while in Region F, extensive areas are modified by 

channelization, navigation, and flood control engineering. Further, in Region G, groundwater is 

highly mineralized in some areas and there is groundwater contamination from fertilizer and 

pesticide applications. Finally, in Region M, groundwater contamination from heavy use of 

agricultural chemicals is a concern. Water in lowland streams can be degraded by sediments and 

salts from agricultural irrigation, drainage, municipal, and industrial waste discharges.

Sediments flowing into water bodies can affect the health of fish, aquatic invertebrates, and other 

wildlife. Sediments reduce light penetration into water, which can adversely impact aquatic plant 

growth and survival. Fertilizer runoff can contribute to chemical and mineral toxicity, higher 

water turbidity, algal blooms, and oxygen depletion in water resources. Soil erosion-mediated 

sedimentation can increase fertilizer runoff causing similar impacts (US-EPA, 2005; TAMU, 

2014).

Major sources of pollutants include storage tanks, septic systems, hazardous waste sites, and 

landfills. Widespread use of road salts, fertilizers, pesticides and other agricultural chemicals are 

also important sources. All surface water pollutants have the potential to be transported into 

groundwater. According to an EPA Report on the Environment for 2008, groundwater also was 

seriously affected by various nutrients and pesticides (USDA-FSA, 2010).

Agricultural pollution is the leading source of impacts on surveyed rivers and lakes. It is also the

third largest source of impairment of water quality in estuaries, and a major source of

contamination of groundwater and wetlands (USDA-NRCS, 2011). The most common types of 

agricultural pollutants include excess sediment, fertilizers, animal manure, and pesticides. 

Management practices that contribute to water contamination include the type of crop 

cultivated, plowing and tillage, and irrigation. Safe and appropriate storage, handling, and 

45
application of agricultural chemicals and wastes reduce the risks of water contamination 

(TAMU, 2014). Irrigation depletes available water and reduces quality by increasing erosion 

and sedimentation, nutrients dissolved in runoff, and chemicals adsorbed onto soil particulates 

washed into surface water. Some of these pollutants eventually contaminate groundwater by

leaching.

Pesticide use introduces chemicals into water through spray drift, the cleaning of pesticide 

application equipment, soil erosion, and subsequent filtration through soil into groundwater (USEPA, 2012c). Consequently, fertilizers and pesticides are in excess in many water bodies in the 

U.S. (USDA-FSA, 2010). The EPA documented over 3 million acres of water bodies and over 

75,000 miles of rivers and streams, large areas of bays and wetlands with excess levels of 

nitrogen and phosphorus. Excess of these two nutrients create harmful blooms of algae and other

aquatic flora which deplete oxygen that can result in many detrimental effects including fish 

kills. 

Nonpoint source (NPS) pollution comes from many diffuse sources. NPS pollution accumulates 

as runoff from rainfall or snowmelt moves over the ground, picks up, and then carries natural 

and human-made pollutants. NPS pollution increases sedimentation in surface waters following

soil erosion by surface runoff. These pollutants may eventually be transported into various types 

of permanent water resources, such as streams, rivers, and lakes. This is in contrast to a point 

source of pollution which has a discernible, confined, and discrete source. 

In addition to conservation tillage that leaves crop residue to absorb water, two other important 

agronomic methods of controlling runoff include furrow diking and use of center-pivot irrigation

systems. The mechanical tillage operation called furrow diking prevents runoff by placing 

mounds of soil at intervals across the furrow between crop rows to form small water storage 

basins. Rainfall or irrigation water is trapped and stored in the basins until it soaks into the soil, 

rather than running off. Center pivot systems irrigate in a circular pattern that can improve water 

distribution. In these systems, runoff is reduced by changing the speed to adapt the precipitation 

rate to the soil infiltration rate (New and Fipps, 2000).

3.3.4 Air Quality

The Clean Air Act (CAA) (amended in 1990) requires States to comply with the National 

Ambient Air Quality Standards (NAAQSs) established by the EPA for six principal pollutants, 

called criteria pollutants. The intention of these standards is to protect public health and the 

environment from these pollutants. The six criteria pollutants are: ozone (O3), nitrogen dioxide 

(NO2), carbon monoxide (CO), sulfur dioxide (SO2), lead (Pb), and inhalable particulate matter 

(PM). There are three subgroups of particulates based on particle size (Cambra-Lopez et al., 

2010). They are PM (coarse particulate matter greater than 10 μm [micrometers]), PM10

(particulates 2.5-10 μm), and PM2.5, (fine particles less than 2.5 μm) (US-EPA, 2013c).

Air quality monitoring data is collected and reviewed by EPA, state, and local regulatory 

agencies, and is available to the public. This data is often published with respect to a local air 

quality index (AQI). The AQI is a measurement (from zero to 500) of the level of criteria 

pollutants in the atmosphere. An AQI above 100 indicates that air quality conditions may be 

unhealthy for certain sensitive groups of people. An AQI over 300 represents air quality that is 

46
hazardous to everyone. AQI values below 100 indicate pollutant levels are at satisfactory levels

(AirNow, 2013).

Agricultural operations can affect air quality by releasing particulates, gases, and other chemicals 

into the air. Particulates may be released through a variety of cropping practices including the 

burning of crop residues or animal carcasses (Yang and Sheng, 2003; Lemieux et al., 2004). 

Burning releases smoke, exhaust from motorized equipment may release criteria pollutants, and 

cropping activities (such as planting, tillage, and harvesting) generate airborne soil particulates

when growers use motorized equipment (Lemieux et al., 2004). Gases, such as carbon dioxide 

(CO2), hydrocarbons, other volatile organic compounds, and methane, are released through 

equipment exhaust (particularly diesel exhaust), disturbance of the soil inducing population 

changes among the microbial flora, and animal production facilities, while fertilizer applications 

are associated with release of oxides of nitrogen, particularly during their manufacture (USDANRCS, 2006a; Zhao, 2007b; Aneja et al., 2009; Cambra-Lopez et al., 2010; US-EPA, 2011b). 

Burning releases smoke, exhaust from motorized equipment may release criteria pollutants, and 

cropping activities (such as planting, tillage, and harvesting) generate airborne soil particulates

when growers use motorized equipment (Lemieux et al., 2004). Gases, such as carbon dioxide 

(CO2), hydrocarbons, other volatile organic compounds, and methane, are released through 

equipment exhaust (particularly diesel exhaust), disturbance of the soil inducing population 

changes among the microbial flora, and animal production facilities, while fertilizer applications 

are associated with release of oxides of nitrogen, particularly during their manufacture (USDANRCS, 2006a; Zhao, 2007b; Aneja et al., 2009; Cambra-Lopez et al., 2010; US-EPA, 2011b).

Aerosols from herbicide, pesticide and fertilizer applications to crops are another source of 

molecules that impact air quality. The effects of aerosols are complex because these various 

molecules can: (1) drift from the target site, (2) volatilize to increase the area impacted, and (3) 

adsorb onto soil particles (Felsot, 2005; Hernandez-Soriano et al., 2007). Tillage and windinduced erosion may lead to suspended soil particles in the air and adsorbed aerosols becoming 

airborne (Felsot, 2005; Hernandez-Soriano et al., 2007). Vapor aerosol particles contribute to the 

formation of haze and decrease visibility (Zhao, 2007a).

Cotton and soybean fields typically are tilled just prior to planting (Albers and Reinbott, 1994). 

Tillage releases particulate matter into the air (Madden et al., 2009) as soil is disturbed. 

Reductions in tillage generate fewer suspended particulates (dust) and lower rates of soil wind 

erosion (Lyles and Woodruff, 1962). Tillage also is associated with increased emissions from 

farm equipment burning fossil fuels. Reducing the number of times tillage is done through a 

growing season reduces these vehicle emissions. Both of these benefits to air quality are variable 

and are affected by factors such as soil moisture and the specific tillage regime employed. The 

ability of reduced tillage to minimize the burning of fossil fuels is illustrated in Table 4, based on 

the Natural Resource Conservation Service (NRCS) Energy Estimator: Tillage Tool (USDANRCS, 2013a).This tool estimates potential fuel savings of 3,010 gallons or 60% savings per 

year based upon producing 1,000 acres of no-till soybean compared to conventional till soybean 

47
in the Urbana, Illinois, postal code.5 NRCS is careful to note that this estimate is only 

approximate because many variables affect an individual operation’s actual savings. This 

example, however, illustrates the magnitude of the contribution of minimum tillage to reducing 

the impact of agriculture on air quality.

Table 4. Total Farm Diesel Fuel Consumption by Tillage Method.

Estimate for 1,000-Acre 

Soybean Crop

(Urbana, Illinois)

Consumption by Tillage Method

(gallons per year)

Conventional 

Tillage

Mulch-till Ridge-till No-till

Total fuel use 4,980 4,110 3,330 1,970

Potential fuel savings over 

conventional tillage -- 870 1,650 3,010

Total savings -- 17% 33% 60%

Source: (USDA-NRCS, 2013a)

Prescribed burning is a land treatment, used under controlled conditions, to accomplish resource 

management objectives. Open combustion produces particles of widely ranging size, depending 

to some extent on the rate of energy release of the fire (US-EPA, 2011a). The extent to which 

agricultural and other prescribed burning may occur is regulated by individual State 

Implementation Plans to achieve compliance with the NAAQS. Prescribed burning of fields is

likely occurring only as a pre-planting option, based on individual farm characteristics.

Growers typically apply pesticides to conventionally grown cotton and soybean by ground spray 

equipment or aircraft. Both may affect air quality through drift and volatilization to the 

atmosphere (Owen, 2008). Drift is defined by the EPA as, “the movement of pesticide through 

air at the time of application or soon thereafter, to any site other than that intended for 

application” (Kiely et al., 2004). Small, lightweight droplets are produced by equipment nozzles; 

many droplets are small enough to remain suspended in air for long periods of time allowing 

them to be moved by air currents, until they adhere to a surface or drop to the ground. The 

amount of drift varies widely and is influenced by a range of factors, including weather 

conditions, topography, the crop or area being sprayed, application equipment and methods, and 

other practices followed by the applicator (Kiely et al., 2004). For example, the fine droplet size

of pesticides applied through center-pivot irrigation systems can lead to evaporation and drift 

unless minimized by addition of Low Elevation Spray Application applicators or Low Energy 

Precision Application irrigation methods (New and Fipps, 2000).

5 Postal codes are used in the NRCS Energy Estimator to estimate diesel fuel use and costs in the production of key 

crops for an area.

48

 
The EPA defines volatilization as the point “when pesticide surface residues change from a solid 

or liquid to a gas or vapor after an application of a pesticide has occurred.”6 Volatilization of 

herbicides and pesticides from soil and plant surfaces introduces these chemicals into the air.

A long-term USDA Agricultural Research Service (ARS) study to identify factors that affect 

pesticide levels in the Chesapeake Bay Region airshed (USDA-ARS, 2011) has determined that 

volatilization is highly dependent on exposure of disturbed loose and unstratified 

(unconsolidated) soils, and variability in measured compound levels is correlated with 

temperature and wind conditions. Another ARS study of volatilization of certain herbicides after 

application to fields has found moisture in dew and soils in higher temperature regimes 

substantially increases volatilization rates (USDA-ARS, 2011).

The EPA’s Office of Pesticide Programs (OPP), which regulates the use of pesticides, including

herbicides, in the United States, introduced initiatives to help pesticide applicators minimize offtarget drift. Currently, EPA-OPP is evaluating new regulations for pesticide drift labeling, and 

developing voluntary best management practices (BMPs) to aid in reducing drift, as well as 

identifying scientific issues surrounding field volatility of conventional pesticides (US-EPA, 

2010b). Additional information on off-target movement of pesticides is included in Appendix 7.

Other conservation practices may allow growers to qualify for crop insurance, federal loans, and 

other beneficial programs (USDA-ERS, 2009). Using conservation practices can effectively 

reduce crop production impacts to air quality through the deployment of windbreaks, 

shelterbelts, reduced tillage, and cover crops that promote soil protection on highly erodible 

lands.

The aspects of air quality discussed in this section, and water in Section 3.3.4, focused on the 

relatively small-scale activities occurring in and around cotton and soybean fields. We combine 

issues related to water and air with a broader, long-term perspective in the next section by 

examining aspects of climate change.

3.3.5 Climate Change

Climate change represents a statistical change in global climate conditions, including shifts in the 

frequency of extreme weather (Cook et al., 2008). Agriculture is estimated to contribute roughly 

six percent of all human-induced greenhouse gases (GHG) in the U.S. (US-EPA, 2011b). The 

EPA identified CO2, methane, and nitrous oxide as the key GHGs affecting climate change (USEPA, 2011c).

Agricultural practices are associated with the production and sequestration of GHG. Emissions 

of GHG released during the use of agricultural equipment (e.g., irrigation pumps and tractors) 

include carbon monoxide, nitrogen oxides, methane, reactive organic gases, particulate matter, 

and sulfur oxides (US-EPA, 2011b). Additional emissions arise from the production and delivery 

of fuels to farms (West and Marland, 2002). Nitrogen-based fertilizers are the largest source of 

6 http://www.epa.gov/pesticides/about/intheworks/volatilization.htm

49

 
U.S. nitrous oxide emissions (US-EPA, 2011b). Nitrous oxide is naturally produced in soils 

through microbial nitrification and denitrification, and it can be dramatically influenced by 

fertilization, grazing animals, cultivation of nitrogen-fixing crops and forage (e.g., alfalfa), 

retention of crop residues (i.e., no-till conservation), irrigation, and the fallowing of land (USEPA, 2011b). These same agricultural practices can influence the decomposition of carboncontaining organic matter sequestered in soil, resulting in conversion to carbon dioxide and 

subsequent loss to the atmosphere (US-EPA, 2011b). Agricultural sources of methane emissions 

are associated primarily with enteric emissions of gas from cattle and manure management. The 

conversion of cropland to pasture increases carbon and nitrogen sequestration in soils (US-EPA, 

2011c). Agricultural lands afford great opportunities for sequestering carbon (reducing carbon 

dioxide levels) and reducing or mitigating emissions of other GHGs. To a great extent, the 

contribution of agricultural activities to climate change depends on the production practices 

employed to grow various commodities, the region in which the commodities are grown, and the 

individual choices made by growers.

Three sources of carbon emissions from tillage practices have been identified. First is exhaust 

from machinery for cultivating the land, second is the application of fertilizers and pesticides. 

The third source is the soil organic carbon that is oxidized following soil disturbance (West and 

Marland, 2002).

Tillage contributes to GHG emissions by releasing CO2 previously sequestered in soil. 

Disruption and exposure of soil promotes CO2 production by the oxidation of soil organic matter

(Baker et al., 2005). The carbon footprint for any crop is directly affected by the associated

cultivation practices. For example, cotton cultivation is estimated to produce higher total CO2

emissions than soybeans (Nelson et al., 2009). On-site emissions can be reduced by half for 

some crops by replacing conventional with no-till systems agriculture (Nelson et al., 2009). In 

general, conservation tillage may decrease the rate of loss of soil organic carbon; however, CO2

emissions during pesticide and fertilizer application may negate the increased carbon sequestered 

in soils (West and Marland, 2002). The uncertainty inherent in these comparisons arises from 

industry-wide estimates based on production being juxtaposed against estimates based on 

grower-reported practices.

The EPA identified regional differences in GHG emissions associated with agricultural practices 

on different soil types, noting that carbon emission rates differ between mineral soils and organic 

soils (US-EPA, 2011b). Mineral soils contain from 1 to 6% organic carbon by weight in their 

natural state, but organic soils may contain as much as 20% carbon by weight (US-EPA, 2011b). 

Up to 50% of the soil organic carbon in mineral soils can be released to the atmosphere when 

land is initially converted to crop production. Over time, the soil establishes a new equilibrium 

that reflects a balance between carbon from decaying plant matter and organic amendments, and 

carbon released by microbial decomposition. On-site emissions can be reduced by half for some

crops by replacing conventional with no-till systems agriculture (Nelson et al., 2009). In general, 

conservation tillage may decrease the rate of loss of soil organic carbon, however, carbon 

emitted during pesticide and fertilizer inputs may negate the increased carbon sequestered in 

soils (West and Marland, 2002; US-EPA, 2011b).

Organic soils continue to release carbon to the atmosphere for a longer period of time than 

mineral-based soils (US-EPA, 2011b). Mineral soils contain from 1 to 6% organic carbon by 

50
weight in their natural state, but organic soils may contain as much as 20% carbon by weight 

(US-EPA, 2011b). EPA estimated that mineral soil-based cropland areas sequestered over 45.7 

Tg CO2 Eq7 in 2008. Carbon emissions from croplands with organic soils were estimated to be 

27.7 Tg CO2 Eq (US-EPA, 2011b). The highest rates of carbon sequestration occurred under 

conservation tillage, particularly in Midwest regions where mineral-based soils prevail (US-EPA, 

2011b).

Between 1980 and 2011, total GHG are reported to have increased by 10% for cotton production 

and 13% for soybean production (Field-to-Market, 2012). Agriculture-related GHG production 

will not change considerably unless large amounts of crop plantings produce changes in 

measureable concentrations of these gases (US-EPA, 2011b). For example, the EPA identified a 

net decline in the sequestration of carbon in soil over an 18-year period. The EPA attributed this 

to the impact of the Conservation Reserve Program which encouraged growers to take marginal 

lands out of production (US-EPA, 2011b). To a certain extent, the EPA also noted that adoption 

of conservation tillage resulted in increases in carbon sequestration on those croplands (US-EPA, 

2011b). The highest rates of carbon sequestration in mineral soils occurred in the Midwest, 

which is the region with the largest area of cropland managed with conservation tillage (USEPA, 2011b). This is in contrast to the highest emission rates from organic soils noted in the 

southeastern coastal region, the areas around the Great Lakes, and the central and northern 

agricultural areas along the West Coast (US-EPA, 2011b). However, conclusions about total 

carbon sequestration remain somewhat questionable, since the use of uniform protocols for 

measurement of changes may reduce the significance of some of the differences that have been 

observed (Baker et al., 2007; Maraseni and Cockfield, 2011). 

Global climate change may also affect agricultural crop production (Backlund, 2008). These 

potential impacts on the agro-environment and individual crops may be direct, including 

changing patterns in precipitation, temperature, and duration of growing season, or may cause 

indirect impacts influencing weed and pest pressure (Rosenzweig et al., 2001; Schmidhuber and 

Tubiello, 2007). A recent Intergovernmental Panel on Climate Change (IPCC) forecast (IPCC, 

2007) for aggregate North American impacts on agriculture from climate change projects yield 

increases of 5 to 20% for this century. The IPCC report notes that certain regions of the U.S. will 

be more adversely impacted because water resources may be substantially reduced. In addition, 

the current range of weeds and pests of agriculture is expected to change in response to climate 

change (USGCRP, 2009). While agricultural impacts on existing crops may be substantial, North 

American production is expected to adapt with improved cultivars and responsive farm 

management (IPCC, 2007).

Climate change may have a positive impact on agriculture. However, the extent of positive 

effects on agriculture from climate change is highly speculative, and will not be observed in all 

growing regions. For example, the IPCC indicates that certain regions of the U.S. will be 

7 The global warming potential of greenhouse gases is measured against the reference gas CO2; reported as 

teragrams (millions of metric tons) of CO2 Equivalent (Tg CO2 Eq).

51

 
negatively impacted by a substantive decline in available water resources. The IPCC also 

predicts potential climate change in North America may increase crop yields by 5 to 20 percent 

during the current century (Field et al., 2007).

3.3.6 Land Resources

According to the Food and Agricultural Organization of the United Nations (FAO), land cover is 

the observed physical cover on the surface of the earth as seen from the ground or through 

remote sensing. It includes vegetation (natural or planted) and human constructions such as 

buildings and roads (FAO, 1997).

Land use refers to the function or the purpose of the land. Therefore, land use can be defined as 

an activity or series of activities undertaken to produce one or more goods or services (FAO, 

1997). The FAO also indicates that a given land use may take place on one or more parcels, and 

several different uses may occur on a single parcel. This definition provides a basis for precise 

and quantitative economic and environmental impact analyses of different uses.

Land cover data were obtained for each Level III ecoregion using USDA-NASS CropScape 

(USDA-NASS, 2013j). The statistical estimates for acreage as generated by CropScape are 

considered as raw numbers requiring a correction factor to account for statistical bias (USDANASS, 2013j). However, the bias in estimates of area for different land covers is

proportionately equal, enabling comparisons of the area of different land cover classes relative 

to each other.

USDA-NASS uses the 2006 USGS National Land Cover Dataset (USGS-NLCD, 2006) to help

identify non-agricultural land cover (USDA-NASS, 2013j). Table 5 compares the land cover

groups and classes used by the National Land Cover Dataset to those used in this analysis, and

lists the class number used in each categorization. Definitions of land classes can be found in 

NLCD, 2013 (National Land Cover Database, 2014).

Table 5. Comparison of NLCD 2006 Land Cover Groups with Classes in This Document.

National Land Cover Dataset

(NLCD 2006) This Document

Water:

Open water (11)

Perennial ice/snow (12)

Water (1)

Water (1)

Developed:

Open space (21)

Low Intensity (22)

Medium Intensity (23)

High Intensity (24)

Developed (2)

Developed (2)

Barren (31) Barren (3)

52
National Land Cover Dataset

(NLCD 2006) This Document

Forest:

Deciduous (41)

Evergreen (42)

Mixed (43)

Forest:

Deciduous (4a)

Evergreen (4b) Mixed (4c)

Shrubland (52) Shrubland (5)

Herbaceous:

Grassland/Herbaceous(71)

Herbaceous:

Grassland/Herbaceous (6)

_____ Pasture and Hay (7)

(excluding alfalfa)

Planted/Cultivated:

Pasture/Hay (81)

(including alfalfa)

Cultivated Crops (82)

(including orchards; vineyards)

Cropland:

Orchards/Vineyards (8a)

Row crops (8b)

(including alfalfa; non- forestry trees)

Fallow (8c)

Wetlands:

Woody (90)

Herbaceous(95)

Wetlands (9)

Dominant vegetation types vary throughout the United States; these are described by region in 

the summary that follows: 

Region A: cropland and forest are co-dominant, accounting for one-third of land cover each, 

followed by pasture/hay and developed land at roughly 10% each.

Region B: cropland is dominant, accounting for one-third of land cover, forest covers 27%, and 

pasture/hay, developed land, and wetlands each cover about 10%.

Region C: cropland is dominant, accounting for more than 50% of land cover, with roughly 

equal amounts of forest and developed land (15%), followed by pasture/hay at 11%.

Region D: forest is dominant, accounting for nearly 40% of land cover, followed by cropland 

and wetlands at approximately 15% each and developed land at 11%.

Region E: forest is dominant, accounting for about 40% of land cover, while cropland and 

pasture/hay each account for approximately 25% of land cover.

Region F: cropland is dominant, accounting for slightly less than 40% of land cover, while 

forest covers 20% and wetland covers 17% of the region.

Region G: cropland is dominant, accounting for about 55% of land cover, while pasture/hay and 

grassland account for about 10% each.

53
Region H: grassland and cropland dominate land cover, accounting for more than 40% each.

Region I: cropland is dominant, accounting for about 45% of land cover, while pasture/hay

accounts for 30% and grassland for about 15%.

Region J: shrubland is slightly dominant, accounting for slightly more than 35% of land cover, 

followed closely by cropland at slightly more than 30% and grassland at 25%.

Region K: Cropland and pasture/hay are co-dominant, each accounting for slightly less than

25% of land cover, followed by shrubland, grassland, and wetland at roughly 12% each.

Region L: Desert shrubland is overwhelmingly dominant, accounting for 85% of land cover, 

while developed land accounts for 5% and cropland for about 3%.

Region M: Cropland is dominant, accounting for 70% of land cover, followed by grassland at 

about 20% of land cover.

Land cover composition varies across the affected environment (Table 6). For example, 

developed land ranges from 5 to 15% of land cover among the regions, accounting for 10% or 

more of the land cover in Regions A, B, C, D, and K. Central plains Regions H, I, J, and L in the 

Central Plains, Texas, and Arizona have much lower amounts of developed land. Wetlands 

account for 17% of the Mississippi Alluvial (Region F), and 16% of coastal Region D, and 13%

of coastal Region K, but are present in much lower amounts in all other regions.

Table 6. Land Cover Composition by Region.

Land Cover

Composition

Percent* Composition by Region

Region

A B C D E F G H I J K L M

1. Water 3 3 1 2 2 3 2 4 1 <1 2 <1 <1

2. Developed 10 10 15 11 8 6 7 4 5 5 13 5 9

3. Barren <1 <1 <1 <1 <1 <1 <1 <<1 <<1 <1 1 2 1

4a. Deciduous 26 26 16 15 38 13 7 1 3 1 2 <<1 <<1

4b. Evergreen 1 1 <1 22 1 5 <<1 <<1 <<1 1 1 <<1 <<1

4c. Mixed 2 <1 <<1 2 <1 2 <1 <<1 <<1 <<1 <1 <<1 <<1

5. Shrubland 5 <1 <<1 5 <1 5 <<1 <<1 <<1 37 12 85 <1

6. Grassland 0 5 1 4 1 <1 11 43 13 25 11 1 18

7. Pasture/hay 10 11 11 6 23 11 13 6 31 <<1 23 <1 <1

54
Land Cover

Composition

Percent* Composition by Region

Region

A B C D E F G H I J K L M

8a. Orchards 1 <1 <<1 <1 <<1 <1 <<1 <<1 <<1 <<1 <1 <1 27

8b. Row crops 33 33 53 15 25 34 56 40 43 30 18 3 30

8c. Fallow 1 <1 <<1 3 <<1 4 <1 1 3 2 5 2 13

9. Wetlands 7 9 2 16 1 17 4 2 1 <<1 13 1 2

*Rounded to nearest whole percent; totals may not add to 100% because of rounding errors.

Source: USDA-NASS CropScape land cover data for 2012(USDA-NASS, 2013e).

The major land uses of the affected environment are agriculture (including crop cultivation, 

pasture and rangeland, animal production, forestry and logging), industrial, housing/residential 

(including urban, suburban and rural), and recreational and tourism. Wildlife habitat loss and 

urban sprawl are environmental concerns throughout the country. The relative proportions of 

major land uses vary between and within regions, as described below and in Table 7. Data on 

animal production is from the 2007 Census of Agriculture (USDA-NASS, 2009d).

Region A: Principal crops include corn, soybean, and alfalfa. Grain production is primarily for

dairy cattle. Hay and alfalfa cultivation are roughly equivalent. Orchards, vineyards and 

vegetable farming (particularly cabbage) are also important in New York. Other major land uses 

include urban development, industry, recreation, and tourism.

Region B: Agricultural uses include cultivated cropland, pasture, livestock and dairy farming.

Corn, soybean, and alfalfa are the principal crops, along with some wheat. Potatoes and 

vegetables are other important crops in the eastern part of the region. Dairy farming is prevalent 

in Wisconsin. Other land uses peat harvesting, industrial sand and gravel mining, suburban and 

residential land uses, recreation and tourism (USGS, 2013).

Region C: Agriculture and cropland is extensive throughout the region. The predominant crops 

are corn and soybeans. Less abundant crops include wheat, alfalfa, dry beans, and squash. In

Wisconsin, most of the cropland is devoted to forage and feed grains to support dairy operations. 

Livestock and egg production are common. There are several large urban and industrial centers.

Smaller urban, suburban and rural residential land uses occur throughout the region.

Region D: In the north, land use is primarily agriculture with urban and suburban industrial 

uses. Soybeans, feed, and forage crops are prevalent. Hay production areas are approximately

equivalent to corn production areas. Nurseries for horticultural products and Christmas tree 

farms occupy some areas. Pine plantations are particularly prevalent to the south. Predominant 

crops in the region are soybean, corn, cotton, wheat, and peanuts. Other important crops 

include tobacco, pecans, sweet potatoes, peaches, and watermelon. The remainder of the region 

includes a mosaic of cropland, pasture, woodland and forests. There is also a high density of

55
poultry and hog production in some parts of the region. Land use in coastal areas within the

region is characterized by a high density of urban and suburban development with recreation 

and tourism.

Region E: Land use in the north and west is dominated by cropland agriculture and pasture. The

east and south tends to have a higher diversity of land uses that includes cropland, pasture, forest,

and woodlots with some expanding urban areas. Corn and soybean are the predominant crops. 

Wheat is also an important crop in the region, and tobacco is a major crop in Kentucky.

Livestock production, poultry farming, and egg production are also common. Mineral extraction

is important in some parts of the region. This includes some oil and gas production in the south

and east. Surface and underground coal mining are important industries in western Kentucky,

southern Illinois and Indiana (USGS, 2013), and these areas are associated with substantially

degraded downstream wetland habitat and water quality.

Region F: Except for the southern-most portion of the Mississippi Alluvial Plain (CEC/EPA 

Ecoregion 8.5.2), most of the region is cropland or pasture. Soybean is the predominant crop.

Rice is another major crop. More than 70% of U.S. rice is produced in this region. Other 

important crops include corn, cotton, wheat, sugarcane, and sweet potatoes. About 85% of U.S. 

aquaculture is conducted in this region. Principal products are catfish and crawfish from 

commercial ponds. Important minerals are ball clay mined in western Kentucky and Tennessee 

(USGS, 2013), and oil and gas production in the southern part of the region.

Region G: This is one of the most productive agricultural areas in the world. Cropland is

extensive, exceeding 75% of land use in some parts of the region. Principal crops are corn and 

soybean. Other important crops include wheat, canola and rapeseed, sunflower, hay and alfalfa, 

sugar beets, dry beans and peas, and flaxseed. Hog, cattle, and egg production are also prominent 

in the region.

Region H: The primary land uses in this region are rangeland for cattle grazing and cropland.

The dominant crop is wheat. Other major crops are corn, soybean, sunflower, alfalfa, flaxseed, 

and lentils. Hay production acreage is about 85% of that used in corn production.

Region I: Cropland (dryland and irrigated) and rangeland for cattle grazing are the principal land

uses. Wheat and corn are the primary crops. Soybean and sorghum are also important. Livestock 

cattle production also is common.

Region J: Most of the region is devoted to cropland, pasture, and rangeland. Major crops include 

wheat and cotton. Other major crops are corn and sorghum. Oil and gas production are 

prominent in the southwest portion of the region, largely non-overlapping with crop cultivation, 

and concentrated animal feeding operations (primarily cattle) are also economically important

(USDA-NRCS, 2006d).

Region K: Much of the region is cropland. Sorghum is the dominant crop. Cotton, corn, rice,

and citrus are also important. Grasslands and shrub rangeland provide fodder for livestock

grazing. Salt (USGS, 2013), oil and gas are important mineral production activities. Increased

urbanization and industrialization are recent trends in the region.

56
Region L: Multiple areas of intensive, irrigated cropland are dominated by alfalfa, cotton, and 

wheat production. The region is also a major producer of lettuce, celery, melons, and greens 

despite being highly susceptible to droughts. Much of the land is federally owned, either as 

military lands or national parks, monuments, and wildlife refuges. Rapid urbanization around the 

larger communities is greatly reducing cropland acreage.

Region M: Land use is dominated by agriculture. Nearly half the land in the region is cropland.

Three quarters of it is irrigated. A very wide variety of crops are grown. The major crops by

land area are almonds, wheat, alfalfa, cotton, corn, and grapes. Other major crops, often

constituting more than 50% of U.S. production, include walnuts and pistachios, pomegranates, 

nectarines, garlic, tomatoes, camelina, melons, lettuce, and olives. Cattle and dairy production is 

largely feedlot based. Urban areas and oil and gas production are also important.

Table 7. Major Cultivated Crops by Region in 20121.

Region Crop

Cropland

As a Percent of Total 

Cropland Acreage in 

the Region2

In Region As a 

Percent of Total 

U.S. Acreage

A

Corn

Soybean

Alfalfa

Wheat

Apples

Cabbage

48%

18%

18%

6%

3%

1%

1%

<1%

1%

<1%

8%

38%

B

Corn

Soybean

Alfalfa

Wheat

Potatoes

Asparagus

Cucumbers

Celery

53%

26%

15%

3%

1%

<1%

<1%

<1%

8%

5%

13%

1%

10%

35%

29%

C

Corn

Soybean

Wheat

Alfalfa

Dry beans

Cucumbers

Gourds

Pumpkins

53%

40%

3%

3%

1%

<1%

<1%

<1%

19%

18%

2%

6%

11%

47%

39%

33%

57
Region Crop

Cropland

As a Percent of Total 

Cropland Acreage in 

the Region2

In Region As a 

Percent of Total 

U.S. Acreage

D

Soybean

Corn

Cotton

Wheat

Peanuts

Tobacco

Pecans

Sweet Potatoes

Peaches

Watermelon

32%

28%

21%

15%

10%

1%

2%

<1%

<1%

<1%

5%

4%

20%

3%

79%

76%

63%

45%

42%

32%

E

Corn

Soybean

Wheat

Cotton

Alfalfa

Gourds

52%

46%

7%

1%

<1%

<1%

8%

9%

2%

1%

<1%

59%

F

Soybean

Corn

Cotton

Rice

Wheat

Sweet Potatoes

Sugarcane

51%

20%

12%

11%

10%

<1%

1%

12%

4%

15%

70%

3%

36%

22%

G

Corn

Soybean

Wheat

Alfalfa

Canola

Sugarbeets

Dry beans

Flaxseed

45%

40%

8%

2%

1%

1%

1%

<1%

34%

39%

11%

8%

61%

54%

41%

37%

H

Wheat

Corn

Soybean

Sunflower

Alfalfa

Flaxseed

Lentils

34%

26%

20%

6%

3%

2%

1%

5%

2%

2%

29%

2%

47%

28%

58
Region Crop

Cropland

As a Percent of Total 

Cropland Acreage in 

the Region2

In Region As a 

Percent of Total 

U.S. Acreage

I

Wheat

Corn

Soybean

Sorghum

Alfalfa

33%

34%

23%

9%

3%

12%

7%

6%

26%

4%

J

Cotton

Wheat

Sorghum

Corn

Peanuts

54%

39%

6%

2%

<1%

47%

8%

11%

<1%

2%

K

Sorghum

Cotton

Corn

Rice

Citrus

48%

26%

13%

6%

6%

19%

5%

<1%

6%

9%

L

Alfalfa

Cotton

Wheat

Lettuce

Barley

Celery

Misc. 

Fruit/Vegetable

Honeydew melons

Greens

40%

25%

12%

6%

6%

<1%

2%

<1%

1%

2%

2%

<1%

65%

2%

59%

30%

30%

25%

59
Region Crop

Cropland

As a Percent of Total 

Cropland Acreage in 

the Region2

In Region As a 

Percent of Total 

U.S. Acreage

M

Almonds

Wheat

Alfalfa

Grapes

Cotton

Corn

Pomegranates

Pistachios

Nectarines

Garlic

Tomatoes

Camelina 

Cantaloupes

Walnuts

Honeydew 

Melons

Lettuce

Olives

21%

14%

13%

13%

10%

9%

1%

5%

<1%

<1%

5%

3%

<1%

2%

<1%

<1%

1%

69%

1%

3%

42%

3%

<1%

97%

94%

85%

84%

53%

52%

45%

43%

36%

32%

25%

 1

Statistics for hay not included. 2

Some regional totals may be less than or more than 100% because of rounding errors or double cropping

practices.

By identifying land uses and the underlying soil parameters within the affected environment we 

can understand how to manipulate these environmental features to produce crops. Growers must 

use the land resources available to them and modify that environment to successfully produce 

crops. In Section 3.5, we review major agronomic methods important for cotton and soybean 

production. These include aspects of tillage, crop rotation, and agronomic inputs such as 

pesticides.

3.4 Biological Resources

Biological resources include the animal and plant communities associated with the major cotton 

and soybean cultivation areas within Regions A-M, as described in Table 2. Soil microorganisms 

are also reviewed in this section.

3.4.1 Animal Communities

Animal communities in this discussion include wildlife species and their habitats. Wildlife refers 

to both native and introduced species of mammals, birds, amphibians, reptiles, invertebrates, and 

fish/shellfish. Wildlife may feed on cotton and soybean plants in the field and/or use the habitat 

surrounding cultivated fields for nesting and refuge. Mammals and birds may seasonally 

60
consume soybean and occasionally cotton; invertebrates can feed on the plant during the entire 

growing season. The function and integrity of ecosystems and the wildlife populations they 

support influences how agricultural and other lands are managed.

The environment surrounding soybean and cotton fields may serve as important food sources and 

habitat for mammals, birds, fish, and insects. Soybean fields may be bordered by other soybean 

fields, or they may be surrounded by other agricultural crops, woods, pasture/grassland, or 

aquatic environments. Regardless of the agricultural operation, animals and insects in adjacent 

environments have the potential to be impacted directly by fertilizers, pesticides, and erosion or 

indirectly from the effects on the habitat surrounding the agricultural fields.

There are several crop management strategies that can increase the value of crop fields to 

wildlife including conservation tillage and no-till practices. Conservation tillage practices benefit 

biodiversity on agricultural land due to decreased soil erosion, improved surface water quality, 

retention of vegetative cover, increased food sources from crop residues, and increased 

populations of invertebrates (Landis et al., 2005; Sharpe, 2010b). Crop rotations also can reduce 

the likelihood of crop disease, insect and weed pests, and pesticide use which can benefit wildlife 

(University of California, 2008b).

Birds, Mammals, and Reptiles

Agricultural fields have the potential to provide food, water, and habitat for birds but each 

landowner’s farming practices and the crop type determines the value of these lands to wildlife. 

In the Cotton Belt, birds generally avoid cotton fields, although some generalist species (geese, 

egrets, gulls, and blackbirds) may periodically be observed in cotton fields (Butcher et al., 2007). 

Geese (Canada [Branta canadensis], snow [Chen caerulescens], and greater white-fronted 

[Anser albifrons] geese} and the northern pintail (Anas acuta) have been observed foraging in 

fallow or disked cotton fields that were flooded to enhance habitat for nonbreeding waterfowl 

during the fall or winter (Fleskes et al., 2003; Butcher et al., 2007). Cattle egrets (Bubulcus ibis) 

use cotton fields in the summer, which could be in response to increased invertebrate densities 

(Mora, 1997).

Waterbirds (e.g., geese, cranes, and shorebirds) and landbirds (e.g., red-winged blackbirds 

(Agelaius phoeniceus), purple martins (Progne subis), and bank swallows (Riparia riparia) are 

common visitors to soybean fields. Migratory birds have been observed feeding on spilled 

soybeans following crop harvest (Galle et al., 2009). However, the energy value of soybeans is 

low, so most birds only use soybeans to supplement their diet. Preferred diets include the 

consumption of nearby agricultural crops, especially corn and sunflower seeds, and the 

consumption of invertebrates and weed seeds in the soybean fields (Butcher et al., 2007). 

Migratory birds may be present in soybean fields year-round.

Some birds occurring within the affected environment that tend to be more localized include:

• Region A: wild turkey, waterfowl, ruffed grouse, woodpecker, warbler, screech owl

• Region B: wild turkey, turkey vulture

• Region C: Canada goose, sandpiper, sparrow

• Region D: wild turkey, herons, cardinal

61
• Region E: cardinal, bobwhite quail, Carolina chickadee

• Region F: wild turkey, migratory waterfowl, mourning dove, Carolina wren, wood 

thrush, cormorants, egrets, herons (widespread loss of forest and wetland habitat, has 

reduced bird populations but this region remains a major migratory flyway)

• Region G: Canada goose, bobwhite quail, sharp-tailed grouse, pheasants (this region is 

a major breeding habitat for waterfowl and other birds)

• Region H: golden eagle, ferruginous hawk, sage grouse

• Region I: numerous waterfowl (this is a major migratory flyway)

• Region J: turkey vulture

• Region K: waterfowl, geese, oriole, prairie chicken

• Region L: migratory waterfowl, chickadee, falcon, raven, thrasher

• Region M: wintering waterfowl, Nuttall’s woodpecker, yellow-billed magpie

Rodents, such as mice or squirrels, may seasonally feed on soybean seeds. During the winter 

months, leftover and unharvested soybeans provide a food source for wildlife. White-tailed deer 

and groundhogs (Marmota monax) feed on soybeans and cause soybean damage, while eastern 

cottontail (Sylvilagus floridanus), raccoon (Procyon lotor), squirrels, and other rodents (such as 

ground squirrels) also feed on soybeans, but their damage is of less substance (MacGowan et al., 

2006). Deer may cause damage by browsing in soybean fields for forage, and in some areas, the 

state may issue licenses to kill deer outside the hunting season to reduce crop damage (Garrison 

and Lewis, 1987; Berk A, 2008). Deer also may feed on seed left after harvest. In Georgia, feral 

hogs (Sus scrofa) have damaged soybean fields through rooting and feeding (Kammermeyer et 

al., 2003). Several mammals are widespread through many or most of the affected environment. 

These include white-tailed deer (Regions A-I; K), mule deer (Regions L and M), coyotes 

(Regions A-C; G-M), foxes (Regions A-G; I), raccoons (Regions A-G; J), red and/or gray 

squirrels (Regions A-D; F-H), bobcats (Regions C-F; H-L), and cottontail rabbits and/or 

jackrabbits (Regions D; G-J, M).

Some mammals occurring within the affected environment that tend to be more localized 

include:

• Region A: black bear, chipmunk, woodchuck, wolf in northern areas, beaver in the south

• Region B: beaver, otter, mink

• Region D: black bear, chipmunk

• Region E: badger, weasel in the north and west

• Region G: badger and skunk in southern areas

• Region H: pronghorn antelope and prairie dogs

• Region I: pronghorn antelope

• Region J: ringtail cat, armadillo, skunk, gopher

• Region K: ringtail cat, armadillo, ocelots

• Region L: pronghorn antelope, elk, cougar, chipmunk, pika, bats

• Region M: pronghorn antelope, elk, kit fox, ground squirrels, kangaroo rat

Some reptiles occurring within the affected environment that tend to be more localized include:

• Region D: box turtle, garter snake, rattlesnake

62
• Region E: snapping and box turtles, rattlesnake, copperbelly water snake

• Region G: this region is a major breeding habitat for waterfowl and other birds, including 

Canada goose, bobwhite quail, sharp-tailed grouse, and pheasants

• Region H: rattlesnakes

• Region J: Texas horned lizard

• Region K: alligator

• Region M: giant garter snake

Invertebrates

Invertebrate communities in agricultural fields represent a diverse assemblage of feeding 

strategies including predators, crop-feeders, saprophages, parasites, and polyphages (Stevenson

et al., 2002). Numerous insects and related arthropods perform valuable functions: they pollinate 

plants, contribute to the decay and processing of organic matter, reduce weed seed populations 

through predation, cycle soil nutrients, and attack other insects and mites that are considered to 

be pests. Although many arthropods in agricultural settings are considered pests, there are many 

beneficial arthropods which are natural enemies of both weeds and insect pests (Landis et al., 

2005). Terrestrial invertebrate food sources are likely impacted by insecticides used in soybean 

fields (including nontarget invertebrates). However, crop insect pests are considered less 

problematic than weeds in U.S. soybean production (USDA-NASS, 2009e).

For the purposes of environmental risk assessment, some high-profile or representative 

invertebrate species, such as honey bees, earthworms, and butterflies, are generally studied more 

thoroughly than others. Risk is a function of the toxicity of the compound to a given species and 

its exposure to the compound.

In order of importance, the most damaging arthropod pests in soybean in 2012 in the southern 

U.S. were corn earworm, soybean looper, and stink bugs (Musser et al., 2013). The soybean cyst 

nematode is a roundworm which is an important pest of soybean fields in several states, 

especially Nebraska and Minnesota (University-of-Minnesota-Extension, 2011). Major arthropod 

insect pests of soybean and the states in which they are distributed are shown in Table 8.

Table 8. Major Arthropod Pests of Soybean.

Pest Scientific Name States

Armyworm, beet Spodoptera exigua AR, NC, SC, TX, VA

Armyworm, fall Spodoptera frugiperda AR, SC, TN, VA

Armyworm, southern Persectania ewengii AR

Armyworm, yellowstriped Spodoptera ornithogallii AR, NC, VA

Armyworms Noctuidae MI, ND

Beetle, bean leaf Cerotoma trifurcata AR, IA, IL, IN, KS, KY, MI, 

MN, MO, NC, ND, NE, OH, 

SC, SD, TN, VA

Beetle, Japanese Popillia japonica IA, IL, IN, KY, MN, MO, NY, 

OH, PA, SC, TN

63
Pest Scientific Name States

Beetle, Mexican bean Epilachna varivestris IL, IN, KY, MO, NC, OH, PA, 

TN, VA

Beetle, seed corn Stenolophus lecontei IN, KS

Beetle, spotted cucumber Diabrotica 

undecimpunctata AR

Beetles, blister Epicauta spp. AR, IA, IL, KS, MO, TN, VA

Beetles, Colaspis Colaspis spp. AR, IA, MO, NC

Beetles, flea Chrysomelidae KS, ND

Borer, common stalk Busseola fusca VA

Borer, lesser cornstalk Elasmopalpus 

lignosellus NC, SC, TX

Borer, soybean stem Dectes texanus AR, IA, KS, NC, NE, SC, TX, 

VA

Bug, kudzu bug Megacopta cribraria VA

Bug, tarnished plant Lygus lineolaris ND

Bugs, stink Pentatomidae AR, IA, IN, KY, MO, NC, NE, 

SC, TN, TX, VA

Caterpillar, alfalfa Colias eurytheme AR, NE

Caterpillar, saltmarsh Estigmene acrea AR, MN, NC, TX, VA

Caterpillar, thistle Vanessa cardui AR, IA, MN, ND, NE

Caterpillar, velvetbean Anticarsia gemmatalis NC, ND, SC

Caterpillar, woolly bear Pyrrharctia isabella MN, TX, VA

Caterpillar, yellow woolly 

bear 

Spilosoma virgnica

NE

Corn earworm Helicoverpa zea AR, IL, MO, NC, SC, TN, TX, 

VA

Cutworms Noctuidae AR, IA, IL, IN, KY, MI, MN, 

ND, TN, TX, VA

Grasshoppers Acrididae AR, IL, IN, KY, MI, MN, MO, 

NC, ND, OH, SC, SD, TN, VA

Green cloverworm Hypena scabra AR, IN, KY, MI, MN, MO, 

NC, ND, NE, OH, PA, SC, 

TN, VA

Imported longhorn weevil Calomycterus setarius NE

Looper, cabbage Trichoplusia ni MO, ND, NE

Looper, soybean Pseudoplusia includens AR, IA, KY, MI, NC, SC, TN, 

VA

Potato leafhopper Empoasca fabae IL, IN, MN, ND, NE, VA

Seed corn maggot Delia platura IA, IN, KS, KY, MI, MN, MO, 

ND, NY, PA, VA

64
Pest Scientific Name States

Silverspotted skipper Epargyreus clarus NC, VA

Soybean aphid Aphis glycines IA, IL, IN: KS, KY, MI, MN, 

ND, NE, NY, OH, SD, TN, 

VA

Soybean leaf miner Odontota horni IA, NE

Spider mites Tetranychidae IA,IL, IN, KY, MI, MN, MO, 

ND, NE, NY, OH, SC, SD, 

VA

Threecornered alfalfa hopper Spissitulus festinus AR, KY, SC, TN, TX, VA

Thrips, especially soybean 

thrips

Thysanoptera

IN, MO, NC, NE, SD, VA

Tobacco budworm Heliothis virescens SC

Variegated leafroller Platynota flavedana AR

Webworm, alfalfa Loxostege commixtalis ND

Webworm, garden Achyra rantalis AR, MN, MO

White grubs Larvae of Scarabaeidae AR, IN,MN, MO, NC

Whiteflies Aleyrodidae NE

Wireworms Elateridae IN, MI, ND

Sources: (Thomas, 1993), (Station, No Date), (Moechnig et al., 2013), (University of Nebraska, 2013),(University of 

Kentucky), (Service, 1999), (University-of-Illinois-Extension), (Knodel et al., 2013), (Tennessee, 2014), (Herbert et 

al., No Date), (Whitworth et al., 2014), (Service, No Date), (Greene, 2014b), (Gouge et al., No Date), (Akin, 

2009b); (Extension, 2013); (Gesell and Calvin, 2000); (Hammond et al., 2009)

The most damaging arthropod pests in cotton fields in the United States in 2012 were: 

1. Thrips (>8 million acres infested); 

2. Bollworms and budworms (>6 million acres infested);

3. Lygus spp. (>5 million acres infested): 

4. Aphids (> 5 million acres infested);

5. Cotton fleahopper (> 4 million acres infested) (Mississippi State University, 2013).

Major arthropod pests of cotton and the states in which they are distributed are shown in Table 9.

Table 9. Major Arthropod Pests of Cotton.

Pests Scientific name States

Aphid, cotton Aphis gossypii AR, AL, CA, FL, LA, MO, MS, 

NM, OK, SC, TX

Aphid, cowpea Aphis craccivora AZ, CA, NC

Armyworm, Beet Spodoptera exigua AR, AL, CA, GA, LA, MO, MS, 

NC, NM, OK, SC, TX

Armyworm, fall Spodoptera frugiperda AR, AL, GA, LA, MO, MS, NC, 

SC, TX

65
Pests Scientific name States

Armyworm, southern Spodoptera eridania

AR

Armyworm, 

yellowstriped

Spodoptera 

ornithogalli AR, AL, MO, MS, NC, TX

Boll weevil Athonomus grandis 

grandis AL, GA, MS, NC, OK, TX

Bollworms Helicoverpa 

punctigera, 

Helicoverpa armigera

AR, GA, KS, LA, MO, MS, NC, 

NM, OK, TX

Common stalk borer Papaipema nebris AL

Corn earworm Helicoverpa zea AL, GA, SC

Cotton fleahopper Pseudatomoscelis 

seriatus KS, LA, MO, OK, SC, TX

Cotton leaf perforator Bucculatrix 

thurberiella TX

Cotton square borer Strymon melinus TX

Cotton stainer Dysdercus suterellus TX

Cutworms Agrotis spp. AL, GA, LA, MO, MS, NC, TX

European corn borer Ostrinia nubilalis AL, MO, MS

Flea beetles Chrysomelidae AZ, MO

Grasshoppers Brachystola magna, 

Melanoplus spp. AR, NM, OK, TX

Leafroller, 

omnivorous

Platynota stultana

TX

Leafroller, variegated Platynota flavedana MO

Leafworm, Brown 

Cotton

Acontia dacia

TX

Leafworm, cotton Alabama argillacea AL, TX

Loopers Geometridae AR, AL, GA, LA, MO, MS, NC, 

OK

Pink bollworm Pectinophora 

gossypiella CA, MS, TX

Plant bug, clouded Neuroculpus nubilus AR, TX

Plant bug, tarnished Lygus lineolaris AR, AL, AZ, CA, FL, GA, KS, 

LA, MO, MS, NC, NM, OK, SC, 

TX

Saltmarsh caterpillar Estigmene acrea AR, MO, TX

Spider mites Tetranychidae AR, AL, CA, GA, LA, MO, MS, 

NC, OK, SC, TX

Stink bugs Reduviidae AR, AL, CA, LA, MO, MS, 

NM: SC, TX

66
Pests Scientific name States

Thrips Frankliniella fusca, 

others

AR, AL, CA, GA, KS, LA, MO, 

NC, NM, OK, SC, TX

Tobacco budworm Heliothis virescens AL, LA, MO, MS, NC, NM, 

OK, SC, TX

Vegetable weevil Listroderes 

costrirostris obliquus AR

Whiteflies Bemisia tabaci, others AZ, AL, CA, GA, LA, MO, MS, 

NM, SC, TX

Whitefringed beetles Naupactus spp. FL

Sources: (Akin, 2009a), (Bohmfalk et al., 2011a), (Carlson and LaForest, 2010), (North-Carolina-CooperativeExtension, 1994), (Mossler, 2013), (Williams, 2013b), (University-of-Arizona-Cooperative-Extension, 2001), 

(Schowalter, 2014); (Entomology); (Greene, 2014a); (Boyd et al., 2004a); (Freeman, 2012); (Franke et al.)

Insect pests are managed during the growth and development of both crops to enhance yield 

(Higley and Boethel, 1994; Aref and Pike, 1998). This includes scouting for pests, establishing 

action thresholds beyond which treatment is required, and spraying with insecticides. In 2013, 

approximately 77% of acreage planted in cotton was sprayed with insecticide (Williams, 2013a).

Insects and other invertebrates can be beneficial to soybean and cotton production, providing 

services such as nutrient cycling and preying on plant pests. Table 10 lists the major beneficial 

arthropods in soybean and cotton fields.

Table 10. Major Beneficial Arthropods in Soybean and Cotton 

Cotton Soybeans

Species or family Controls Species or family Controls

Honey bee (Apis 

mellifera)

Pollinator

Predators Predators

Ants (Formicidae) Bollworm eggs and 

larvae

Ground beetles 

(Carabidae)

Aphids

Ambush and assassin 

bugs (Reduviidae)

Aphids, bollworm eggs, 

larvae

Mite (Phytoseiulus 

persimilis)

Spider mites

Bigeyed bugs (Geocoris 

spp.)

Aphids, bollworm eggs, 

larvae

Spined soldier bug 

(Podisus 

maculiventris)

Mexican bean beetle

Pirate bugs 

(Anthocoridae) 

Aphids, bollworm eggs, 

larvae, thrips, 

whiteflies, spider mites

Pirate bugs 

(Anthocoridae)

Aphids

Damsel bugs (Nabidae) Aphids, bollworm eggs, 

larvae

Lacewing larvae 

(Chyrsopidae)

Aphids, bollworm eggs, 

larvae

Lacewings 

(Chrysopidae)

Aphids

Ladybird beetles 

(Coccinellidae)

Aphids, spider mites, 

bollworm eggs, 

budworm eggs

Ladybird beetles 

(Coccinellidae)

Aphids

67
Cotton Soybeans

Species or family Controls Species or family Controls

Ant, Fire (Solenopsis 

spp)

Immature boll weevils, 

bollworm eggs, 

budworm eggs

Cotton fleahopper Bollworm eggs, 

budworm eggs

Spiders

Parasitoids Parasitoids .

Parasitic wasps

(Trichogramma spp.)

Bollworm eggs Hover flies 

(Syrphidae)

Aphids

Parasitic wasps 

(Cardiochiles spp.)

Budworm eggs Braconid wasp 

(Meteorus communis)

Aphids

Braconid wasp 

(Glyptapanteles 

militari)

Aphids

Source:(Bohmfalk et al., 2011b; Herbert et al.; Mississippi State University, 2014)

Aquatic Animal Communities

Aquatic ecosystems potentially impacted by agricultural activities include water bodies adjacent 

to or downstream from crop field, including impounded bodies, such as ponds, lakes, and 

reservoirs, and flowing waterways, such as streams or rivers. If near coastal areas, aquatic 

habitats affected by agricultural production may also include marine ecosystems and estuaries. 

Aquatic species that may be exposed to sediment from soil erosion and, nutrients and pesticides 

from runoff and atmospheric deposition include freshwater and estuarine/marine fish and 

invertebrates, and freshwater amphibians. Although some ecological research has shown that 

farming practices can be detrimental to stream health (Genito et al., 2002), recently some 

research suggests that agricultural lands may support diverse and compositionally different 

aquatic invertebrate communities when compared to nearby urbanized areas (Lenat and 

Crawford, 1994; Wang et al., 2000; Stepenuck et al., 2002).

Common fish found in each region include:

• Region A: northern pike, walleye, carp, bass, trout

• Region B: trout, perch, catfish

• Region F: alligator gar, pallid sturgeon, other “big river” species

• Region G: walleye, perch

• Region L: trout

• Region M: Chinook salmon, delta smelt

3.4.2 Plant Communities

Plant communities vary by region. In a previous Section (3.3.7) land cover in each of the 13 

regions of the affected environment was reviewed. Dominant vegetation types among the regions 

are summarized in Section 3.3.7. The vegetation types can include forest, shrubland, cropland, 

68
pastures, and grasslands. Table 6 and Table 7 provide descriptions of land cover in each of the 

regions.

Weeds have been estimated to cause a potential yield loss of 37% in world-wide soybean 

production (Heatherly et al., 2009). Weeds compete with soybean for light, nutrients, and soil 

moisture. They can also harbor insects and diseases, and interfere with harvest, causing extra 

wear on harvest equipment (Loux et al., 2008). In addition to weed density, the time that weeds 

compete with the soybean crop influences the level of yield loss. The later the weeds emerge, the 

less impact they will have on yield. Soybean plants withstand early season weed competition 

because the soybean canopy closes earlier (Boerboom, 2000). The extent of canopy closure 

restricts the light available for weeds and other plants growing under the crop. In addition,

canopy closure occurs more quickly when soybean is drilled or planted in narrow rows 

(Boerboom, 1999). However, in some studies it has also been observed that, depending on 

factors such as weed species, environmental conditions (i.e., rainfall amounts) and soybean 

cultivar, soybeans are able to compete with weeds with no resulting yield reduction (Krausz et 

al., 2001).

In addition to the generally described land cover in an area, plant communities in agricultural 

fields include a range of weeds that influence and are influenced by agricultural practices. For 

example, cotton planted at too high a density forces the plants to compete for sunlight, water, and 

nutrients which limits each plant’s production (Rude, 1984), even though a high density of crop 

plants also reduces competition from weeds. Common weeds growing in the regions of the 

affected environment are identified in Appendix 5.

3.4.3 Microorganisms

The ability of animals to move in and out of fields can reduce their exposure to the crop 

production system. In contrast, soil microorganisms and plants living within cotton and soybean 

fields are simultaneously exposed to all of the agronomic practices affecting the crops. This 

section is a brief review of microbial components of the affected environment.

Inorganic and organic matter in soil supports a diversity of fungi, bacteria, and arthropods that

are important components of the growth medium for terrestrial plant life (USDA-NRCS, 2004).

Soil microorganisms are critical for soil structure formation, decomposition of organic matter,

toxin removal, nutrient cycling, and most biochemical soil processes (Young and Ritz, 2000; 

Jasinski et al., 2003; Garbeva et al., 2004). They also suppress soil-borne plant diseases and

promote plant growth (Doran et al., 1996). Soil resilience considers the capability of the soil to 

return to a pre-perturbation condition, and not as an intrinsic capacity to resist displacement from 

an initial equilibrium state (Welbaum et al., 2004).

Soil resilience is affected by the main factors affecting microbial population size and diversity. 

These include plant type (providers of specific carbon and energy sources into the soil), soil type 

(texture, structure, organic matter, aggregate stability, pH, and nutrient content), and agricultural 

management practices (crop rotation, tillage, herbicide and fertilizer application, and irrigation)

(Young and Ritz, 2000; Garbeva et al., 2004). Plant roots release a variety of compounds into the 

soil that create a unique environment for microorganisms in the rhizosphere (Garbeva et al., 

2004). Reduced-tillage practices enhance soil stability and reduce erosion in comparison to 

69
conventional tillage systems. All of these effects enhance soil microbial diversity. Although the 

total species diversity in the soil appears constant, organic matter decomposition continues to 

occur. This leads to the sequential colonization of niche specialists using different substrates as 

they present themselves over time. Consequently, changes in the relative abundance of a soil

species is juxtaposed with aggregate variability in the overall abundance and biomass of the 

microbial community (Welbaum et al., 2004).

The soil microflora includes mycorrhizal fungi, nitrogen-fixing bacteria, and some free-living 

microbes that evolved together with plants to supply nutrients to the plant while obtaining food 

from their plant hosts (USDA-NRCS, 2004). This extensive microbial diversity in the 

rhizosphere differs from the microbial community in the bulk soil (Garbeva et al., 2004) because 

the root-specific exudates are the food sources used by these organisms to maintain and increase 

their populations. Tillage accelerates succession among microorganisms, and crop rotation can 

change soil conditions to favor different microbial communities (Papendick and Moldenhauer, 

1995b).

Inoculants are used to ensure adequate populations of “rhizobia” or Bradyrhizobium japonicum

establish in soybean fields. This bacterium, in association with soybean roots, fixes atmospheric 

nitrogen into forms (ammonia or ammonium) the plant can use for growth and development 

(Alberton et al., 2006). Successful inoculation leads to nodulation on the soybean root, and 

excess fixed nitrogen remains in the soil to become available for subsequent crops or weeds 

(Alberton et al., 2006). Growers inoculating soybean fields can improve soybean yield by an 

average of 1 bushel/acre (Conley and Christmas, 2005). This organism can be added to fields in 

many forms including: non-sterile peat powder applied to the seed at planting, sterile carriers, 

inoculants with adhesives to stick to seed, liquid carriers, concentrated frozen products, preinoculants, and inoculants with extended biofertilizer and biopesticidal properties (Jawson et al., 

1989; Conley and Christmas, 2005).

Another group of soil microorganisms that can affect soil quality, resilience, and crop growth are 

nematodes. These microscopic worms also can be pathogens that feed on the roots of various 

plants, including both cotton and soybeans. Many nematode species are difficult to control 

because it is difficult to find suitable molecules that can penetrate the soil, kill the microscopic 

pests, and not persist or have deleterious effects on other organisms.

3.5 Agronomic Practices in Cotton and Soybean Production

Modern agriculture coordinates a wide variety of ecosystem inputs to maximize crop yield and 

wisely use the land, vegetation, and environmental resources. Cotton and soybean production 

uses specific equipment for each crop’s activities from pre-plant soil preparation to harvest and 

ginning (Weersink et al., 1992; Mitchell et al., 2012). For example, cotton may be harvested 

with spindle pickers, roller gins, or saw ginning depending on the variety (Rude, 1984; 

Anonymous, 2007). Tillage, crop rotation, and inputs such as pesticides are selected from a range 

of options by each grower to achieve their desired outcomes of yield and environmental 

stewardship.

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3.5.1 Tillage 

Prior to planting, soil is typically prepared by eliminating weeds that would otherwise compete 

with the crop for space, water, and nutrients. Field preparation often is accomplished through a

variety of tillage systems, with each system defined by the remaining plant residue on the field 

(USDA-ARS, 1995).

Crop residues are materials left in an agricultural field after the crop has been harvested, 

including stubble (stems), leaves, and seed (USDA-NRCS, 2005). These residues aid in 

conserving soil moisture and reduce wind and water-induced soil erosion (Papendick and 

Moldenhauer, 1995b; USDA-ERS, 1997; USDA-NRCS, 2005; Heatherly et al., 2009). Residue 

on the soil surface breaks the impact of raindrops, improves water infiltration into the soil, and 

reduces evaporation and runoff (TAMU, 2014).

Conventional tillage is associated with intensive plowing and leaving less than 15% crop residue 

in the field (US-EPA, 2010b). In contrast, conservation and reduced tillage practices include: 

mulch-till, eco-fallow, strip-till, ridge-till, zero-till, and no-till (Jia et al., 2007). Reduced tillage 

is associated with 15-30% crop residue. Conservation tillage, including no-till practices requiring

herbicide application on the plant residue from the previous season, is associated with at least 

30% crop residue and substantially less soil erosion than other tillage practices (US-EPA, 

2010b). Additionally, a number of different tillage and planting systems are used in soybean 

production, including primary or secondary tillage (Jia et al., 2007). Pre-plant tillage activities 

in cotton may include smoothing the soil or creating raised ridges for permanent or semipermanent beds (Rude, 1984; Albers and Reinbott, 1994; Mitchell et al., 2012). Increases in 

total acres dedicated to conservation tillage may be facilitated in part by an increased use of 

herbicide-resistant GE crops, reducing the need for mechanical weed control (USDA-NRCS, 

2010a; Fernandez-Cornejo et al., 2014a).

Land management practices for crop cultivation also affect soil quality. Soil quality is related to 

its suitability for chosen uses (Welbaum et al., 2004). Tillage can affect soil properties after 

cultivation depending on the soil type (Papendick and Moldenhauer, 1995b). Several concerns 

relating to soil and agricultural practices include increased erosion, soil compaction, degradation 

of soil structure, nutrient loss, increased salinity, change in pH, and reduced biological activity 

(USDA-NRCS, 2010b). Conventional tillage removes essentially all plant residues and weeds 

from the soil surface prior to planting. Conventional tillage practices may continue cultivation as 

the crop develops to control late emerging weeds (National Corn Growers Association, 2007)

particularly in cotton crops (Frans and Chandler, 1989). This practice increases the potential for 

soil loss from wind and water erosion (NCGA, 2007). Additionally, soil compaction associated 

with tillage machinery moving across fields may damage young, developing cotton crops (Rude, 

1984; Mitchell et al., 2012). The act of mixing soil during tillage increases seed bed 

homogeneity while simultaneously destroying the diversity of microsites in the soil profile, 

consequently, tillage reduces both structural and functional diversity of the soil microbial 

community (Welbaum et al., 2004).

In general, soil conservation practices, such as conservation tillage, reduce field tillage and 

corresponding soil loss (Tyler et al., 1994b; Papendick and Moldenhauer, 1995a; USDA-NRCS, 

2006b). Conservation tillage relies on methods that result in less soil disruption and leaves at 

71
least 30% of crop residue on the surface in soybeans (Peet, 2001). No-till farming only disturbs 

the soil between crops. The new crop is planted into residue or in narrow strips of tilled soil 

(Peet, 2001), which results in less soil disruption. Under no-till practices, there is no turning of 

the soil to break up compacted areas (USDA-NRCS, 1996a). Reducing tillage may also enhance 

conditions for development of economically important pest populations that normally are 

efficiently managed with conventional tillage practices (NRC, 2010a). For example, cotton 

aphids migrate into fields using conservation tillage and consistently reach peak population 

densities more rapidly than in conventionally tilled fields (Leonard, 2007).

Conservation tillage is highly valued as a means to enhance soil quality and preserve soil

moisture, but it also presents potential challenges for disease and pest management (Rude, 1984; 

Tyler et al., 1994a; Papendick and Moldenhauer, 1995b). The surface residues may serve as an 

inoculum source for certain disease-causing organisms (Robertson et al., 2009). This can become 

problematic for growers using crop rotation schemes with minimal tillage (Robertson et al., 

2009).

Cotton production systems generally rely on multiple-pass tillage, which is costly in labor, time, 

maintenance of specialized equipment, and fuel (El-Zik et al., 1989; Frans and Chandler, 1989; 

Albers and Reinbott, 1994; Mitchell et al., 2012). Despite incentives to reduce tillage, such as the 

USDA NRCS Environmental Quality Incentives Program, most cotton continues to be produced 

under traditional, multiple-pass tillage practices (Mitchell et al., 2012). 

In traditional cotton cultivation, after the prior crop is harvested, the surface material is shredded 

and roots are undercut and mixed with the soil (Albers and Reinbott, 1994; Mitchell et al., 2012). 

A series of diskings provides a host-free period that is usually needed to reduce pink bollworm. 

There may be more than five field operations prior to seeding the cotton crop (plow under weeds, 

incorporate herbicides, break-up soil clods, shape the uniform planting beds, prepare for furrow 

irrigation and/or dry mulch) (Albers and Reinbott, 1994; Mitchell et al., 2012). Shallow 

cultivation using rolling harrow implements can kill weeds and even out surface soil moisture. 

Soil types prone to compaction can be loosened or fractured to reduce root restriction in hard soil 

layers (Mitchell et al., 2012). Since the 1990s, tractor traffic zones were separated from crop 

growth zones to create strip and vertical tillage systems where only the crop seed line is tilled. 

Improvements in equipment reduced tractor traffic, energy costs, and the soil compaction by 

combining tillage tools onto a single frame. Reducing the number of tillage passes reduces time, 

fuel use, the amount of dust generated (soil erosion), and can improve various aspects of water 

quality (Tyler et al., 1994a; Mitchell et al., 2012).

Effective pink bollworm and nematode control in cotton require tillage operations to reduce soilborne populations of these pests (Kirkpatrick and Thomas; Mitchell et al., 2012). These pests 

and others overwinter in the soil, and then infect or infest the new crop. Disease control measures 

include cultivation of resistant hybrids, crop rotation, and careful balancing of conservation 

tillage with residue management (Robertson et al., 2009).

Information provided by Monsanto on the trends in tillage practices for cotton showed variation 

across the country in the last five years (Monsanto, 2013d). According to the survey data, 

growers in the Western U.S. did not tend to increase use of conventional tillage practices, in 

contrast to those in the Mid-South. The survey revealed that growers adopt specific tillage 

72
practices based on the cost of production, commodity price, need for seed bed preparation, and to 

manage excessive crop residue or weeds (see Appendix 9).

Tillage in soybean production systems is used to prepare a seedbed, address soil compaction,

incorporate fertilizers and herbicides, manage water movement both within and out of a

production field, and control weeds (Heatherly et al., 2009). A soybean grower’s choice of 

tillage system may be based on factors such as: crop rotation, soil characteristics, nutrient 

management, herbicide program, planting equipment, and management ability and risk (Randall

et al., 2002b). No-till soybean production is not suitable for all producers or areas. For example, 

no-till soybean production is less successful in heavier, cooler soils more typical of northern

latitudes (Kok et al., 1997; Committee on the Impact of Biotechnology on Farm-Level 

Economics and Sustainability; National Research Council, 2010).

Introduction of improved herbicides and planters in the mid-1980s facilitated better weed control

and good seed placement in no-tillage systems, which some farmers began to adopt at that time 

(Randall et al., 2002a; Owen et al., 2011). Adoption of conservation tillage systems in general 

accelerated in the 1990s after soil conservation policy was incorporated into the Food Security

Act of 1985 (NRC, 2010b). The introduction of GR soybeans in 1996 fit into the ongoing trend 

of increasing adoption of conservation tillage by allowing growers to control weeds without the 

need for tillage (Carpenter and Gianessi, 1999; NRC, 2010b).

Between 1996 and 2008, adoption of conservation tillage practices by soybean farmers increased

from 51-63%, and the adoption of no-till increased from 30-41% by2013 (CTIC, 2011). In an

early study of the relationship between the adoption of HR soybeans and the adoption of 

conservation tillage practices using data from 1997, researchers found that soybean farmers 

using no-till practices had a higher probability of adoption of HR soybeans. However, adoption 

of HR soybeans did not appear to affect no-till adoption rates (Fernandez-Cornejo and McBride, 

2002). A later study using data from 2002 found that farmers who adopted no-till practices were

more likely to adopt HR soybeans, and that adopters of HR soybeans were more likely to adopt 

no-till systems (Mensah, 2007). In a review of the studies of long-term relationship between the 

adoption of conservation tillage, and adoption of HR soybean withherbicide use both events are 

correlated, but “in most cases examined, it appears that adopting HT crops facilitates the use of 

conservation tillage systems and vice versa (Fernandez-Cornejo and McBride, 2002; FernandezCornejo et al., 2013).”

3.5.2 Crop Rotation 

Crop rotation is the successive planting of different crops in the same field over a specific 

number of years. Goals of crop rotation include maximizing economic returns and sustaining the 

productivity of the agricultural system (Hoeft et al., 2000). Sustaining the agricultural system is 

achieved by rotating crops that may improve soil health and fertility with more commercially

beneficial “cash crops.” Because soybeans fix nitrogen in soil, the yield of some crops following

a soybean crop, such as corn or wheat, may increase (Berglund and Helms, 2003). Moreover, the 

rotation of crops can effectively reduce disease, pest incidence, weediness, and selection pressure 

for weed resistance to herbicides (USDA-ERS, 1997; Berglund and Helms, 2003). Crop rotation 

may also include fallow periods, or sowing with cover crops to prevent soil erosion and to

provide livestock forage between cash crops (Hoeft et al., 2000; USDA-NRCS, 2010a). 

73
Maximizing economic returns is realized by rotating crops in a sequence that efficiently produces

the most net returns for a producer over a single- or multi-year period.

Many factors at the individual farm level affect the crop rotation system chosen, including the

soil type present in an individual field, the expected commodity price, the need to hire labor, the 

price of fuel, the availability of funding to buy seed, and the price of agricultural inputs

(Langemeier, 1997; Hoeft et al., 2000; Duffy, 2011). Figure 9 shows the cropping patterns of 

soybeans and cotton in the U.S. The benefits of rotation to soybean (Al-Kaisi et al., 2003)

include:

• Improved yield and profitability of one or both crops;

• Decreased need for additional nitrogen on the crop following soybean;

• Increased residue cover resulting in reduced soil erosion;

• Mitigation or disruption of disease, insect, and weed cycles;

• Increased soil organic matter;

• Improved soil tilth and soil physical properties;

• Reduced runoff of nutrients, herbicides, and insecticides.

Crop rotation is not commonly used for cotton in the Cotton Belt, where over 60% of the planted 

acres are commonly described as a cotton monoculture (Hake et al., 1991; USDA-ERS, 2011a). 

The remaining acreage generally is planted to a rotation with small grains / sorghum or other 

crops (El-Zik et al., 1989; USDA-ERS, 2011a). For example, cotton-tomato rotations are 

successfully used in California when irrigation is available to set the transplants after planting

(Mitchell et al., 2012). Preceding or following cotton with crops such as wheat or triticale may 

work well in conservation tillage systems, if seeding operations ensure adequate stands. 

Rotational sequences with sorghum, soybean, or alfalfa are reported to reduce the incidence of 

some soil-borne diseases (El-Zik et al., 1989). Silage corn, which leaves relatively few soil 

residues, may be suitable for crop rotation with cotton (Mitchell et al., 2012).

Since 2000, an increasing percentage of land cropped to cotton was left fallow (USDA-ERS, 

2011a). A dry fallow rotation can control perennial weeds such as field bindweed, bermudagrass, 

Johnsongrass, and nutsedges while providing increased water for irrigation on other fields (Hake

et al., 1991). Regardless of which crop is grown, sustained conservation tillage production 

systems require detailed planning to avoid causing soil compaction (Mitchell et al., 2012).

74
Figure 9. Cropping Patterns for Soybeans and Cotton in the United States. Source: (USDA-ERS, 2011a)

Where it could be grown, cotton became a dominant crop because continuous monoculture of 

cotton provided more income per acre than soybeans, corn, rice, and wheat (Hake et al., 1991). 

Cover crop rotations typically consist of planting a winter cereal or legume in the fall followed 

by cotton next spring. These rotations create an economic control strategy for soilborne diseases, 

interacting nematodes, and resistant weeds. Typically, cover crop rotations provide erosion 

control, improved soil tilth, and suppress diseases. Diversification increases economic stability 

when profitable crops are rotated with cotton, but rotation out of monoculture may not be needed 

if pests can be otherwise managed (Hake et al., 1991). Growers must carefully adhere to label 

use requirements because some herbicides used in cotton production may leave soil residues that 

can injure subsequent rotation crops, and many cotton varieties are sensitive to pesticides used in 

other crops (Rude, 1984).

75
After over 100 years of continuous planting on Pacolet fine sandy loam soil, the oldest 

continuous cotton experiment in Alabama demonstrated cotton lint yield nearly three times 

higher when cotton is rotated with legumes as opposed to un-rotated plots (AUDAS, 2004). 

Yet cotton lint yield response to crop rotation is relatively small in comparison to other crops. 

Rotation with wheat-soybean shows the largest benefit from crop rotation (Hake et al., 1991). 

But most of this benefit is attributed to decreasing disease and nematode populations in the soil, 

as opposed to supplying nutritional needs. Cotton's relatively low nutritional needs are attributed 

to its deep root system, associations with soil microorganisms, and warm season growth habit. 

Consequently, when cotton is grown in rotations it is the needs of the other crops that determine 

the amounts of phosphorus, potassium and micronutrients that must be added (Hake et al., 1991).

Effective nematode and disease suppression through crop rotation is a long-term management 

strategy that depends on the host range of the pathogen, the type of rotational crop used, and the 

length of the rotation. The goal of the rotation is to reduce pathogen populations below their 

threshold level by not planting crops that are susceptible to the disease present in the field 

(Kirkpatrick and Thomas; Hake et al., 1991). For example, rotation to a monocot crop can 

suppress seedling diseases in subsequently planted cotton, but rotation to a legume cover crop is 

not likely to reduce cotton seedling disease (Hake et al., 1991). Intercropping alfalfa as a trap 

crop for lygus bugs was attempted, instead of a rotation, but found impractical (El-Zik et al., 

1989). An effective rotational management strategy must be economically feasible, practical, and 

compatible with herbicide programs (Kirkpatrick and Thomas).

Crop rotation is a common practice on U.S. soybean fields. Soybeans are often rotated with such

crops as corn, winter wheat, spring cereals, and dry beans (OECD, 2000), the selection of which

varies regionally. Corn is the most commonly rotated crop with soybeans. USDA Agricultural

Resource Management Survey (ARMS) results for corn and soybean indicate a small increase in

corn in rotation and continuous corn over the past decade (Ebel, 2012).

Soybean itself may be a cover crop in short rotations for its ability to contribute nitrogen to 

subsequent crops (Hoorman et al., 2009). Continuous soybean production is sometimes

practiced, but yield can be reduced the second or later years, and pest and disease incidence may

increase (Pedersen et al., 2001; Monsanto, 2010).

In a survey of major corn/soybean production states, corn and soybean were alternated on 72 to

80% of acreage, other rotations were grown on 16-20% of acreage, and soybean was grown 

continuously on 5-12% of acreage between 1996–2002 (USDA-ERS, 2006). In 2006, the last

year for which USDA survey data are available, 72% of soybean acreage was planted on acreage 

planted to corn in the previous year, soybean (13%), cotton (0.5%), small grains (8.1%), other 

crops (5.9%) and fallow (0.4%) (USDA-ERS, 2013b).

Double-cropping soybeans is also an option to increase returns. Soybean is frequently planted in

winter wheat stubble to produce a crop in the same growing season. Double-cropping maximizes 

profits if high commodity prices can support it, but careful management to achieve uniform 

stands to sustain high yields is needed: the selection of appropriate varieties, a higher seeding 

rate, closer row spacing, and adequate moisture for germination are important variables

affecting profitability (McMahon, 2011).

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3.5.3 Agronomic Inputs

Crop production typically involves the extensive use of agronomic inputs to maximize yield 

(Ritchie et al., 2008). In general, agronomic inputs include fertilizers to supplement available 

nutrients in the soil; pesticides to reduce weed, insect, microbial, and nematode populations, and 

water to ensure normal plant growth and development (Rude, 1984; El-Zik et al., 1989; Ellington

et al., 2007).

Fertilizers

Commercially available fertilizers usually contain a mixture of the macronutrients nitrogen, 

phosphorus, and potassium which are essential for plant growth (Vitosh, 1996). To fill specific 

crop needs in soils that are deficient, various concentrations of micronutrients may be included in 

fertilizer formulations (Jones and Jacobsen, 2003). Fertility needs also can be met by applying 

organic matter which may alter the soil’s naturally occurring level of nutrients that are available 

for plant growth (Jones and Jacobsen, 2003). Nevertheless, about half of the nitrogen applied in a 

chemical form is not taken up by plants but is lost to the atmosphere and to above- and belowground water supplies (Ellington et al., 2007). Nevertheless, about half of the nitrogen applied in 

a chemical form is not taken up by plants but is lost to the atmosphere and to above- and belowground water supplies (Ellington et al., 2007).

The nutritional needs for cotton are generally recognized as lower than other major crops. 

Nevertheless, the nutrients needed in the largest amounts are nitrogen, phosphorus, potassium, 

calcium, magnesium, and sulfur (Rude, 1984). Other essential nutrients needed in very small 

amounts are iron, boron, manganese, zinc, molybdenum, copper, and chlorine (Rude, 1984). 

Increased cotton growth and yield under higher nitrogen regimes can be offset in value by 

increased populations of pest insects leading to reduced lint quality (El-Zik et al., 1989; 

Ellington et al., 2007). Efficient fertilizer use in cotton requires there to be no excessive nitrogen 

at the end of the season because nitrogen applied too late triggers the need for extra applications 

of defoliants (Rude, 1984; El-Zik et al., 1989). Cotton plants produce more flowers than can be 

grown to maturity, so they typically shed excess squares and bolls when under carbohydrate 

stress (Rude, 1984).

Efficient fertilizer use in cotton requires there to be no excessive nitrogen at the end of the 

season because nitrogen applied too late triggers the need for extra applications of defoliants 

(Rude, 1984; El-Zik et al., 1989). Cotton plants produce more flowers than can be grown to 

maturity, so they typically shed excess squares and bolls when under carbohydrate stress (Rude, 

1984).

Nitrogen is not frequently added to soybean fields because the plants have a microbial 

relationship that fixes atmospheric nitrogen into a form the plant can use for growth (Alberton et 

al., 2006). A 2006 survey reported by USDA National Agricultural Statistics Service (NASS) 

(USDA-NASS, 2009d) found that among 19 select states, nitrogen was applied to 18% of the 

planted soybean acreage in those states at an average rate of 16 pounds (lb)/acre per year, and 

phosphate was applied to 23% of the planted acres at an annual average rate of 46 lb/acre. Potash 

was applied to 25% of the planted acreage at an average annual rate of 80 lb/acre, and sulfur was 

applied to 3% of the planted acres at an average annual rate of 11 lb/acre (USDA-NASS, 2009d). 

77
Other micronutrient supplements such as zinc, iron, and magnesium were applied as needed to 

soybean production (Whitney, 1997; USDA-NASS, 2007a; NSRL, No Date).

Insecticides

Pesticides that kill, inhibit, or control insect populations are called insecticides. A wide variety of 

insecticides are registered for use in cotton, but growers typically scout for pests and apply 

insecticides only when economic thresholds are met (Rude, 1984; Benedict et al., 1989; Higgins, 

1997). Some of the currently registered insecticides for use in cotton are listed in Table 11, 

however, this listing is provided for comparison purposes and should not be construed as a 

recommendation.

Table 11. Commonly Used Insecticides for Cotton Pests.

Cotton Pest Insecticidal Products1

Aphids acetamiprid, clothianidin, flonicamid, imidacloprid, and 

thiamethoxam 

Beet and Fall Armyworms chlorantraniliprole, emamectin benzoate (R), flubendiamide, 

indoxacarb, methomyl (R), methoxyfenozide, novaluron, spinosad, 

and thiodicarb

Bollworm bifenthrin (R), chlorantraniliprole, cyfluthrin (R), beta- cyfluthrin 

(R), gamma-cyhalothrin, lambda-cyhalothrin (R), cypermethrin (R), 

zeta-cypermethrin, zeta-cypermethrin/bifenthrin, emamectin 

benzoate (R), esfenvalerate (R), flubendiamide, indoxacarb, 

methomyl (R), novaluron, profenofos, spinosad, and thiodicarb

Tobacco Budworm (in 

Varieties Containing Bt 

Genes)2

chlorantraniliprole, emamectin benzoate (R), flubendiamide, 

indoxacarb, methomyl (R), novaluron, profenofos, spinosad, and 

thiodicarb

Cutworms acephate, bifenthrin, chlorpyrifos, cyfluthrin, lambda-cyhalothrin, 

gamma-cyhalothrin, cypermethrin, zeta-cypermethrin, zetacypermethrin / bifenthrin, and esfenvalerate 

Cotton Fleahopper and 

Tarnished Plant Bug

acephate, clothianidin, dicrotophos (R), flonicamid, imidacloprid, 

novaluron, oxamyl (R), and thiamethoxam

Soybean Looper and 

Cabbage Looper

emamectin benzoate (R), flubendiamide, indoxacarb, 

methoxyfenozide, novaluron, spinosad, and thiodicarb

Spider Mites abamectin, bifenthrin (R), chlorpyrifos, dicofol, etoxazole, 

fepyroximate, propargite, and spiromesifen

Stink Bugs non-pyrethroids: acephate, dicrotophos, methyl parathion, 

novaluron, and oxamyl. 

pyrethroids: bifenthrin (R), cyfluthrin (R), beta-cyfluthrin (R), 

lambda-cyhalothrin (R), gamma-cyhalothrin (R), cypermethrin (R), 

zeta-cypermethrin (R), zeta-cypermethrin/bifenthrin (R), and 

esfenvalerate (R)

Thrips (at Planting) aldicarb (R), imidacloprid, and thiamethoxam

Thrips (Foliar Sprays) acephate, dicrotophos (R), and dimethoate

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Cotton Pest Insecticidal Products1

Whiteflies acephate, acetamiprid, imidacloprid, pyriproxyfen, and 

thiamethoxam 1 (R) = use. Pre-mixed or co-packaged products also may be available when there are multiple pests requiring 

simultaneous treatment.

2 Bt - Insect resistant crops (Bt crops) contain a gene from a soil bacterium, Bacillus thuringiensis (Bt), which 

produces a protein that is toxic to specific lepidopteran insects.

Source: (Greene, 2012).

Insect injury in soybean seldom reaches levels that cause important economic loss, as indicated 

by the low percentage (18 percent) of soybean acreage that receive insecticide treatments

(USDA-NASS, 2012b). Of the 27 reported insecticides applied to soybean acreage in 2012, the 

four most commonly applied were lambda-cyhalothrin, dimethoate, chlorpyrifos, and lambdacyhalothrin (USDA-NASS, 2009d). Insect infestation levels indicate when insecticide 

applications are actually necessary (Higgins, 1997). When insect infestations found in field 

sampling surveys and/or during standard defoliation exceed specific levels, the thresholds are 

met. The National Information System of the Regional Integrated Pest Management Centers in 

pest management strategic plans provide a number of insect thresholds (USDA-AMS, 2011a). 

Other methods of addressing insect infestations include the introduction of beneficial pests that 

prey on targeted insects obtained from commercial suppliers, as well as crop rotation and tillage.

A wide variety of pests hinder crop production, and many require applications of agricultural 

pesticides to keep pest populations below economic thresholds. The development of pest 

populations with resistance to various classes of insecticides requires growers to wisely 

coordinate the compounds used at various times during the production of a crop. For example, 

insecticide seed treatments that increase planting efficiency in cotton may use neonicotinoids and 

over-the-top foliar sprays used later in the season may include non-selective organophosphates. 

Many cotton aphid populations are resistant to these chemistries, so while other pests are 

controlled, the cotton aphid populations increase (Leonard, 2007). Several groups and types of 

insects feed on foliage, seed pods, and/or roots of the soybean plant leading to reductions in yield 

if these pests are not adequately controlled (Lorenz et al., 2006; Whitworth et al., 2011).

Herbicides

The following section provides a brief background of herbicide use in cotton and soybeans in the 

U.S. It is provided to give the context for the analyses related to HR weed selection. Further 

information is presented in Appendices 3-8.

Pesticides that are used to control undersirable vegetation are termed herbicides. In selecting an 

herbicide, a grower must consider, among other factors, whether it can be used on the crop 

(herbicides are registered by the EPA for specific uses/crops), the potential adverse effects on the 

crop, residual effects that can limit crops that can be grown in rotation, effectiveness on expected 

weeds, and cost. Herbicides have different ways of acting on plant physiology (i.e., modes of 

action) to affect the health of a given plant (see Appendix 3). Some common modes of herbicide 

action include: auxin growth regulators like 2,4-D; amino acid inhibitors such as glyphosate; 

photosynthesis inhibitors such as atrazine; lipid biosynthesis inhibitors like quizalofop; 

glutamine synthase inhibitors such as glufosinate (UW-NPMP, No Date) (see Appendix 3). 

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Herbicides have been the primary tactic used to manage weed communities in soybeans since the 

mid-1960s and are likely to continue to be an important feature of row crop weed management 

for the foreseeable future. As aptly noted by Crespo (Crespo, 2011), “Herbicides have become 

the primary means of weed control in all of the major row crops in the U.S. Herbicides have 

allowed farmers to reduce the amount and intensity of tillage operations once used to control 

weeds.” One study, which examined aggregated data on crop yield losses and herbicide use, 

estimated that even if additional tillage and hand weeding labor replaced the use of herbicides, 

U.S. crop production would decline by 20% with a $16 billion loss in value if herbicides were 

not used (Gianessi and Reigner, 2007).

GR crops have become adopted widely since their introduction in the 1990s for several reasons. 

Glyphosate works non-selectively on a wide range of plant species, is a relatively low-cost 

herbicide, enhances ‘no-till’ farming practices, and has minimal animal toxicological and 

environmental impacts (USDA-APHIS, 2010). However, increased selection pressure resulting 

from the wide-spread adoption of GR crops, with the reductions in the use of other herbicides 

and weed management practices, has resulted in both weed population shifts and growing 

numbers of GR individuals among some weed populations (Owen, 2008; Duke and Powles, 

2009).

Herbicide use varies with each crop based on both the types of herbicides used and the variety of 

herbicide sites of action8 (see Appendix 3). Cotton establishment takes longer to close the 

canopy than soybeans, so cotton becomes more susceptible to competition by early season weeds

(Frans and Chandler, 1989). Cotton may be planted in wider rows than soybeans, and the 

resulting light penetration into an unclosed canopy allows weed germination and growth over a 

longer period of time than in soybeans (Frans and Chandler, 1989). For these reasons, postemergent applications of herbicides are more common in cotton crops than in soybeans, but there 

may be fewer herbicide options. 

To obtain the best cotton yields, growers manage weeds with a diversification of weed control 

strategies ranging from mechanical choppers and cross-cultivation to hand-labor and modern 

herbicides (Frans and Chandler, 1989). The rotation of combinations of herbicide treatments can 

reduce the undesirable ecological shifts to new weed species or herbicide- resistant weed species 

(Frans and Chandler, 1989). Herbicide residues from organic arsenicals have been a concern in 

cotton seed, particularly if applications occurred during early reproductive growth stages (Frans 

and Chandler, 1989). Cotton is particularly sensitive to drift from phenoxy herbicides used on 

nearby crops (Frans and Chandler, 1989). 

Until recently, soybean growers relied almost exclusively on glyphosate for weed control. Prior to 

the adoption of GR soybean, growers relied heavily on herbicides with a mode of action called 

“acetolactate synthase (ALS) inhibitors” or “acetohydroxyacid synthase (AHAS) inhibitors”.

With the adoption of GR soybean, glyphosate was used on greater than 95% of soybean acreage 

and for 75% of soybean growers, glyphosate represented the only herbicide mode of action used. 

As GR weeds have become more prevalent, the trend among soybean growers is to use more 

8 The site off action is the location within the plant where the herbicide impacts the development process.

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modes of action including 2,4-D, chloroacetamides, protoporphyrinogen oxidase (PPO), and ALS

inhibitors.

Growers choose pesticides based on weed, insect and disease pressures, cost of seed and other 

inputs, technology fees, human safety, potential for crop injury, and ease and flexibility of the 

production system (Heiniger, 2000; Farnham, 2001). The continued emergence of GR weeds will 

likely require modifications of crop management practices to address these weeds. Herbicide use 

may increase to meet the need for additional integrated weed management tactics to mitigate HR

weeds in different cropping systems (Owen and Zelaya, 2005; Culpepper, 2008; Heap, 2014d).

In selecting an herbicide, a grower must consider, among other factors, whether an herbicide can 

be used on the crop (herbicides are registered by the EPA for specific uses/crops), the potential 

adverse effects on the crop, residual effects that can limit crops that can be grown in rotation, 

effectiveness on expected weeds, and cost. Herbicides have different ways of acting on plant 

physiology (i.e., modes of action) to affect the health of a given plant (see Appendix 3). Some 

common modes of herbicide action include auxin growth regulators like 2,4-D; amino acid

inhibitors such as glyphosate; photosynthesis inhibitors such as atrazine; lipid biosynthesis 

inhibitors like quizalofop; and glutamine synthase inhibitors such as glufosinate (UW-NPMP,No 

Date) (see Appendix 3). Applications of herbicides to a crop may occur pre-plant (i.e., 

burndown), pre-emergence, or post-emergence (Schneider and Strittmatter, 2003).

Weeds are estimated to cause a potential yield loss of 37% in world-wide soybean production 

(Heatherly et al., 2009). Weeds compete with soybean for light, nutrients, and soil moisture. 

They can also harbor insects, plant diseases, and interfere with harvest, causing extra wear on 

harvest equipment (Loux et al., 2008). In addition to weed density, the time that weeds compete 

with the soybean crop influences yield. The later weeds emerge, the less impact they will have 

on yield. Soybean plants withstand early season weed competition longer than most other crops

because the soybean canopy closes earlier (Boerboom, 2000). The extent of canopy closure 

restricts the light available for weeds and other plants growing below the soybean. In addition, 

canopy closure occurs more quickly when soybean is drilled or planted in narrow rows 

(Boerboom, 1999); however, in some studies it has also been observed that, depending on factors 

such as weed species, environmental conditions (i.e., rainfall amounts) and soybean cultivar, 

soybeans are able to compete with weeds with no resulting yield reduction (Krausz et al., 2001).

Herbicides have been the primary tactic used to manage weed communities in soybeans since the 

mid-1960s and are likely to continue to be an important feature of row crop weed management 

for the foreseeable future. One study, which examined aggregated data on crop yield losses and 

herbicide use, estimated that even if additional tillage and hand weeding labor replaced the use of 

herbicides, U.S. crop production would decline by 20% with a $16 billion loss in value if 

herbicides were not used (Gianessi and Reigner, 2007).

HR crops have become adopted widely since their introduction in the mid-late 1990s for several 

reasons. Increased selection pressure caused by wide-spread adoption of HR crops and reduction 

in the use of other herbicides and weed management practices, resulted in both weed population 

shifts and growing numbers of HR individuals among some weed populations (Owen, 2008; 

Duke and Powles, 2009). Figure 10 depicts states reported to have dicamba-, 2,4-D-, and 

glufosinate-resistant weeds.

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Figure 10. States of the United States Reported to Have Populations of Dicamba-, 2,4-D-, 

and Glufosinate-Resistant Weeds.

Source: (Heap, 2014d)

As HR weeds increase in prevalence, costs of weed control may also increase if additional 

compounds, applications, or equipment must be used. Growers may be able to control HR weeds 

without increasing costs if less expensive chemicals or multi-chemical formulations are 

available.

Extension weed scientists estimated the increased cost of the additional herbicides needed to 

control glyphosate-resistant weeds in soybean to be as much as $42/acre (for Palmer amaranth in 

Tennessee), with most estimates of the increased costs falling in the range of up to $20 to 

$30/acre (Carpenter et al., 2002). These costs will vary depending on the specific weed species 

present in any particular field. However, as resistance to glyphosate and other herbicides has 

developed and spread in weed populations, these costs may have increased since these estimates 

were made. For example, there are waterhemp populations in Iowa corn and soybean production 

fields with resistance to five herbicide sites of action (Owen, 2012).

Growers choose certain pesticides based on weed, insect and disease pressures, cost of seed and 

other inputs, technology fees, human safety, potential for crop injury, and ease and flexibility of 

the production system (Heiniger, 2000; Farnham, 2001; University of California, 2008a). 

Growers have traditionally used multiple herbicides for weed control. For pre-plant application 

82
herbicides that have residual activity are typically used (see Appendix 3). For more details about 

herbicides used for cotton and soybean production see Appendix.

Water Use in Cotton and Soybean Production

Soil is the storage site for water available to plants, and the primary factors in determining waterholding capacity of soil is its texture and depth of the root zone (TAMU, 2014). Roots grow in 

moist soil, not in saturated or dry soil (Brown et al., 2002). Several factors can affect soil 

moisture variability, including soil type and intrinsic heterogeneity, plant growth variation, 

rainfall interception, reduced application efficiency and uniformity in irrigation (Muñoz-Carpena

et al., 2006). 

Cotton varieties are now bred to be a relatively drought tolerant plants (see Figure 11), so the 

majority of U.S. cotton uses supplemental irrigation to optimize production (TAMU, 2014). 

From 1980 to 2011, the proportion of irrigated cotton acreage remained relatively constant at 

approximately 32% (Field-to-Market, 2012), even though the total irrigated acreage increased 

because of the increase in total land used for cotton production during that interval. Between 

1980 and 2011, total irrigation water applied for U.S. cotton decreased 35% (1.4% compound 

annually); total water use was 95.5 million acre inches in 1980 and 62.9 million acre inches in 

2011 (Field-to-Market, 2012). On average worldwide, at least 500 mm of rainfall (about 20 

inches) is required during the growing season for dryland (non-irrigated) cotton crops (OECD, 

2008a).

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Figure 11. Cotton Water Use and Average Water Use Efficiency 

Compared to Other Crops, 2003/2004. The “water use efficiency” is calculated from the marketable crop yield divided by crop water 

use. Source: (Cantrell, 2006)

The water supply for cotton germination and seedling development can be met either by preplant 

irrigation or by “irrigating up” after planting (Rude, 1984; El-Zik et al., 1989). The amount of 

water depends on rainfall and the nature of the soil profile (Rude, 1984). The need for water 

increases dramatically from less than 1 inch per week at emergence to 2 inches per week at first 

bloom. The critical period to avoid water stress is during flowering and boll development when 

peak water use occurs. Drought during this interval causes the plant to shed small squares first. 

Continued water stress leads to larger squares and then bolls being shed (Rude, 1984; TAMU, 

2014). The need to avoid water stress during the flowering period must be balanced against the 

likelihood of boll rot epidemics (Rude, 1984). Proper timing for the final irrigation provides

adequate moisture for the last harvestable bolls to mature even though the plant’s water needs 

dropped considerably by harvest (TAMU, 2014). Irrigating too late can delay the opening of 

mature bolls, may increase lodging, and complicated defoliation by promoting late season 

growth and regrowth (Rude, 1984). An over-supply of water and/or nitrogen is associated with 

lanky or “rank” growth with excessive foliage and stems and reduced yield (Rude, 1984). Cotton 

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will continue to grow and fruit until weather conditions are no longer favorable for growth

(Cantrell, 2006).

Established cotton plants metabolically adapt to cope with periods of water loss, but water stress 

can cause the shedding of leaves, flowers, and bolls; upset osmosis regulators; and reduce 

photosynthesis in cotton plants (El-Zik et al., 1989). As water stress increases, cotton plants put 

more biomass into reproductive growth, and this sequence can be manipulated by growers to 

increase yield (El-Zik et al., 1989; Gibbs et al., 2005). In certain cotton varieties, stem color is an 

indicator of water stress. Crops treated by a growth regulator may exhibit different stem 

coloring; plant wilting or flowering at their tops also can be used to identify water stress (Rude, 

1996; McGuire, 2006).

Ongoing drought in the U.S. limits water allotment for agricultural use (Figure 12). Increasing 

costs of irrigation and labor also are incentives for growers to seek efficient ways to conserve 

and reuse water. Water availability for cotton crops can be improved with conservation tillage 

(TAMU, 2014). Conservation tillage must be carefully managed in cotton production because 

crop residues on cotton fields after harvest can provide a source for pest spread and volunteer 

cotton over a large surrounding area (McGuire, 2006). A prompt, thorough plowdown is 

essential for cotton crops. Plowdown involves the shredding and burial of all crop debris 

immediately after harvest, to a depth of 6 inches (Rude, 1984; 1996).

Figure 12. A Recent Compilation of Drought Affected Areas in the United States. Source: (Rippey, 2004)

The soils and climate in the Eastern, Midwestern, and portions of the Great Plains region of the 

U.S. retain sufficient water supplies under normal climatic conditions to produce a soybean crop. 

In regions of the U.S. that experience low amounts of rainfall during the growing season or 

during drought, soybean yields benefit from proper irrigation. Soybeans require approximately 

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20 to 25 inches of water during the growing season to produce a relatively high yield of 40 to 50 

bushels per acre (Hoeft et al., 2000; University of Arkansas, 2006; Nafziger, 2007). In 2006 and 

2008, approximately 9% of the planted acres of soybeans in the U.S. were irrigated (USDANASS, 2010a; USDA-ERS, 2011e). In 2007, when approximately 6% of the total soybean crop 

was irrigated, over 92% of the irrigation supply was from groundwater supply (USDA-ERS, 

2012d).

A majority (approximately 73%) of irrigated soybean acreage occurs in the Missouri and Lower

Mississippi Water Resource Regions, and soybean acreage in the states of Nebraska, Arkansas, 

Mississippi, Missouri, and Kansas accounts for 85% of all irrigated acres (USDA-NASS, 

2011d). In 2006, approximately 8.4 inches of water per irrigated acre were used, producing an 

average of more than 51 bushels per irrigated acre (USDA-ERS, 2011e). This yield was

approximately 19.8% higher than the national average (42.9 bushels per acre) for that year

(USDA-NASS, 2011a).

Many residual herbicides require adequate rainfall or irrigation water to be activated (Hager et 

al., 2011). In 2012, only 90% control of palmer amaranth was achieved under both furrow and 

sprinkler irrigation systems using residual herbicides, leading to recommendations that residual 

herbicides should be applied every 2 to 3 weeks until canopy formation to minimize the number 

of escapes that must be removed using other weed control measures (Riar et al., 2012).

3.5.4 Organic Cotton and Soybean Production

National Organic Program and Organic Soybean Farming

In the U.S., only products produced using specific methods and certified under the USDA’s 

Agricultural Marketing Service (AMS) National Organic Program (NOP) definition of organic 

farming can be marketed and labelled as “organic” (USDA-AMS, 2010). Organic certification is 

a process-based certification, not a certification of the end product; the certification process 

specifies and audits the methods and procedures by which the product is produced.

In accordance with NOP, an accredited organic certifying agent conducts an annual review of the 

certified operation’s organic system plan and makes on-site inspections of the certified operation 

and its records. Organic growers must maintain records to show that production and handling 

procedures comply with USDA organic standards. 

The NOP regulations preclude the use of excluded methods. The NOP provides the following 

guidance under 7 CFR §205.105—

To be sold or labeled as “100 percent organic,” “organic,” or “made with organic 

(specified ingredients or group(s)),” the product must be produced and handled 

without the use of:

(a) Synthetic substances and ingredients,...

(e) Excluded methods,...

Excluded methods are then defined at 7 CFR §205.2 as—

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A variety of methods used to genetically modify organisms or influence their 

growth and development by means that are not possible under natural conditions 

or processes and are not considered compatible with organic production. Such 

methods include cell fusion, microencapsulation and macroencapsulation, and 

recombinant DNA [deoxyribonucleic acid] technology (including gene deletion, 

gene doubling, introducing a foreign gene, and changing the positions of genes 

when achieved by recombinant DNA technology). Such methods do not include 

the use of traditional breeding, conjugation, fermentation, hybridization, in vitro 

fertilization, or tissue culture.

The NOP has recognized the feasibility of protecting organically-produced crops from accidental 

contamination by GE crops by requiring that organic production plans include practical methods 

to protect organically produced crops—

Organic crops must be protected from contamination by prohibited substances 

used on adjoining lands (for example, drifting pesticides, fertilizer-laden runoff 

water, and pollen drift from genetically engineered crops ...) (National Center for 

Appropriate Technology, 2003).

The NOP requires organic production operations to have a management plan approved by an 

accredited certifying agent, that may include measures such as distinct, defined boundaries and 

buffer zones to prevent unintended contact with excluded methods from adjoining land that is not 

under organic management. Organic production operations also must develop and maintain an 

organic production system plan approved by their accredited certifying agent to prevent genetic 

commingling due to pollen flow, as well as post-harvest commingling. Plans under the approved 

operating system enable the production operator to achieve and document compliance with the 

National Organic Standards, including the prohibition on the use of excluded methods. In NOP 

organic systems, the use of GE crops is excluded (USDA-AMS, 2010).

EPA-registered synthetic pesticides are prohibited in organic production; however, there is the 

potential for inadvertent or indirect contact from neighboring conventional farms or shared 

handling facilities. As long as the operator has not directly applied prohibited pesticides and has 

documented efforts to minimize exposure to them, the USDA organic regulations allow for 

residues of prohibited pesticides at or below 5 percent of the EPA tolerance (USDA-AMS, 

2012).

Although the National Organic Standards preclude the use of excluded methods, they do not 

require testing of inputs or products for the presence of excluded methods. The presence of a 

detectable residue of a product of excluded methods alone does not necessarily constitute a 

violation of the National Organic Standards (USDA-AMS, 2011b). The current NOP regulations 

do not specify an acceptable threshold level for the adventitious presence of GE materials in an 

organic-labeled product. Manufacturers and retailers that sell organic products may use GE 

product tolerance levels set by the private sector in the U.S. The non-profit third party 

verification ‘Non-GMO Project Verified’ is widely used. International governments may set 

lowest level presence standards (LLP) based on PCR testing for GE DNA; buyers may set higher 

or even zero standards. Rejection of U.S. organic products due to commingled GE content has 

87
occurred; soybean has been rejected in Taiwan and Korea containing an identifiable GE 

commodity.

The unintentional presence of the products of excluded methods will not affect the status of an 

organic product or operation when the operation has not used excluded methods and has taken 

reasonable steps to avoid contact with the products of excluded methods as detailed in their 

approved organic system plan (USDA-AMS, 2011b).

U.S. Organic Cotton Production

Cotton grown without synthetic chemicals such as pesticides and fertilizers is referred to as 

“organic” (OTA, 2010; Babu et al., 2013) and is certified under the National Organics Program 

(TOCMC, 2014). Production of organic cotton includes the use of natural defoliants; beneficial 

insects for pest control; compost, manure, and crop rotations for fertilizers; hand-weeding;

mechanical cultivation; cover crops and mulching for weed control. A comparison of 

conventional cotton and organic fibers showed that morphologically and chemically, the two 

types of cotton are similar (Babu et al., 2013). 

Organic cotton has been produced in the U.S. since 1991 (Funtanilla et al., 2009). In 2012, the 

majority of the U.S. organic cotton crop was planted to upland cotton, with pima cotton 

representing fewer than 1,000 planted acres (OTA, 2014). Acreage planted in organic cotton 

increased 36% from 2009 to 2010 (OTA, 2014). According to USDA, in 2011, approximately 

12,000 acres of certified organic cotton were planted; this acreage represents 0.08 percent of 

cotton acreage in the United States (USDA-ERS, 2013a). Organic cotton production is centered 

in West Texas with additional acreage in Arizona, California, New Mexico, and North Carolina

(USDA-AMS, 2013). The Organic Trade Association, projects a two percent increase in organic 

cotton acreage or approximately 16,406 acres for 2012. A total of 16,716 acres of organic cotton, 

representing an additional two percent gain over the next five years, is forecasted to be planted 

(OTA, 2014). Limitations on the growth of the U.S. organic cotton industry are tied to challenges 

also faced by growers of conventional cotton, including weather, geography, weeds, drought, and 

pests. Also, there is reported to be a limited availability of organic seeds and not much work 

dedicated to improving cottonseed by traditional breeding techniques (OTA, 2014).

One of the main organic production regions is the South Plains area of Texas (TOCMC, 2011). 

Organic cotton production in this area benefits from winter temperatures that are cold enough to 

limit insect pressure and to provide a hard freeze to defoliate the cotton plants prior to 

harvesting, as well as a sunny climate and quick-drying soils to facilitate timely mechanical 

weed control. As many of these farmers do not irrigate, yields are heavily dependent upon 

rainfall (TOCMC, 2011). 

American organic cotton typically commands premium prices over conventionally grown cotton; 

organic cotton growers indicated they received $1.40 per pound for organic upland cotton and 

$2.15 for organic pima cotton in 2012 (OTA, 2014). These prices are slightly lower than those 

from previous years due to global competition and weather-related quality issues with the 2012 

crop (OTA, 2014). According to USDA’s Agricultural Marketing Service, prices for organic 

cottonseed ranged from $500 to $650 per ton, while conventional cottonseed is $210 to $320 per 

88
ton. Most of the cottonseed is sold to organic dairies, with some saved for replanting (USDAAMS, 2013).

However, organic cotton production is typically about 50% more expensive than conventional 

cotton production (ATTRA, 2003). Higher production costs are due to factors such as hand 

hoeing and weeding labor (ATTRA, 2003; TOCMC, 2014); gins and mills must be operated 

separately for organic cotton; higher dyestuff costs; small run penalties (TOCMC, 2014); more 

seed used/acre; higher energy costs due to more water typically used in organic cotton fields; 

loss in production for three years while converting conventional fields to organic fields 

(Funtanilla et al., 2009); crop loss due to defoliation; and costs of organically acceptable disease 

and insect management (ATTRA, 2003). In addition to higher production costs, organic cotton 

yields are typically lower than conventional cotton yields (Funtanilla et al., 2009; Chaudhry et 

al., 2012; TOCMC, 2014), as much as 30% lower (Funtanilla et al., 2009). 

Most U.S. organic cotton growers sell their cotton products through a marketing cooperative, the 

largest of which is the Texas Organic Cotton Marketing Cooperative (TOCMC), with 

approximately 30 members (TOCMC, 2011; OTA, 2012). Cottonseed is marketed to organic 

dairies for feed (TOCMC, 2011). According to a survey conducted by OTA, organic cotton 

growers’ biggest barriers to planting more organic cotton are finding a market willing to pay the 

added costs of organic products, production challenges such as weed and insect control, and 

labor costs. Growers have indicated challenges due to competition from international organic 

cotton producers, as well as the cost of transition to organic (OTA, 2010). 

Organic cotton represents about 1.1% of global cotton production, and world production and 

sales have increased steadily, with world sales rising from $4 billion in 2009 to $5.3 billion in 

2010 (Memon, 2012). As of 2012, the United States was the sixth-ranking producer of organic 

cotton in the world, behind India, Syria, Turkey, China, and Tanzania (Memon, 2012).

Upland and Pima cotton are mostly self-pollinated, but insect pollination does occur via insects 

or pollen dispersion in wind (Hutmacher et al., 2006). Organic cotton production systems must 

therefore be isolated from GE cotton by both space and time to ensure cross-pollination will not 

occur. As stated above, these distances would be established with the organic certifying agent. A 

recent multi-year pollen mediated gene flow study in commercial cotton production from GE 

cotton fields found sporadic pollen mediated gene flow beyond 30 meters, between 0.01% and 

0.1% from 200 to 1625 meters in the presence of pollinators (Van Deynze et al., 2005). In the 

absence of pollinators, pollen mediated gene flow was not identified beyond 10 meters (Van 

Deynze et al., 2005). 

U.S. Organic Soybean Production

In 2011, U.S. acreage in organic soybeans totaled 132,411 acres. The states with the most 

acreage, in descending order, were Minnesota, Iowa, Michigan, Arkansas, Missouri, New York, 

Wisconsin, Nebraska and Ohio (USDA-ERS, 2011b). U.S. acreage has increased steadily since 

1995, when 47,200 acres were dedicated to organic soybean (USDA-ERS, 2011b).

Typically, two types of organic soybeans are grown in the U.S.: food-grade, used for products 

such as tofu, miso, and soymilk, and feed-grade, for livestock (University-of-Minnesota89
Extension; Delate, 2003). Many organic food-grade soybean products are for export to Japan and 

other countries (Delate, 2003).

Because of major price premiums paid for organic soybean (Place et al., 2009), it can be 

profitable for growers to produce organic rather than conventional soybeans (ATTRA, 2003). 

For example, in 2006, a bushel of organic soybeans sold for about $9 more than a bushel of 

conventional soybeans (McBride and Green, 2008), and in 2013, the projected price for organic 

soybean was $19.73/bushel compared with $9.73/bushel for conventional soybeans (Clark and 

Alexander, 2010). For the week of March 7-15, 2014, the price range of organic soybean was 

$26.50-29.71/bushel; for organic feed-grade soybeans it was $24.00-26.50/bushel (USDA, 

2014). However, without price premiums, organic soybeans had net market returns about the 

same as for conventional soybeans (McBride and Green, 2008). With a high dependence on 

fertilizers and pesticides, conventional soybean growers spend more money on chemicals than do 

organic soybean growers, but organic growers dedicate more operating funds to fuel and labor 

than do conventional soybean growers (McBride and Green, 2008). Operating costs for organic 

soybean production are about $0.82/bushel higher than for conventional soybean production 

(McBride and Green, 2008). In addition, crop yields for organic soybeans are generally lower 

than for conventional soybeans (University of Kentucky; McBride and Green, 2008; Place et al., 

2009; Baldock et al., 2012), as much as 15% lower (Clark and Alexander, 2010). Organic 

soybeans are more likely to be grown on smaller, family-owned farms (McBride and Green, 

2008).

To grow organic soybeans, growers need to be certified by the USDA National Organic Program 

(NOP) (Delate, 2003), and must use only organic seed (University of Minnesota). Organic 

soybeans need to be segregated from conventional soybeans during all aspects of planting, 

harvesting, and storage (Delate, 2003). Highest premiums are obtained by planting Clear-Hilum 

food-grade seed (Delate, 2003). Growers of organic soybean may utilize various risk 

management strategies to compensate for the lack of chemical control. For example, most 

organic growers tend to plant 1-2 weeks after conventional growers to reduce weed populations; 

however, this may then lead to lower yields (University of Minnesota). In order to provide better 

competition with weeds which can substantially depress yields (Place et al., 2009), organic 

growers frequently use higher seeding rates than conventional growers: from 175,000 to 200,000 

seeds/acre for organic fields compared with 100,000 seeds/acre for conventional fields 

(University of Minnesota; Delate, 2003; Place et al., 2009). More soybean seedlings/acre may 

help with shading out weeds (Place et al., 2009). Increasing row space to accommodate 

cultivators and other machinery to control weeds is also used frequently by organic soybean 

growers, but may also reduce yield (Baldock et al., 2012). 

Organic soybean producers use production practices designed to prevent commingling of their 

value-added crop with neighboring crops treated with herbicides and other pesticides or that may 

be using plant varieties produced by excluded methods. Additionally, well-established practices 

help avoid spray drift from neighboring fields, including isolation zones, use of buffer rows 

surrounding the organic crop, adjusted planting dates, and varietal selection (Kuepper, 2006).

The efficacy of management practices utilized to avoid pollen movement from a GE crop to 

organic soybean production operations is facilitated by the nature of soybean pollination.

Soybean is a highly self-pollinated species and exhibits a very low level of outcrossing. 

90
Outcrossing most commonly results from cross-pollination. Since soybean is highly selfpollinating, organic or conventional soybean producers can and have effectively implemented 

practices (e.g., isolation during the growing season, equipment cleaning during harvest, and postharvest separation of harvested seed) that allow them to reasonably avoid GE soybean and 

maintain organic or conventional production status (Brookes and Barfoot, 2004).

3.5.5 GE Cotton and Soybean

Growers can choose from a large number of cotton and soybean hybrids generated either from 

traditional breeding or GE systems. Large-scale field testing of GE crops began in the 1980s, 

but it was not until ten years later the first generation of GE soybean varieties became

commercially available.

Plantings of GE HR cotton expanded from about 10% of U.S. acreage in 1997 to 96% in 2014 

(USDA-ERS, 2014a). Plantings of insect-resistant (HR plus insect resistant) cotton also 

expanded rapidly, from 15% of U.S. cotton acreage in 1997 to 84% in 2014 (USDA-ERS, 

2014a). Seed choices of both Roundup Ready (glyphosate resistant) and Liberty Link 

(glufosinate resistant) varieties are available from four major seed providers, as well as several 

smaller ones (USDA-AMS, 2014).

Since GE soybeans’ initial commercial availability in 1996, plantings of GE HR soybean 

increased from 54 percent of U.S. soybean acreage in 2000 to 94 percent in 2014 (USDA-ERS, 

2014a). Although other varieties are available for selection by growers, the Roundup Ready® GR

varieties continue to dominate the market (see, e.g., (Tarter, 2011)). Another cultivated HR

soybean variety is the LibertyLink® soybean (a GE soybean that is resistant to glufosinate

ammonium herbicide and was granted nonregulated status in 1996) and STS (a conventionally

bred sulfonylurea- resistant soybean first introduced in 1993). As of 2012, 3.9% of U.S. soybean 

acres planted were glufosinate-resistant (DAS, 2013a). Additional GE traits, such as lepidopteran 

resistance, high oleic acid content, improved fatty acid profile, and increased stearidonic acid 

have nonregulated status (USDA-APHIS, 2014c). Of these, at this time, only high oleic acid 

content soybean has been commercialized, in a limited launch. Other GE traits with nonregulated 

status may be made available for commercial production in the future.

GR soybeans were first commercialized in 1996, and adoption by growers was rapid, reaching

54% already by 2000 and more than 90% by 2007 (USDA-NASS, 2013c). While some potential

herbicide cost savings may have driven adoption, early studies recognized the primary reason 

that growers adopted the technology as the simplicity and flexibility of a weed control program

that relied heavily on a single herbicide to control a broad spectrum of weeds without crop injury

or crop rotation restrictions. The increased cost of GE HR seed was outweighed by the often 

lower cost of glyphosate-based weed control programs, although this cost advantage was quickly

eroded by reductions in the prices of other conventional herbicides. The glyphosate-resistant

soybean weed control program reinforced on-going trends towards post-emergence weed control

and the adoption of conservation tillage programs (Carpenter and Gianessi, 1999). For 1997, 

USDA estimated that herbicide-resistant soybeans led to a 3% increase in yields and a reduction 

in weed control costs (including, application, scouting, cultivation, herbicides, and technology

fees) of $3.50/acre (10.65%) in the Heartland (Price et al., 2003).

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The simplicity and flexibility of the glyphosate-resistant soybean program has resulted in

reduced management time. The time savings related to adoption of HR soybeans was estimated 

to be 14.5% in 2002 (Gardner et al., 2009). Off-farm income has been found to be an important

source of household income for many soybean producers, with approximately two-thirds of 

soybean-growing farm families receiving income from off-farm work (Foreman and Livezey, 

2002). The adoption of GE soybean varieties has been associated with increases in off-farm 

income due to reduced on-farm managerial time requirements. In an analysis of soybean 

producing households between 1996 and 2004, a 16% increase in off-farm income was 

associated with a 10% increase in the probability of adopting HR soybean (Fernandez-Cornejo, 

2007).

The reduction in management time is one of the non-pecuniary benefits that influence farmer

adoption decisions, but are not direct contributors to increased profits. In a study of GR soybean 

in the U.S. in 2002, nonmarket valuation techniques were used to estimate farmer valuation of 

three non-pecuniary characteristics: increased farmer and worker safety, environmental safety,

and convenience. Convenience was most highly valued, followed by environmental safety, and 

operator and worker safety (Marra and Piggott, 2006). These results are reinforced by an analysis 

of nationwide survey results from 2007, which found that growers rated characteristics such as 

consistency of control, crop safety, and family and employee health as very important more often 

than herbicide cost. In addition, health and environmental concerns, yield concerns, and 

herbicide-application concerns were found to influence grower decisions (Hurley et al., 2009).

Synthetic herbicides have provided growers with practical and economical weed control 

strategies for nearly 70 years. The later development of glyphosate resistant crops has been 

highly successfuland provides substantial benefits to growers. Increasing populations of GR 

weeds have however threatened the utility and sustainability of these benefits. HR weeds can 

reduce crop yields and increase costs of weed control. However, if growers use best management 

practices incorporating a diversity of weed control practices, herbicides should remain a viable 

strategy long into the future. New developments in weed management that include new types of 

herbicides and possibly new technologies are likely to enhance sustainability.

HR weeds are discussed more fully in Appendix 6. Genetically modified crops with herbicide 

resistance are a major part of conventional commodity agriculture in the United States, and 

comprise the majority of corn, soybeans and cotton products consumed by humans and livestock. 

In this country, people rely on a network of legal and procedural requirements designed to reduce 

risk to acceptable levels and assure the health and safety of themselves and their livestock. In the 

next section, we discuss health and safety issues related to cotton and soybean production with a 

focus on worker safety and public health.

3.6 Health and Safety for Humans and Livestock 

Cotton seed and associated linters are processed to produce cottonseed oil and cottonseed meal 

which is used for human food and animal feed. In the U.S., cottonseed oil annual production 

averages more than 1 billion pounds, ranking behind soybean and corn oil in volume, and 

representing about 5 to 6% of the total domestic fat and oil supply (National Cottonseed Products 

Association, 2002). Cottonseed oil is primarily used as a salad or cooking oil. It is among the 

most unsaturated of food oils, and is rich in natural antioxidants called tocopherols (NCPA, 

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2002). Others, however, view cottonseed oil as unhealthy because they consider it too high in 

saturated fat and too low in monounsaturated fat (Weil, 2008). They believe it may contain 

natural toxins and unacceptably high levels of pesticide residues (Weil, 2008).

Processed soybeans are the world's largest source of animal protein feed and the second largest 

source of vegetable oil. Soybean meal is high in protein and is used in food products such as 

tofu, soymilk, meat replacements, and protein powder; it provides a natural source of dietary 

fiber (USB, 2009). Nearly 98% of soybean meal produced in the U.S. is used as animal feed, 

while less than 2% is used to produce soybean flour and proteins for food use (Soyatech, 2011). 

Soybeans can be the dominant component of livestock diets, such as in poultry, where nearly 

two-thirds of their protein intake is derived from soybeans (Waldroup and Smith, 2008). Poultry 

consume more than 45% of domestic soybean meal or 590 million bushels of the U.S. soybean 

crop, with soybean oil increasingly replacing animal fats and oils in broiler diets (USB, 2011). 

Other animals fed domestic soybeans (by crop volumes consumed) include swine (26%), beef

cattle (12%), dairy cattle (9%), other (e.g., poultry, farm-raised fish 3%), and household pets 

(2%) (Soy Stats, 2010; USB, 2011).

Soybean liquids produce salad and cooking oils, baking and frying fat, and margarine. Soybean 

oil is low in saturated fats, high in poly- and monounsaturated fats, and contains essential omega3 fatty acids. Soybean oil comprises nearly 70% of the oils consumed in U.S. households (Soy 

Stats, 2010). Soybeans comprise about 90% of U.S. oilseed production, while other oilseeds 

(peanuts, sunflower seed, canola, and flax) make up the remainder 10% (USDA-ERS, 2014e).

Although the current soybean market is dominated by seed production, soybean has a long 

history as nutritious grazing forage, hay, and silage for livestock (Blount et al., 2009). Soybean 

may be harvested for hay or grazed from the flowering stage to near maturity; the best soybean 

for forage is produced in the beginning of the pod stage (Owen et al., 2011). For silage, 

harvesting should be at maturity before leaf loss. Then the soybean matter should be mixed with 

a carbohydrate source, such as corn, for optimal fermentation characteristics (Blount et al., 

2009). There are varieties of soybean specifically developed for grazing and hay, but use of the 

standard grain varieties often is recommended because of the whole plant feeding value

(Weiderholt and Albrecht, 2003).

Non-GE soybean varieties, both those developed for conventional use and for use in organic

production systems, are not evaluated by any regulatory agency in the U.S. for human food or

animal feed safety prior to release in the market. Under the FFDCA, it is the responsibility of

food and feed manufacturers to ensure that the products they market are safe and properly

labeled. Food and feed derived from any GE crop events must be in compliance with all 

applicable legal and regulatory requirements.

Food safety reviews frequently compare the compositional characteristics of the GE crop with 

non-transgenic, conventional varieties of that crop (see e.g., (Aumaitre et al., 2002; FAO, 2009)).

Moreover, this comparison also evaluates the composition of the modified crop under actual 

agronomic conditions, including various agronomic inputs (Monsanto, 2012a; 2012b). 

Composition characteristics evaluated in these comparative tests include moisture, protein, fat, 

carbohydrates, ash, minerals, dietary fiber, essential and non-essential amino acids, fatty acids, 

vitamins, and anti-nutrients (Monsanto, 2012a; 2012b).

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Anti-nutrients represent an important element of food safety comparisons that follow US-FDA’s 

guidelines (DAS, 2013a). Anti-nutrients are compounds produced by a plant that interfere with 

the absorption and metabolism of the consumed vegetable as well as other foods in the digestive 

tract (Cordain, 1999). Anti-nutrients commonly found in raw soybean include trypsin inhibitors 

and lectins (US-FDA, 2011b). 

Some plant constituents are toxins, such as gossypol. Except for varieties bred to suppress the 

trait, it is produced in glands on cotton stems, true leaves, bolls, and other plant parts. Gossypol 

is toxic to humans, pigs, chickens, and some other animals, so its presence reduces the value of 

cottonseed for food and feed. Gossypol-producing varieties have been shown to reduce rabbit 

and rodent feeding on cotton (Rude, 1984).

There are multiple ways in which organisms can be genetically modified through human 

intervention. Traditional methods include breeding or crossing an organism to elicit the 

expression of a desired trait, while more contemporary approaches include the use of 

biotechnology such as genetic engineering to produce new organisms (Committee on Identifying 

and Assessing Unintended Effects of Genetically Engineered Foods on Human Health, 2004). As 

noted by the National Research Council (NRC), unexpected and unintended compositional 

changes arise with all forms of genetic modification, including both conventional hybridizing 

and genetic engineering (NRC, 2004). The NRC also noted in its 2004 report that no adverse 

human health effects attributed to genetic engineering have been documented. Reviews on the 

nutritional quality of GE foods generally have concluded that there are no biologically 

meaningful nutritional differences in conventional versus GE plants for food or animal feed 

(Aumaitre et al., 2002; Faust, 2002; Van Deynze et al., 2005).

More recently, the NRC found the cultivation of GE crops resulted in changes in pesticide 

application practices (NRC, 2010b). For example, this included applications of fewer pesticides 

or using pesticides with lower environmental toxicity. Consequently the cultivation of HR crops 

is advantageous because of their superior efficacy in pest control and concomitant economic, 

environmental, and presumed personal health advantages (NRC, 2010b).

Human health topics associated with GE crops include the potential toxicity of the introduced 

genes and their products, the expression of new antigenic proteins, and altered levels of existing 

allergens (Malarkey, 2003; Dona and Arvanitoyannis, 2009). Under the FFDCA, it is the 

responsibility of food and feed manufacturers to ensure that the products they market are safe 

and labeled properly. Food and feed derived from GE organisms must be in compliance with all 

applicable legal and regulatory requirements. GE organisms for food and feed may undergo a 

voluntary consultation process with the FDA prior to release onto the market. The PAT protein, 

conferring resistance to glufosinate, has already been evaluated by FDA; soybeans (and other 

crops) containing the pat gene are already in commerce.

3.6.1 Worker Safety

Approximately 3.1 million people in the United States are reported as farm workers, representing 

approximately 1 percent of the total U.S. population (EPA, 2014). Agriculture is one of the most 

hazardous industries for U.S. workers. Farmers and, in some instances, family members who 

share the work and live on the premises, are at a very high risk for fatal and nonfatal injuries. 

94
Worker hazards in farming are common to all types of agricultural production, and include 

hazards associated with operation of farm machinery and common agricultural management 

practices, such as pesticide application. Cuts, bruises, loss of fingers and limbs are examples of 

injuries resulting from mechanical hazards. 

As a result, in 1990, Congress directed the National Institute of Occupational Safety and Health 

to develop an agricultural safety and health program to address the high risks of injuries and 

illnesses experienced by agricultural workers and families. NIOSH supports and funds programs 

conducting research on agricultural injuries, as well as pesticide exposure, pulmonary disease, 

musculoskeletal disorders, hearing loss, and stress.

Pesticides, which include insecticides and herbicides, are used on most U.S. soybean and cotton 

fields to manage weeds and pests. Agricultural workers, including pesticide applicators, may be 

exposed to pesticides through mixing, loading, or applying chemicals, or by entering a 

previously treated field. As discussed in Subsection 1.5, Coordinated Framework Review and 

Regulatory Review, all pesticides labeled for use on crops in the United States must first be 

registered by the EPA and used in accordance with label instructions. Among other elements, the 

EPA pesticide registration process involves the design of use restrictions that, if followed, have 

been determined to be protective of worker health. Worker safety precautions and use restrictions 

are noted clearly on pesticide registration labels. These restrictions provide instructions as to the 

appropriate levels of personal protection required for agricultural workers to use herbicides. 

These may include instructions on personal protective equipment, specific handling 

requirements, and field reentry. Used in accordance with the EPA label, registered herbicides are 

determined to not present a health risk to workers.

In consideration of the risk of pesticide exposure to field workers, EPA’s Worker Protection 

Standard (WPS) (40 CFR Part170) was published in 1992 to require actions to reduce the risk of 

pesticide poisonings and injuries among agricultural workers and pesticide handlers. The EPA 

Worker Protection Standard (WPS) (40 CFR Part 170) provides occupational protections to over 

2 million agricultural workers and pesticide applicators at more than 600,000 agricultural 

establishments (farms, forests, nurseries and greenhouses) (US-EPA, 2014b). The WPS contains 

requirements on pesticide safety training, notification of pesticide applications, use of personal 

protective equipment, restricted entry intervals following pesticide application, decontamination 

supplies, and emergency medical assistance. Under the WPS, the EPA requires the pesticide 

label to specify personal protective equipment and restricted entry intervals that will provide an 

appropriate level of protection, based on the properties of the product. Furthermore, the 

Occupational Safety and Health Administration (OSHA) require all employers to protect their 

employees from hazards associated with pesticides and herbicides.

On February 20, 2014, the US-EPA announced proposed changes to the agricultural WPS to 

increase protections from pesticide exposure for agricultural workers and their families9

. The 

EPA is proposing to strengthen the protections provided to agricultural workers and handlers 

under the WPS by improving elements of the existing regulation, such as training, notification, 

9 For the proposed changes see: http://www.epa.gov/oppfead1/safety/workers/proposed/index.html

95

 
communication materials, use of personal protective equipment, and decontamination supplies. 

The proposed changes to the current WPS requirements, specifically improved training on 

reducing pesticide residues brought from the treated area to the home on workers and handlers' 

clothing and bodies and establishing a minimum age for handlers and early entry workers, other 

than those covered by the immediate family exemption, mitigate the potential for children to be 

exposed to pesticides directly and indirectly. The EPA expects the revisions, once final, to 

prevent unreasonable adverse effects from exposure to pesticides among agricultural workers 

and pesticide handlers; vulnerable groups, such as minority and low-income populations, child 

farmworkers, and farmworker families; and the general public.

To register a pesticide product, the EPA evaluates the potential risks to humans and the

environment using various scientific studies designed to determine whether a potential product 

has the potential to cause adverse effects on wildlife, fish, humans (including acute, chronic,

reproductive, and carcinogenic risk), and plants (including endangered species and other nontarget organisms). The EPA requires reregistration of products with active ingredients registered

prior to November 1, 1984, under the amended FIFRA in 1988. During the reregistration and

registration renewal processes, the EPA thoroughly reviews the scientific databases underlying 

registrations for pesticides to ensure consistency with current scientific and regulatory standards.

To determine the risks to workers from dicamba and glufosinate, the EPA evaluated exposure 

data in occupational worker safety evaluations and risk assessments. For dicamba, the EPA

completed the reregistration process and a Registration Eligibility Decision (RED) was issued in

2006. It was subsequently amended in 2008 and 2009 (US-EPA, 2009). The EPA concluded

current dicamba uses were eligible for reregistration based on findings in three areas. First, the

available data is adequate to support the continued registration of dicamba products and uses. 

Second, the worker exposure to dicamba for all registered agricultural uses, including exposures 

associated with the current preemergence cotton uses, meets the "no unreasonable adverse 

effects" criteria of FIFRA. Third, there is a reasonable certainty that no harm will result to the

general population, or to infants and children, as a result of aggregate exposure to dicamba 

residues (US-EPA, 2009a).

The EPA assessed the safety of using glufosinate (as an active ingredient) to control broadleaf 

weeds on many crops, including cotton and soybeans, in a 2003 human health risk assessment in 

support of registration review (US-EPA, 2003). The EPA performed a second human health risk 

assessment for registration of glufosinate use on citrus, pome, and stone fruits, olives and sweet 

corn (US-EPA, 2012b). In 2013, the EPA updated their occupational assessment for glufosinate 

to include: (1) handler exposure and risk estimates for spot/directed treatments to citrus, pome, 

stone fruits, and olives, (2) handler exposure and risk estimates for the representative crops of 

corn, cotton, sorghum, and canola, and (3) a new summary of estimated post-application risks for 

various crops (US-EPA, 2013b). Based on the most recent EPA review, glufosinate is currently 

registered for use on apples, berries, canola, citrus, corn, cotton, currants, grapes, grass grown for 

seed, olives, pome fruit, potatoes, rice, soybeans, stone fruit, sugar beets, and tree nuts with 

preplant and post-emergent applications (US-EPA, 2013a). 

The EPA pesticide registration process involves the development of use restrictions that protect 

worker health regardless of changes in acreage, crops, farming practices, the amounts and types 

of pesticides, and concomitant risks to workers. Growers are required to use pesticides in a 

96
manner consistent with the application instructions as provided on the EPA-approved pesticide 

labels. Worker safety precautions and use restrictions are clearly noted on pesticide registration 

labels. These restrictions provide instructions for the appropriate levels of personal protection 

required for agricultural workers to use herbicides. These instructions may include requirements 

for personal protective equipment, specific handling requirements, and field reentry procedures. 

Used in accordance with the EPA label, registered herbicides are determined to not present a 

health risk to workers (US-EPA, 2009a; 2013b).

The current labels for both dicamba and glufosinate include label use restrictions intended to 

protect humans, including PPE to be worn during mixing, loading, applications and handling; 

equipment specifications to control pesticide application; and reentry periods that establish a safe 

duration between pesticide application and exposure to the pesticide in the field. Used in 

accordance with the EPA label, these herbicides are determined to not present a health risk to 

humans (US-EPA, 2013b).

The greatest risk to human safety in agriculture is associated with physical injuries. These 

typically occur during maintenance and use of farm machinery. Cuts, bruises, loss of fingers and 

limbs are examples of injuries resulting from mechanical hazards.

3.6.2 Public Health

Health effects to the general public, including children in the vicinity of the cotton and soybean 

fields may arise from pesticide exposures via incidental ingestion, inhalation, and dermal 

contact. Pesticide exposures may occur from drift or accidental entry to the field during pesticide 

application. Adverse health effects to the general public, however, are not anticipated because of 

the pesticide label directions and restrictions, the EPA required agricultural workers trainings on 

proper pesticides uses, and restricted entry signage. 

Health effects to consumers may arise from pesticide exposure through the consumption of 

harvested cotton and soybean food products. The EPA protects consumer health by setting 

tolerances (maximum residue levels), or establishing an exemption from the requirement for a 

tolerance, under the FFDCA. A tolerance is the amount of pesticide residue that can remain on or 

in food for human consumption or animal feed. Before establishing a pesticide tolerance, the 

EPA is required to reach a safety determination based on a finding of reasonable certainty of no 

harm under the FFDCA, as amended by the FQPA.

Consumers of cottonseed oil and/or processed soybeans may become exposed to residual levels 

of pesticides in these processed products or in animal-based food products. The FDA controls

pesticide residue limits (known as tolerances) in both cotton and soybean harvested food 

products, while the EPA established tolerances (the maximum pesticide residue levels can 

remain on food and feed products or commodities) protect consumers from harmful levels of 

pesticides on food. For example, the EPA-established dicamba residue tolerance of 0.2 ppm for

cottonseed supporting the current uses of dicamba on cotton is the result of combining residue 

tolerances for both the parent dicamba and its metabolite 5-hydroxy dicamba (40 CFR §

180.227). The EPA-established glufosinate residue tolerances are 4.0 ppm and 15.0 ppm for 

cottonseed and gin by-products, respectively (40 CFR § 180.473). Both of these tolerances

include the combined residues of parent glufosinate and its metabolites N-acetyl glufosinate

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and 3-methylphosphinico-propionic acid. Any adverse health effects from exposure to pesticide 

residues for cottonseed oil and processed soybean consumers are minimized by FDA residue 

monitoring and EPA tolerance requirements. 

A variety of opinions exist on the human health safety of genetically modified foods. The 

American Association for the Advancement of Science concluded that consuming food 

containing ingredients derived from genetically modified crops is not riskier than consuming the 

same food containing ingredients from crops modified by conventional plant breeding 

techniques. The NRC (NRC, 2004) found that no adverse health effects attributed to genetic 

engineering had been documented in the human population. They also indicated the contribution 

of genetically engineered food to the genetic vulnerability of some individuals to some 

compounds is unclear (NRC, 2004).

A European Union- (EU) funded GMO research (Commission, 2010) concluded at least equal 

assurance of the safety of GM foods compared to conventional counterparts. The World Health 

Organization concluded that GM foods currently available on the international market are not 

likely to present risks for human health based on risk assessment results. These risk assessments 

evaluate five types of direct health effects: (1) any tendencies to provoke allergic reactions, (2) 

specific components thought to have nutritional or toxic properties, (3) the stability of the 

inserted gene, (4) nutritional effects associated with genetic modification, and (5) any unintended 

effects resulting from the gene insertion (WHO, 2014). (Lendman, 2014)GE organisms used for 

food or feed purposes undergo a voluntary consultation process with the FDA prior to release 

to the U.S. market (US-FDA, 2001). The FDA established this voluntary consultation process to

review the safety of foods and feeds derived from GE crops for human and animal consumptions. 

During the consultation, FDA evaluates the scientific and regulatory assessment summary of the 

food and feed safety of a product submitted by a developer, and responds to the developer by 

letter (US-FDA, 2014). Developers intending to commercialize a bioengineered food meet with 

the FDA to identify and discuss relevant safety, nutritional, or other regulatory issues regarding 

the bioengineered food. They submit a summary of their scientific and regulatory assessment of 

the food including: (1) an evaluation of the amino acid sequence introduced into the food crop to 

confirm whether the protein is related to known toxins and allergens, (2) an assessment of the 

protein’s potential for digestion, and (3) an evaluation of the history of safe use in food 

(Hammond and Jez, 2011). The genetically engineered MON 88701 cotton and MON 87708 

soybean completed the FDA consultation process with no further questions (US-FDA, 2011b; 

2013).

3.7 Cotton and Soybean Production as Related to the Affected Environment

Some of the trends in U.S. cotton and soybean production from 1980 to 2011 are summarized in 

Table 12 (Field-to-Market, 2012). The cotton information was derived by combining seed and 

lint information at the percentages of production (83% lint and 17% seed). The total production 

for both crops increased through 2011. While soybean production continues to increase, cotton 

production decreased in the past few years (USDA-OCE, 2014a). From 1980 to 2011, the land 

use trends showed an increase in efficiency based on the increased yield combined with 

reductions in the acres per unit of production. Soil erosion and irrigation efficiency increased 

during the interval, probably as a result of the adoption of conservation tillage and improved 

irrigation technologies by growers. While overall CO2 emission equivalents increased, the 

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concomitant decreases in emissions per unit of production suggest awareness of agricultural 

contributions to GHG may be leading to conservation efforts.

Table 12. Summary of Trends in U.S. Cotton and Soybean Production, Resource Use and

Impact from 1980-2011.

Soybean Cotton

Indicator Percent Change1 Indicator Percent Change

Trend2 Entire 

Period

Compound 

Annual Trend Entire Period

Compound 

Annual

Crop 

Yield

Total 

Production

↑ 96 2.2 Total 

Production

↑ 55 1.4

Land 

Use

Total 

Planted 

Acres

↑ 24 0.7 Total 

Planted 

Acres

↑ 11 0.3

Acres per 

Bushel

↓ (35) (1.4) Acres per 

Pound

↓ (30) (1.2)

Soil 

Eroded

Total Tons ↓ (28) (1.0) Total Tons ↓ (42) (1.7)

Tons per 

Bushel

↓ (66) (3.5) Tons per 

Pound

↓ (68) (3.6)

Irrigate

Water

Total 

Volume

↑ 271 4.3 Total 

Volume

↓ (35) (1.4)

Volume 

per Bushel

↓ (42) (1.8) Volume 

per Pound

↓ (75) (4.4)

GHG:

CO2

Total 

Pounds

↑ 13 0.4 Total 

Pounds

↑ 10 0.3

Pounds 

per Bushel

↓ (41) (1.7) Pounds 

per Pound

↓ (30) (1.1)

1

Percent change results are based on a least squares trends analyses from 1980-2011.

Source: (Field-to-Market, 2012) citing: (1) USDA, NASS, Census of Agriculture, Farm and Ranch Irrigation Survey

http://www.agcensus.usda.gov/Publications/index.php. (2) USDA, Economic Research Service (ERS), (ARMS) 

http://www.ers.usda.gov/Briefing/ARMS/Access.htm; (3) USDA, National Resources Conservation Service 

(NRCS), National Resource Inventory (NRI) Reports

http://www.nrcs.usda.gov/wps/portal/nrcs/main/national/technical/nra/nri 

2

Trend direction: ↑= Increasing, ↓ = Decreasing.

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4 POTENTIAL ENVIRONMENTAL CONSEQUENCES

This chapter examines the environmental effects associated with the alternatives on the affected 

environment (as identified in Chapter 2). In this chapter, APHIS only examines the direct and 

indirect effects of its decision regarding the regulatory status of MON 88701 cotton and MON 

87708 soybean. While the Agency recognizes that these varieties were engineered to be resistant 

to applications of the herbicide dicamba, the EPA has the regulatory authority to approve new 

uses of all pesticides, including those for dicamba on MON 88701 cotton and MON 87708 

soybean. The EPA is currently evaluating the proposed new uses of dicamba for these varieties, 

and is the Federal agency which determines possible human health and environmental 

consequences of dicamba use in agriculture. The EPA registers herbicide use when consistent 

with a conclusion of no unreasonable environmental impacts. In this chapter, we assume that any 

use of dicamba should be discussed as a cumulative effect of APHIS’ action combined with 

future actions that may be taken by the EPA or other agencies. Thus, the analysis of these 

possible cumulative effects is discussed in Section 5 of the EIS.

4.1 No Action Alternative

Under the No Action Alternative, APHIS would not approve the petitions for deregulation. This 

alternative represents the status quo, or the situation that would occur if APHIS denies the 

petitions. This section describes the effects of cotton and soybean production on the human 

environment that are occurring and are anticipated to continue to occur if APHIS selects the No 

Action Alternative. The analysis examines the effects of cotton and soybean production on 

physical, natural and biological resources to allow meaningful comparison to the other 

alternatives reviewed in this document.

4.1.1 Land Use and Acreage

Cotton

In the U.S., cotton is grown exclusively in the southern states because this is the only U.S. region 

with a growing season long enough for cotton to mature. During the past 10 years, total U.S. 

cotton acreage has varied from approximately 9.15 to 15.77 million acres, with the lowest 

acreage recorded in 2009 and the highest in 2001 (See Figure 13) (USDA-NASS, 2014a). In 

2013, the harvested acreage for all types of cotton was 7.66 million acres, a reduction of 18 

percent from the previous year (USDA-NASS, 2014a).

The most recent USDA projections for cotton anticipate an increase to 11 million acres in 2014 

(USDA-OCE, 2014b). Prices for competing crops are projected to fall more than cotton prices, 

making cotton cultivation more favorable. The trend for cotton acreage plantings over the 

projection period shows a decrease to 10 million acres in 2015 and remains near that level for the 

remainder of the projection period, as a result of projected world and U.S. cotton prices below 

the recent 5-year average (USDA-OCE, 2014b). Under the No Action Alternative, the projected 

acreage of cotton production is not expected to change over the next decade.

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Figure 13. Acres of Upland and Pima Cotton Planted and Harvested from 

1993 to 2013.

Source: (USDA-NASS, 2014e)

Soybean

During the last two decades, the number of acres planted to soybeans increased because of 

favorable prices (USDA-ERS, 2012a) (see Figure 14). This increase in soybean production was 

accompanied by decreases in other crops, including upland cotton, corn grown for silage, spring 

and specialty wheat, and oats (USDA-ERS, 2011c). In 2013, 75.9 million acres of soybeans were 

harvested in the U.S., a slight decrease from the 75.9 million acres harvested in 2012. However, 

the 2013 soybean harvest was the fourth highest on record, and production was up 8 percent

from 2012 (USDA-NASS, 2014a).

The most recent USDA projections are for U.S. soybean plantings to remain near 78 million acres 

through 2023 (USDA-OCE, 2014b). The expected growth in the demands for soybean for 

domestic use and export will result in price increases, allowing soybeans to compete with corn 

and other crops for land use (USDA-OCE, 2014b). Under the No Action Alternative, the 

projected acreage of soybean production is not expected to change over the next decade.

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Figure 14. Acres of Soybeans Planted and Harvested from 1993 to 2013. 

Source: (USDA-NASS, 2014e)

Genetically Engineered Cotton and Soybean

Under the No Action Alternative, the current trend of adoption of GE cotton and soybean 

varieties by U.S. farmers is likely to continue. However, continued adoption in the future will 

depend on whether growers continue to derive benefits from GE crops and will be dependent on 

the ability of farmers to adopt best management practices to avoid resistance issues, the ability of 

biotech companies to develop new GE varieties, and consumer acceptance of products from GE 

sources (Fernandez-Cornejo et al., 2014b).

Growers can choose from a large number of cotton or soybean hybrids produced from 

conventional breeding or GE practices. Like other major commodities, GE varieties of cotton 

and soybean have been adopted during the past decade. Large-scale field testing of GE crops 

began in the 1980s, but it was not until 10 years later that the first generation of GE varieties 

became commercially available (Fernandez-Cornejo and Caswell, 2006). Since commercial 

introduction in 2000, GE cotton has expanded to approximately 90 percent of U.S. cotton 

acreage in 2011 (USDA-ERS, 2014a). Of that number, 15 percent of the U.S. cotton crop was 

GE HR, 17 percent was insect-resistant, and 58 percent was stacked with both GE herbicide 

resistance and insect resistance (USDA-ERS, 2014a).

Since GE soybeans became commercially available in 1996, their use has expanded to greater 

than 90 percent of the total U.S. soybean acreage (USDA-ERS, 2014a). Although other varieties 

are available for selection by growers, the Roundup Ready® GR varieties continue to dominate 

the market (Tarter, 2011). Other cultivated HR soybeans include the LibertyLink® soybean 

varieties (a GE soybean that is resistant to glufosinate ammonium herbicide and was granted 

nonregulated status in 1996) and STS (a conventionally bred sulfonylurea-resistant soybean first 

introduced in 1993). As of 2012, 3.9 percent of U.S. soybean acres planted were glufosinateresistant (DAS, 2013a). Varieties with other GE traits, such as lepidopteran resistance, high oleic 

acid content, improved fatty acid profile, and increased stearidonic acid have since been granted 

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nonregulated status (USDA-APHIS, 2014c). Of these, at this time, only high oleic acid content 

soybean has been commercialized.

4.1.2 Socioeconomics

Domestic Cotton and Soybean Production

Under the No Action Alternative, MON 88701 cotton and MON 87708 soybean will continue to 

be regulated articles under 7 CFR Part 340. Growers and other parties who are involved in 

production, handling, processing, or consumption of cotton and soybean will continue to have 

access to nonregulated GE and non-GE cotton and soybean varieties. Domestic growers will 

continue to utilize GE and non-GE cotton and soybean varieties based upon availability and 

market demand.

Management practices associated with cotton and soybean production, including uses of 

agronomic inputs, vary from grower to grower, and would not be affected under the No Action 

Alternative. Farm income is positively impacted by GE cotton and soybean by reducing 

production costs (e.g., reduced tillage for weed management and, potentially, reduced herbicide 

use). While growers are expected to continue benefiting from the adoption and cultivation of 

currently deregulated GE crops, growers in some U.S. regions with HR weed problems may

incur increased costs because of the increased need for more pesticide treatments and/or 

increased tillage. These trends are unaffected under the No Action Alternative.

Cotton

In 2014, the area planted for all cotton is expected to total 11.1 million acres, 7 percent above 

2013 acreage (USDA-NASS, 2014b). This increase is anticipated because of the lower prices 

expected for competing crops as compared to cotton prices (USDA-OCE, 2014b). Upland cotton 

area is expected to total 10.9 million acres, up 7 percent from 2013; Pima cotton area is expected 

to total 158,000 acres, a 21 percent decrease from 2013 (USDA-NASS, 2014b). Cotton acreage 

in 2015 is projected to fall to 10 million and remain near that level through 2023 with both world 

and U.S. cotton prices projected below the recent 5-year average (USDA-OCE, 2014b).

In 2013, all cotton production in the U.S. is estimated at 13.2 million 480-pound bales, a 

decrease of 24 percent from 2012. Cotton yield is estimated at 826 pounds per acre, 61 pounds

per acre less than last year (USDA-NASS, 2014b). As a result of both higher planted acreage and 

expected lower abandonment, the U.S. cotton crop is projected to rise sharply to 16.3 million 

bales in 2014/15 (Johnson et al., 2014).

U.S. mill use fell to a low of 3.3 million bales in 2011, but has moved higher and is estimated at 

3.7 million bales for 2014 (National Cotton Council of America, 2014). U.S. mill use of upland 

cotton is projected to rise moderately, while cotton exports appear likely to remain level after 

2016/17 (USDA-OCE, 2013) (Figure 15). With the help of the Economic Adjustment Assistance 

Program that began with the 2008 Farm Bill, and is continued under the 2014 Farm Bill, new 

investments and expansions within the U.S. cotton industry are reported with companies 

upgrading existing facilities and/or building new facilities. New plants are scheduled to open

beginning in early 2015 (Adams et al., 2014). The 2014/15 marketing year average price 

received by U.S. cotton producers is projected to range between 65 and 70 cents per pound,

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which is below the 2013/14 mid-point estimate of 76 cents per pound. Supporting the lower price 

projections are December 2014 cotton futures, which as of early February, were around 77 cents 

per pound (Johnson et al., 2014).

Figure 15. Domestic Mill Use and Exports of U.S. Upland Cotton with 

Projections Through 2022.

Source: (USDA-OCE, 2013)

Soybean

U.S. soybean production in 2013 totaled 3.29 billion bushels, an 8 percent increase from 2012 

and the third largest on record (USDA-NASS, 2014a). According to USDA-NASS, the average 

yield per acre for 2013 is estimated at 43.3 bushels, 3.5 bushels per acre more than 2012 yield

(USDA-NASS, 2014a). USDA forecasts an increase in soybean planted area for 2014 at a record 

high of 81.5 million acres, a 6 percent increase from 2013 (USDA-NASS, 2014b). Projections 

for U.S. soybean plantings through 2023 indicate plantings remaining near 78 million acres over 

most of the projection period (USDA-OCE, 2014b). 

Soybean prices are expected to increase from growth in both domestic use and export demand 

(see Figure 16), and are projected to remain historically high (above pre-2007 levels) (USDAOCE, 2014b). The average U.S. on-farm market price for soybeans for the 2012-13 marketing 

year increased to $14.40 per bushel, compared to $12.50 per bushel for the 2011-12 and $11.30 

per bushel for the 2010-11. On-farm soybean market prices for the 2013-14 marketing year are 

estimated by USDA to fall from the previous year’s high to an average $12.70 per bushel (Corn 

and Soybean Digest, 2014). Soybean prices are then estimated to rise moderately after 2015-16, 

as a result of increasing demand for soybeans and soybean products (USDA-OCE, 2014b).

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Figure 16. Projections of U.S. Soybean Domestic Use and Exports to 2023. Source: (USDA-OCE, 2014b)

These trends in domestic production and uses for cotton and soybean are not expected to change 

under the No Action Alternative.

Foreign Trade

U.S. crop exports have experienced steady growth in recent years. From 2009-2013, the value of 

agricultural exports in the U.S. increased from $96.3 to $141.0 billion. Fiscal year (FY) 2015 

agricultural exports are projected to be $144.5 billion (USDA-ERS, 2014c). The FY 2015 export

forecast for oilseeds and products is projected at $29.7 billion, and for cotton $4.1 billion 

(USDA-ERS, 2014c). Exports for both soybean and cotton are expected to increase through 2023 

under the No Action Alternative, although the 37.6% U.S. share of the world soybean exports 

will decline slightly by 2023, and the 26.7% share of world cotton will also decline slightly 

(USDA-OCE, 2014b).

The USDA anticipates world cotton production will exceed consumption for the fifth 

consecutive season. Production throughout the world is expected to rise by less than 1 percent to 

117.0 million bales, resulting from lower production in China, Brazil, and Australia being offset 

by an increase in U.S. production. Global 2013/14 cotton production is expected to fall 5 percent

from the previous year to 116.7 million bales. The harvested area is estimated at 33.1 million 

hectares, down 3.5 percent from last year. World average yield is 766 kilograms (kg)/hectare, 

down 2 percent (Johnson et al., 2014).

World trade is forecast down 18 percent from last season, the large fall in imports by China 

masks strong demand elsewhere. Imports in the rest of the world are forecast to increase 7

percent (Johnson et al., 2014). Improved textile demand and lower cotton price volatility is 

anticipated to support a slight recovery in cotton’s fiber share (Johnson et al., 2014). U.S. exports 

are forecast to rise in 2013/14 and appear likely to level off after 2016/17 (USDA-OCE, 2013)

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(Figure 15). Exports for most other major exporters will remain near 2013/14 levels (Johnson et 

al., 2014). Overall, USDA projects that world cotton trade will trend upward at a growth rate of 

3.8 percent between 2014/15 and 2023/24 (see Figure 17) (USDA-OCE, 2014b).

Figure 17. Projections of Global Cotton Exports to 2023. Source:(USDA-OCE, 2014b)

An increase in U.S. cotton acreage coupled with high worldwide reserves is considered likely to 

reduce prices in the medium term, primarily due to the lag between cotton production and cotton 

demand (AgriMoney, 2014). World stocks more than doubled, mainly due to cotton policies in 

China. USDA projects that lower China domestic support levels, higher stocks outside of China, 

and falling grain and oilseed prices could reduce the world cotton price to a 5-year low (Johnson

et al., 2014). Higher world ‘free’ stocks and lower price projections for the 2014 corn and 

soybean crops will also affect U.S. cotton prices (Johnson et al., 2014).

Soybean exports in the form of bulk beans, meal, and oil are a major share of the total 

agricultural exports for the U.S. (Figure 18 and Figure 19).The U.S. was responsible for 35 

percent of world soybean production, 21 percent of world soybean meal production, and 21 

percent of soybean oil production (USDA-FAS, 2013a). The U.S., Brazil, and Argentina are 

expected to continue to account for 88 percent of global exports of soybeans and soybean 

products (Figure 20). Underlying these projections is an assumption that China would continue 

to be heavily reliant on soybean imports (Figure 21), which are projected to rise 59 percent to 90 

million tons in 2021/22 (USDA-OCE, 2013). 

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Figure 18. Projections of Global Cotton Imports to 2023.

Source: (USDA-OCE, 2014b)

Figure 19. Projected U.S. Global Exports of Soybeans, Soybean Meal, and 

Soybean Oil.

Source: (USDA-OCE, 2014b)

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Figure 20. Projections of Global Soybean Exports to 2023.

Source: (USDA-OCE, 2014b)

Figure 21. Projections of Global Soybean Imports to 2023.

Source: (USDA-OCE, 2014b)

China is the largest importer of U.S. soybeans and soybean products at 50 percent of the total 

value of U.S. soybean and soybean product exports, followed by Mexico (8.9 percent) and Japan 

(4.2 percent) (USDA-FAS, 2013a). Over the next decade, global trade in soybeans is expected to 

increase by 31 percent, soybean meal by 17 percent, and soybean oil by 12 percent.

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Under the No Action Alternative, the U.S. is expected to continue to be a leading producer and 

exporter of cotton and soybean products.

4.1.3 Agronomic Practices in Cotton and Soybean Production

Under the No Action Alternative, MON 88701 cotton and MON 87708 soybean would continue 

to be regulated by APHIS. Current availability and usage of commercially-available (both GE 

and non-GE) cotton and soybean varieties are expected to remain the same under the No Action 

Alternative.

General agronomic practices such as planting and harvesting times, crop nutrition, use of plant 

growth regulators, and pre-harvest and harvest practices are expected to remain the same 

Specialized agronomic practices such as row spacing, the use of cover crops and crop rotation

practices, as well as adoption of precision agriculture may change over time.

Tillage

Under the No Action Alternative, if hard-to-control and/or GR weeds continue to be problematic 

or to become a problem where they were not previously found, cotton and soybean growers may 

need to increase or revert to conventional tillage or hand-weeding. This may be a greater 

problem in soybean growing states because of the high prevalence of no-tillage used for soybean 

production. 

Most growers are not expected to increase tillage in the short-term due to the economic (reduced 

fuel use, less time in the field) and environmental benefits (reduced soil erosion and better 

moisture retention) associated with these practices. The increase of GR weeds makes glyphosate 

use less attractive, although, glyphosate still controls large numbers of weeds (Monsanto, 2013a). 

Mid-South and possibly Southeastern states soybean growers who previously adopted no-till 

production are now replacing that with increasingly aggressive tillage in their management 

programs (see Cumulative Impacts: Cotton and Soybean Agronomic Practices and Costs of 

Production, Changes in Tillage). In parts of the Heartland, GR waterhemp and marestail are 

widespread (Bowman, 2013). No-till practices are being maintained in many areas, but the 

presence of HR weeds and rapidly increasing presence of GR weeds in particular, sometimes 

necessitate the inclusion of tillage in weed control strategies (Arbuckle and Lasley, 2013). An 

Iowa poll disclosed that farmers there used mechanical weed control (i.e., cultivation) 25 percent

of the time, and 55 percent found it to be effective or very effective for weed control (Arbuckle 

and Lasley, 2013). Farmers apparently value soil cultivation for weed control, but practice it only 

to a limited extent (25 percent) at present.

The fact that tillage is increasing in soybean production suggests that this trend may continue 

under the No Action Alternative as herbicide-resistant weeds become more difficult to control 

with available herbicide chemistries. In an attempt to offset the increase in tillage that might 

otherwise result in the effort to manage herbicide resistant weeds, the Natural Resources 

Conservation Service (NRCS) is offering farmers technical and financial assistance to manage 

herbicide resistant weeds while maintaining conservation stewardship through two programs: the 

Conservation Security Program and the Environmental Quality Incentives Program.

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In the majority of the states that produce cotton, conventional tillage is used (USDA-NRCS, 

2013d), suggesting that the existing practice of conservation agriculture before the era of HR 

crops provide erosion control, but that no additional erosion loss improvements derive from use 

of HR crops. Other benefits of conservation tillage can be measured in improvements to soil 

organic matter, stability, infiltration, nutrients, and water management (USDA-NRCS, 2006b).

However, Alabama, North Carolina, South Carolina, and Tennessee are cotton-producing states 

where no-till exceeds conventional tillage (Table 13). (In the era beginning with the first 

herbicide resistant crops (1996/1997) and through 2010, the rate of this erosion stabilized at 

around 1 billion tons per year (USDA-NRCS, 2013d) suggesting that the existing practices of 

conservation agriculture before the era of herbicide resistant crops provide erosion control, but 

that no additional erosion loss improvements derive from use of HR crops. Other benefits of 

conservation tillage can be measured in improvements to soil organic matter, stability, 

infiltration, nutrients, and water management (USDA-NRCS, 2006c)

In these states, shifts toward conventional tillage may be more dramatic as GR weeds increase. 

Overall, conservation tillage is likely to decrease over time as GR weed populations continue to 

develop and spread. Under the No Action Alternative, an increase in the use of traditional tillage 

methods in states where GR weeds may be found could result in the potential loss of many of the 

benefits of conservation tillage. In areas where the NRCS had agreements with growers that 

restrict cultivation, an increasing number of variances are likely to be needed to accommodate 

grower needs.

Conservation tillage provides growers with benefits that include reduced soil erosion. The period 

before HR crops began to be commercialized and for which NRCS has records, shows that for 

U.S. cropland from 1982-1997, rill erosion (i.e., small channel) and surface erosion was 

declining (USDA-NRCS, 2013d). The reduction in erosion was accompanied by an increasing 

trend towards various types of conservation tillage (about 11% between 1990 and 1998); by the 

period 1998-2004, use of conservation tillage showed an increase of less than 3 percent 

(Conservation-Technology-Information-Center, 2006). In the era beginning with the first 

herbicide resistant crops (1996/1997) and through 2010, the rate of this erosion stabilized at 

around 1 billion tons per year (USDA-NRCS, 2013d) suggesting that the existing practices of 

conservation agriculture before the era of herbicide resistant crops provide erosion control, but 

that no additional erosion loss improvements derive from use of HR crops. Other benefits of 

conservation tillage can be measured in improvements to soil organic matter, stability, 

infiltration, nutrients, and water management (USDA-NRCS, 2006c)

Table 13. Tillage Practices by Crop, 2007. 

Tillage Method Soybean Cotton

Acres in No-Till 

Exceeds Conventional 

Tillage

Illinois

Indiana

Kansas

Kentucky

Maryland

Michigan

Missouri

Alabama

North Carolina

South Carolina

Tennessee

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Tillage Method Soybean Cotton

North Carolina

Ohio

Pennsylvania

South Dakota

Virginia

Wisconsin

Acres in Conventional 

Tillage Exceeds Other 

Types of Tillage

Arkansas

Louisiana

Arkansas

California

Georgia

Louisiana

Mississippi

Missouri

Texas

Mulch Till Exceeds 

Other Types of Tillage

Iowa

Minnesota

Nebraska

North Dakota

New York

Data derived from (USDA-ERS, 2014b).

Crop Rotation

Crop rotations are unlikely to change under the No Action Alternative, because existing varieties 

can be profitably produced by continuing to use current methods. This likely means continued 

reliance on producing cotton in a monoculture unless a cover or rotational crop can either reduce 

pests or soil compaction, or is needed to increase soil fertility. For soybeans, increased rotations 

are likely to continue as long as the crops can be profitably produced.

Cotton should be rotated with other crops on a regular basis to maintain soil productivity and

reduce the incidence of various weeds, insect pests, or diseases (Hake et al., 1996). However, 

because of economic factors including production costs, relative rate of return, and current 

market conditions, continuous cotton production has been and is likely to remain unchanged on 

the majority of U.S. cotton acres (Sandretto and Payne, 2006; USDA-ERS, 2006). By region, 

however, different patterns of rotation exist. Based on interviews conducted by Monsanto in

2010, approximately 54 percent of U.S. cotton acres are followed by cotton in the crop

rotation sequence. By region, this percent is highest in the Southwest (61 percent) and lowest

in the West (30 percent). Only in the West region is cotton rotated to another crop, wheat, on

the majority of cotton acres. Corn (16 percent), wheat (9 percent), soybean (8 percent),

sorghum (8 percent), and peanuts (4 percent) are the other crops most frequently rotated with

cotton (Monsanto, 2013a). Based on recent state-specific information from interviews with 

university extension crop production specialists and extension weed control specialists, 

regional changes in crop rotation patterns on cotton fields may be occurring due to economic 

factors, including production costs related to GR weeds. 

Crop rotation is a common practice on U.S. soybean fields. Soybeans are often rotated with corn, 

winter wheat, spring cereals, and dry beans (OECD, 2000), the selection of which varies 

111
regionally. Corn is the most commonly rotated crop with soybeans. USDA ARMS results for 

corn and soybean indicate a small increase in corn in rotation and continuous corn over the past 

decade (US-FDA, 2011b; Ebel, 2012). Returns for producers from a corn-soybean rotation are 

variable and depend on the price and projected yield of both corn and soybean for an individual 

operator (Stockton, 2007). Studies have found the soybean yield tends to increase under this 

rotation sequence and is attributed to an effective break in the soybean disease and pest cycle

(Nafziger, 2007; Al-Kaisi, 2011). Soybean itself may be a cover crop in short rotations because it 

contributes nitrogen to the soil (Hoorman et al., 2009). Continuous soybean production is 

sometimes practiced, but yield can be reduced the second or later years as pest and disease 

incidence tends to increase (Pedersen et al., 2001; Monsanto, 2010).

As described in the No Action Alternative analysis of tillage, tillage may increase as part of the 

effort to manage herbicide-resistant weeds. In an attempt to offset the increase in tillage that 

might otherwise result in the effort to manage herbicide resistant weeds, the Natural Resources 

Conservation Service (NRCS) is offering farmers technical and financial assistance to manage 

herbicide resistant weeds while maintaining conservation stewardship through two programs: the 

Conservation Security Program and the Environmental Quality Incentives Program. Among the 

practices that qualify for financial and technical incentives are the use of cover cropping and 

crop rotation. As a result, cover cropping and crop rotation, both of which have been shown to 

reduce weed pressure, are practices that are expected to increase under the No Action 

Alternative.

Agronomic Inputs

Nutrients/Fertilizer

Under the No Action Alternative, cotton and soybean fertilizer requirements for macronutrients 

(including nitrogen, phosphorus, and potassium) and micronutrients (such as zinc, iron, and 

magnesium) are not likely to change because fertilizer formulations will continue to be applied to 

existing varieties of cotton and soybeans.

With respect specifically to soybean, some growers will add microbial inoculants to the soil to 

facilitate the symbiotic relationship between nitrogen-fixing bacteria and soybean (Conley and 

Christmas, 2005). Industry has approximated that about one-third of U.S. soybean acreage was 

inoculated in 2009 (Seed Today, 2009). Under the No Action Alternative, the use of inoculates is 

unlikely to change from current use because of its benefits to soybean yield.

Insecticides

The use of insecticides on cotton and soybean crops is likely to continue so long as insecticideresistant pest populations do not develop under the No Action Alternative.

In the U.S., the cotton industry has consistently relied heavily on insecticide use strategies to 

manage arthropod pests (Gianesi and Carpenter, 1999). Insecticides were applied to 66 percent

of the cotton acreage in 2007 (USDA-NASS, 2008b). Of 30 listed insecticides, acephate was the 

most utilized insecticide, with 26 percent of the planted acreage being treated at an average rate 

of 0.900 pounds per acre per crop year (USDA-NASS, 2008b). Dicrotophos was the second most 

112
commonly utilized insecticide, applied to 21 percent of the acreage at an average rate of 0.565 

pounds per year (USDA-NASS, 2008b). Other insecticides applied in the 2007 growing year 

included acetamiprid (6 percent of acreage), cyfluthrin (8 percent of acreage), cypermethrin (7

percent of acreage), imidacloprid (6 percent of acreage), lambda-cyhalothrin (5 percent of 

acreage), malathion (5 percent of acreage), and thiamethoxam (11 percent of acreage) (USDANASS, 2008b). Overall, insecticide use in cotton has decreased while the adoption of GE Bt 

cotton varieties has increased (Fernandez-Cornejo et al., 2014b).

While insect management is important in soybean production, the crop is able to sustain a 

substantial amount of insect damage without loss of yield. This resiliency of soybean against 

insect damage is best represented by a 2006 survey (USDA-NASS, 2009e) that found that 

insecticides were applied to only 16 percent of the 72.9 million soybean acres planted in 

surveyed states in 2006. Of the 12 reported insecticides, the three most common - lambdacyhalothrin, chlorpyrifos, and esfenvalerate - were applied to 6, 5, and 3 percent of the planted 

acres, respectively (USDA-NASS, 2009e).

If insecticide-resistant insect populations are selected for and reproduce unhindered, the use of a 

particular insecticide formulation is likely to diminish unless another MOA/chemistry becomes 

available. If new insecticidal chemistries become available, growers are likely to change to the 

novel insecticide until a resistant population arises. This pattern of insecticide use, followed by 

resistant pest populations developing and concomitant decease in use in the product is likely 

unless growers strategically deploy the use of existing insecticides. Integrated pest management

(IPM) strategies currently in use seek to strategically use existing pesticides to ensure pesticideresistant populations are less likely to develop and spread. Under the No Action Alternative, it is 

likely that the cost of insect control and the time spent managing insect pests in soybean will be 

similar to the current use levels. Under the No Action Alternative, insecticide use in cotton may 

increase if Bt-resistant insect pests continue to develop. 

Herbicides

EPA-registered herbicides will continue to be used for weed management on GE cotton and 

soybean varieties no longer regulated by APHIS. The increase of GR weeds makes glyphosate 

use less attractive, although, glyphosate still controls large numbers of weeds (Monsanto, 2013a). 

From 2008 to 2011, acres to which glyphosate was applied were either stable or declined, but 

other herbicides (residuals applied to soil that persist for extended periods) applied increased by 

177 percent (Monsanto, 2013a). To manage glyphosate resistance, growers are not using more 

glyphosate, but are using more sites of action in addition to glyphosate. 

Dicamba is currently labeled for use in cotton only in pre-plant applications because cotton

plants can be damaged by this herbicide (US-EPA, 2006b; 2009c). Dicamba is limited to early 

pre-plant and late post-emergence (pre-harvest) applications in soybean. Under the No Action 

Alternative, the use of GR cotton and soybean is expected to continue, accompanied by an 

increasing use of additional herbicides to control other HR weeds. The use of pre-plant (less 

selective) residual herbicides is also increasing and is likely to continue to increase.

The following section provides a brief background of herbicide use in cotton and soybeans in the 

U.S. It is provided to give the context for the analyses related to HR weed selection (more

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information on these subjects is provided in Appendix 3: Weed Management and Herbicide Use; 

Appendix 4: Herbicide Use Trends in Cotton and Soybean; Appendix 5: Common Weeds in 

Cotton and Soybean; and Appendix 6: Herbicide Resistance).

Herbicide use in cotton differs substantially from that in soybean both in the types of herbicides 

used and the variety of herbicide sites of action (see Appendix 3 and 4). Cotton requires more 

time to develop a closed canopy than soybeans, so cotton becomes more susceptible to 

competition by early season weeds (Frans and Chandler, 1989). Cotton may be planted in wider 

rows than soybeans, and the resulting light penetration into an unclosed canopy allows weed 

germination and growth over a longer period of time than in soybeans (Frans and Chandler, 

1989). For these reasons, post-emergent applications of herbicides are more common in cotton 

crops than in soybeans, but there may be fewer herbicide options.

In contrast, soybean growers have come to rely almost exclusively on glyphosate for weed 

control. Prior to the adoption of GR soybean, growers relied heavily on ALS and microtubule 

inhibitors. With the adoption of GR soybean, glyphosate was used on more than 95 percent of 

soybean acreage and by three quarters of soybean growers. Glyphosate represented the only 

herbicide site of action used. As GR weeds have become more prevalent, the trend among 

soybean growers is to use more sites of action including 2,4-D, chloroacetamides, PPO and ALS 

inhibitors (USDA-NASS, 2013a; Hartzler, 2014a; VanGessel, 2014b). 

As described in more detail in Appendix 4, the trend to use more herbicides with different modes 

of action is observed for both cotton and soybean. Between 2009 and 2011, there was a 113

percent and 220 percent increase in pre- and post-application, respectively, of non-glyphosate 

treatments on GR cotton. From 2008 to 2011, there was also a 177 percent and 345 percent

increase in the use of pre- and post-emergence herbicide application, respectively, of nonglyphosate herbicides on GR soybeans (Monsanto, 2013a). With respect to dicamba, however, 

after 1994, the use of dicamba steadily declined through 2006 to 17.4 million treated acres with 

2.7 million pounds used because of competitive market introductions of sulfonylurea herbicides 

(chlorsulfuron, metsulfuron-methyl, and thifensulfuron-methyl) in wheat, new broadleaf 

herbicide active ingredients in corn, and GR corn. However, dicamba-treated acres have 

increased by as much as 4.0 million acres since 2006. Most of the increase in dicamba-treated 

acres has occurred in fallow, pastureland, sorghum, and cotton (Monsanto, 2013a). Dicambatreated acres have increased in cotton, in particular, because it is a common pre-plant herbicide 

recommendation for GR marestail (horseweed) and Palmer amaranth in the Midsouth region 

(McClelland et al., 2006). Approximately 25.3 million acres of crops were treated with dicamba 

in 2011 (see Table 8-1 in Appendix 8). Based on USDA-NASS (USDA-NASS, 2005b; 2007a; 

2010b; 2011c; 2012d) statistics, dicamba application rates ranged from 0.07 to 0.24 pounds per 

acre with the average number of applications ranging from 1 to 1.9 applications per cropping 

season. Dicamba rates are lowest in barley, wheat and oats, where typically more than one 

application is made on these crops per cropping season.

Growers are also applying herbicides with different modes of action, and adopting other 

stewardship practices that reflect the recommendations for BMPs as outlined by the Weed 

Science Society of America and the National Science Foundation (WSSA, 2010; Ferrell, 2013). 

Heavily infested fields are being hand-weeded at a cost of up to $100 per acre (Ferrell, 2013). 

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While these changes are positive in that they diversify weed control, the cost of these treatments 

poses a substantive threat to soybean production in this region.

In addition to increased tillage, growers are also using pre-plant burndown treatments with 

multiple herbicides on their minimum-till acres and are using residual herbicides more frequently 

(Prince et al., 2012b). They also are moving to multiple herbicide applications, and are applying 

herbicides with several different sites of action at different times over the course of the season to 

eliminate weeds (including some HR biotypes). In an Iowa poll, farmers reported that 60 percent

of the time, they used multiple herbicide modes of action (Arbuckle and Lasley, 2013). 

Increasingly, herbicide suppliers offer multiple herbicides as pre-mixes (Owen, 2014a). These 

might include both 2,4-D and glyphosate as recommended in these regions by extension 

herbicide specialists (Hartzler, 2014b).

Extension weed scientists estimated the increased cost of the additional herbicides needed to 

control glyphosate-resistant weeds in soybean to be as much as $42/acre (for Palmer amaranth in 

Tennessee), with most estimates of the increased costs falling in the range of $20 to $30/acre 

(Carpenter et al., 2002). These costs will vary depending on the specific weed species present in 

any particular field. However, as resistance to glyphosate and other herbicides has developed and 

spread in weed populations, these costs may have increased since these estimates were made. For 

example, there are waterhemp populations in Iowa corn and soybean production fields with 

resistance to five herbicide sites of action (see (Owen, 2012)).

The continued selection of weeds resistant to glyphosate and other herbicides used will continue 

under the No Action Alternative. As such, crop management practices will require modifications 

to address these weeds. These include management practices including the use of alternative

herbicides for weed control, as well as mechanical cultivation practices, and crop rotation

(Benbrook, 2009; Norsworthy et al., 2012). Under the No Action Alternative, it is likely that the 

cost of weed management and the time spent managing weeds will continue to increase.

Organic Production Systems

Under the No Action Alternative, the current availability of GE, non-GE, and organic cotton and 

soybean would remain unchanged from what it is currently in the U.S. Organic seed producers 

would continue to utilize the same methods as applied in certified seed production systems 

designed to maintain soybean and cotton seed identity and meet National Organic Standards as 

established by the NOP. Production costs associated with organic systems will also generally be 

higher than conventional systems, resulting in higher pricing for organic cotton compared to 

conventional cotton.

The USDA census of organic agriculture reported organic cotton farming on 30 farms in the U.S. 

in 2008, two in Arizona, three in New Mexico, four in California, and 21 in Texas (USDANASS, 2008a). Texas (66 percent) and New Mexico (20 percent) together accounted for 

approximately 86 percent of the production. Based on USDA Economic Research Service (ERS)

data, between 1997 and 2008, organic cotton acreage ranged from 9,213 acres in 2004 to 15,377 

acres in 2008 (USDA-ERS, 2008). In 2008 about 0.16 percent of the total 9.41 million acres of 

cotton was produced organically (USDA-ERS, 2008). In recent years, small and sporadic 

acreages of organic cotton production have been cultivated in other states, including Missouri, 

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Illinois, Kansas, Tennessee, and Colorado (USDA-ERS, 2010). As of 2012, the U.S. was the 

sixth-ranking producer of organic cotton in the world, behind India, Syria, Turkey, China, and 

Tanzania (Memon, 2012). Based upon recent trend information, the presence of GE cotton 

varieties on the market has not affected the ability of organic production systems to maintain 

their market share. Between 2000 and 2008, although 11 GE cotton events were no longer 

subject to regulation under the PPA and 7 CFR part 340, the acreage of organic cotton 

production remained at approximately 15,000 acres (USDA-ERS, 2008; USDA-APHIS, 2014c).

Organic soybean production practices include crop rotation, use of cover crops, green and animal 

manures, application of rock minerals such as lime, other soil additives, mechanical weed 

control, biological control of pests, and disease control primarily through management practices

(Kuepper, 2003; (CAST), 2009; USDA-AMS, 2011b). Organic soybean was produced on 96,080 

acres in 2011 and yielded 2.9 million bushels, equal to approximately 0.09 percent of U.S. 

soybean production (USDA-NASS, 2013d). The average yield was 30 bushels per acre. Major 

production states are Iowa, Minnesota, Michigan, New York, Illinois, Nebraska, and Wisconsin 

(USDA-NASS, 2012a). Based upon recent trend information, the presence of GE soybean

varieties on the market has not affected the ability of organic production systems to maintain 

their market share.

All producers of organic or specialty crops must address the potential for cross-pollination with 

undesired varieties, which may include GE varieties. Methods such as isolation distances, use of 

border or barrier rows, and differing planting schedules are used by producers of specialty crops 

to prevent unwanted material from entering their fields (Wozniak, 2002; NCAT, 2003; 

Bradford, 2006; Thomison, 2009; Roth, 2011). Several categories of specialty soybeans are 

currently grown in the U.S. and marketed both domestically and internationally. Producers of 

organic and other specialty soybeans currently have production and handling procedures in place 

to ensure that their product meets standards specified either in the USDA NOP regulations or 

through contracts, as relevant.

Organic and other non-GE specialty soybeans offer consumers the option of choosing non-GE 

products if that is their preference. The consumer reaction to GE crops since their 

commercialization has been well researched, particularly as to whether consumers would prefer 

non-GE and whether they support labeling of foods containing GE ingredients. The hundreds of 

surveys that have been done over the years present contradictory evidence, likely due to 

differences in sampling techniques, the survey instruments used, and the way questions are 

framed (Kalaitzandonakes et al., 2005). Further, preferences expressed in surveys may not be 

consistent with actual purchasing behavior (Fernandez-Cornejo and Caswell, 2006). For 

example, a study of consumers in the Netherlands from 1997 to 2000, a period of time during 

which GE ingredients were required to be labeled and similar products were available to 

consumers with and without GE ingredients, showed no major changes in purchasing behavior 

with respect to the GE-labeled products (Kalaitzandonakes et al., 2005).

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4.1.4 Health and Safety for Livestock and Humans

Humans Health

Under the No Action Alternative, MON 88701 cotton and MON 87708 soybean would continue 

as a regulated article under APHIS. Grower exposure to these products would be limited to 

individuals involved in the cultivation under regulated conditions. Cotton and soybean growers 

and farm workers will continue to be exposed to existing traditional and GE cotton and soybean 

varieties and their respective cultivation practices. 

Under the No Action Alternative, human exposure to existing conventional non-GE and GE 

cotton and soybean varieties and their products is not expected to change. Ninety percent of 

cotton and 93 percent of soybean grown in the U.S. in 2013 was GE (USDA-ERS, 2014a). 

Human health concerns associated with GE crops include the potential toxicity of the introduced 

genes and their products, the expression of new antigenic proteins, and/or altered levels of 

existing allergens (Malarkey, 2003; Dona and Arvanitoyannis, 2009). GE crops are subjected to 

far greater levels of scrutiny than foods produced by traditional plant breeding techniques. They 

are assessed for the potential toxicity of the introduced genes and their products, and for altered 

levels of existing allergens, to assure that a GE food is as safe and nutritious as its conventional 

counterpart (Malarkey, 2003). FDA has no further questions that MON 87708 soybean and 

MON 88701 cotton are as safe as conventional soybean and cotton for consumption by humans 

and animals. Furthermore, there is a broad consensus among scientific professionals with 

expertise in assessing risks associated with the safety of food, feed and fiber derived from GE 

crops that they are no different from those derived from non-GE crop varieties.

Under the FFDCA, it is the responsibility of food and feed manufacturers to ensure that the 

products they market are safe and labeled properly. Food and feed derived from GE organism 

must be in compliance with all applicable legal and regulatory requirements. GE organisms for 

food and feed may undergo a voluntary consultation process with the FDA prior to release onto 

the market. As described in Section 1.4.2, MON 88701 cotton contains the phosphinothricin Nacetyltransferase (PAT) protein, conferring resistance to glufosinate. FDA has previously 

reviewed submissions regarding the safety of food and feed derived from crops containing the 

pat gene (BNFs 000055 (soybean), 000073 (corn), 000081 (corn), 000085 (cotton), and 000092

(cotton)). The PAT protein is considered to be safe for consumption by humans and animals.

Both cotton and soybean (and other crops) containing the pat gene are already in commerce and 

this exposure is expected to continue under the No Action Alternative.

The greatest risk to human (worker) safety in agriculture is associated with physical injuries

usually occurring during the maintenance and use of farm machinery. Cuts, bruises, loss of 

fingers and limbs are examples of injuries resulting from mechanical hazards. Physical injuries 

resulting from maintenance and use of farm machinery are unlikely to change in frequency or 

severity if the No Action Alternative is adopted.

Cotton and soybean growers and farmworkers may be exposed to a variety of EPA-registered 

pesticides in both GE and non-GE production systems. Herbicide use may increase to meet the 

need for additional integrated weed management tactics to mitigate herbicide-resistant weeds in 

different cropping systems (Owen and Zelaya, 2005; Culpepper, 2008; Owen, 2008; Heap, 

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2014d). However, worker safety is taken into consideration when a pesticide label is developed 

during the EPA registration process. When use is consistent with the label, pesticides present 

minimal risk to the worker. No changes to current worker safety are anticipated under the No 

Action Alternative.

Animal Feed

Under the No Action Alternative, MON 88701 cotton and MON 87708 soybean would continue 

as regulated articles under APHIS. Under the No Action Alternative, livestock exposure to 

cotton and soybean would continue to be limited to currently-available varieties, including nonGE and GE varieties.

Processing of cotton generally provides cottonseed meal, cottonseed hulls, and whole cottonseed 

to be utilized in the animal feed industry as sources of protein, fiber and energy (NCPA, 2002; 

OECD, 2009a). The value of cottonseed as animal feed represents a substantial portion of the 

grower’s income from cotton (Blasi and Drouillard, 2002).

Cottonseed meal, which makes up over a third of the value of cottonseed, is an excellent source 

of protein for ruminant animals and is widely used in animal feed (Blasi and Drouillard, 2002; 

Calhoun, 2011). Cottonseed contains the anti-nutrients gossypol and cyclopropenoid fatty acids. 

Gossypol helps protect the cotton plant from pathogens, but is an anti-nutrient for which 

sensitivity is species-dependent. Gossypol is also toxic to some species (Gadberry, 2011).

The cottonseed hull is the tough, protective covering of the cottonseed that is removed prior to 

processing the seed for oil and meal. It is used as feed for livestock and can be an economical 

roughage that provides fiber, as well as serving as a good carrier for cottonseed meal and grain 

(NCPA, 2002). Gin by-products, the dried plant material cleaned from the fiber during ginning, 

is also used as a source of roughage for livestock feeds.

Cottonseed is typically fed to ruminants (i.e., cattle), because they have a relatively low 

sensitivity to gossypol and can tolerate moderate gossypol inclusion in their diets. Highly 

processed cottonseed meal is also fed to non-ruminant farm animals in limited quantities (OECD, 

2009b). Cyclopropenoid fatty acids interfere with the metabolism of saturated fats (Rolph et al., 

1990; Cao et al., 1993) and reportedly have adverse effects on egg yolk discoloration and 

reduced hatchability in chickens (OECD, 2004; Lordelo et al., 2007; OECD, 2008b).

Soybeans yield both solid (meal) and liquid (oil) products. Soybean meal is high in protein and is 

used for products such as tofu, soymilk, meat replacements, and protein powder; it also provides 

a natural source of dietary fiber (USB, 2009). However, anti-nutrients commonly found in raw 

soybean also include trypsin inhibitors and lectins (US-FDA, 2011a). Routine processing in 

moist heat inactivates these anti-nutrients (US-FDA, 2011a).

Nearly 98 percent of soybean meal produced in the U.S. is used as animal feed (Soyatech, 2011). 

Poultry consume more than 45 percent of domestic soybean meal or 590 million bushels of the 

U.S. soybean crop, with soy oil increasingly replacing animal fats and oils in broiler diets (USB, 

2011). Soybean can be the dominant component of livestock diets, such as in poultry, where 

upwards of 66 percent of their protein intake is derived from soy (Waldroup and Smith, 2008). 

Other animals fed domestic soybean (by crop volumes consumed) include swine (26 percent), 

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beef cattle (12 percent), dairy cattle (9 percent), other (e.g., poultry, farm-raised fish) (3 percent), 

and household pets (2 percent) (Soy Stats, 2010; USB, 2011).

Although the soybean market is dominated by seed production, soybean has a long history in the 

U.S. as a nutritious grazing forage, hay, and silage crop for livestock (Blount et al., 2009). 

Varieties of soybean have been developed specifically for grazing and hay, but use of the 

standard grain varieties is recommended by some because of the whole plant feeding value 

(Weiderholt and Albrecht, 2003).

Non-GE cotton and soybean varieties, both those developed for conventional use and for use in 

organic production systems, are not routinely required to be evaluated by any regulatory agency 

in the U.S. for animal feed safety prior to release in the market. Under the FFDCA, it is the 

responsibility of food and feed manufacturers to ensure that the products they market are safe 

and properly labeled. Food and feed derived from any GE crop event must be in compliance with 

all applicable legal and regulatory requirements.

Animal feed safety reviews frequently compare the compositional characteristics of the GE crop 

with non-transgenic, conventional varieties of that crop (Aumaitre et al., 2002; FAO, 2009). This 

comparison also evaluates the composition of the modified crop under actual agronomic 

conditions, including various agronomic inputs (Herman et al., 2010). Composition 

characteristics evaluated in these comparative tests include moisture, protein, fat, carbohydrates, 

ash, minerals, dietary fiber, essential and non-essential amino acids, fatty acids, vitamins, and 

anti-nutrients (Herman et al., 2010).

GE organisms for food and feed typically undergo a voluntary consultation process with the 

FDA prior to release onto the market. Although a voluntary process, to date, all applicants 

proposing to commercialize a GE variety that would be included in the food supply have 

completed a consultation with the FDA. In a consultation, a developer who intends to 

commercialize a bioengineered food meets with the FDA to identify and discuss relevant safety, 

nutritional, or other regulatory issues regarding the bioengineered food and then submits to the 

FDA a summary of its scientific and regulatory assessment of the food. This process includes: 1) 

an evaluation of the amino acid sequence introduced into the food crop to confirm whether the 

protein is related to known toxins and allergens; 2) an assessment of the protein’s potential for 

digestion; 3) an evaluation of the history of safe use in food (Hammond and Jez, 2011). The 

FDA evaluates the submission and responds to the developer by letter with any concerns it may 

have or additional information it may require.

Most of the cotton and soybean currently grown in the U.S. is GE (USDA-NASS, 2006), and this 

market share is expected to continue under the No Action Alternative. Livestock are routinely 

exposed to GE cotton and soybean in animal feed. All currently-available GE cotton and soybean 

varieties used in animal feed are considered safe for animal consumption and this is unlikely to 

change under the No Action Alternative. 

4.1.5 Animal Communities

Under the No Action Alternative, MON 88701 cotton and MON 87708 soybean would continue 

to be regulated by APHIS. The current availability and use of commercially cultivated soybean 

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and cotton, including conventional and GE varieties, would be unaffected under this alternative. 

Herbicide use may increase to meet the need for additional integrated weed management tactics

to mitigate HR weeds in different cropping systems (Owen and Zelaya, 2005; Culpepper, 2008; 

Heap, 2014d), which may adversely impact wildlife and habitats. Most growers strive to cultivate 

a single plant species in a field while excluding all other plant species to maximize yield and 

increase ease in cultivation and harvesting. As a result, using herbicides in agricultural fields 

directly decreases plant biodiversity, and indirectly reduces the resources available to animals for 

habitat and food. Herbicides are used on 98 percent of soybean acreage (USDA-NASS, 2013a)

and on greater than 99 percent of cotton acres (USDA-NASS, 2011b).

Growers choose pesticides based on weed, insect and disease pressures, cost of seed and other

inputs, technology fees, human safety, potential for crop injury, and ease and flexibility of the

production system (Heiniger, 2000; Farnham, 2001). Agricultural production of cotton and

soybean uses EPA-registered pesticides, including dicamba and glufosinate, for weed

management. The environmental risks of pesticide use on wildlife and wildlife habitat are 

assessed by the EPA during the pesticide registration process, and are regularly reevaluated by the 

EPA for each pesticide to maintain its registered status under FIFRA.

Additional integrated weed management tactics may impact the adoption of conservation tillage

practices. Under the No Action Alternative, if tillage rates increase as a means of weed

suppression, then increases in soil erosion are expected, and this could adversely impact wildlife 

habitat. In contrast, increased use of cover crops may create beneficial impacts on wildlife by

providing habitat and food. 

The widespread use of conservation tillage and no-till practices, especially in association with the

planting of GE HR soybean varieties, benefitted wildlife through improved water quality,

availability of waste grain, retention of cover in fields, and increased populations of invertebrates

(Brady, 2007; Sharpe, 2010a). Conservation tillage practices that leave crop residue serve to 

increase the diversity and density of birds and mammals in agricultural fields (USDA-NRCS, 

1999a). Increased residue also provides habitat for insects and other arthropods. This increases

food sources for insect predators. Insects are important for many upland game birds and other 

birds during the spring and summer brood-rearing season because they provide a protein-rich diet

for their fast-growing young A nutrient-rich diet also benefits migratory birds (USDA-NRCS, 

2003). If growers abandon conservation tillage practices, then these benefits to wildlife may be 

lost.

Changes to crop management practices may create both beneficial and adverse effects on 

biological resources, but their net impact on biological resources under the No Action Alternative

is unknown.

4.1.6 Plant Communities

Weeds are commonly found in cotton and soybean fields and if not controlled can substantially

decrease yields. The most problematic weeds of each crop are shown in Appendix 5. Appendix 3

lists three categories of weeds: annual broadleaf weeds, annual grass weeds, and perennial 

weeds. In summary, common weeds in cotton fields include barnyardgrass, crabgrass, pigweed 

species (including Palmer amaranth), morning glory spp., common cocklebur, and common 

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lambsquarters. These are common annual weed species in almost all cotton-growing regions. 

Johnsongrass, bermudagrass, and nutsedge are common perennial weed species.

Weeds in soybean include: foxtail, pigweed, velvetleaf, lambsquarters, and cocklebur, which are 

common weeds in Midwestern soybean fields. Certain growers in Indiana have reported giant 

ragweed, lambsquarters, Canada thistle, cocklebur, and velvetleaf to be difficult-to-control weeds 

in soybean (Nice and Johnson, 2005). Giant and/or common ragweed are also common and 

problematic in Minnesota, Missouri, Arkansas, Wisconsin and Illinois (Iowa-State-University, 

2003; Andersen et al., 2004; Boerboom, 2006). In a 2005-2006 survey of 1,200 growers of GR

crops (e.g., soybean, corn and cotton) in six Midwestern and Southern states, growers classified 

these as most difficult to control (Kruger et al., 2009). Waterhemp is also reported to be 

problematic in Minnesota, Indiana, Nebraska, Wisconsin and Missouri (Iowa-State-University, 

2003; Andersen et al., 2004; Boerboom, 2006; Kruger et al., 2009; Legleiter et al., 2009). 

Horseweed has been reported to be problematic in Ohio, Arkansas, Tennessee, Kansas, 

Wisconsin and Illinois (Mueller et al., 2005; Boerboom, 2006; Peterson and D., 2012).

Among these three categories, annual broadleaf weeds include the species that have become 

most difficult to control due to the selection of HR biotypes10. For example, velvetleaf and 

lambsquarters are both somewhat tolerant of glyphosate and also for some species such as 

pigweed, waterhemp, ragweed, and kochia, GR biotypes have been selected (Heap, 2014d). 

Species such as waterhemp have developed resistance to as many as five different herbicide sites 

of action (Owen, 2012). Annual grass weeds that inhabit soybean fields are still largely 

controlled by glyphosate. Foxtail is an important weed actively managed on almost all acreage 

used for soybeans. Perennial weeds are particularly difficult to control because they can survive 

for more than two years and can regrow every year from rhizomes. Among the perennial weeds, 

biotypes of Johnsongrass have been selected for glyphosate resistance.

In 2012, the area of U.S. cropland infested with GR weeds expanded to 61 million acres, 

according to a survey conducted by Stratus Agri-Marketing (Farm Industry News, 2013). At 

present, dicamba-resistant and glufosinate-resistant weeds account for <1 percent and 0.5 percent

of resistant biotypes, respectively (Heap, 2014a). No dicamba-resistant populations have been 

reported in the main soybean production areas, including the Midwest, the South and the East 

Coast of the U.S. Additional discussion of HR weeds can be found in Appendix 6.

Soybean is not listed as a weed in major weed references, nor is it present on the lists of noxious 

weed species distributed by the federal government (7 CFR part 360). Modern soybean 

harvesting equipment is efficient, so few seeds remain in soybean fields following harvest. 

Therefore, volunteer soybeans are typically not a problem in subsequent crops rotated with 

soybeans. Even when volunteer soybeans occur they do not compete well with other crops and 

10 Plants of a given species are not identical, but are made up of “biotypes” with various genetic traits. Within a 

weed species, individuals may possess an inherent ability to withstand the effects of a particular herbicide. Repeated 

use of that herbicide in the absence of other weed control herbicides or practices has the potential to expose the 

weed population to a “selection pressure,” which may potentially lead to an increase in the number of surviving 

resistant biotypes in the population (Herbicide-Resistance-Action-Committee, 2013). Herbicide resistance is 

discussed in more detail in Appendix 6 of the EIS.

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are easily controlled with common agronomic practices. Volunteer soybeans are limited by the 

geography in which soybean is planted. Soybean requires specific environmental conditions to 

grow as a volunteer (OECD, 2000). Mature soybean seeds are sensitive to cold and rarely

survive in freezing winter conditions (Raper and Kramer, 1987). Volunteer soybeans can occur 

in regions with warmer climates where temperature and moisture conditions are suitable for 

viability and germination can occur year-round, such as the Mississippi Delta and the southeast

U.S. (Zapiola et al., 2008). For volunteer soybean emerging after planting, shallow cultivation or

use of another herbicide will control volunteers and effectively reduce competition with the crop. 

Several post-emergence herbicides are also available to control volunteer soybean (either

conventional or herbicide-tolerant soybean) in each of the major soybean rotational crops

(Monsanto, 2013a).

With regard to volunteer cotton, volunteer cotton populations can be managed (Fromme et al., 

2010; Morgan et al., 2011) and feral populations occur rarely in the U.S. Cotton Belt (Wozniak, 

2002). Cotton is not listed as a weed in major weed references, nor is it present on the lists of 

noxious weed species distributed by the federal government (7 CFR part 360). Cotton does not 

possess any of the attributes commonly associated with weeds, such as long persistence of the 

seed in the soil, ability to disperse, invade, or become a dominant species in new or diverse 

landscapes, or the ability to compete well with native vegetation. It is recognized that in some 

agricultural systems, cotton can volunteer in a subsequent rotational crop. However, volunteers 

are easily controlled through tillage or the use of appropriate herbicides with diverse modes-ofaction (e.g., ALS inhibitor, chloroacetamide, 5-enolpyruvylshikimate-3-phosphate synthase

(EPSPS), PPO inhibitor, Photosystem I (PSI) disruption, Photosystem II (PSII) inhibitor, 

synthetic auxin, and tubulin inhibitor classes) (Monsanto, 2013a).

Volunteer cotton is an issue for growers when much seed may germinate in a spring crop after a 

dry fall (Fromme et al., 2010). Following harvest, cotton volunteers are an important issue, 

because most cotton-producing states have an active Boll Weevil Eradication Program, one of 

whose goals is to destroy cotton so that it cannot persist after harvest and support weevil growth. 

These programs are directed by various state and regional organizations. Directives from the

Program authorities for support of weevil control measures are enforced by state laws and 

authorities. Cotton producers must destroy cotton stalks after cotton harvest for successful boll 

weevil eradication, which focuses on removal of over-wintering habitat and breeding sites for 

boll weevils. Growers must destroy cotton stalks by a published date each year. Growers remove 

these cotton stalks by applying the herbicide 2-4,D and additionally may shred cotton stalks

(Robertson et al., 2002). 

4.1.7 Soil Microorganisms

Under the No Action Alternative, MON 87708 soybean and MON 88701 cotton would continue 

to be regulated by APHIS. Agricultural practices such as pesticide applications and tillage are 

known to impact soil microbial populations, species composition, colonization, and associated 

biochemical processes. The use of these practices from what is currently practiced today is 

unlikely to change under the No Action Alternative.

Growers inoculating soybean fields with Bradyrhizobium japonicum bacteria experience 

increased yields (Conley and Christmas, 2005). In 2009, the industry estimated that one-third of 

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U.S. soybean acreage was inoculated (Seed Today, 2009). Under the No Action Alternative, the 

use of inoculates is unlikely to change from the current use, unless new or improved strains

become available.

4.1.8 Water 

If drought conditions west of the Mississippi continue, then abandonment rates for cotton appear 

likely to increase. Cotton prices are expected to fall less than competing crops which makes 

planting cotton relatively more attractive to growers. Stronger soybean prices relative to corn 

should also favor soybean plantings in 2014 (USDA-OCE, 2014a). Corn and soybeans generally 

require less water than cotton (see Table 14 on comparative water needs) (Brouwer and 

Heibloem, 1986)

Table 14. Comparison of Water Needs and Drought Sensitivity for Some Globally 

Important Crops.

Crop

Minimum-maximum water 

(mm needed over total growing 

period)

Sensitivity to drought

Alfalfa 800-1600 low-medium

Citrus 900-1200 low-medium

Cotton 700-1300 low

Corn (Maize) 500-800 medium-high

Soybean 450-700 low-medium

Sugarbeet 550-750 low-medium

Sugarcane 1500-2500 high

Sunflower 600-1000 low-medium

Tomato 400-800 medium-high

Source: (Brouwer and Heibloem, 1986)

USDA projections indicate that demands on agricultural water supplies are likely to increase 

over time as alternative nonfarm uses of water continue to grow. Potential Native American 

water-right claims were estimated at nearly 46 million acre-feet annually and could impact the 

distribution and cost of irrigation water in the West. For many states, the scope of water demands 

for the environment have expanded from a minimum in-stream flow to an “environmental-flows” 

standard (i.e., a concept requiring water to meet the needs for water quality, but to also 

rehabilitate ecosystem habitats). Energy-sector growth is expected to substantially increase water 

demands for an expanding biofuels sector, utility-scale development of solar power, innovation 

in thermoelectric generating capacity, and commercial oil-shale and deep shale natural gas 

development (Schaible and Aillery, 2012a).

Projected climate change—through warming temperatures, shifting precipitation patterns, and 

reduced snowpack—is expected to reduce water supplies and increase water demand across 

much of the West. These trends are placing greater pressure on existing water allocations, 

heightening the importance of U.S. water management and conservation for the sustainability of 

irrigated agriculture (Schaible and Aillery, 2012a). Expansion in competing areas of national 

water demand may present U.S. cotton and soybean producers with more difficult farming 

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decisions and fewer socioeconomic options (e.g., whether to purchase enough water for a crop, 

or to clear or even sell land).

Under the No Action Alternative, water allotment for agricultural use is expected to be restricted 

as demand for water increases globally. Pressure for the conservation of existing surface water 

and groundwater resources is expected to increase. In areas where increased tillage is used to 

control weeds and soil erosion, water may be more likely to be impacted by sediments in 

agricultural runoff (Fawcett and Towery).

4.1.9 Air Quality

Agricultural activities such as the use of tillage, pesticides, prescribed burning, and farm 

equipment can all effect air quality. Growers choose those activities that are most suited for their 

operations. To manage weeds growers may use a combination of activities including pesticide 

use. In some areas, tillage is increasing as growers use tillage to manage herbicide-resistant 

weeds. This activity affects air as particulate matter can increase with increasing tillage. Also 

conventional tillage can use more fossil fuels than conservation tillage methods, resulting in 

emission of air pollutants from fossil fuel combustion. Under the No Action Alternative, these 

potential emissions may cause some transient impacts to local air quality. These impacts are

unlikely to affect areas with impaired air quality because of the potential for chemical dispersion 

in air currents and the relatively large distances from agricultural production areas to areas under 

air quality management plans, which generally encompass urban areas.

4.1.10 Climate Change

Under the No Action Alternative, cropping practices to manage weeds will likely increase in 

intensity. Increases in herbicide applications or the use of tillage would increase the contribution 

of cotton and soybean cultivation to GHG emissions. This increase would occur from the 

combustion of fossil fuels for equipment used to apply herbicides and to till fields. The 

manufacture of herbicides may also contribute to the release of greenhouse gases, but the overall 

contribution is likely to be minor. The magnitude of the effect will depend on the HR weed 

management practices that growers choose to use. 

4.2 Preferred Alternative

Under the Preferred Alternative, MON 88701 cotton and MON 87708 soybean would not be 

regulated by APHIS. MON 88701 cotton has increased resistance to the herbicides dicamba and 

glufosinate. MON 87708 soybean has increased resistance to the herbicide dicamba. As with 

other deregulated GE crop varieties, if these dicamba-resistant varieties are no longer regulated 

they would also be available for cross-breeding with all other GE varieties that are no longer 

regulated by APHIS and non-GE cultivars. Monsanto intends to cross MON 87708 soybean with 

MON 89788 (Roundup Ready 2 Yield soybean) utilizing traditional breeding techniques, 

producing a soybean variety with resistance to both dicamba and glyphosate (Monsanto, 2012a)

(see Section 1.4.1). Monsanto has indicated MON 88701 cotton will be stacked with Roundup 

Ready Flex Cotton and Bollgard II (MON 88913 and MON 15985), resulting in a cotton variety 

with resistance to dicamba, glufosinate, and glyphosate, as well as protection against feeding by

a range of Lepidopteran species (see Section 1.4.2 for more details) (Monsanto, 2013a). More 

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commercially available GE cotton and soybean varieties provide growers with more choices and 

additional tools for weed management. Growers may adopt these new varieties where HR weeds 

already are present. Continued use of commercially available GE cotton and soybean varieties is 

expected if the varieties meet grower needs.

4.2.1 Land Use

Under the Preferred Alternative there would be no direct or indirect effects on land use resulting 

from the decision to approve the petitions. The drivers of land used for cotton and soybean 

production include the price of cotton and soybean and the suitability of the land for this 

production. The decision to approve these petitions will not affect these factors. 

In 2014, GE cotton and soybean, including stacked and herbicide-resistant varieties, covered

approximately 96 and 94 percent, respectively, of the total acreage planted to cotton and soybean

in the U.S. (USDA-ERS, 2014d). Under the Preferred Alternative, it is not anticipated that the 

availability of MON 88701 cotton and MON 87708 soybean will chance the acreage of GE 

cotton or GE soybean as compared to the No Action Alternative.

4.2.2 Socioeconomics

Domestic Cotton and Soybean Production

According to the petitions submitted by Monsanto, MON 88701 cotton and MON 87708 soybean

are compositionally similar to currently available varieties of cotton and soybean, respectively. 

These events would be suitable for use in food, feed, and industrial applications of cotton and 

soybean products. Therefore, the use of these events in cotton or soybean processes would not 

change when compared to the No Action Alternative.

Foreign Trade

A determination of nonregulated status of MON 88701 cotton and MON 87708 soybean is not 

expected to adversely impact trade under the Preferred Alternative. Although the primary U.S. 

cotton and soybean export destinations do not present major barriers to trade in GE products, 

Monsanto would need to obtain approval of MON 88701 cotton and MON 87708 soybean in 

destination countries before commercialization to avoid adversely affecting current trade flows. 

As a result, Monsanto has requested import approval of MON 88701 cotton and MON 87708 

soybean in key export markets of the U.S. that have functioning regulatory systems. These 

include, but are not limited to: Canada, Mexico, Japan, the EU, South Korea, and China 

(Monsanto, 2013a). The regulatory status of these events is summarized in Table 15 and Table 

16.

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Table 15. Status of Import Approvals of MON 88701 Cotton in Key U.S. Cotton 

Export Markets.

MON 88701 Cotton MON 88701 Cotton Stacks1,2

Country Submission Approval Submission Approval

Canada June 2012 June 2014 June 2014

September 

2014

Mexico May 2013 In review June 2013 -

Japan November 2012 In review June 2013 In review

Korea October 2012 In review Not yet submitted -

Australia January 2013 January 

2014 NA -

EU February 2013 In review Not yet submitted -

China Not yet submitted - NA

Philippines Not yet submitted - Not yet submitted -

Source: (Monsanto, 2013a)

Definitions: EU = European Union; NA = Not Applicable

1

 MON 88701 cotton will be stacked with Roundup Ready Flex Cotton and Bollgard II (MON 88913 and 

MON 15985). 2

 Progeny (breeding stacks) of GE crops are not regulated by APHIS.

Table 16. Status of Import Approvals of MON 87708 Soybean in Key U.S. Soybean 

Export Markets.

MON 87708 Soybean MON 87708 Soybean Stack1,2

Country Submission Approval Submission Approval

Canada November 2010 October 2012 November 2012 January 2013

Mexico November 2011 July 2012 June 2012 February 2013

Japan March 2011 October 2013 September 2012 February 2014

Korea February 2011 October 2013 January 2013 June 2014

Australia May 2011 May 2012 NA

EU January 2011 In review March 2012 In review

China October 2012 In review NA

Taiwan March 2011 April 2013 April 2013 In review

India April 2013 April 2013 April 2013 September 2014

Source: (Monsanto, 2013a)

Definitions: EU = European Union; NA = Not Applicable

1 MON 87708 soybean will be stacked with Roundup Ready 2 Yield (MON 89788). 2 Progeny (breeding stacks) of GE crops are not regulated by APHIS.

4.2.3 Agronomic Practices in Cotton and Soybean Production

Under the Preferred Alternative, there would be no direct or indirect effect on cotton or soybean 

agronomic practices or the cost of production as a result of deregulation of MON 88701 cotton 

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and MON 87708 soybean. Under this alternative, growers would be able to plant MON 88701 

cotton and MON 87708 soybean, but would not be able to make applications of dicamba other 

than currently approved by the EPA. The new post-emergent use of dicamba on these cotton or 

soybean events is not permitted until the EPA approves the new uses. Glufosinate use is allowed 

on GE cotton and soybean containing the LibertyLink® glufosinate-resistance traits. It is 

assumed that glufosinate will be able to be used on deregulated MON 88701 cotton varieties.

Therefore, the types of agronomic practices used to cultivate these cotton and soybean varieties, 

such as tillage, crop rotation, fertilization, and pesticide use, would be similar to those currently 

used. Growers would continue to manage weeds using a combination of chemical and cultural 

methods described in the No Action Alternative and Appendix 3. Under the Preferred 

Alternative, similar to the No Action Alternative, growers may continue to rely on glyphosate 

and glufosinate to manage weeds in cotton and soybean. Weed scientists will continue to 

encourage growers to use best management practices.

Organic Production Systems

Under the Preferred Alternative, there are no major impacts anticipated to organic cotton or 

soybean production systems beyond what may be already occurring under the No Action 

Alternative. As stated above in Section 3.5.4, USDA recognizes the importance for coexistence 

for all agricultural production systems, and has several initiatives in place focused on unintended 

presence.

Under the Preferred Alternative, MON 88701 cotton and MON 87708 soybean would not be 

regulated by APHIS and would be available for growers to adopt. Both MON 88701 cotton and 

MON 87708 soybean are not anticipated to increase acreage of GE cotton or GE soybean, as 

growers already cultivating GE cotton or soybean are the growers most likely to adopt MON 

88701 cotton and MON 87708 soybean, respectively. Therefore, isolation practices of organic 

growers that are already in place in their production systems would not need to change due to the 

introduction of these cotton and soybean varieties. GE GR soybean and cotton varieties are 

already extensively grown (93 percent of all soybean acres and 90 percent of all cotton acres

(USDA-NASS, 2013c)), while organic soybean and cotton production represents a small 

percentage of the total U.S. soybean and cotton acreage. Similar to the No Action Alternative, 

combined organic soybean and cotton acreage is likely to remain small, regardless of whether 

new varieties of GE or non-GE cotton and soybean, including MON 88701 cotton and MON 

87708 soybean, become available for commercial production.

When compared to other GE varieties of soybean and cotton, MON 88701 cotton and MON 

87708 soybean should not present any new or different issues and impacts for organic and other 

specialty producers and consumers. Organic producers manage identity and preserve the integrity 

of organic production systems utilizing various measures (Guerena and Sullivan, 2003). 

Agronomic tests conducted by Monsanto found MON 88701 cotton and MON 87708 soybean to 

be substantially equivalent to the non-GE control variety. Therefore, pollination characteristics 

would be similar to other soybean varieties currently available to growers (USDA-APHIS, 

2014a; 2014b). As stated above, isolation practices that organic producers are currently using 

whether spatial or temporal would not be affected by the nonregulated status of these products. 

Because cotton and soybean are largely self-pollinating, there is limited pollen movement, so

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organic farmers are not expected to be affected by a determination of nonregulated status of 

MON 88701 cotton and MON 87708 soybean. Agronomic practices used in organic cotton and 

soybean production would remain unaffected by selection of the Preferred Alternative.

4.2.4 Health and Safety for Livestock and Humans

Worker Safety

APHIS has not identified any direct or indirect adverse effects on worker safety associated with 

the selection of the Preferred Alternative. Existing hazards to workers occurring through the 

various management practices that are used to grow cotton and soybean are expected to continue.

Workers will continue to use farm equipment and agricultural chemicals. The decision to 

approve the two petitions does not authorize a change in herbicide use on these cotton or soybean 

varieties. The EPA regulates the use of herbicides under FIFRA and considers the effects on 

human health when approving the use of herbicides (See Appendix 8 for a summary of the 

EPA’s human health assessment of the proposed new uses of dicamba on these GE crop 

varieties).

Food and Feed

The direct and indirect effects on food and feed will not be different under the Preferred 

Alternative when compared to the No Action Alternative. People and livestock will continue to 

consume GE cotton and soy based-products, as well as animal products from livestock fed cotton 

and soy products. As described in the petition, MON 88701 cotton and MON 87708 soybean are 

compositionally similar to currently available varieties of cotton and soybean. Therefore, they 

are not expected to have different nutritional qualities than other available cotton or soybean

varieties.

Monsanto provided the FDA with information on the identity, function, and characterization of 

the genes in MON 88701 cotton and MON 87708 soybean. The FDA evaluated the information 

in Monsanto’s submissions to ensure that regulatory and safety issues regarding the human food 

and animal feed from the new plant varieties have been resolved prior to commercial 

distribution. Consultations with the FDA for MON 88701 cotton (US-FDA, 2013) and MON 

87708 soybean (US-FDA, 2011b) have been completed and the FDA has no further questions 

about food and feed derived from these cotton and soybean varieties.

No potential impacts to the safety of people and livestock are expected to result from exposure to 

the introduced dicamba mono-oxygenase (DMO) and PAT proteins in food and feed derived 

from MON 88701 cotton. Cottonseed, which is a by-product of fiber production, is used in 

human food, animal feed, and a range of industrial products. Food uses of cottonseed include 

cottonseed oil and, to a lesser degree, cotton linters (US-FDA, 2013). Cottonseed oil or refined, 

bleached, and deodorized (RBD) oil is highly refined to remove naturally occurring toxicants, 

gossypol, and cyclopropenoid fatty acids (Reeves and Weihrauch, 1979; US-FDA, 2013). 

Cottonseed oil is primarily consumed as a salad or cooking oil, for frying, in mayonnaise, and 

shortening. Cotton linters are short fibers that remain on cotton seeds after the long fibers have 

been removed at the ginning process for textile manufacturing (US-FDA, 2013). They are 

removed from the seeds and processed into pure cellulose, which is used in casings for bologna, 

sausages, and frankfurters and in ice cream and salad dressings (US-FDA, 2013). 

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Whole cottonseed, cottonseed meal, hulls, and cotton gin trash are used in animal feeds for 

cattle, sheep, goats, horses, poultry, swine, fish, and shrimp. Cottonseed meal is the product 

obtained after removal of oil from whole cottonseed flakes or cake and is used as a protein 

supplement in animal feed. Cottonseed hulls are used as a source of fiber in feeds (US-FDA, 

2013).

RBD oil and linters are processed fractions that contain negligible amounts of total protein 

(Reeves and Weihrauch, 1979). The DMO and PAT proteins represents a very small portion of 

the total protein in the cottonseed of MON 88701 cotton; therefore, no exposure to MON 88701

DMO or PAT proteins is anticipated for food uses of MON 88701 cotton.

During the consultation process, the FDA reviewed information on the identity, function, and 

characterization of the inserted gens and a safety and nutritional assessment of the food and feed

derived from MON 88701 cotton (US-FDA, 2013). Neither the DMO nor PAT proteins have

relevant amino acid sequences similar to known allergens, toxins or other proteins that may have 

adverse effects on mammals. Furthermore, the DMO and PAT proteins in MON 88701 cotton

are rapidly digested in simulated gastric and intestinal fluids, and these studies did not show any 

observable adverse effects in mouse acute oral toxicity analyses (Monsanto, 2013a). A 

compositional analysis of MON 88701 cotton demonstrates that it is comparable with currentlyavailable cotton varieties, further indicating that there would be no negative impact on human or 

livestock health from consumption of MON 88701 cotton in food or feed (Monsanto, 2013a).

The PAT enzyme present in MON 88701 cotton is identical to the wild-type protein produced in 

S. hygroscopicus and is analogous to the PAT proteins in commercially available glufosinateresistant products in several crops including cotton, corn, soybean, and canola (USDA-APHIS, 

2014c). The Organization for Economic Co-operation and Development (OECD) recognizes 

PAT proteins produced from different genes to be equivalent with regard to function and safety 

(OECD, 1999). PAT proteins are structurally similar only to other acetyltransferases known to 

not cause adverse effects after consumption (Herouet et al., 2005). In 1997, a tolerance 

exemption was issued for PAT proteins by the EPA (40 CFR part 180, 1997; CFR Part 180.1151, 

2005). Additionally, the FDA has previously reviewed submissions regarding the safety of food 

and feed derived from crops containing the pat gene (BNFs 000055 (soybean), 000073 (corn), 

000081 (corn), 000085 (cotton), and 000092 (cotton)). Because the PAT protein, expressed in 

MON 88701 cotton and in the crops noted above, has already been reviewed by the FDA and has 

been in commercially produced crops, there are not expected to be any effects on food and feed 

from MON 88701 cotton, when compared to the No Action Alternative.

With respect to MON 87708 soybean, no potential impacts to the safety of people and livestock 

are expected to result from exposure to the introduced DMO protein. Upon deregulation and 

commercialization, soybean and forage produced from MON 87708 soybean would enter the 

food and feed chain and would be consumed by humans and animals. During the consultation 

process on MON 87708 soybean, the FDA reviewed information submitted by Monsanto on the 

safety of the DMO protein, including a dietary risk assessment (US-FDA, 2011b). The DMO 

protein is rapidly digested in simulated gastric and intestinal fluids, and did not show any 

observable adverse effects in mouse acute oral toxicity analyses (Monsanto, 2013a). A 

compositional analysis of MON 87708 soybean demonstrated that it is comparable with 

currently-available soybean varieties, further indicating that there would be no negative impact 

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on human or livestock health from consumption of MON 87708 soybean in food or feed

(Monsanto, 2013a).

4.2.5 Biological Resources

Animal Communities

Under the Preferred Alternative, the direct and indirect effects on wildlife from approving these 

petitions for deregulation would be similar to the effects under the No Action Alternative. 

Wildlife would continue to visit cotton fields on a limited basis with preferences for other 

agricultural fields, including soybean fields. As described in the No Action Alternative, animal 

populations could be indirectly impacted by changes in agricultural practices, such as tillage. 

Increases in tillage to control weeds can increase soil erosion and cause indirect impacts on 

wildlife.

Under the Preferred Alternative, cultivation of MON 88701 cotton or MON 87708 soybean will 

not result in any changes in current agricultural practices. Growers will continue to use cultural 

practices and herbicides to manage weeds, and biodiversity within a field is expected to remain 

unchanged. Agricultural production of cotton and soybean is expected to continue relying upon 

EPA-registered pesticides, including dicamba and glufosinate, for weed management.

Feed derived from GE soybean and cotton must comply with all applicable legal and regulatory 

requirements, which are designed to protect human health. Monsanto completed the 

biotechnology consultation process with the FDA for the safety and nutritional assessment of 

food and feed derived from MON 88708 soybean on October 11, 2011 (BNF No. 00125) and for 

MON 88701 cotton on April 24, 2013. MON 88701 cotton (US-FDA, 2013) and MON 87708 

soybean (US-FDA, 2011b) are compositionally similar to other commercially available upland 

cotton and soybean varieties, and there are no known toxic properties associated with them.

Data submitted by Monsanto indicate that these proteins are unlikely to be a toxin or allergen in 

animal diets (Monsanto, 2013a). As a result, animals that may consume these cotton or soybean 

varieties are not expected to be affected from deregulation of MON 88701 cotton and MON 

87708 soybean under the Preferred Alternative.

Plant Communities 

Under the Preferred Alternative, the direct and indirect effects of approving these petitions on 

plant communities, including weed complexes, is expected to be the same as those under the No 

Action Alternative. Agronomic practices and inputs associated with MON 88701 cotton and 

MON 87708 soybean would not be different than what is utilized on current commercially 

available GE cotton and soybean varieties. As a result, choosing the Preferred Alternative would 

not result in changes to the plant communities in or around cotton and soybean fields.

Weed communities within agricultural fields, including cotton and soybeans are impacted 

primarily by tillage practices and herbicide treatments (Owen and Zelaya, 2005). Non-target 

plant communities in areas surrounding production fields would be exposed to the effects 

associated with agricultural production, including exposure to various inputs, such as herbicides. 

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Management practices such as herbicide use and mechanical cultivation can select for weeds that 

are adapted to these management practices. 

MON 88701 cotton contains the PAT protein conferring resistant to the herbicide glufosinate. 

Both MON 88701 cotton and MON 87708 soybean will be combined with glyphosate-resistance 

traits using traditional breeding techniques (Monsanto, 2013a). Other deregulated GE cotton and 

soybean varieties are available with resistance to each of these herbicides. Additionally, GE 

cotton varieties with resistance to both glufosinate and glyphosate are already available (e.g., 

GlyTolTM LibertyLink® and WidestrikeTM Roundup Ready FlexTM). Therefore, a determination 

of non-regulated status for MON 88701 cotton and MON 87708 soybean by APHIS under the 

Preferred Alternative is not expected to change current agronomic practices. Additionally, MON 

88701 cotton and MON 87708 soybean have been shown to be phenotypically and agronomically 

similar to other commercially grown cotton and soybean varieties; therefore, agronomic practices 

associated with cotton and soybean cultivation, such as tillage, are not different than currently 

used. Therefore, there are no changes in effects to plant communities under the Preferred 

Alternative when compared to the No Action Alternative. 

While MON 88701 cotton and MON 87708 soybean can resist applications of dicamba, nonregulated statues of APHIS under the Preferred Alternative would not allow for the new (i.e., 

post-emergence) uses on these varieties. Pre-plant dicamba use on these and other cotton and 

soybean varieties could continue as permitted by the EPA. The EPA regulates the use of 

herbicides under FIFRA and is making a separate decision on the proposed new uses of dicamba; 

the potential cumulative impacts of the EPA’s decision are reviewed in Chapter 5.

Soil Microorganisms 

The potential effects on soil quality of choosing the Preferred Alternative are no different than 

the effects under the No Action Alternative. Soil microorganisms are affected by agricultural 

management practices, as described in the No Action analysis on soil microorganisms (Section 

4.1.8). One factor that drives a grower’s selection of agricultural practices is weed management. 

Another is the trend toward increased herbicide use to control HR weeds in different cropping 

systems (Owen and Zelaya, 2005; Culpepper, 2008; Owen, 2008; Heap, 2014d) and they will be 

similar under the No Action and the Preferred Alternative.

The decision to approve these petitions will not directly or indirectly effect these grower 

decisions to use tillage to manage weeds. Approving the petitions would allow these varieties to 

be planted, but it does not allow for the use of dicamba on the plants. The use of dicamba is 

regulated by the EPA. The EPA regulates the use of herbicides under FIFRA and is making a 

separate decision which may or may not allow its use on these plants. APHIS considers the 

potential cumulative impacts on soil microorganisms of its decision combined with the EPA’s 

decision in the Cumulative Impacts analysis in Chapter 5.

Growers inoculating soybean fields with Bradyrhizobium japonicum bacteria are likely to 

continue using this organism when additional plant varieties become available. This is because 

seed breeders have an ongoing interest in making their varieties compatible with existing 

cropping materials and practices. Under the preferred alternative, uses of inoculates is unlikely to 

change from current uses.

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4.2.6 Physical Environment

Water 

Agricultural practices can affect water quality. Under the Preferred Alternative, the overall 

agricultural impacts on water quantity are likely to be the same as those described under the No 

Action Alternative. Choosing the Preferred Alternative does not change grower choices on how 

to grow cotton and soybeans or manage weeds in their fields. Any reduction in tillage 

compared to the amount of tillage occurring under the No Action Alternative would be 

associated with relatively less agricultural runoff and sedimentation. This would result in less

water quality impacts. The converse is also true. In areas where tillage is used or increased to 

control weeds in cotton and soybean, water may be affected by sedimentation from surface 

runoff (Robertson et al., 2009).

Use of pesticides for field crop production may introduce residues into water from spray drift, 

runoff from cleaning pesticide application equipment, soil erosion, and filtration through soil into

groundwater. As part of assessing the risk of the exposure of aquatic organisms and the

environment to a pesticide, the EPA estimates concentrations of pesticides in natural water 

bodies, such as lakes or ponds. As part of the Food Quality Protection Act (FQPA) of 1996, the 

EPA estimates pesticide concentrations in drinking water when it establishes maximum 

pesticide residues in and on food (tolerances). For both drinking water and aquatic exposure 

assessments and for water quality assessments, the EPA typically relies on field monitoring data

as well as mathematical models to generate exposure estimates (US-EPA, 2012c).

Approving the petitions would allow these varieties to be planted, but it does not allow for the 

new post-emergence use of dicamba on the plants. The EPA regulates the use of herbicides under 

FIFRA and is making a separate decision which may or may not allow its use on these plants. 

APHIS considers the potential cumulative impacts on water quality of its decision combined 

with the EPA’s decision in Chapter 5.

Air Quality

Agricultural activities, such as the use of tillage, pesticides, prescribed burning, and farm

equipment, can all effect air quality. Growers choose those activities that are most suited for

their operations. To manage weeds, growers may use a combination of activities, including

pesticide use. In areas where HR weeds are increasing in prevalence, increased tillage is 

occurring in cotton and soybeans to combat these weeds. Increasing the frequency of tillage 

increases the release of air pollutants by releasing particulate matter and exhaust from the

burning fossil fuels used to run tillage equipment.

MON 88701 cotton and MON 87708 soybean have been shown to be phenotypically and 

agronomically similar to other commercially grown cotton and soybean varieties; therefore, 

agronomic practices associated with cotton and soybean cultivation are not expected to change.

Under the Preferred Alternative, any effects to air quality associated with deregulation of MON 

88701 cotton and MON87708 soybean are likely to be similar to the No Action Alternative

because agronomic practices are not expected to change.

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Approving the petitions would allow MON 88701 cotton and MON 87708 soybean to be 

planted, but it does not allow for the additional new uses of dicamba. The use of herbicides is 

regulated by the EPA under FIFRA, and the EPA is making a separate decision on the proposed 

new uses of dicamba on these plants. APHIS considers the potential impacts on air quality of its 

decision combined with the EPA’s decision in Chapter 5 (Cumulative Impacts).

Climate Change

Various environmental parameters are anticipated to be altered under the influence of continued 

climate change. Droughts, floods, and temperature changes are predicted to become more 

prevalent and more severe as climate change occurs. This requires faster crop improvement 

programs to develop climate-adapted varieties (James, 2013). The ongoing trend of a general 

increase in the current range of weeds and pests reflects one impact of climate change on 

agriculture. In general, North American production is expected to adapt to climate change 

impacts with improved cultivars and responsive farm management (Field et al., 2007; IPCC, 

2007).

The same types of agricultural activities that affect soil, water and air quality can contribute to 

climate change. Choosing the Preferred Alternative does not change these production practices. 

Therefore, the potential impacts on climate change are the same under the Preferred and the No 

Action Alternative.

4.3 Potential Environmental Consequences - Alternative 3 

Under Alternative 3, Petition 12-185-01p for deregulation of MON 88701 cotton would be 

approved, but not Petition 10-188-01p (MON 87708 soybean). Approving the petition would 

allow MON 88701 cotton to be planted without an APHIS permit or acknowledged notification. 

MON 87708 soybean would continue to be regulated by APHIS. This decision does not allow for 

additional uses of herbicides on cotton or soybeans. The EPA regulates the use of herbicides 

under FIFRA and is making a separate decision which may or may not allow the new uses of 

dicamba on these plants. APHIS considers the potential cumulative impacts associated with its 

decision combined with the EPA’s decision in Chapter 5.

Under the Preferred Alternative, neither of these two events (MON 88701 cotton and MON 

87708 soybean), either individually or together, would have different effects on natural or 

biological resources than the No Action Alternative No direct or indirect effects associated with 

of growing MON 88701 cotton were identified in the Preferred Alternative (Alternative 2) when 

compared to the No Action Alternative. Therefore, approving Petition 12-185-01p for 

deregulation of MON 88701 cotton under Alternative 3 is also not expected to have different 

direct and indirect effects on those resource areas. In addition, APHIS does not expect 

Alternative 3 to have different socioeconomic or human health-related effects than the No Action

Alternative.

4.4 Potential Environmental Consequences - Alternative 4

Under Alternative 4, Petition 10-188-01p for deregulation of MON 87708 soybean would be 

approved, but not Petition 12-185-01p (MON 88701 cotton). By approving Petition 10-188-01p

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for deregulation, MON 87708 soybean could be planted without an APHIS permit or 

acknowledged notification. MON 88701 cotton would continue to be regulated by APHIS. 

APHIS’ decision does not allow for additional uses of herbicides on cotton or soybeans. The 

EPA regulates the use of herbicides under FIFRA and is making a separate decision on the 

proposed new uses of dicamba on these plants. APHIS considers the potential cumulative 

impacts associated with its decision combined with the EPA’s decision in Chapter 5.

Under the Preferred Alternative, neither of these two events (MON 88701 cotton and MON 

87708 soybean), either individually or together, would have different effects on natural or 

biological resources than the No Action Alternative. No direct or indirect effects associated with 

of growing MON 87708 soybean were identified in the Preferred Alternative (Alternative 2) 

when compared to the No Action Alternative. Therefore, approving just Petition 10-188-01p for 

MON 87708 soybean is also not expected to have any different direct and indirect effects on 

those resource areas than the No Action Alternative. In addition, APHIS does not expect 

Alternative 4 to have different socioeconomic or human health-related effects than the No Action 

Alternative.

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5 CUMULATIVE IMPACTS

Cumulative impacts are defined as the “impact on the environment, which results from the 

incremental impact of the action when added to other past, present, and reasonably foreseeable 

future actions regardless of what agency (federal or non-federal) or person undertakes such other 

actions” (40 CFR 1508.7). This section assesses current and reasonably foreseeable future 

impacts associated with the three Action Alternatives (see Section 2). APHIS considers the 

impacts of Action Alternatives combined with its past, present, and reasonably foreseeable future 

actions, as well as the actions of others, in this section.

Considered in this section are the potential cumulative impacts related to changes in management 

practices that are likely to be associated with the adoption of MON 88701 cotton or MON 87708 

soybean in the context of the impacts that agriculture has on biological, physical, human health

and socioeconomic (including production) resources in the areas where cotton and soybeans are 

grown. Impacts on natural and biological resources are also considered in the cumulative impacts 

analyses. Possible implications of how these impacts might affect the availability of those 

resources for human use and consumption are also analyzed. The initial step in this process was 

an analysis of the potential changes in management practices likely to occur if APHIS approves 

one or more of the Monsanto petitions and the EPA approves the new uses of dicamba on MON 

88701 cotton and MON 87708 soybean. In the second phase of analysis, APHIS analyzed how 

changes in management practices might impact natural and biological resources. Possible 

impacts of an interaction with other APHIS actions (past and those currently pending) were also 

considered.

The first reasonably foreseeable future action considered is that EPA will approve the 

registration of the proposed new uses of the dicamba on MON 88701 cotton and MON 87708 

soybean. A second reasonably foreseeable action is the expected determinations of nonregulated 

status for other HR crops, whose implications are noted later in this section. APHIS assumes that 

the EPA will approve the proposed new uses of the dicamba formulation M1691 (U.S. EPA Reg. 

No. 524-582) on MON 88701 cotton and MON 87708 soybean following the determinations of 

nonregulated status for MON 88701 cotton and MON 87708 soybean. This herbicide product 

contains the dicamba diglycolamine (DGA) salt which has a lower volatility profile than the 

dimethylamine (DMA) salt or other acid- based formulations of dicamba currently in use. 

APHIS also assumes that the EPA will approve these proposed new uses on two new products 

containing the BAPMA salt of dicamba (Engenia, Reg No 7969-GUL and MON 100111, Reg. 

No. 524-ANO), which are pending at EPA, as well as two Monsanto formulations (Reg No 524-

616 and 524-617). Monsanto has indicated the use of the higher volatility DMA salt and dicamba 

acid formulations on MON 87708 soybean and MON88701 cotton will not be allowed

(Monsanto, 2013a).

Because these types of potential impacts would occur only if both APHIS and the EPA take the 

actions previously described, APHIS has analyzed in more detail these types of potential 

cumulative impacts in this section. 

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5.1 Cumulative Impacts Methodology

For this analysis of cumulative impacts, Alternative 1, the No Action Alternative, was the 

baseline for comparisons. Under Alternative 1, MON 88701 cotton and MON 87708 soybean 

would not be determined as nonregulated and could only be grown under APHIS notifications or 

permits. Under this scenario, APHIS assumes that the EPA would not approve Monsanto’s 

application for the new dicamba uses on the GE varieties that are the subject of this EIS. Existing 

EPA-approved uses of dicamba would continue to be available and currently available varieties 

of cotton and soybean would continue to be grown.

5.2 Geographic Boundaries for the Analysis of Cumulative Effects

APHIS evaluated impacts at the regional and national levels for this analysis. Regional levels 

included the ecoregions defined in Section 3 (Affected Environment). The national level is the 

conterminous U.S. states, as little cotton and soybeans are grown elsewhere in the U.S. 

5.3 Proposed New Dicamba Uses and EPA Risk Assessments 

The EPA uses risk assessments for registration decisions. It evaluates risk based on exposure and 

hazard to both humans and other organisms. A pesticide cannot be registered, nor can an 

existing registration be amended, unless the registered use conforms to the EPA standard of “no

unreasonable adverse effects on the environment” as described in FIFRA. In the general sense, 

there are four aspects of the risk assessment process: hazard identification, exposure assessment, 

dose/response assessment, and risk estimation. Once the EPA determines that this standard can 

be met, it issues a registration or modifies an existing one. The registration label includes strict 

limits on the quantities and methods allowed for the use of a pesticide to ensure that the standard 

is met.

The EPA uses environmental fate data to predict potential concentration of the pesticide and its 

degradation products in air, soil, and surface and groundwater. These data are also used to 

estimate residue levels in the drinking water component of human dietary risk assessments.

Results of environmental fate studies enable the EPA to determine where a pesticide and its

degradates (byproducts) go in the environment (i.e., air, water, and soil), how long they persist,

and in what quantities (i.e., concentrations) they would be found in environmental media. This 

information is used by the EPA to develop estimated environmental concentrations (EECs) that 

can be compared to toxicity and ecotoxicology data as part of the risk assessment process. EEC 

values are based on the maximum allowable application rate for a pesticide, although typical 

application rates are usually lower than the maximum allowed. This approach, along with other 

factors such as the conditions on the farm field, result in “high-end” to “bounding” estimates of 

exposure. When these are compared to the most sensitive toxicological endpoints in human and 

ecological effects studies, the results are conservative risk estimates. If these estimates exceed 

concern levels, the EPA will refine the exposure estimates using additional information or may 

perform a probabilistic assessment of risks. 

The EPA is conducting an independent assessment of direct and indirect effects associated with 

the use of dicamba on MON 88701 cotton and MON 87708 soybean concurrently with the 

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development of this EIS. The EPA Health Effects Division (HED) of the Office of Pesticide 

Programs (OPP) is charged with estimating the risk to human health from exposure to pesticides. 

HED evaluated hazard and exposure data and conducted dietary, residential (non-occupational), 

aggregate, and occupational exposure assessments to estimate the risk to human health that will 

result from the proposed new use of the DGA salt formulation of dicamba on dicamba-resistant 

soybean and cotton. Additionally, the Environmental Fate and Effects Division (EFED) 

completed a review of the new use request for the herbicide dicamba. 

The primary difference between the proposed new use of dicamba on soybeans and cotton and 

the previous soybean and cotton use assessed is the timing of the applications. For conventional 

cotton, the maximum seasonal application rate of dicamba is the same as that proposed for use 

on MON 88701 cotton. However, for dicamba-resistant cotton, if the EPA approves Monsanto’s 

application as APHIS assumes, cotton may be treated with dicamba at later plant growth stages 

during the growing season compared to its current uses. Consequently, Monsanto estimates that 

at peak MON 88701 cotton adoption at of about 50% of U.S. cotton acreage more frequent 

applications of dicamba will be made to cotton, since the trait allows new post-emergent 

exposure (Appendix Table A-40) (Monsanto, 2013a). 

For MON 87708 soybean, the new label would similarly allow for applications at later stages of 

plant growth than currently approved for dicamba use on soybean. Monsanto estimates that about 

40% of U.S. soybean acreage will be planted with the technology. Again, more frequent 

applications can be expected on MON 87708 soybean since post-emergent exposure is tolerated 

(Table A-2, A-3, A-5) (Monsanto, 2013a). Thus, more soybean acreage is likely to be treated 

with dicamba on MON 87708 soybean than on present varieties, where it is used only as a 

burndown herbicide. 

A summary of the EPA’s human health and ecological risk assessments for the proposed new 

uses of dicamba on MON 88701 cotton and MON 87708 soybean is provided in Appendix 8 of

this EIS. These assessments provide the EPA with information needed to develop label use 

restrictions for the pesticide. Growers are required to use pesticides, such as dicamba, 

glyphosate, and glufosinate, consistently with the application instructions provided on EPAapproved pesticide label and any other applicable federal or state laws and regulations. Labels 

include restrictions on pesticide use/application, such as required personal protective equipment 

for applicators and requirements related to minimizing drift or exclusion distances from bodies 

of water when necessary. These label restrictions carry the weight of law and are enforced by the 

EPA and states (FIFRA 7 USC 136j (a)(2)(G) Unlawful Acts). 

These direct effects of dicamba use are outside the scope of this EIS. APHIS decisions regarding 

the regulated status of the petitions for these new GE varieties will be made independently of the 

results of the EPA assessments. One assumption of the APHIS analysis is that EPA will establish 

label restrictions associated with the uses of dicamba on these varieties that will ensure the safety 

standards for human health and the environment. 

Because of concerns about weed resistance the EPA is proposing new management requirements 

when appropriate for specific herbicides. These requirements include robust resistant weed 

monitoring and reporting to EPA, grower education and remediation, and will allow the EPA to 

take swift action to impose additional restrictions on the manufacturer and the use of the 

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herbicide if resistance develops (US-EPA, 2014a). One example of the EPA’s new requirements 

related to weed resistance management for registration of another herbicide formulation with an 

active ingredient (2,4-D) that has the same mode of action as dicamba is detailed in Appendix 10 

of the EIS. These provisions would require Dow to conduct an active stewardship program 

including monitoring and swift steps as needed to remediate weed resistance to 2,4-D. It would 

allow the EPA to modify the registration quickly and easily to impose additional measures to 

manage resistance when appropriate. The label would also contain information on resistance 

management consistent with the Weed Science Society of America’s BMPs for comprehensive 

resistance management approaches (US-EPA, 2014a). Practices such as the use of an herbicide 

with a trait for a third mode of action in glyphosate resistant crops, and recommendations 

regarding the most effective rates and timing of applications for dicamba and glufosinate 

treatments will reduce the potential for weed communities in cotton and soybean fields to shift to 

more resistant weed species. EPA has specified such requirements be included on the label for 

the Enlist Duo herbicide as part of that proposed registration (US-EPA, 2014a). In the future, the 

agency intends to apply this approach to weed resistance management for all existing and new 

herbicides used on herbicide tolerant crops.

11 APHIS expects that the EPA will implement 

similar resistance management requirements for the registration of M1691 dicamba formulation 

(US-EPA, 2014a).

APHIS sees as reasonably foreseeable that these provisions will be generally useful for

preventing or remediating the development of weed resistance. Nevertheless, APHIS’ analysis in 

this section focuses on the cumulative impacts associated with these varieties, including possible

development of HR weeds associated with application of EPA-approved herbicides, as well as

changes in management practices resulting from their use.

5.4 No Action Alternative. Current Management Practices Considered in the Analysis 

of Cumulative Impacts

This analysis addresses the potential impacts of the Alternatives on natural and biological 

resources and their interrelated socioeconomic impacts within the U.S. on APHIS’ determination

of nonregulated status for MON 88701 cotton and MON 87708 soybean. First, the overall 

background in which US cotton and soybean are produced, and herbicides are used is a dynamic 

one, in that various agronomic factors are changing such as an increase in glyphosate resistant 

weeds and other herbicide resistant weeds. Superimposed on this is the price of commodities, 

which determines what economic practices can be used for cotton and soybean production and 

which are not economically justifiable. Rotation crops and their economies and needs also are 

part of this complex interation, as are the production practices that take place on these. Cultural 

and physical methods to control weeds are also a large and important part of the Agroecosystem 

and grower production processes for these crops. In this miliueu, dicamba use is already a part of 

the agronomic input practices, along with other herbicides. In the Environmenal Consequences 

section (Section 4), APHIS has presented these issues and facts, and in this section of 

Cumulative impacts focuses on changing patterns of dicamba use, and of tillage, both important 

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considerations in the potential for environmental impacts that might derive from planting of 

MON 88701 cotton and MON 87708 soybean.

Current Dicamba Use

The agronomic practices that are expected to be affected by nonregulated status for MON 88701 

cotton and MON 87708 soybean are those that relate to the application of dicamba. The factors 

that would contribute to increased dicamba use on cotton and soybean include the application 

rate and the number of acres to which dicamba would be applied on these new GE plant 

varieties. 

In 2012, the highest use of dicamba was on corn crops, with almost 12 million acres of corn 

treated. About 12% of corn acres received a dicamba application either alone or with another 

herbicide. The second crop most frequently treated with dicamba was fallow or idled cropland, 

with approximately 6.7 million acres treated. On spring and winter wheat, 1.8 and 3.6 million 

acres received dicamba applications or 14.6% and 8.4% of acres, respectively. Dicamba was 

used on 1.5 million cotton acres which represents 11.5% of the total U.S. cotton crop acreage 

(Monsanto, 2014a). Dicamba usage on additional crops is summarized in Table 17 and Appendix 

8.

Table 17. Summary of Dicamba Use on U.S. Agricultural Crops.

U.S. Total

2012 Treated Acres % 

Dicamba 

Only

Treated 

as % of 

Total 

U.S. 

Crop

Total Dicamba 

Usage

(Mixtures + Alone)

Dicamba 

Only Dicamba Mixtures

Corn 11,919,841 441,945 11,477,896 4% 12.4%

Fallow1 6,665,137 17,757 6,647,380 0.3% 17.9%

Winter Wheat 3,622,105 135,020 3,487,085 4% 8.4%

Pastureland 3,221,382 492,671 2,728,711 15% 8.9%

Spring Wheat 1,804,741 79,148 1,725,593 4% 14.6%

Sorghum 1,683,586 49,491 1,634,095 3% 14.6%

Cotton 1,455,312 79,093 1,376,219 5% 11.5%

Soybeans 1,055,926 3,215 1,052,711 0.3% 1.4%

Sugarcane 190,317 - - 0% 26.9%

Source: BASF Corporation market research (Monsanto, 2014a) 1 Total acreage is from cropland idled (USDA-ERS, 2011d).

For 2011, Monsanto proprietary and USDA-NASS data indicate that 10% of cotton crops 

received a single pre-plant application of dicamba (Tables A-2 and A-3 of the Monsanto ER)

(Monsanto, 2013a). Monsanto proprietary data show that dicamba use on cotton has increased 

2.4 times between 2006 and 2012 (Table 23). For 2011, 1.2% of soybean crops received a single 

application of dicamba, likely for burndown before planting. Because of the sensitivity of 

soybean to dicamba, application has been infrequent and accompanied by lengthy plant-back 

restrictions. 

Current Tillage Patterns

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The relationship of weed control to changes in tillage practices may be evident in different 

regions of soybean and cotton production. Surveys and studies of cotton and soybean 

management practices reveal some trends in a four-region tillage report, comprising West, 

Midwest, Mid-South and Southeast regions (Monsanto, 2013d). Conservation tillage practices 

increased, especially no till acres, at the expense of conventional tillage for cotton, corn and 

soybean in the 10 year period 1998 to 2007 but subsequently began to change (Appendix 9)

(Monsanto, 2013d). 

Recent tillage trends in cotton. Conventional tillage of cotton fields in the Mid-South increased 

from 2007 to 2012/2013, while conservation tillage substantially declined. In the Midwest and 

Southeast, no till declined, but appears to be replaced by reduced-till methods, since 

conventional tillage is flat but only trending toward an increase in both areas. The survey of 

experts from both Southern regions together showed that the first factor identified that led to the 

change in tillage practices was economics, the second reason was to manage existing weeds

(Monsanto, 2013d); the first factor was likely a part of the second factor, which would be to

solve important evolving weed problems using economically justifiable practices.

Recent tillage trends in soybean. During the five year period 2007-2012, soybean growers in the 

Mid-South (includes MS, LA, AR, and TN) increased conventional tillage and practiced less notill, but did not change reduced-till efforts in the most recent period (Monsanto, 2013d). The first 

and second drivers behind the observed trend were stated as the same as those for cotton 

(economics and weed management), while the third driver was seed bed preparation, the fourth, 

managing soil moisture and the fifth as preventing weed resistance.. Some locations such as 

Tennessee, receive action recommendations from extension weed specialists to respond to severe 

Palmer amaranth with discing out the crop and replanting, unless they can find a chopping crew 

to selectively remove this weed (Steckel, 2013). Soybean production in Midwestern states12 also 

showed a two year trend towards increasing conventional tillage, with a substantive decrease in 

no-till, but instead with an increase in reduced-till. Other regions such as the Southeast and East 

showed a two year trend toward increased conventional tillage, or no change, but no 

corresponding increase in reduced-till practices. Experts considered that economics and 

managing existing weeds were the third and fourth proximate reason for the changes in these 

states (Monsanto, 2013d), although the second reason, a need for better seed bed preparation, 

could also be related to weed management issues, since seed bed preparation controls early weed 

competitors of the crop (Gunsolus et al., 2010). A first reason for this grower response was a 

need to manage increased crop residue, which may be a consequence of newer varieties leaving 

increased stalk and crop detritus (Monsanto, 2013d). While all reasons for the tillage changes are 

not clear, and require further assessment, at least some of the changes were responses to weeds 

and weed resistance.

Magnitude of Potential Impacts on Resources

APHIS identified changes in management practices that could cause impacts on natural and 

biological resources. If approved for general use, the degree to which the GE crop varieties that 

12 Ohio, Michigan, Indiana, Illinois, Wisconsin, Missouri, Minnesota, Iowa, Kentucky, Kansas, Nebraska, North 

Dakkota, and South Dakota.

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are the subject of this EIS are adopted will determine the magnitude of the impacts of the 

associated new management practices. Therefore, APHIS reviewed and analyzed here the range 

of possible management practices and their impacts. Because APHIS does not regulate 

production or management practices, the agency cannot control the choices growers make.

5.5 Assumptions

A summary of the assumptions made for the analyses included in this section follow:

• The APHIS PPRAs did not identify any changes in MON 88701 cotton or MON 87708 

soybean that would directly or indirectly affect natural or biological resources. These 

plants are compositionally similar to other cotton and soybean plants. The growth habits 

of these plants are also similar to other cotton and soybean plants. APHIS assumes that 

growers will choose management practices appropriate for the crops planted.

• APHIS used information available from extension services, trade journals, scientific 

journals, and public comments for petitions to identify common practices.

• Most of the U.S. cotton and soybean acreage is currently planted in HR varieties. APHIS 

assumes that HR cotton and soybean varieties will continue to be planted under all of the 

Alternatives. 

• Under Alternatives 2, 3, and 4, when MON 88701 cotton and MON 87708 soybean, and 

the crops are determined as nonregulated, these could be crossed with any currently 

available varieties of these crops, including GE varieties no longer regulated by APHIS. 

• APHIS considers that herbicide applications will conform to the EPA-registered uses for 

cotton and soybean.

• In addition to cotton and soybean, APHIS assumes that other approved dicamba uses (e.g. 

on pastures, wheat, oats, barley, millet, turf, sorghum, corn, sugarcane, asparagus) will 

conform to EPA-approved label requirements. 

• APHIS assumes that the impacts associated with drift from dicamba and other pesticide 

applications will be mitigated to an acceptable level by the registration requirements 

established by EPA.

• APHIS assumes that dicamba treatments may or may not include glyphosate, although 

many treatments may be made with the dicamba (M1691) formulation to cotton and 

soybean which could possibly include both as a premix. Stewardship agreements and 

registration requirements for new dicamba herbicide use with respect to MON 87708 

soybean and MON 88701 cotton will include a requirement to use both dicamba and 

glyphosate and another herbicide in certain circumstances. Monsanto states: “In fields 

where glyphosate-resistant broadleaf weeds are present or suspected glyphosate plus 

dicamba will be recommended. In addition, Monsanto will recommend an additional 

herbicide with a third mode-of-action that also has activity on the glyphosate-resistant 

broadleaf weed, thereby providing two effective modes-of-action to control glyphosateresistant weeds” (Monsanto, 2013d). 

• APHIS accepts as likely the Monsanto estimate of herbicide use for dicamba, glyphosate, 

and glufosinate for the four Alternatives, assuming approval of the new dicamba uses by 

EPA. The herbicide volume estimates are discussed in detail in Appendix 4. These 

estimates were based on the assumption that dicamba use on MON 88701 cotton and 

MON 87708 soybean will increase, while dicamba uses on turf, range, pasture, and 

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industrial management will not change. In brief, dicamba use is expected to increase 

under the No Action and Action Alternatives (analysis by Monsanto of trends between 

2011 and 2015 shows an expected 100% increase in use of non-glyphosate herbicides 

(Monsanto, 2013a)). Under the Action Alternatives, the increase in dicamba use is 

expected to be greater when compared to the No Action Alternative. Glyphosate use on 

cotton and soybean is not expected to increase under the No Action and Preferred 

Alternatives because of market saturation; between 2011 and 2013, HR soybean was 

planted on 93-94% of total acres and HR cotton was planted on 73%-82% of total acres 

(USDA-NASS, 2012c; 2013c). As of 2010, 98% of the corn acres, 99% of the cotton 

acres and 98% of the soybean acres are treated with herbicides (with glyphosate being the 

most commonly used) (USDA-NASS, 2011b; 2013a). APHIS understands that growers 

will be required to participate in Monsanto Technology Stewardship Agreements 

(MTSA) and Technology Use Guides (TUGs). The Technology Use Guides contain best 

management practices and requirements for growers who use MON 88701 cotton and 

MON 87708 soybean varieties, including weed resistance management practices 

(Monsanto, 2013a). Practices such as the use of an herbicide with a trait for a third mode 

of action in glyphosate resistant crops, and recommendations regarding the most effective 

rates and timing of applications for dicamba and glufosinate treatments will reduce the 

potential for weed communities in cotton and soybean fields to shift to more resistant 

weed species. EPA has specified such requirements be included on the label for the Enlist 

Duo herbicide as part of that proposed registration (US-EPA, 2014a). In the future, the 

agency intends to apply this approach to weed resistance management for all existing and 

new herbicides used on herbicide tolerant crops.

13 APHIS expects the EPA to implement 

similar appropriate label requirements on the registration of M1691 herbicide regarding 

resistance management.

5.6 Preferred Alternative: Cumulative Impact

Production of MON 87708 soybean and MON 88701 cotton would not affect natural or 

biological resources directly, but rather the agricultural management practices (e.g., pesticide 

applications) associated with cultivation of these crops and its potential impact on natural and 

biological resources. The interaction of cultural and mechanical practices affect agricultural and 

natural resources, and these include crop rotations, and sequences of crops, selections of varieties 

and traits and tillage practices. Pest control practices are also relevant and include patterns, 

numbers and specific choices of applied herbicides or other pesticidal chemicals as well as 

mechanical and cultural controls. These management practices all accumulate specific outcomes 

for crop yield, and soil, water, or air impacts. Other consequences may include development of 

problem or herbicide resistant weeds, or adverse effects on successive crops planted on the same 

land. APHIS will discuss those selected issues which will or may potentially impact these 

agricultural and natural resources in the context of the Cumulative Impacts section, since as 

noted, the EPA approval of new dicamba uses was a foreseeable event, rather than an already 

existing status.

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5.6.1 Land Use and Acreage

Summary: MON 87708 soybean and MON 88701 cotton commercialization and the EPA 

approval of the new uses of dicamba on these crops are not likely to change overall 

agricultural acreage in the United States. If weed control costs become lower as a result 

of the availability of these crops with the proposed new EPA-registered dicamba uses, 

and net returns on either soybean or cotton are also higher, APHIS concludes that under 

the Preferred Alternative, there may be economic incentives for growers to increase

soybean and cotton acreage in two of the 13 regions of soybean and cotton production.

U.S. soybean acreage increased over the past two decades. The greatest increase occurred in the 

northern and western parts of the Region G and the Region H (USDA-NASS, 2013d). During the 

same period, wheat and small grain acreage decreased in these areas (USDA-NASS, 2013d). 

U.S. planted cotton acreage declined somewhat, and between1996 and 2004, averaged 14.4 

million acres, while between 2005 and 2013, averaged 11.9 million acres (USDA-NASS, 2014c). 

Cotton acreage is expected to increase about 1 million acres in 2014, with subsequent moderate 

growth, reflecting falling values for other crops; soybean acreage will remain around 78 million 

acres until 2023, but both soybean and corn will compete for land use with other crops (USDAOCE, 2014b).

An APHIS determination of nonregulated status of the two varieties and the EPA registration of 

new formulations of dicamba is not anticipated to change cotton and soybean acreage in Regions 

A-M because other factors such as cotton and soybean prices have a greater influence on 

planting decisions. Cotton and soybean acreage in Regions G and I is not likely to change unless 

the MON 87708 soybean and MON 88701 cotton crop strategy for weed control reduces costs 

compared to the No Action Alternative. If the cost of production is sufficiently reduced to allow 

the net returns from growing dicamba-resistant soybeans to exceed that of other crops, growers 

may choose to plant more soybeans in these areas under this Alternative. Other factors such as 

changes in price of commodities and input costs are also variable and affect planting decisions. 

One of these is the pricing of these products, and the utility to growers of purchasing MON 

87708 soybean and MON 88701 cotton seeds. The potential contribution of MON 88701 cotton 

to expanding cotton acreage in Region D and J (70% of U.S. cotton acreage) and MON 87708 

soybean in Region C and G (57% of U.S. soybean acreage) is not known. APHIS does not 

interpret the dicamba-resistance trait as having any potential for changing the economics of 

soybean and cotton production in the United States, and so these crops (MON 87708 soybean 

and MON 88701 cotton) are not likely to increase production acreage of either of these crops.

5.6.2 Agronomic Practices

Summary: Currently, dicamba is used on only about 1% of soybean acres, and on 

average, once a season as a burndown or pre-plant herbicide. On dicamba-resistant

soybean, Monsanto projects dicamba is likely to be used twice a year on no-till and GR 

weed infested fields, or once on conventional fields. While dicamba use is expected to 

increase if dicamba-resistant soybean is determined as nonregulated, APHIS agrees with 

analyses indicating that substantive PRE non-glyphosate herbicide applications will 

likely be eliminated, as may more than half of POST non-glyphosate applications.

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Currently, dicamba is used on about 12% of cotton acres, mainly as a pre-plant 

application once per season. Monsanto asserts that the rate and number of applications 

made on MON 88701 cotton will depend on two primary factors: 1) the tillage practices 

and 2) the weed spectrum. Monsanto projects that 39% of MON 88701 cotton acreage 

will receive one application, about one half will receive two applications of dicamba per 

season and the remaining 11%, three. Overall, the projected adoption of MON 88701

cotton will be about 50% of all cotton acres. The amount of dicamba that would be used 

on cotton may increase 14-fold, but APHIS agrees with estimates that the application of 

other herbicides would likely decrease on 2.6 million acres of cotton, which would be 

26% of harvested cotton acres from 2014.

Glufosinate use on soybean and cotton has been increasing in recent years as a result of 

growers choosing to plant glufosinate-resistant varieties because of the increased 

prevalence of glyphosate-resistant weeds. APHIS concludes that total U.S. glufosinate 

use on soybean and cotton is expected to decrease because dicamba is a more versatile 

and efficacious herbicide, and use of dicamba as a POST application will likely be 

preferred on MON 87708 soybean and MON 88701 cotton. 

Glyphosate use is not expected to increase, since it is used on most soybean acreage 

already and on at least 83% of cotton, but will continue to be used because of its efficacy 

in controlling many weed species. APHIS concludes that pressure to increase 

conventional tillage rates because of increasing weed resistance of some species to 

glyphosate can be alleviated with use of a new herbicide chemistry in addition to use of 

the existing effectiveness of glyphosate herbicide.

Non-glyphosate herbicide use in cotton and soybean during the period from 2008 to 

present has been steadily increasing in response to a need to control glyphosate-resistant 

weeds that are increasingly present. Some of the increases may also have come in 

response to advice from weed scientists for averting the development of herbicideresistant weeds. It is likely that because PRE and POST applications of dicamba 

(including those with glyphosate) will control certain HR weeds, use of MON 87708 

soybean and MON 88701 cotton will allow for replacement of other herbicides. Similar 

results are likely in cotton as well. Under the Preferred Alternative the addition of POSTapplied dicamba and residual herbicides will be parts of a coordinated herbicide use 

strategy on MON 87708 soybean and MON 88701 cotton crops. 

Changes in Dicamba Use

Dicamba is currently registered for use on soybeans at application rates similar to those proposed 

for MON 87708 soybean. However, the proposed EPA-approved label would allow for dicamba 

applications at later stages of plant growth than currently approved for soybean. At peak MON 

87708 soybean use, Monsanto estimates that the technology will be adopted on about 40 percent 

of all soybean acres, compared to 2011 when only 1.2 percent of soybean growers used dicamba 

once per year for burndown or pre-plant weed control (Tables A-2, A-3, and A-5 of the 

Monsanto ER) (Monsanto, 2013a). Dicamba will likely be used on average twice per season on 

Xtend soybean, on no-till and GR Ameranthus-infested fields, and twice for conventional tillage 

fields (Table A-5 of the Monsanto ER) (Monsanto, 2013b; 2013a). Thus, more dicamba

herbicide will be sprayed on Xtend soybean acreage than are likely to be sprayed with dicamba 

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on present varieties. Increased use of dicamba would however, result in a decrease of up to 21 

percent of projected total acreage treated with PRE14non-glyphosate herbicide, and 56 percent of 

projected total area treated with POST15 non-glyphosate herbicide, when peak use of Xtend 

soybean attains 40 percent of all soybean crops (Section A.3.6 of the Monsanto ER) Monsanto 

(Monsanto, 2013b). 

At peak extent of Xtend cotton adoption, 50% of US acres will be planted to the variety, and notill cotton acres would be sprayed three times in W.TX, AZ, OK, NM, and KS and conventional 

till acres two times. In all other cotton growing regions, Xtend no-till cotton will be sprayed

twice and conventional till but once (Monsanto, 2013b). One commenter on the DEIS suggested 

that because GR Palmer ameranth was common in the Delta and Southeast regions that an 

additional application of dicamba would be needed in these states (Merchant et al., 2013). 

However, this study actually showed that a second herbicide chemistry was needed for Palmer 

control, but not a second application of dicamba (CFS Science Comment I, 2014). Replacement 

of non-glyphosate PRE herbicides by Xtend dicamba will likely occur on 34% of cotton acres, 

and replacement of POST herbicides on 37% of cotton acres (Monsanto, 2013b). APHIS 

concludes that these values of herbicide reductions presented by Monsanto are reasonable 

estimates of future herbicide use.

If the Preferred Alternative is chosen, and the EPA approves new uses of dicamba for MON 

87708 soybean and MON 88701 cotton the increase in dicamba use on cotton acres with respect 

to the present use of dicamba on cotton would be an increase of 14.3 times more than that 

estimated under the No Action Alternative (Appendix 4, Table 4-9). The increased use of 

dicamba on soybean would be 88 times more than present, since it is so sparingly used in current 

practice. The use of dicamba on soybean with respect to dicamba use on all other crops would 

present an increase of 5.4 times, and the increased use of dicamba in both crops compared to all 

dicamba uses would be 6.8 times. Dicamba at present can mainly be used as a pre-plant on 

cotton (if the maximum application rate is used), and the planting can come only 21 days after 

application (Clarity dicamba label). No dicamba application is permitted west of the Rocky 

Mountains. If dicamba is used on soybean in pre-plant applications under present label directions 

(at maximum application rate: planting not earlier than 28 days after application, (see Clarity 

dicamba label (BASF, 2010)) relatively little is used because allowable exposure to the crop is 

limited. 

One additional source for a possible increase in crop use of dicamba is on corn fields that are 

adjacent to MON 87708 soybean. Growers who might have used a non-dicamba herbicide on 

corn, possibly to protect adjacent and sensitive soybean might instead apply dicamba herbicide to 

corn because this sensitivity issue would be no longer relevant. APHIS has considered this 

concern (CFS Science Comment I), but concludes that corn growers have many choices of 

herbicides, many newer than dicamba, and would not necessarily be any more likely to choose 

dicamba for weeds on the corn adjacent to MON 87708 soybean. Previous dicamba use on corn

from 1993-1997 attained to 21-29% of corn acreage, but later declined in 2010 and 2011 to 7-

14 PRE = pre-plant/pre-emergence application to the crop 15 POST = post-emergence in-crop use

145

 
10% of acres (see CFS Science Comments I). Again, APHIS considers that this older, three fold 

higher use of dicamba reflects needs for the herbicide at that time, and that newer herbicides may 

be better, more numerous and more economical. So, additional dicamba use on adjacent corn 

production near soybean is not likely to be observed. 

Changes in Glufosinate Use

Glufosinate use is expected to increase under the No Action Alternative as growers continue to 

increase their adoption of glufosinate-resistant crops. Under the Preferred Alternative, APHIS

agrees that glufosinate use may decline, based on comparative efficacy data and the observation 

that dicamba is considered a more effective option for GR weed control compared to glufosinate 

(Monsanto, 2013a). As one commenter noted (CFS Science Comments I), efficacy in control of 

some GR weeds such as Palmer ameranth is enhanced by using both glufosinate and dicamba 

(Merchant et al., 2013). Monsanto does recommend for the Mid South and in Southeast states 

that when GR weeds are present, growers should apply glufosinate. Since use of glufosinate 

resistant cotton and soybean is already high in these states (USDA-AMS in (York, 2012), 39-

67% Glufosinate tolerant varieties planted in NC, VA, SC, GA, TN). Glufosinate (Liberty) can 

be used on Bayer varieties, and is commonly used off-label on Phytogen Widestrike lines. If 

glufosinate with dicamba were in new cotton usages, APHIS concludes that the dicamba-and 

glufosinate-resistant varieties would replace these glufosinate-resistant-only varieties and would 

not result in additional glufosinate applications.

Changes in Glyphosate Use

Glyphosate use on cotton and soybean is not expected to increase under the No Action or

Preferred Alternatives because of market saturation; between 2011 and 2013, HR soybean was 

planted on 93-94% of total acres and HR cotton was planted on 73%-82% of total acres (USDANASS, 2012c; 2013c). As of 2010, 98% of the corn acres, 99% of the cotton acres and 98% of 

the soybean acres are treated with herbicides (with glyphosate being the most commonly used)

(USDA-NASS, 2011b; 2013a).

Changes in Use of Non-Glyphosate Herbicides

APHIS considered the question of whether some existing agronomic practices may facilitate 

new resistant weeds and more herbicide use. Mortensen et al. (2012) assert that the use of 

additional herbicide resistant crops will only increase the frequency of herbicide applications. 

The appearance of new herbicide resistant weeds then becomes an unavoidable consequence of 

more herbicide applications. Under that assertion, the availability of MON 87708 soybean and 

MON 88701 cotton could be accompanied first by first enhanced control, but followed by 

increasing weed resistance that required higher rates of herbicide applications to meet the 

increasing weed resistance. Using glyphosate, growers discovered that they could simplify weed 

control often with use of only glyphosate. In the absence of two-factor herbicide control, 

resistance to glyphosate easily developed and following that, non-glyphosate herbicide 

treatments expanded. While dicamba use will increase following determination of nonregulated 

status of MON 87708 soybean and MON 88701 cotton, the likelihood that use of other 

herbicides will decrease should also to be assessed. The larger tapestry of how existing 

herbicides will be used together is also a key part of the success of herbicides in directing 

sustainable weed control measures.

146
APHIS concludes that herbicides alone do not cause resistance, nor do HR crops, rather, the 

absence of diversity in herbicide use and in tactics for weed management is more relevant 

(Norsworthy et al., 2012; Shaner, 2014 ). While managing existing and future problem weeds

with herbicides is a focus at present, APHIS agrees that this focus is not likely to provide for 

agronomic sustainability. New research into weed science and broader weed management 

practices might take new directions to improve the prognosis, but limited options may be 

available at present to deal sustainably with weeds (Shaner, 2014 ). 

Soybean herbicide trends and replacement by MON 87708 soybean and MON 88701 cotton. 

Some assert that new herbicide use on synthetic auxin-type resistant soybean will simply add to

existing herbicide use. It is informative to measure how herbicide usage changed from the first 

availability of glyphosate resistant crops to the present. Mortensen et al. (2012) used data from 

2007 and earlier from an 2010 NRC publication showing a decrease in use of the non-glyphosate 

herbicides. Using this, they postulated constant levels of non-glyphosate herbicide use until 

additional herbicide resistant crops were available. After these crops were adopted, these authors

assumed highly increased herbicide usage rates. Using extensive market research data, Monsanto 

(Monsanto, 2013a) showed that total area treated PRE with non-glyphosate herbicides for 2002-

2007 on soybean increased only 11% and treated POST decreased 7% ((Monsanto, 2013a), 

Appendix A, Herbicide use trends: Impact of DR soybean on future herbicide use; Table A-10 

and A-11). In the more recent period 2008-2011, PRE applications increased 177% and POST 

345% (Tables A-10 and A-11). From these it is clear that the present pattern of non-glyphosate 

herbicide applications is steadily increasing, even without any additional herbicide resistant 

crops. The factors which drive this increase are the development of glyphosate resistant weeds, 

and the advice of weed experts and extension personnel which advocate increased use of best 

management practices, often including multiple herbicides(Marshall, 2012; Norsworthy et al., 

2012)

Data derived from market research on herbicide use by growers (Monsanto, 2013a) was 

subjected to regression analysis procedures, and assessment made of existing trends. From this, 

forecasts of how much herbicide would be used in future PRE and POST applications to soybean 

crops were made, based on weed management needs, acceptable weed control, and on costs of 

herbicide and mechanical tillage (ER, Herbicide use trends: Impact of DR soybean on future 

herbicide use (Monsanto, 2013a)). As noted in Figures A-1 and A-2 ((Monsanto, 2013a), 

Appendix A), beginning in about 2015, the increase in non-glyphosate herbicide use levels off 

because of the restraints of economics and efficiency of weed control. 

As can be shown later in this section, the use of the dicamba and glyphosate tolerant crops will 

have advantages over many of the non-glyphosate herbicides presently being used on soybean 

((Monsanto, 2013a), Appendix A, Section A-4.2.2 and following). Under the Preferred 

Alternative, APHIS agrees that dicamba may displace substantial quantities of these herbicides, 

and potentially stabilize increases in the total herbicides that are applied to soybean. For 

example, dicamba and glyphosate resistant Xtend plants may lead to displacement of 60% of 

some of the PRE herbicides used in soybean production. These include synthetic auxins like 2,4-

D, the PSI inhibitor paraquat or the glutamine synthase inhibitors, like glufosinate, because of 

improved efficacy, lack of a carryover effect, and for reasons of crop safety ((Monsanto, 2013a), 

Appendix A, Herbicide use trends: Impact of DT soybean on future herbicide use; Table A-15). 

For POST herbicides, various PPO herbicides such as fomesafen and chloransulam-methyl, 

147
various ALS inhibitors such as chlorimuron and imazamox, and a PSII inhibitor bentazone, are 

projected to be 80% displaced by dicamba/glyphosate used on herbicide-resistant soybean. Issues 

related to efficacy, carryover, crop safety and existing weed resistance to these herbicides will 

drive this displacement ((Monsanto, 2013a), Appendix A, Herbicide use trends: Impact of DT 

soybean on future herbicide use; Table A-16). 

The PPOs are one of the few classes of effective POST herbicides for soybean, given that 

widespread weeds have both resistance to glyphosate and resistance to several classes of 

herbicide (Hager, 2013). Dicamba can replace the PPOs (some PPOs have less efficacy on GR 

waterhemp compared to other PPOs (fluthiacet) (Hager, 2013) while others are effective as 

residuals on GR and ALS resistant weeds (such as flumioxazin (VanGessel, 2014a)) but should 

be used cautiously to avoid new resistance (University of Illinois, 2013). In both situations, 

availability of MON 87708 soybean would be a useful tool to deal with GR weeds and to spare 

the use of effective PPOs. As a professor and extension agronomist notes with respect to cotton 

(S. Culpepper, University of Georgia. Public Comment APHIS-2013-0043-3209), “The greatest 

risk for developing herbicide resistance is actually occurring at this moment with the PPO 

herbicides and glufosinate. These products are being over used as growers have no other 

effective herbicidal options. New technologies such as dicamba could be used to delay resistance 

development to the PPO herbicides and glufosinate and, in turn, systems could be developed 

using the PPO herbicides, glufosinate and dicamba extending the life of each of these 

chemistries.” APHIS concludes that the usefulness of the PPO herbicide class and glufosinate 

could be prolonged by reducing overexposure of weeds to these effective soybean herbicides by 

the availability of dicamba- and glufosinate- resistant crops. 

Effects of MON 87708 soybean and MON 88701 cotton on herbicide use trends. A pattern of 

increasing use of non-glyphosate herbicides (see Table A-37 to A-39) on cotton can be discerned 

from grower surveys conducted by a contracting company for Monsanto in 2012 (Monsanto, 

2013a). PRE herbicide use over the period 2002 to 2009 increased about 15%, with growers 

notably using 2,4-D and paraquat for burndown, fomesafen, trifluralin and fumioxazin as 

preplants with activity extending into post emergent growth, and pendimethalin as a preemergent 

((Monsanto, 2013a), Appendix A, A.4.1.3. Analysis of Cotton Herbicide Use From 2002-2011). 

PRE non-glyphosate herbicide use in cotton increased more sharply between 2009 and 2011, 

rising 113% ((Monsanto, 2013a), Appendix A, Table A-37). To some extent, the totals reflect a 

decline in total cotton acres from 2002 and 2003 compared to 2009, and an increase in cotton 

acreage again by 2011 ((Monsanto, 2013a), Table A-39).

A 250% increase in non-glyphosate herbicide applications occurred between 2003 (30.2%) and 

2011 (75.8%) when expressed as ratios of the acreage of non-glyphosate herbicides to total 

planted cotton acres (Table 18). Applications of non-glyphosate herbicide treatments increased in 

2008 from 1.5 and in 2011 to almost 2.2 ((Monsanto, 2013a), Table A-38). Glyphosate-resistant 

cotton plantings declined 24% during the first period, then increased 68% from 2009 to 2011. 

The much larger increase in non-glyphosate herbicides applied was not correlated with GR 

cotton plantings, but with a rise in GR weed development, and the recommendations by weed 

scientists and extension personnel that growers should employ diversity in weed management 

practices to counteract the pattern of resistant weed development.

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Table 18. Acres and Percentages of Cotton Acres Treated with Non-Glyphosate Herbicides.

Acreage 

(X1000)

Year

2003 2005 2007 2009 2011

Total Area 

Treated-NonGlyphosate 

Herbicides

4,119 4,625 2,941 3,734 11,018

Total Planted 

Cotton Acres 13,626 14,024 10,732 9,042 14,533

Ratio of 

Treated Acres 

to Total Acres 30.2% 33.0% 27.4% 41.3% 75.8%

Data from ER, Appendix Table A-39 (Monsanto, 2013a)

For POST emergent non-glyphosate herbicide usage on GR cotton, a pattern of stasis and slight 

decline was seen between 2002 and 2009 based on grower survey data assembled by Monsanto 

((Monsanto, 2013a), Appendix A, A. 4.1.4., Table A-39). For 2009 to 2011, the total acreage 

treated with non-glyphosate herbicides increased 220%. Just as was observed in the case of PRE 

herbicides, the amount of increased herbicide application was far greater than that caused by the 

large increase in planted GR cotton acres. Again, management of weed resistance, both that 

already present, and avoidance of future weed resistance was the likely cause of the observed 

increases ((Monsanto, 2013a), Appendix A, A.4.1.4., Analysis of Cotton Herbicide Use From 

2002-2011). For both PRE and POST glyphosate applications, the average numbers per year 

remained relatively stable, about 1.2 for PRE and about 1.7 for POST applications ((Monsanto, 

2013a), Table A-38). Just as observed for PRE applications of non-glyphosate herbicide to 

cotton, POST applications began rising from about 1.5 per season to around 2.2 ((Monsanto, 

2013a), Tables A- 38 and A-40).

APHIS concludes that under the Preferred Alternative the determination of nonregulated status 

for MON 87708 soybean and MON 88701 cotton will likely have considerable impacts on 

herbicide use patterns. Monsanto predicts that at peak adoption, 10.8 million acres will be 

planted with the MON 88701 cotton ((Monsanto, 2013a), Appendix A, A.4.1.5, Table A-40). 

The prediction is based on regional-specific patterns of treatments per acre, the differences 

between no-till (21%) and conventional tillage in herbicide treatments and with the assumption 

that 50% of growers will plant MON 87708 soybean and MON 88701 cotton. The consequences 

of this level of dicamba use for application of other herbicides on cotton were then assessed. 

For PRE cotton herbicides, 100% displacement of diflufenzopyr was likely because of crop 

safety issues, 75% displacement of nine herbicides including paraquat, thifensulfuron, and 

carfentrazone because of crop safety issues, carryover, efficacy or grower preferences, and 50% 

displacement of seven herbicides including 2,4-D, fomesafen, and metolachlor for reasons of 

efficacy, crop safety, weed resistance and convenience ((Monsanto, 2013a), Table A-42). At 

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peak adoption of MON 88701 cotton, 2.6 million acres will not receive these displaced 

herbicides with which these acres otherwise would have been treated. Among the likely 

displaced herbicides, the agronomic risk issues of these in comparison with dicamba shows that 

the displaced have between 2 and 5 issues in which they scored lower than dicamba in efficacy 

of the herbicide, Palmer amaranth resistance in the class, number of resistant weeds to the class, 

long rotational restrictions, or serious crop injury potential ((Monsanto, 2013a), Appendix, Table 

A-55). Among the herbicides that may be replaced, several can be used as both PRE residuals, 

and POST directed-spray herbicides, such as fluometuron, prometryn, and diuron (Steckel, 

2014). Under the Preferred Alternative, MON 87708 soybean and MON 88701 cotton will be

available, and dicamba can be used to prolong the useful activities of these herbicides by 

providing a means for overlapping herbicidal control of problem and resistant weeds. It is more 

likely that weed resistance will not develop as quickly as under the No Action alternative. Under 

the Preferred Alternative, with this HR crop available, growers will be offered an opportunity to

alternate herbicide resistance systems (such as glufosinate and HPPD inhibitor resistant cotton) 

in successive seasons.

Dicamba Volatilization and Drift

Summary: APHIS anticipates that the EPA will approve the registration of the proposed 

new uses of dicamba formulation M1691 (U.S. EPA Reg. No. 524-582) on MON 88701 

cotton and MON 87708 soybean. This herbicide product contains the dicamba 

diglycolamine (DGA) salt which has a lower volatility profile than the dimethylamine 

(DMA) salt or other acid- based formulations of dicamba currently in use. APHIS also 

anticipates that the EPA will approve these proposed new uses on two new products 

containing the BAPMA salt of dicamba (Engenia, Reg. No. 7969-GUL and MON 100111, 

Reg. No. 524-ANO), which are pending at EPA, as well as two Monsanto formulations 

(Reg. No. 524-616 and 524-617). Monsanto will not allow the use of the higher volatility 

DMA salt and dicamba acid formulations on MON 87708 soybean and MON 88701 

cotton (Monsanto 2013a). Consequently, if the EPA registers new herbicide uses for 

MON 87708 soybean and MON 88701 cotton, volatilization and drift issues will not 

likely be substantially different from those for other herbicides on conventional crops 

following a determination of nonregulated status for these crops. The EPA retains 

oversight and regulatory authority for all environmental impacts caused by herbicide 

drift or volatility. APHIS accepts that there are also numerous practical measures that 

good growers will adopt to reduce off-target movement of applied herbicides.

An assumption in the No Action Alternative is that dicamba will be applied increasingly to 

cotton and soybean, because dicamba can be used to control GR weeds. As a result, the acreage 

to which dicamba will be applied may likely increase from 1.4 to 40% of soybean cropland and 

from11.5% of cotton cropland to 50% (Monsanto, 2013b). Dicamba burndown applications on 

cotton and soybean have been steadily increasing since 2006 (see Table 23) since it has activity 

against several GR weeds, often when applied with 2,4-D (Monsanto, 2013a). Current use of 

dicamba for burndown applications in cotton and soybean are 10% and 12%, respectively 

(Monsanto, 2013a). The formulations used under the No Action Alternative are those dicamba 

formulation currently registered by EPA, including both the dimethylamine (DMA) formulation 

and the DGA. The DGA formulation is about 10 times less volatile than for DMA.

150
If MON 87708 soybean and MON 88701 cotton are nonregulated and EPA approves the 

proposed new uses of dicamba on these crops, Monsanto estimates that dicamba would replace 

about one-third of other non-glyphosate herbicides at maximum adoption rates. However, the 

relative use of dicamba on cotton would increase 14.5-fold (Appendix 4, Table 4-12) and on 

soybean 88-fold (Appendix 4, Table 4-9). Potential for off-target impacts would decline because 

growers would be applying the lower volatility dicamba formulation in place of these other 

higher volatility herbicides.

Unlike the No Action Alternative, for the Action Alternatives, APHIS expects that the EPA will 

approve the registration of the proposed new uses of dicamba formulation M1691 (U.S. EPA 

Reg. No. 524-582) on MON 88701 cotton and MON 87708 soybean. This herbicide product 

contains the dicamba diglycolamine (DGA) salt which has a lower volatility profile than the 

dimethylamine (DMA) salt or other acid- based formulations of dicamba currently in use. APHIS 

also expects that the EPA will approve these proposed new uses on two new products containing 

the BAPMA salt of dicamba (Engenia, Reg. No. 7969-GUL and MON 100111, Reg. No. 524-

ANO), which are pending at EPA, as well as two Monsanto formulations (Reg. No. 524-616 and 

524-617). Monsanto will not allow the use of the higher volatility DMA salt and dicamba acid 

formulations on MON 87708 soybean and MON 88701 cotton. Consequently, APHIS deems it 

likely that overall use of more volatile formulations of dicamba may decline if MON 87708 

soybean and MON 88701 cotton are determined as nonregulated. 

Though off-target dicamba effects may be lower for the Preferred Alternative than for the No 

Action Alternative, the use of dicamba may occur over a longer season under the Preferred 

Alternative. This could increase exposure of dicamba-sensitive plants at growth stages later in 

the season than under the No Action Alternative. These offsetting impacts (less volatile 

formulations but potentially greater exposure) make it difficult to predict which Alternative is 

likely to result in more drift and possible plant injury. 

Recently, EPA approved the registration of Enlist Duo herbicide (a premix of 2,4-D and 

glyphosate) for use on 2,4-D-resistant corn and soybean. Measures to limit off-site transport of 

2,4-D choline salt in spray drift have been included as part of the label requirements specified by 

EPA for the registration of Enlist Duo. To mitigate against potential risks to non-target 

organisms or crops, the herbicide label will require specific techniques, such as a 30-foot on-field 

buffer zone and use of a specific nozzle/formulation combination (US-EPA, 2014a). APHIS 

expects the EPA to implement similar appropriate label requirements on the registration of 

M1691 herbicide regarding resistance management.

APHIS recognizes that there are many practical methods available to growers to reduce offtarget herbicide effects. The sources of the movement is either spray particle drift, volatility of 

the herbicide or tank contamination (Boerboom, 2004). York (2014) notes that for 2,4-D, 

growers should always use the the 2,4-D amine, and avoid the 2,4-D ester or acid formulations 

within a mile of cotton production because of large potential for volatile damage; similarly for 

dicamba, the diglycolamine salt is much less volatile than is the dicamba dimethylamine or acid 

formulation (Monsanto, 2013c). Spray drift with auxinics can also be handled adequately with 

200 foot buffers, avoiding nozzles with fine spray output, and not applying these herbicides on 

windy days (which would also be counter to label directions for crop applications) (York, 2014). 

Contamination of tanks can be avoided either by not using previously deployed tanks that 

151
contained auxinic herbicides or by thorough tank cleaning. While inadvertent off-target dicamba 

always provides a potential for injury to cotton or soybean, APHIS emphasizes that grower 

attentiveness to commonsense rules for choosing formulations and practices can substantially

eliminate such incidents of crop injury.

Tillage Practice

Summary: Conventional tillage is increasing in some soybean and cotton growing areas, 

most likely because of increased problems with glyphosate-resistant weeds. This 

conclusion applies especially to Mid-South states, which includes declines in both 

conventional and reduced tillage practices. Production of MON 88701 cotton and MON 

87708 soybean and other newer herbicide-resistant crops may be able to reverse some of 

those trends, especially in the near term, because new HR crops will be available for 

commodity growers experiencing problem weeds. Under the Preferred Alternative, 

adoption of MON 88701 cotton and MON 87708 soybean may help reverse these recent 

trends, allowing some growers to return to using conservation tillage. 

No-till farming practices are centered on effective herbicide-based weed control. Under the No 

Action Alternative increased or more extensive tillage is occurring in certain areas where HR 

weeds are no longer effectively controlled by currently-registered herbicides. More aggressive 

tillage is one effective weed control option. APHIS suggests that adoption of MON 88701 cotton 

and MON 87708 soybean may reverse this trend of increasing tillage that is occurring under the 

No Action Alternative. Reports of increased tillage as a result of GR weeds have already been 

made for cotton and soybean (Shaw et al., 2012; Riar et al., 2013 ). In some Tennessee counties

(included in the region “Mid-South”), the area devoted to conservation tillage decreased by as 

much as 25% in soybean fields infested with GR horseweed (Shaw et al., 2012). As noted 

earlier, survey of regional tillage patterns and expert assessments suggest that problem weeds 

were at least partially responsible for increases in conventional tillage and declines in 

conservation tillage; these conclusions were especially applicable in the Mid-South states (see

Current Management Practices, Section 5.4). To some extent these were similar to other regions 

that showed declines in no-till practices, although these were accompanied with increases in 

reduced till practices.

Under the Preferred Alternative, adoption of MON 88701 cotton and MON 87708 soybean and 

the EPA registration of new dicamba uses on these crops is expected to improve the control of 

GR weeds, decreasing tillage intensity when compared to the No Action Alternative. This 

potential reduction in tillage is most likely to occur with the use of MON 88701 cotton because 

the increase in the use of tillage for weed management has occurred particularly in the 

management of Palmer amaranth in cotton where “researchers recognize that integrated weed 

management (IWM) strategies that include tillage may be necessary” (Shaw et al., 2012). 

Soybean-planted acres that are in direct rotation with corn acres that also have the same weed 

complex will also benefit from the adoption of MON 87708 soybean and facilitation of reduced 

tillage. Midwestern states are beginning to identify GR Palmer amaranth just as in locations in 

the Southern States (Brooks, 2013) and indications are that tillage practices have begun to 

change similar to those observed in the Mid-South states. Under the Preferred Alternative, 

APHIS concludes that control of these GR weeds could improve in both regions, since a 

dicamba-based herbicide strategy using MON 87708 soybean and MON 88701 cotton should 

152
provide herbicide diversity and effective use of dicamba. If dicamba resistant weeds develop, 

growers might consider increased tillage as a remedy. APHIS anticipates that growers who 

practice good stewardship of this technology will attain extended usefulness of MON 87708 

soybean and MON 88701 cotton. However, alternatives will eventually be needed, and thus 

additional effective herbicide strategies may need to be developed, as will new or classic cultural 

or mechanical practices may need to be adopted.

Crop Rotation

Under the Preferred Alternative, adoption of MON 88701 cotton and MON 87708 soybean and 

EPA registration for new dicamba formulations for these crops is not expected to change cotton 

and soybean crop rotational practices. However, if dicamba-resistant weeds reduce the cost 

effectiveness of growing certain crops, rotation practices may need to change. For example (see

Table 19 and Table 20), wheat and small grain crops are sometimes rotated with soybeans (wheat 

22%, barley 1.9%, oats 4.9%) and with cotton (wheat 9.3%, barley, 0.4%). Usage of dicamba on 

wheat crops was either 0.5% (following cotton rotation) or 5% (following soybean rotation ( see 

Table 19 and Table 20). Some growers of small grain cereals rely on dicamba for inexpensive 

weed control. If dicamba was to become ineffective and the cost of alternative herbicides was too 

expensive, these growers may choose not to grow small grains. Input costs are just one factor 

that determines whether a given rotation crop is grown. However, other considerations include 

benefits to the soil, disease management considerations, and economic returns from growing the 

rotation crop. Under the Preferred Alternative, APHIS concludes that minor changes to crop 

rotations are possible, but not likely to be substantial.

153
154

Table 19. Rotational Practices Following Soybean Production in the United States.

This U.S. summary was developed by compiling the data from all three regional summaries. All acreage is expressed as 1000s of acres. 1

Acreage planted of the specific crops is based on 2008 planting data (USDA-ERS, 2012b) “other” crop and newly seeded alfalfa acreages are based on 2008

planting data from the Individual States data which was obtained from Quick Stat searches on

http://www.nass.usda.gov/Data_and_Statistics/Quick_Stats/index.asp.

Originally provided in Petition for the Determination of Nonregulated Status for Dicamba-Tolerant Soybean MON 87708 (Monsanto, 2012a)Table VIII-24 2

Column E is obtained by compiling the data from all three regional summaries.

3

Column F is obtained by dividing Column E by Column D.

4

Column G is obtained by dividing Column E by Column B.

5

Column H is obtained by compiling the data from all three regional summaries.

6

Column I is obtained by dividing Column H by Column E.

7

Column J is obtained by dividing Column B by Column D Total.

8

Column K is obtained by dividing Column H Total by Column D Total.

9

Various vegetables. 

A B C D E F G H I J K

Major Total % % Acreage of % Dicamba % Soybean Estimated

Crops Acreage of Rotational Rotational Rotational Dicamba in Usage in Acres % Dicamba

Total Following Rotational Crop Acres Crop Crop of Rotational Rotational Preceding Usage in

Soybean Soybean in Crop in the Following Following Total Crop Crop Major Major

State Acres1 Rotation U.S.1 Soybean2 Soybean3 Soybean4 Option5 Option6 Rotations7 Rotations8

United 75,037 Corn 80,130 51,500 64.3 68.6 5,053 9.8%

States Soybean 75,037 10,866 14.5 14.5 4,350 40.0%

Sorghum 4,020 841 20.9 1.1

Cotton 3,767 1,570 41.7 2.1 153 9.7%

Wheat 37,414 8,396 22.4 11.2 448 5.3%

Barley 2,159 41 1.9 0.05

Oats 1,995 98 4.9 0.1

Rice 2,301 1,042 45.3 1.4

Alfalfa 1,864 162 8.7 0.2

Sugar Beets 830 144 17.3 0.19

Potatoes 334 32 9.6 0.04

Dry Beans 1,183 35 3.0 0.05

Dry Peas 520 38 7.3 0.05

Millet 250 41 16.4 0.05

Flax 345 76 22.0 0.10

Other9 452 155 31.3 0.20

Total 212,601 75,037 10,004 35.3 4.7
155

Table 20. Rotational Practices Following Cotton Production in the United States. 

A B C D E F G H GI J K L M

Total Acres

Cotton

Acres1

Rotational 

Crops 

Following 

Cotton

Rotational

Crop Acres2

%

Rotational 

Crop of 

Total 

Cotton3

Dicamba 

Usage in 

Rotational

Crop4

Glufosinate 

Usage in 

Rotation Crop5

Glyphosate 

Usage in 

Rotation Crop6

% Usage in Total Rotational Crop

Acres7

% Acres % Acres % Acres Dicamba Glufosinate Glyphosate

United Cotton 5,858 53.4 50 2,930 21. 1,264 90.2 5,284 26.7 11.5 48.2

States Corn 1,736 15.8 8.1 141 6 37 88.0 1,527 1.3 0.3 13.9

10,974 Soybean 861 7.8 50 431 2.1 8 95.9 826 3.9 0.1 7.5

Sorghum 836 7.6 8.3 69 1.0 34.7 290 0.6 2.6

Wheat 1,025 9.3 5.6 57 NL 14.1 145 0.5 1.3

Barley 40 0.4 5.0 NL 27.5 11 0.02 0.1

Peanut 432 3.9 NL NL 21.1 91 0.8

Sunflower 22 0.2 NL NL 72.7 16 0.1

Alfalfa8 47 0.4 NL NL 50 24 0.2

Vegetables9 50 0.5 NL NL 2 1 0.01

Dry Beans 0.5 0.005 NL NL 40.0 0.2 0.002

Peppers 8 0.1 NL NL 37.5 3 0.03

Tomatoes 24 0.2 NL NL 45.8 11 0.1

Onions 6 0.06 NL NL 33.3 2 0.02

Tobacco 0.3 NL NL NL

Total: Total: Total: Total:

10,974 3,630 1,309 8,231 33.1 11.9 75.0

This table was developed by compiling the data from all four regional summaries (Tables VIII-21 through VIII-24 of Monsanto Petition for Dicamba Cotton). All acreages are 

expressed as 1000s of acres.

NL indicates not labeled for use.

1 Cotton acreage based on 2010 planting data (USDA-ERS, 2012b; USDA-NASS, 2014c).

2 Column C is obtained by compiling the data from the four regional summaries.

3 Column D is obtained by dividing Column C by Column A.

4 Column E is obtained by dividing Column F by Column C; Column F is obtained by compiling the data from all four regional summaries.

5 Column G is obtained by dividing Column H by Column C; Column H is obtained by compiling the data from all four regional summaries.

6 Column I is obtained by dividing Column J by Column C; Column J is obtained by compiling the data from all four regional summaries

7 Column K is obtained by dividing Column F Total by Column C Total; Column L is obtained by dividing Column H Total by Column C Total; Column M is

obtained by dividing Column J Total by Column C Total.

8 Newly seeded alfalfa.

9 Vegetables: Cauliflower (37,000 acres), lettuce (271,000 acres), and broccoli (124,000 acres) (USDA-ERS, 2012b).

10 Totals may not be exact due to rounding
General Agronomic Inputs

Adoption of MON 88701 cotton and MON 87708 soybean is not expected to change the general 

agronomic inputs associated with cotton and soybean production except to increase dicamba 

usage. Fertilizer, insecticide, fungicide, and water use are expected to remain unchanged from 

the No Action Alternative.

5.6.3 Socioeconomics 

Potential Impacts of Dicamba-Resistant Weeds on Production Practices for Other Crops and 

Grower Economics

To analyze the potential impacts from increased selection for dicamba-resistant weeds under the 

Preferred Alternative, APHIS assumed that the greatest potential for impacts would be in regions 

where appreciable acres of cotton or soybean were grown in proximity to appreciable acres of 

crops that already use dicamba for weed management.

This impact is likely to be highest in crops grown in rotation with MON 87708 soybean and 

MON 88701 cotton. Corn is the largest crop grown after soybean, followed in frequency by

soybean again, then wheat, cotton and rice (Table 19). When moisture is adequate, growers in 

southern Indiana, Illinois, Missouri and Arkansas may double-crop winter wheat and soybeans in 

the same year. This leads to rotation of much of the winter wheat in this area with soybeans. 

However, there are no accurate ways of determining exactly what land is rotated from corn or 

soybean to other crops reliant on dicamba for weed control. The rotation varies by region, such 

that for the eight state Southeast region, where soybean most frequently follows soybean, then 

corn, cotton, wheat and rice (ER Table VIII-26, (Monsanto, 2012a)). Cotton again is the largest 

crop grown following cotton (i.e., continuous cotton), followed by corn, wheat, soybean and then 

sorghum (Table 20).

Selection of dicamba-resistant weeds in cotton or soybean may cause some types of cumulative 

impacts on other regional crops. APHIS conservatively assumed that proximity of other 

dicamba-treated crops to dicamba-treated MON 87708 soybean and MON 88701 cottoncould 

facilitate the potential impacts. The APHIS analysis is based on percentage of cropland devoted 

to cotton and soybean and the percent of cropland devoted to crops to which dicamba is applied 

in each region. Table 17 identifies the major crops onto which dicamba is applied. Crops include: 

small grains (e.g., barley, oats), corn, cotton, sorghum, soybeans, sugarcane, and wheat. APHIS 

also obtained the percent of regional cropland devoted to other major rotational crops of each 

region. These data are summarized in Table 21. 

Regions D, E, F, and J are areas where cotton and soybean production are predominant (at least 

>45% of crop acres) and could potentially be at greater risk for development of dicamba resistant 

weeds. Crops which receive applications of dicamba are components of this landscape (see Table 

17. In Regions L and M, cotton (no soybean) is of modest acreage and not expected to contribute 

to the cumulative impacts because there are few crops grown in these regions on which dicamba 

are applied. Region K has sorghum associated with a modest cotton crop, and selection of 

dicamba-resistant weeds may have possible impact on sorghum production. In contrast, Regions 

D, F, and I, represent areas where cotton and soybean, and other crops onto which dicamba is 

156
applied are grown frequently in rotation and in proximity of one another (shaded in gray in Table 

21).

Region J has frequent co-planting of cotton and wheat, which may be supportive for generating 

dicamba-resistant weeds and be difficult to suppress if dicamba were used frequently in wheat. 

However, use of dicamba on wheat amounts to only 8% [winter wheat] on these crops (see Table 

17) and so alternatives to dicamba are being used and loss of dicamba usage because of dicamba 

resistant weeds would not be an insurmountable problem to control of weeds in wheat. Region D 

includes the coastal Southeast and the Northeast to Pennsylvania. Principal crops to which 

dicamba is applied in this region are corn and wheat which together make up 43% of the crops

grown. Soybean and cotton account for 53% of the crop acreage. With a large percentage of the 

acreage potentially planted to MON 87708 soybean and MON 88701 cotton, and another two 

crops to which dicamba would be applied (cotton other than MON 88701) as a pre-plant and 

wheat as a post-emergent), this region may have an increased potential to generate dicambaresistant weeds. If dicamba-resistant weeds become widely prevalent in these regions, growers of 

dicamba appropriate rotation crops would be affected, although those who are affected could

change their management practices.

Region F includes southern states bordering the Mississippi River (Louisiana, Mississippi, 

Arkansas, Tennessee, and Missouri). Soybean is a principal crop for 51% of acres, and other

crops that have dicamba applied in this region are wheat, cotton, and sugarcane (although 

sugarcane has limited rotation potential). This region has a high incidence of GR weeds. 

Therefore, the potential for selecting weeds with multiple resistance to both glyphosate and 

dicamba is higher relative to other regions. However, because dicamba only controls broadleaf 

weeds, herbicides with different modes of action will have to be used to control grasses. This 

will reduce the likelihood of multiple resistance because growers will not be able to depend 

exclusively on herbicide formulations labeled for MON 87708 soybean and MON 88701 cotton, 

and because of losses recently experienced with GR weeds, they will have another incentive to 

use best management practices. By employing a range of other management techniques they can 

reduce the risk of multiple resistance in weeds. In addition, the EPA has the authority to address 

weed resistance by modifying the labeled uses of dicamba to mitigate risks of developing 

multiply resistant weeds. 

Region H includes parts of western North and South Dakota. The major crop in this region is 

wheat on which dicamba may be applied. Acreage for wheat in this region (34% of acres) is 

somewhat lower than that for corn and soybean together (46% of acres). A large percentage of 

the crops could have dicamba applied, and these may enhance the potential for development of 

weed resistance.

Region I consists of central Kansas, Nebraska, and part of Oklahoma. Major crops in the region 

that may receive dicamba treatment are wheat, cotton, sorghum, and small grains. Soybean is 

about one fifth of the crop acreage and potentially could be replaced with MON 87708 soybean, 

while 43% of the other crops would use a modest amount of dicamba. This region could 

potentially see an increased development of weed resistance to dicamba.

Region J consists of a part of north-central Texas. This region most frequently grows cotton. 

Crops that receive applications of dicamba include small grains, cotton, and sorghum. In both 

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Regions I and J, other crops receiving applications of dicamba exceed the amount of cotton and 

soybean that is grown. Determinations of nonregulated status for MON 87708 and 88701 could 

increase the potential for development of weed resistance to dicamba in several crops. 

Cumulative impacts are not expected in Region J under Alternative 4 (nonregulated status of 

MON 87708 soybean, only) or in the case that MON 88701 cotton is not widely adopted in this 

region.

Table 21. Percent of Regional Cropland Devoted to Crops on which Dicamba is Used in 

Each EcoRegion.

Percent of Regional Cropland

Ecoregion Crops on which dicamba is used (table also includes other important crops) Total Total

Corn Soy Wheat

Oat, 

Barley, 

Millet Cotton Rice2 Sorghum Alfalfa1

Nut 

and 

Fruit 

Trees1

% of 

Cropland 

in 

Cotton +

Soy

% of 

Cropland 

in Other 

Crops 

Using 

Dicamba

A 48 18 6 2 18 18 56

B 53 26 3 15 26 56

C 53 40 3 3 40 56

D 28 32 15 21 <1 53 43

E 52 46 7 1 <1 47 59

F 51 20 10 12 11 1 32 72

G 45 40 8 40 53

H 26 20 34 3 20 60

I 34 23 33 1 12 9 35 76

J 2 0 39 54 6 54 47

K 13 0 26 6 48 6 26 67

L 12 0 12 6 25 40 25 30

M 9 0 14 10 13 28 10 23

Multiple crops may be grown the same year: double cropping of wheat for example, is common. Regions shaded in gray 

indicate areas where cotton and soybean are major crops (>40%) and other dicamba using crops are also widely prevalent 

(>40%). 

1. No dicamba use

2. Little or no dicamba use

Possible Economic Impacts of MON 87708 Soybean and MON 88701 Cotton on Rotation Crops 

on Which Growers Use Dicamba

Summary: Production of minor crops in ecoregions where soybean, cotton and corn are 

major parts of the landscape (i.e., those crops that represent a small proportion of total 

crop acreage), are not likely to be impacted by the potential development of new 

dicamba-resistant weeds. APHIS considered whether the possibility of dicamba-resistant 

weed developing in cotton or soybean would lead to new problem weeds in typical 

rotation crops. APHIS concludes that in the use of dicamba for fallow and burndown, 

there are several other herbicides that may be used in the same price range, in the event 

158
that dicamba resistant weeds were to develop. Although use of any herbicide requires 

consideration of cost, efficaciousness, plant-back considerations and problem weeds, and 

the possibility of new dicamba resistant weeds appearing, then any increases in costs for 

weed control in some crops may be acceptable. In the case of sorghum, it appears that 

dicamba resistant weeds would be controllable by availability of at least some of the 

alternative herbicides. An APHIS determination of nonregulated status would not cause 

large impacts to pasture and rangeland by diminished effectiveness of dicamba because 

use of dicamba is relatively small, mechanical and cultural techniques are relatively 

important and numerous other herbicide choices are available. For small grains, cost 

comparative alternatives exist, including those effective on broadleaf weeds, but some 

alternatives require more restrictions and may be more costly. Other tillage and 

cultivation possibilities that are practical present themselves in the event of developing 

dicamba resistant weeds, however. Should dicamba resistant weeds develop in 

conventional corn (that is, not dicamba resistant) no appreciable impacts on corn are 

expected, since only 12% of the corn producers are using dicamba, and there are a 

number of alternative choices available for burndown use, both for PRE and POST 

applications. APHIS concludes that additional choices for control of multiply resistant 

weeds in soybean (such choices are increased with dicamba resistant varieties) may also 

be helpful for corn production, which is a frequent rotation crop, and this benefit may 

outweigh possible impacts of the loss of dicamba usefulness in corn production.

To evaluate how crops on which dicamba is currently used for weed control might be impacted if 

dicamba-resistant weeds become more prevalent, APHIS examined the management options and 

costs for weed control in these crops. Weed control programs vary by crop, weed problem, 

geography, and cropping system (e.g., no-till, conventional-till, etc.). In those crops where it is 

labeled for use, dicamba is usually just one part of a much broader weed management strategy. 

Many growers use a combination of weed control techniques including cultural, mechanical, and 

chemical. APHIS is aware that the weeds of importance in one crop (e.g., soybean) are not 

necessarily the same ones that are problem weeds in a rotation crop (e.g., wheat). Thus, the 

potential impacts from a dicamba resistant weed species arising in soybean may not have a 

similar impact on wheat crops. 

From a 2012 BASF market estimate of agricultural uses of dicamba (Monsanto, 2014a), APHIS 

identified eight crops (or fallow cropland) where as much as 8% of the crop is treated with 

dicamba (Table 17). Many of these, (e.g., small grains) are managed similarly and are considered 

together. For each crop, or group of similar crops, APHIS considered the types and cost of 

herbicides that are used for broadleaf weed control. APHIS focused on post-emergent, broadleaf 

weed control, as this is the primary use of dicamba in these crops.

Pasture

One important agricultural use of dicamba is for broadleaf weed control on pastures, as noted in 

Table 17. 

Alternative Herbicides and Management Options

Effective management of weeds in pasture and rangeland usually involves a combination of 

cultural, mechanical, and chemical methods. The primary means of controlling weeds is proper 

management of desirable forage grasses and legumes. Overgrazing is a major cause contributing 

159
to the establishment and proliferation of weeds. Low soil fertility in pastures also contributes to 

weed problems. Some degraded pastures can be revitalized by reseeding or inter-seeding to 

improve forage growth and competition. For some situations, burning or mowing can stimulate 

forage grass growth and suppress weeds. Combined with well-timed herbicide applications, these 

methods can effectively manage weeds (Martinson and Peterson, 2013).

Other methods that have a definite place in range management are: chemical, roto-beating, 

plowing, disking, railing, chaining, burning, reseeding, and changes in grazing schedules. There 

are specific sites and reasons for use of the controls listed. Each is effective if used properly 

(Prather, 2014).

Table 22 shows a range of herbicide products that are currently registered for pastures and 

rangeland and their estimated costs. Herbicide alternatives to dicamba that provide reasonable 

low-cost herbicide control are shaded in gray. Most pasture is not treated with herbicide. 

Mowing is a non-chemical control method that is often used and is estimated to cost $13.95/acre 

in Nebraska (University of Nebraska, 2012).

Table 22. Post-emergence Broadleaf Herbicides Commonly Used in Pastures 

and Rangeland.

Herbicide

(common name)

MOA1 Rate

(lb ae or ai/A)

Cost

$/Acre

2,4-D 4 1-2 5.00-10.00

Aminopyralid 4 0.06-0.11 16.12-32.11

Metsulfuron 2 0.06-0.6 1.35-13.53

Carfentrazone 14 0.015-0.031 1.70-3.40

Chlorsulfuron 2 0.19-1.0 5.00-25.08

Clopyralid 4 0.14-0.375 13.33-35.70

Dicamba 4 0.5-1.5 9.99-29.97

Fluroxypyr 4 0.6-0.72 20.63-24.76

Picloram 4 0.25 7.50

Triclopyr 4 0.25 3.75

Hexazinone 5 0.67-1.12 25.54-42.69

Paraquat 22 0.25-0.5 3.98-7.96

Tebuthiuron 7 0.4 16.00

Source: (Texas Cooperative Extension)

1

Weed Science Society of America mode of action category

Note: Alternative low cost herbicide options to dicamba are shaded.

lb ae/A = pounds acid equivalent per acre

lb ai/A = pounds active ingredient per acre

Potential Impacts to Pasture and Rangeland from Increased Weed Resistance

Although, according to BASF market estimates, pasture and rangeland represents the fourth 

largest agricultural use of dicamba, most pasture and rangeland is not treated with herbicides. 

Non-chemical options are most often used, and there are similarly priced chemical alternatives to 

dicamba (Table 22). Healthy stands of forage pastures tend to exclude weeds, and good 

160
management includes mechanical, cultural, biological as well as chemical controls, so a variety 

of weed control methods are typically used, that may or may not use herbicides (Green et al., 

2006). The cumulative impacts on pasture and rangeland would be the diminished utility of 

dicamba if used, because of selection for dicamba-resistant weeds in crops rotated with MON 

87708 soybean and MON 88701 cotton. APHIS concludes that even if dicamba-resistant weeds 

became more prevalent, the cumulative impacts to pasture and rangeland weed management are 

expected to be small under all the Alternatives. 

Small Grains (Wheat, Barley, Oats)

Spring wheat applications of dicamba have declined from 12% to 5% of acres from 2006 to 

2012, respectively (USDA-NASS, 2014d), in NASS’s seven program states16 (USDA-NASS, 

2005a). Applications to winter wheat17 increased from 8% to 15% in that same period in USDANASS’ 15 program states. Conditions are usually very favorable to winter wheat growth in the 

fall, and the crop out-competes many weeds. About 96% of spring wheat was treated with 

herbicide, while about 57% of winter wheat was treated. Wheat may be rotated with corn or 

soybeans. In some areas such as Indiana, Illinois, Kentucky, Missouri, and Arkansas, winter 

wheat is often planted with the intent to double crop with soybeans the same season. Winter 

wheat is harvested (usually in June) and soybeans are planted in no-till wheat stubble when there 

are favorable moisture conditions (North Dakota State University; Moechnig and Wrage, 2012). 

In 2003 and 2011, 5% of barley acres received applications of dicamba (USDA-NASS, 2014d)

and 88% of barley acres were treated with herbicides in NASS’s program states.

18 Market 

reports indicate that the use of dicamba in barley has been declining since 2008 (Table 23) 

(Monsanto, 2014a). 

Table 23. Changes in Dicamba Application to Crops 2006-2012.

Year 2006 2008 2010 2012

Crop Dicamba-Treated Acres

Corn 8,080,614 8,113,801 6,459,632 11,919,844

Fallow 2,144,260 3,017,717 4,274,678 6,665,140

Wheat, Winter 2,348,897 3,742,572 2,577,953 3,622,102

Pastureland 1,454,649 1,218,179 2,604,944 3,221,382

Wheat, Spring 1,569,079 1,351,665 1,512,894 1,804,742

Sorghum (Milo) 550,795 1,114,162 955,997 1,683,584

Cotton 590,953 589,919 854,649 1,455,309

Soybeans 279,275 529,638 648,509 1,055,926

Sugarcane 198,042 177,089 225,295 190,317

Barley 108,393 211,067 101,158 47,144

Source: BASF market data. In Monsanto NOI supplement (Monsanto, 2014a)

Alternative Herbicides and Management Options

16 Arkansas, Minnesota, Montana, North Dakota, Oregon, South Dakota, Washington.

17 Program States 2012: CO, ID, IL, KS, MI, MO, MT, NE, OH, OK, OR, SD, TX and WA (USDA-NASS, 2013b)

18 Program States 2011: AZ, CA, CO, ID, MN, MT, ND, OR, PA, VA, WA, WI, and WY (USDA-NASS, 2012 ).

161

 
A wide range of herbicide products are currently registered for small grains that could replace 

dicamba. Use of pre-plant or pre-emergence herbicides occurs on a small portion of grain 

acreage usually with 1-2 post-emergence applications. Post-emergence graminicides are often 

used to control grass weeds such as wild oats and foxtail. Many different herbicides are available 

for post-emergence broadleaf weed control. Dominant modes of action in small grains are auxins 

(WSSA Group 4) and ALS inhibitors (WSSA Group 2). While one auxinic class herbicide, 2,4-D 

is a widely used herbicide for these crops, it does not provide acceptable control of some key 

broadleaf weeds such as kochia and wild buckwheat (Zollinger et al., 2006). Glyphosate and 2,4-

D treatments are often combined with one of the herbicides listed in Table 24 (Zollinger et al., 

2006).

A number of alternative herbicides and estimated costs are listed in Table 24. Chlorsulfuron, an 

ALS inhibitor for example, can provide control similar to dicamba at low cost (Zollinger et al., 

2006; Zollinger, 2014). However, resistance to ALS inhibitors is widespread. The cost of some 

other products is similar, such as pyrosulfotole and bromoxynil or premixes of both, which 

provide high levels of control of some key broadleaf weeds, such as kochia and also wild 

buckwheat (Zollinger et al., 2006).

Some non-chemical control methods can also substitute for dicamba or enhance other control 

measures. Weeds such as common lambsquarters and common ragweed often germinate early in 

the spring. Tillage just before spring planting can eliminate the major flush of these early 

emerging weeds. A 2009 USDA report on custom tillage rates estimated the cost of harrowing at 

$7.30-8.40 per acre in Kansas (USDA-NASS, 2009f). Crop rotation is a recommended weed 

management practice, providing a tangible, recognized level of control where practiced, and this 

cultural means of control is often an important part of an integrated weed control plan.

Table 24. Post-emergence Broadleaf Herbicides Currently Approved for Use in Wheat, 

Barley, Oats, and Rye.

Herbicide

(common name) MOA1 Crops2

Rate

(lb. acid 

equivalent or 

active 

ingredient/A)

Cost

$/Acre Comments

2,4-D amine 4 WW, SW, B, 

O, R 0.25-0.5 1.15-2.30

MCPA 4 WW, SW, B, 

O, R 0.25-0.5 1.30-3.20 Similar in spectrum to 2,4-D

Bromoxynil 6 WW, SW, B, 

O, R 0.25-0.5 8.80-19.05

Carfentrazone 14 WW, SW, B, 

O, R 0.008-0.031 4.00-15.10

Chlorsulfuron 2 WW, SW, B, 

O 0.008-0.015 3.60-7.05

Clopyralid 4 WW, SW, B, 

O 0.09-0.12 16.80-

22.15

Dicamba 4 WW, SW, B, 

O, R 0.06-0.12 2.30-5.25

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Herbicide

(common name) MOA1 Crops2

Rate

(lb. acid 

equivalent or 

active 

ingredient/A)

Cost

$/Acre Comments

Pyrasulfotole 27 WW, SW, B, 

O 0.028-0.038 8.50-11.55 Available only in premix w/ bromoxynil

Florasulam 2 WW, SW, B, 

O 0.004 7.20 Available only in premix w/ MCPA

Fluroxypyr 4 WW, SW, B, 

O 0.11-0.14 10.60-

14.15

Thifensulfuron 2 WW, SW, B, 

O 0.014-0.019 15.95-

31.85

Tribenuron 2 WW, SW, B 0.008-0.16 4.70-9.35

Metsulfuron 2 WW, SW, B 0.004 1.50

Prosulfuron 2 WW, SW, B, 

O 0.009-0.018 3.65-7.25

Pyraflufen 14 WW, SW, B, 

O, R 0.0008-0.0016 1.65-3.30 Primarily pre-plant but can be applied 

POST

Triasulfuron 2 WW, SW 0.013-0.026 3.00-6.05

Imazamox 2 WW, SW 0.031-0.047 16.25-

24.40 Clearfield varieties only

Alternative low cost herbicide options to dicamba are shaded.

1. WSSA Mode of Action

2. Crops labelled for use

Abbreviations:

B=barley; O=oats; SW=spring wheat; R=rye; WW=winter wheat 

Source: (DAS, 2013b)

A final note on potential future impact of dicamba resistant crops is that Monsanto has been field 

testing dicamba- and glufosinate- resistant wheat, and dicamba-resistant canola as well. These 

products are not likely to have any near term availability, and any predictions about their status 

would be highly speculative at the present time.

Potential Impacts of Dicamba-Resistance on Small Grains

Winter wheat, spring wheat, barley, and oat growers often do not use herbicides. When needed, 

dicamba provides an inexpensive and effective weed management tool especially for some 

weeds not controlled by some other herbicides, such as wild buckwheat. As noted in the 

discussion that follows, there are several areas where these crops are rotated with either cotton or 

soybean or grown in proximity. If dicamba-resistant weeds were to develop in cotton and 

soybean fields, it is likely that they could eventually be found in wheat and small grain crops on 

rotated with MON 87708 soybean and MON 88701 cotton acreage or on neighboring farms. 

MCPA and 2,4-D are low priced, common alternatives, but if applied to emerged wheat can 

cause damage, and as noted, may not control key weeds (Johnson and Nice, 2009). Other low 

cost herbicides, such as the ALS inhibitor chlorsulfuron, may not be as effective because of 

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widespread resistance to ALS inhibitors. Pyraflufen is a low-cost PPO inhibitor that is usually 

used pre-plant. It cannot be used post-emergent (unlike dicamba) on small grains except wheat, 

and it has more restrictions than dicamba when used on wheat. Most likely, APHIS concludes 

that alternative chemical control options would be more expensive and that some chemical 

alternatives are less flexible. APHIS concludes some potential cumulative impacts to wheat and 

small grain growers if dicamba-resistant weeds become more prevalent, but alternatives to 

control weeds in small grains may still be effective for many growers. 

Fallow and Burndown Uses 

For many crops, including soybean, dicamba has been used in mixes with other herbicides such 

as glyphosate, 2,4-D, glufosinate, or paraquat in the spring or fall as a “burndown” herbicide 

prior to planting, especially in connection with a glyphosate- or glufosinate-resistant crop 

(PennState-Extension, 2013a). This timing may extend anywhere from 0-30 days prior to 

planting, depending on the crop, geography, and product used. It is used to improve control of 

winter annuals, perennials, and early-emerging, summer annual weeds. Examples of weeds 

controlled include shepard’s purse, marestail, dandelion, common lambsquarters, and giant 

ragweed. When used as a burndown, its control of broad leaf weeds is excellent, but control of 

Palmer amaranth may not be as effective as that achieved by flumioxazin (Edwards et al., 2012). 

More recent recommendations include mixtures of flumioxazin (residual) with diuron or with 

paraquat (foliar active herbicides) (University of Georgia CAES Extension, 2014).

Often burndown herbicides are a critical part of an overall weed control program since these 

remove weeds that will be competing with the crop as it emerges. Burndown herbicide 

applications are almost obligatory for no-till crop production systems where tillage is not desired. 

Use of no-till crop culture is common in corn, soybeans, cotton, and wheat. Both soybeans and 

cotton are largely planted as GR varieties and glyphosate is an important herbicide used in postemergent weed control. For wheat managed with herbicides, burndown applications are popular 

but there are post-emergent options including bromoxynil and pyrasulfotole, provided these are 

applied in early stages of wheat growth (Johnson and Nice, 2009; Zollinger, 2014).

Fallowing (land left plowed or disced lightly but not sown to crops) is used in arid areas of the 

plains and the West as a means to store soil moisture for a following crop. Fallow may 

encompass the summer season but is usually applied to a longer period of time (often 4-12 

months). Weed control on fallowed acres is critical for reducing moisture loss. While tillage is an 

alternative to herbicidal control, it is usually less desirable because it increases erosion, adds 

costs of fuel and labor, and enhances soil moisture loss (Simmons and Nafziger, 2012; 

Fernandez-Cornejo et al., 2013).

Alternatives to Dicamba

Herbicides effective for burndown and foliar activity on broadleaf weeds are listed in Table 25. 

Depending on the crop to be planted and the target weed species, these products can offer an 

alternative to dicamba, with some at greater cost. In several cases, these herbicides offer some 

advantages over dicamba such as longer residual control. 

164
Some non-chemical control methods can also substitute for dicamba or enhance other control 

measures. Tillage can substitute for herbicide applications to remove weeds before planting 

except where no-till conditions are desired (Croissant et al., 2008). Using a price for diesel of 

$3.50 per gallon, the fuel cost for tillage ranges from $19-25/acre using the USDA energy 

estimator for tillage in Iowa, North Carolina, and Arkansas (USDA-NRCS, 2013b). 

Table 25. Herbicides Available for Use on Fallow and for Burndown.

Herbicide

(common 

name)

MOA1 Crops2

Rate

(lb acid 

equivalent or 

active 

ingredient/A)

Cost

$/Acre Comments

2,4-D amine 4 C, SB, CT, SG 0.25-0.5 1.15-2.30

Atrazine 5 C 1.0 3.20

Isoxaflutole 6 C 0.05-0.09 14.90-29.80

Chlorimuron 14 SB 0.033 8.10 Usually in combination with 

metribuzin ($18/Acre)

Metribuzin 5 C, SB 0.5-0.75 5.60-8.50

Often at lower rates in 

combination w/ other 

herbicides

Dicamba 4 C, SB, CT,SG 0.25 5.25

Mesotrione 28 C 0.18-0.24 32.00-41.00

Glyphosate 9 C, SB, CT, SG 1.0-1.5 4.00-6.00

Flumioxazin 14 CT, SB 0.05-0.1 9.00-18.00

Sulfentrazone 14 SB 0.14-0.375 23.60-63.00 Obtained at lower cost in 

premixes

Saflufenacil 14 C, SB, SG 0.02 5.45

Paraquat 22 C, SB, CT, SG 0.5-1.0 9.00-18.00

Glufosinate 10 C, CT, SB 0.53-0.66 13.60-16.85

Iodosulfuron 2 C, SB 0.0019 7.20 Fall only for soybeans, up to 

30 days before corn

1

WSSA mode of action category

2

C=corn, SB=soybean, CT=cotton, SG=small grain

Alternative low cost herbicide options to dicamba are shaded.

Source: (DAS, 2013b)

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Potential Impacts of Dicamba Resistance on Fallow and Burndown Applications

Under the Preferred Alternative, development of weed resistance to dicamba would have limited 

impact on fallow and burndown applications because numerous herbicides are available, and 

mixes of glyphosate with 2,4-D or atrazine complements glyphosate effectiveness (University of 

Nebraska Extension, 2014). Important or resistant weeds may be controlled by various herbicides 

or combinations, and as the University of Nebraska Extension presents for corn, 31 combinations 

or single herbicides are recommended as broadleaf burndowns for corn alone; soil-active 

residuals (such as flumioxazin) also may be mixed into the burndown application (University of 

Nebraska Extension, 2014). Soybean burndown in Nebraska has about 20 choices, of which five 

are glyphosate or a tank mixture with glyphosate. Certain weeds (e.g., lambsquarters) have 

always been tolerant of glyphosate and are more effectively controlled by other herbicides. 

Several herbicides priced similar to dicamba are available for general weed management. For 

specific weed applications, many recommended herbicides are more costly. However, when 

weed pressure of certain species has become high, growers will necessarily choose these to 

provide efficacious control. Each grower selection takes into account crop selectivity (plant back 

limits), problem weeds, application requirements and cost. APHIS concludes that loss of 

dicamba as an effective herbicide may increase management costs in some cases. Crops that may 

be adversely impacted include cotton, soybean, corn, and possibly wheat. 

Corn

Dicamba is used on about 12% of U.S. corn and unavailability of dicamba treatment options 

because of dicamba resistant weeds in corn could require that growers choose other herbicides, if 

available. Since soybean is followed by corn 64% of the time, the possibility of dicambaresistant weeds arising in corn may be a relevant issue. A large number of herbicide alternatives 

are available for weed control in corn. Iowa State (2014b) for a herbicide effectiveness rating 

chart lists 10 PRE herbicides and 23 POST choices. For burndown options in no-till corn, Penn

State Extension (PennState-Extension, 2013b) lists14 herbicides used alone or in combinations 

with other herbicides. Various Amaranthus species can be problem weeds because of multiple 

herbicide resistance, and PPO-, HPPD-, ALS- and glyphosate-resistant weeds are known in 

Iowa. (Owen, 2014b) For preplant use, if these resistant weeds are not present, seven of ten of 

the Iowa-listed herbicides give good to excellent control. For POST use, 17 of the 23 herbicides 

have good to excellent effectiveness.

Potential Impacts of Dicamba-resistant Weeds on Corn

While the potential for dicamba-resistant weeds arising in soybean and then found in corn 

following typical rotations is a possible consequence of MON 87708 soybean production, 

sufficiently broad numbers of choices of alternative corn herbicides are available. Some of the 

Ameranthus with resistance to various herbicide classes may be more likely controllable with a 

new option for POST dicamba treatment in soybean. APHIS concludes that dicamba may not be 

usable in field corn, in which at present it is only modestly deployed, but that the loss of dicamba 

utility may be outweighed by the benefits of having new control measures for resistant weeds in 

soybean.

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Sorghum 

Sorghum is most commonly rotated with wheat, corn, and soybean (Bean and Trostle, 2013). In 

Texas, sorghum is also rotated with cotton, and sometimes peanuts.

A number of herbicide products are currently labeled for sorghum. Herbicide management for 

sorghum can include burndown, pre-emergence, and post-emergence herbicide applications. Preemergence applications typically use atrazine in combination with an acetamide such as 

metolachlor. Post-emergence herbicides such as 2,4-D, atrazine, dicamba, bentazon, and 

bromoxynil are used to control broadleaf weeds that escape the pre-emergence treatment. These 

herbicides may be combined in premixes or tank mixes to broaden the weed control spectrum. 

Common combinations include 2,4-D with atrazine, dicamba with atrazine, and bromoxynil with 

atrazine (Kansas State University Agricultural Experiment Station and Cooperative Extension 

Service, 2014). In-season row cultivation has been used in the past to control weeds, but it is less 

commonly used today because it requires costly fuel and labor expenses (Kansas State 

University Cooperative Extension, 1998).

Alternative Herbicides and Management Options

Several possible alternative herbicides for weed control in sorghum and their estimated costs are 

summarized in Table 26. Atrazine, pendimethalin, saflufenacil and 2,4-D/atrazine mixtures are 

effective on a variety of broadleaf weeds and are similar in cost (Moechnig et al., 2010). 

Some non-chemical control methods can also substitute for dicamba or enhance other control 

measures. Weeds such as common lambsquarters and common ragweed often germinate early in 

the spring. Tillage just before planting can eliminate these early emerging weeds. A 2009 USDA 

report on custom tillage rates estimated the cost of harrowing at $7.30-8.40 per acre in Kansas 

(USDA-NASS, 2009f). In season row cultivation provides another, non-chemical alternative and 

costs between $7.00 and $8.00 per acre (University of Nebraska, 2012).

Table 26. Post-emergence Broadleaf Herbicides Currently Available for Use on Sorghum.

Herbicide

(common 

name)

MOA1

Rate

(lb acid 

equivalent or 

active 

ingredient/A)

Cost

$/Acre Comments

2,4-D amine 4 0.25-0.5 1.15-2.30

Atrazine 5 1.0 3.20

Bromoxynil 6 0.25-0.5 8.80-19.05

Carfentrazone 14 0.008 4.00

Bentazon 6 0.5-1.0 12.60-25.20

Not a recommended 

tank mix on label but 

not prohibited.

Dicamba 4 0.25 5.25

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Herbicide

(common 

name)

MOA1

Rate

(lb acid 

equivalent or 

active 

ingredient/A)

Cost

$/Acre Comments

Prosulfuron 2 0.009-0.018 3.30-6.60

Halosulfuron 2 0.03 12.50

*Alternative low cost herbicides to dicamba are shaded.

1 WSSA mode of action category.

Source: (DAS, 2013b)

Potential Impacts of Dicamba-Resistant Weeds on Sorghum

If dicamba-resistant weeds were to become a problem, sorghum growers would likely have 

additional choices of herbicides. 2,4-D may be applied with other herbicides such as 

carfentrazone (a PPO inhibitor) for more rapid activity to improve control. Weeds effectively 

controlled with 2,4-D, include ragweed, pigweed, and lambsquarters, but atrazine- and ALSresistant biotypes may exist for these weeds. Therefore, APHIS concludes that if dicambaresistant weeds become a problem, weed management costs for sorghum would not likely 

increase, since alternatives exist, but alternatives may be somewhat limited. 

Rice 

Rotating rice with corn or soybean is limited to the Mississippi River Valley and Texas 

(Louisiana State University Research and Extension, 2013; University of Arkansas, 2013). In 

2008, rice followed soybean in 1.4% of overall planted soybean acreage (Table 19). As indicated 

in Table 21, for Region F, rice production rises to 11% of acres of the region. Although rice is 

not a registered usage of dicamba, another auxinic herbicide, 2,4-D, was used on 13% of planted 

fields (USDA-NASS, 2014d). However, there is no information about cross-resistance of weeds 

to dicamba in rice; therefore, this is not further discussed within Cumulative Impacts.

Non-MON 88701 Cotton 

Cotton is rotated with other crops less than one-half the time (Table 20). In Texas and the High 

Plains, for example, few other crops are productive in the conditions of low rainfall and high heat 

favorable for cotton cultivation. In drought years, dryland cotton may be abandoned on a large 

percentage of these acres (Smith, 2013). Mostly in the mid-South, rotations are more common. 

There, cotton may be rotated with soybeans or corn (University of Georgia CAES Extension, 

2014). Most dicamba applications are made prior to planting, with some made in the late fall 

(Monsanto, 2014a). If growers were to plant cotton varieties other than MON 88701and use 

dicamba as an herbicide after having produced a MON 88701 cotton crop in the previous season, 

they would not be making an appropriate choice, since rotation of herbicides is an important 

principle of weed management. Grower decisions to repeatedly use dicamba-based weed control 

will determine whether dicamba-resistant weeds become an issue or not.

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Weed Management Programs and Options 

Cotton is an annual crop that is usually planted in wide rows (38-40 inches apart). Use of no-till 

is common in cotton and herbicides are an important means of weed control. Currently, most 

cotton varieties in the U.S. are glyphosate-resistant, so glyphosate is the primary herbicide used. 

A common cotton production practice is application of a pre-plant or pre-emergence, soilresidual herbicide followed by 1-2 post-emergence treatments usually with glyphosate. The soilresidual herbicides include a range of modes of action. Although a large portion of cotton 

acreage was once treated only with post-emergence applications of glyphosate or with a 

glyphosate burndown (Givens et al., 2009), this practice is declining because GR weeds are now 

widely prevalent in cotton fields. Glufosinate-resistant cotton varieties are increasingly being 

used (e.g., in a five state region of the mid-South, these crops accounted for 33% of all 

professionally surveyed cotton acres), so post-emergent glufosinate applications are replacing 

glyphosate for some growers (Riar et al., 2013). 

Recent recommendations for cotton production in those areas experiencing GR weeds in 

glyphosate-resistant crops would include a burndown with multiple herbicides, a pre-emergent 

treatment with residual herbicides, post-emergent herbicide treatments of glyphosate and a 

residual broadleaf herbicide or graminicide, and perhaps layby application to keep weeds 

controlled until canopy closure (Marshall, 2012; Bond et al., 2014). Because cotton is naturally 

sensitive to dicamba, 2,4-D and other auxinic herbicides, the current use of dicamba for this crop 

is limited to pre-plant burndown or fall application. 2,4-D is sometimes added to burndown 

applications to improve control of winter annuals, perennials, and early emerging summer annual 

weeds and was used on about 7% of cotton acres in a 2010 survey (USDA-NASS, 2014d) and 

dicamba at 8 percent during that same season. Estimates for 2011 suggest that on cotton, 2,4-D 

was used on 17 percent of acres and dicamba on 10 percent (Monsanto, 2013a). Burndown 

occurs 0 to 30 days prior to planting depending on crop, geography, and product used. Burndown 

herbicide applications are almost obligatory for no-till crop production systems (Hartzler, 2013). 

Dicamba and 2,4-D are typically used in combination with other broad-spectrum herbicides, such 

as glyphosate, glufosinate or paraquat. Herbicides with utility in burndown and major foliar 

activity on broadleaf weeds are listed in Table 25. These herbicides are alternatives to dicamba. 

Some non-chemical control methods can also substitute for dicamba or enhance other control 

measures. Tillage can be a substitute for herbicide applications to remove weeds before planting 

except where no-till conditions are desired. USDA reports on custom tillage rates estimated the 

cost of most pre-plant tillage at $13-15 per acre (University of Nebraska, 2012).

Potential Impacts to Cotton Growers from Dicamba-Resistant Weeds 

According to BASF proprietary grower surveys, dicamba use in cotton is limited to pre-plant 

burndown since cotton is sensitive to the herbicide. However, because of the widespread 

adoption of no-till in cotton production combined with the prevalence of GR weeds in cotton 

fields, dicamba is one of several herbicides for burndown applications in cotton and these could 

include 2,4-D, paraquat, and flumioxazin. Consequently, if dicamba-resistant weeds become 

more prevalent in cotton varieties other than MON 88701, PRE weed management costs will 

likely be similar or possibly slightly increased for some cotton producers. As noted earlier, a 

variety of post-emergent or lay-by herbicides can be used for cotton weed control, and dicamba 

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is not used for such post emergent uses. Under the Preferred Alternative, the nonregulated status 

of MON 87708 soybean and MON 88701 cotton would have inconsequential effects on the 

cultivation of other varieties of soybeans and cotton if dicamba resistant weeds were to increase.

Sugarcane

While a large proportion of sugarcane is treated annually with dicamba, the crop may be 

harvested in three seasons including the one following planting, and then receive a fallow year, 

so in the four year cycle, rotated crops are not an issue in typical sugarcane production (LSUExtension, 2014). 

Weed Management Choices and Development of Resistant Weeds

MON 87708 soybean and MON 88701 cotton are expected to be attractive to those cotton and 

soybean growers who have or will have difficulty with weed control caused by GR weeds. In the 

event that MON 87708 soybean and MON 88701 cotton become widely used, and dicambaresistant weeds become more widespread, there are three types of growers that are most likely to 

be impacted.

1) The first type is the soybean and cotton growers who almost exclusively have adopted 

GR crops and are already confronted with weed control problems related to GR weeds. 

Until now, these growers have relied more on glyphosate than dicamba, but it can be 

assumed they will adopt MON 87708 soybean and MON 88701 cotton and develop a 

reliance on dicamba as a solution to the GR weed problem. The ease and effectiveness of 

dicamba will tend to encourage growers to use a less diversified approach to weed

control, but because dicamba only controls broadleaf weeds, this will require growers to 

pursue a more diversified weed management strategy. Therefore, they will have an 

incentive to diversify before they are forced to do so when dicamba-resistant weeds 

emerge.

2) A second type of grower includes those that have responded to the recommendations of:

state extension experts (e.g., following advice received during seminars attended by 

growers [e.g., B. Young, Purdue University, 2014 Commodity Classic (Young, 2014)];

state agronomy publications (Iowa State Extension, 2014); national grower associations 

such as the American Soybean Association (ASA, 2011), and representatives of seed 

technology companies). These specialists continue to alert growers to the need for new 

models for weed control that will require integrated weed resistance management and an 

understanding of target weeds sensitivity to herbicide sites of action. 

Reliance on a single herbicide, such as glyphosate for weed control, is no longer a 

realistic option. Since dicamba is only effective on broadleaf weeds, it does not provide 

the single herbicide option to achieve effective weed control.

Failure to consider and vigorously respond to the existence of resistant weed populations

will result in a loss of yield and sometimes loss of an entire crop. Consequently, these 

growers will use best management practices to both avoid weed resistance and control 

resistant weeds already present or that are believed to be present. The potential for 

enhanced weed control offered by this and other new HR crops will be fully embraced.

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Growers who do will be actively delaying the onset of weed resistance within their own 

fields. Because these growers will be following best management practices, their 

response to weed control will be more integrated with greater precautions taken to avert 

new weed resistance.

These growers will be likely to deter new weed development using MON 87708 soybean 

and MON 88701 cotton, and use other HR crops such as 2,4-D-resistant crops or MGIresistant (mesotrione, glufosinate, isoxaflutole) soybean. Because new herbicide best 

management practices exemplify initiatives of growers, they will likely find that 

availability of MON 87708 soybean and MON 88701 cotton will provide weed 

management benefits for multiple years.

3) The third type of growers is those who already rely on dicamba for weed control in nonGR crops; growers of sorghum, corn or certain small grains are examples. These growers 

are more reliant on dicamba than glyphosate for weed control and may not currently be 

faced with the same degree of weed control problems as the first group. The development 

of dicamba-resistant weeds resulting from reliance on either dicamba in current or new 

herbicide formulations for MON 87708 soybean and MON 88701 cotton may render 

dicamba less effective to those who were already using it on these other crops. This could 

necessitate adopting more costly and less environmentally beneficial weed management 

practices than are currently in use. 

No cumulative impacts are expected on organic growers because these growers do not use 

synthetic herbicides, such as dicamba, for weed control, therefore weed resistance to dicamba 

would not impact the practices they employ for weed control (including tillage, cultivation, 

hand-weeding, cover crops). USDA acknowledges that the overall increase in herbicide resistant 

weeds negatively impacts our agricultural system as a whole, given the overall number of weeds, 

weed pollen, and weed seed may be increased and this may have an impact on weed control for 

all production systems. The potential for undesired volatilization or drift of applied dicamba onto 

organic crops is as of high possibility, but no less than those onto conventional soybean or 

cotton. APHIS concludes that because EPA will mandate use of the low-volatility formulations 

of dicamba, and that organic crops likewise are not at any higher risk than conventional crops, 

impacts on organic crops may occur, but at reduced incidence because the formulation of 

dicamba being delivered onto the MON 87708 soybean and MON 88701 cotton crop is less 

volatile than dicamba being used on other crops; the low volatility formulation may also be more 

frequently used in place of higher volatility and older dicamba formulations.

5.6.4 Health and Safety for Livestock and Humans

No cumulative impacts were identified on human health or livestock for any of the Alternatives. 

The EPA considers the direct and indirect impacts from herbicide use on human health and nontarget organisms as part of their regulatory decision. Those impacts are outside the scope of this 

EIS.

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5.6.5 Biological Resources

Animal Communities

As described in the No Action Alternative, agricultural practices can affect wildlife in and 

around agricultural fields. Wildlife commonly found in each region is described in the Affected 

Environment, Chapter 3. As discussed in Chapter 4, MON 88701 cotton and MON 87708 

soybean are not expected to directly or indirectly impact wildlife differently from the cotton and 

soybean varieties that are currently available under the No Action Alternative. While direct 

impacts from the changes in herbicide use associated with MON 87708 soybean and MON 

88701 cotton could potentially affect certain wildlife, those impacts are outside the scope of this 

EIS.

The EPA considers impacts on wildlife as part of its evaluation of the new label. Dicamba has an 

extensive history of safe use. It has been thoroughly reviewed and reregistered by all major 

regulatory agencies in the world within the last ten years. The EPA affirmed that dicamba posed 

no unreasonable adverse effects on the environment when used as directed. Therefore, 

cumulative impacts on animal resources are not expected to differ from the No Action and 

Action Alternatives. Impacts of herbicides on nontarget organisms are assessed by the EPA.

Those impacts are outside the scope of this EIS.

Plant Communities

Summary: Populations of waterhemp with multiple herbicide resistance have been 

detected in some states in the Midwest. While not widespread, they are a concern because 

they are only susceptible to some PPO inhibitors, PSII inhibitors and dicamba. In some 

southern states, pigweeds in soybean are only susceptible to PPO inhibitors and to 

dicamba. When dicamba can be applied coordinately with one of the few herbicides to 

which these weeds are susceptible, it reduces the chance that resistance to these 

herbicides will develop, since the use of overlapping sites of action is an important 

strategy advanced by weed scientists for suppressing weed resistance. APHIS concurs

that dicamba use in MON 87708 soybean and MON 88701 cotton can potentially extend 

the longevity of unique herbicides that are needed for the control of specific highly 

resistant weeds. 

An important consideration for the potential of weeds to develop resistance is knowing

whether growers will select appropriate strategies for management practices. These 

practices must be actively selected to avert future weed resistance. Best management 

practices include employing a diversity of herbicides, rotation of herbicide choices, crop 

rotation, and others. APHIS anticipates that the EPA will implement appropriate 

measures with respect to weed resistance management associated with the registration of 

dicamba on MON 87708 soybean and MON 88701 cotton. State extension agents, seed 

providers, herbicide suppliers and other professionals, will also provide advice and 

training to growers, who are becoming more likely to perceive the needs for sustainable 

weed management and execute best management practices. APHIS concludes that the 

overall success in averting weed resistance will depend on these management practice 

choices made by individual growers.

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Clearly the grower’s responses to recommended management practices prescribed by 

extension personnel and weed scientists will determine the potential impacts and benefits 

of associated with adoption of MON 87708 soybean and MON 88701 cotton. Reduced 

usefulness of herbicides for cotton and soybean crops must be balanced with the potential 

benefits deriving from applying intensive risk-averting practices. Because growers have 

become more receptive to understanding the causes of herbicide resistance in weeds, they 

have also become more responsive to these issues. Under the Preferred Alternative, as 

under the No Action Alternative, APHIS concludes that more growers are likely to take 

actions (e.g., best management practices to reduce development of resistance) that 

reduce the chances for weed resistance, especially as more recent studies have shown 

that there is only modest additional short-term cost for applying these actions, with no 

change in profitability. Large long-term costs for not applying these actions are also a 

likely consequence, which weed experts will continue to emphasize to growers.

Monsanto estimates of herbicide use under the likeliest adoption scenario are listed in Table 4-9 

of Appendix 4 for soybean at 40% and 100% adoption, and 4-12 for cotton at 50% adoption. An 

increase in herbicide use is expected under all four Alternatives. Dicamba use on crops may 

increase from 3.8 million pounds in 2011 under the No Action Alternative to 29.5 million 

pounds at full adoption (Table 8-1 in Appendix 8 and Appendix 4) (Monsanto, 2013a). Under

Alternative 2, the increase may reach 25.7 million pounds at the height of adoption, assumed to 

be 50% of cotton acres and 35% of soybean acres, but these rates are difficult to predict. 

The presently increasing use of dicamba under the No Action Alternative (see Table 23 and

Appendix A in the Monsanto ER (Monsanto, 2013a)) and the potential for increasing use 

following the EPA approval of new uses of dicamba, may be expected to increase the selection 

pressure for dicamba-resistant weeds. However, selection pressure is influenced by factors other 

than the volume of herbicide applied. The selection pressure is strongly related to the long-term 

repeated use of one or a limited number of herbicides or modes of action (Durgan and Gunsolus, 

2003; Duke, 2005). It is also a function of the diversity of management practices employed. The 

greater the diversity of management practices, the smaller the selection pressure for resistant 

weeds. 

Without diversified weed control practices, all management techniques, including the use of 

herbicides, hand weeding, mowing, etc., exert pressure to select weeds with resistance to that 

management practice. For hand weeding, weed forms are selected that resemble the crop. For 

example, spurred anoda and nightshade resemble young cotton, so these weeds are often 

overlooked during hand-weeding (University of California Davis, 1996; Coble, 2012). Mowing 

selects plants that flower rapidly and grow low to the ground (Radosevich et al., 2007). Mowing 

alters the stature of some weeds. Repeated mowing can change the appearance of a weed from a 

single-stemmed, tall, upright form to a plant with multiple shoots that are relatively prostrate 

(Radosevich et al., 2007). Repeated use of herbicides with diversification selects for resistant 

plants that are no longer sensitive to its mode of action (Owen, 2008). 

The increased selection pressure resulting from the wide-spread use of glyphosate on GR crops, 

the subsequent reductions in the use of other herbicides, and changes in weed management 

practices (such as the reduction in tillage and decreased use of crop rotation), has resulted in both 

weed population shifts and increasing glyphosate resistance among some weed populations 

173
(Owen, 2008; Duke and Powles, 2009). GR crops themselves do not influence weeds any more 

than non-transgenic crops. It is the weed control tactics chosen by growers that create selection 

pressure that gradually shifts these weed communities and may result in the evolution of HR 

weeds (Owen, 2008). Impacts of herbicide treatment on nontarget organisms are assessed by the 

EPA. Those impacts are outside the scope of this EIS.

Control of volunteers arising after harvest and of persisting cotton plants is often accomplished 

by use of 2,4-D applications, which growers may combine with mechanical destruction

(Robertson et al., 2002). As noted earlier, the cotton destruction for overwintering plants is 

mandated by Boll Weevil Control programs. Assuming 2,4-D resistant cotton is available to 

growers, other herbicide regimes will need to be selected, and DowAgrosciences has indicated 

that it is currently accomplishing trials to find suitable herbicide replacement for control of this 

cotton variety (DowAgrosciences, personal communication, 2014). A similar experimental 

approach to manage post-harvest cotton may be needed for MON 88701 cotton. Although the 

Dow Agrosciences patent for 2,4-D resistant crops does not indicate that Enlist corn has 

tolerance to dicamba, a non-commercial level of 2,4-D resistance could potentially be displayed 

by dicamba resistant cotton, since cross resistance in weeds to both herbicides has been noted

(Monsanto, 2012a; 2012b). Dicamba soybean appears to have only slight resistance to 2,4-D 

compared to a nontransgenic control soybean (Feng and Brinker, 2010), with no information 

available about 2,4-D resistance in dicamba-resistant cotton (Brinker et al., 2012). APHIS 

concludes that potential for cross resistance of HR cotton has not been shown, and doubtless new 

herbicide procedures for eliminating overwintering potential in these cotton varieties will need to 

be established. 

Overall USDA Responsibility for Averting Resistant Weed Development

When assessing issues of herbicide-resistant weeds, especially those with existing resistance, but 

also those that may develop resistance to dicamba from commercialization of MON 87708 

soybean and MON 88701 cotton, there are at least two perspectives that these assessments must 

take into account. The first is that growers are presently in need of short-term solutions for GR 

weeds, which are certainly extensive and probably increasing. The second is that growers need to 

embrace the complexity of weed control with not just herbicides and HR crops, but with all the 

possible cultural, mechanical, chemical and preventative management practices. The first 

perspective is intimately tied to short-term approaches to resistant weed control and weed control 

in general, but the second is one that is longer term, requiring more experimental effort, and 

experience with control of problem weeds. This EIS deals necessarily with the first perspective, 

since that can be addressed with herbicide resistant crop technology provided by seed companies

and pesticide providers, including making MON 87708 soybean and MON 88701 cotton

commercially available. Unquestionably, there is a grower- and professionally-expressed need 

for additional herbicide technologies for responding to widespread issues of existing herbicide 

resistance. 

From the second perspective, weed control should optimally be done using integrated weed 

management practices, without over-reliance on herbicides. Many growers are already using 

multiple technologies (Prince et al., 2012b; Sosnoskie and Culpepper, 2014), and as noted by a 

Georgia agronomist and professor (Public Comment APHIS-2013-0043-3209), 

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“It is also critical to highlight, at least in Georgia, no weed management program relies 

exclusively on herbicides. The University of Georgia Weed Science Extension Team 

stresses to growers at more than 50 meetings each year that herbicides are only one part 

of the weed management program. Sustainability is only possible with the adoption and 

implementation of diverse management programs and Georgia growers have accepted 

this message as fact (Sosnoskie and Culpepper 2014). Growers are using programs that 

are complex and diverse integrating herbicides, hand weeding, and tillage or cover 

crops. Dicamba will not change this approach but would simply be an additional tool to 

add into these management systems.” 

As more challenging problem weeds arise (with resistance to both herbicides and other 

techniques) there is need to further develop these practices. Agencies within USDA deal with 

developing agronomic production practices, such as the NRCS with improving tillage practices, 

and with planting cover crops that may outcompete weeds. Other parts of USDA, such as ARS,

take into account the physiology of crops and weeds, and the interactions between them, and are 

providing practical research in understanding the biology and ecology of agricultural weeds in 

farm ecosystems. 

USDA-APHIS has responsibility for assuring that new GE crops are not plant pests, which is a 

limited category of agricultural concern. Necessarily, APHIS must focus primarily on that issue, 

making brief notes of possible impacts on the agroecosystem by the plant. At its discretion,

APHIS may secondarily note possible changes in herbicide usage on the crop. The Coordinated 

Framework and U.S. statutes clearly relegate the authority to regulate all other pesticide-related 

issues including environmental impacts, and stewardship issues to EPA.

The EPA has noted the increasing problems and also the economic issues growers are facing 

from the emergence of HR weeds. When evaluating the proposed new uses of 2,4-D on 2,4-Dresistant corn and soybean, EPA recognized that using herbicide formulations consisting of a 

premix of two different active ingredients (e.g., 2,4-D and glyphosate) could increase the number 

of species and the distribution of weeds resistant to 2,4-D. As a result, the EPA is proposing to 

impose requirements on DowAgrosciences to ensure better management practices. These 

proposed requirements include robust monitoring and reporting to the EPA, grower education 

and remediation, and would allow the EPA to take swift action to impose additional restrictions

on the manufacturer and the use of the pesticide if resistance develops (US-EPA, 2014a). It 

would allow the EPA to modify the registration quickly and easily to impose additional measures 

on growers to manage resistance if needed. Because EPA has signaled a new direction in 

stewardship, APHIS anticipates that the EPA may implement similar label requirements relevant 

to resistance management for the registration of the M1691 dicamba formulation for MON 

88701 cotton and 87708 soybean (US-EPA, 2014a).

The label for dicamba resistant crops would most likely also contain information on resistance 

management consistent with the Weed Science Society of America’s BMPs for comprehensive 

resistance management approaches (US-EPA, 2014a). The details of the EPA’s new proposed 

requirements related to weed resistance management for the recent registration of a new 

herbicide product is provided in Appendix 10 of the EIS. APHIS anticipates that the EPA will

implement similar appropriate label requirements relevant to resistance management on the 

registration of M1691 herbicide (US-EPA, 2014a).

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A large complex of state extension agents, herbicide producer representatives, seed company 

staff, are all involved in bringing science and technology to farms, showing growers how to 

efficiently deal with weeds, and weed resistance issues, and these certainly include appeals to 

consider all the possible non-chemical means of improving weed control. The advice of state 

extension experts, as well as input from USDA studies, will continue to provide growers with 

expert support as they design ever more complex management systems to preserve profitability 

and sustainability of their production systems. Financial reward for growers will ultimately be 

the mechanism by which increased integrated weed management is practically advanced in U.S. 

farming.

Herbicide-Resistant Weeds

In this section, the likelihood that problem weeds in cotton and soybean (i.e., those weeds that 

are actively managed in these crops) will become more resistant to dicamba is reviewed. 

Appendix 5 includes an analysis of the problem weeds of cotton and soybean. Those that have 

HR biotypes are described in Appendix 6. 

As of April 12, 2014, worldwide, there were 429 instances of HR weeds in 234 species (Heap, 

2014d). The first HR biotypes were described in the 1950s. The number of weeds resistant to 

herbicides increased dramatically in the 1980s and 1990s. Today, resistance to 22 of the 25 

known herbicide sites of action has been identified (Heap, 2014c). Of the 25 known herbicide 

sites of action, 11 are commonly used on cotton and soybean (Appendix 4). Furthermore, while 

there are hundreds of cases of HR weeds, most of these weeds are not actively managed or 

directly targeted in cotton and soybean. The analysis below focuses on weeds that are actively 

managed in cotton and soybean fields and addresses which of these have developed herbicide 

resistance to the major herbicides used in cotton and soybean.

There are 69 broadleaf and 11 grass weed species that require control measures in the major 

growing regions of soybean and cotton (Appendix 5). There are 25 broadleaf and six grass 

weeds, respectively, that are a problem in both cotton and soybean, 23 broadleaf and three grass 

weeds that are mostly problematic in cotton (Table 5-1 in Appendix 5), and 21 broadleaf and two 

grass weeds that are mostly problematic in soybean (Table 5-1 in Appendix 5). 

The most common types of weed resistance in the U.S. are to ALS and PSII herbicides. There 

are 15 problem weed biotypes resistant to each mode of action. The problem weed resistant to 

the most sites of action is waterhemp (Table 27). Multiple resistance involving biotypes with 13 

combinations of sites of action have been reported, including one biotype that is resistant to five 

sites of action (Owen, 2012). Common ragweed, and pigweed, waterhemp, and kochia are each 

reported to have biotypes resistant to four or more sites of action including biotypes that are 

multiply resistant to two herbicides (Table 27, Table 28). Multiple HR biotypes have also been 

selected in redroot pigweed and giant ragweed. None of the problem grasses have multiple 

resistances.

Resistance of kochia to dicamba arising in wheat and corn in two states (Colorado and Nebraska)

has been described (Heap, 2014d). Other observations suggest possible tolerance or variability of 

susceptibility in some Kansas populations (Crespo et al., 2014) but also one resistant accession 

was detected in 67 that were screened. The authors caution that dicamba should not be the only 

effective herbicide applied to Kochia in this region, and that higher rates of dicamba were needed 

176
to control Kochia if the plants had reached 8-12 centimeters in height. Resistant kochia appears 

to occupy an enlarging area of the western and northern Great Plains states, and control efforts in 

these areas. As is true of all soybean and cotton growing areas, agronomists and growers in this

area need to be especially vigilant and selective of best weed management practices for 

potentially problematic weeds.

To respond to the trend of increasing weed resistance to herbicides and to avoid decreased crop 

yields resulting from weed competition, growers must continually employ and adapt

management strategies. Appropriate weed management requires much more than the application 

of herbicides, including diversified methods and cultural practices (Norsworthy et al., 2012). Use

of herbicides with alternating sites of action is one method (Norsworthy et al., 2012), as is using 

multiple herbicides effective on specific problem weeds. Alternative sites of action refer to using 

herbicides that have different physiological modes of action. Some common sites of herbicide 

action include auxin growth regulators, amino acid inhibitors, chlorophyll pigment inhibitors, 

and lipid biosynthesis inhibitors (Ross and Childs, 2011) (see Appendix 3). 

Dicamba Resistance in Cotton and Interference with Boll Weevil Eradication

As noted earlier in the Environmental Consequences Section, Plant Communities, the auxinic 

herbicide 2,4-D is used extensively to eliminate post season persistence of cotton. These cotton

removals are mandated, in many cases, by law, as part of Boll Weevil Eradication programs, 

When the cotton plant removals are not be accomplished by shredding, herbicides must be used. 

The most effective stalk herbicide is 2,4-D and MON 88701 cotton already has some minor level 

resistance to 2,4-D. Consequently, Monsanto’s dicamba-resistant cotton may not be destroyed by 

2,4-D application and may not necessarily be usable if either Dow’s 2,4-D-resistant cotton is 

grown, or this second auxinic resistant variety, MON 88701 cotton. Additional herbicide 

protocols may be needed to chemically destroy these late season post-harvest herbicide-resistant 

cotton varieties. Several herbicide choices have been shown to control cotton volunteers when 

these are treated in spring before planting (Morgan et al., 2011), and effective herbicide

protocols for immediate post-season stalk devitalization of 2,4-D resistant cotton using dicamba,

2,4-DP or dicamba + diflufenzopyr herbicides have recently been documented (Lassiter et al., 

2014). 

Dicamba Resistance Trait Sustaining Other Effective Herbicides

Use of overlapping sites of action, in which problem weeds are targeted with more than one 

effective herbicide is a key weed management strategy (Herbicide-Resistance-ActionCommittee, 2014). The practice of using herbicides with overlapping and alternative sites of 

action could potentially diminish the populations of GR weeds and reduce the likelihood of the 

development of new HR weed populations (Dill et al., 2008; Duke and Powles, 2008; Owen, 

2008; Duke and Powles, 2009; DAS, 2010; Norsworthy et al., 2012).

In the Midwest, some populations of waterhemp currently have susceptibility only to Nphenylthalamides of the PPO group (saflufenacil, flumioxin, sulfentrazone used on soybean) 

(Legleiter and Johnson, 2013), the PS II groups (metribuzin), and dicamba (Table 28). In 

southern states, some populations of pigweed species (see Table 27) have resistance to all 

herbicide groups commonly used on soybean except for PPOs and dicamba. Because resistant 

weeds should be treated with overlapping, effective herbicides (Herbicide-Resistance-Action177
Committee, 2014), dicamba-resistant soybean and cotton treated concurrently with dicamba and 

a PPO herbicide is the only herbicide weed control strategy likely to be successful (Culpepper, 

Public Comment APHIS-2013-0043-3209). Furthermore, prevention of resistance to both would 

more likely be achieved if they were used in accordance with a best management plan that 

specified treatments within the same season, rather than individually in alternate seasons. 

Therefore, the availability of MON 87708 soybean and MON 88701 cotton used with suitable 

choices of herbicides could promote sustainable use of herbicides, such as PPOs in the case of 

these two major resistant weeds.

178
Table 27. Known Weed Resistance in the Southern United States.

1

Most 

Common 

Broadleaf 

Weeds 

(# states 

where 

listed as a 

top weed)

Resistance 

Group 2

ALS

(Group 2)

PPO

(Group 14)

PS II 

(Group 

5)

Glycine (Group 

9)

Phenoxy

(Group 

4)

Chemistry 

Class 2

Sulfonylurea Imidazolinones Triazoles Diphenyl 

ether

N-phenyl 

thalimide

Triazinones - Phenoxy Benzoic 

acid

Example chlorimuron imazethapyr chloransulam lactofen

fomesafen

flumioxazin metribuzin glyphosate 2,4-D dicamba

Pigweed spp. 3 (12) X X X X X

Velvetleaf (11)

Lambsquarters (10) X X X

Cocklebur (9) X X X

Common ragweed (7) X X X X X X

Smartweed spp. (6)

Morning glory (5)

Waterhemp (5) X X X X X X

Horseweed (marestail) 

(3)

X X X

Giant ragweed (3) X X X X

Kochia (2) X X X X

1 Source: (Heap, 2014d)

2 Cross resistance is possible within a resistance group and/or chemistry class

3 Includes redroot pigweed and smooth pigweed

179
Table 28. Known Weed Resistance in the Midwestern United States.

Most

Common

Broadleaf

Weeds

(# states

where

listed as a

top weed)

Resistance

Group1

ALS

(Group 2)

PPO

(Group 14)

PS II

(Group 5)

Glycine (Group 9) Phenoxy

(Group

4)

Chemistry

Class 1

Sulfonurea Imidazolinones Triazoles Diphenyl

ether

N-phenyl

thalimide

Triazinones - Phenoxy Benzoic

acid

Example chlorimuron imazethapyr chloransulam lactofen

fomesafen

flumioxazin metribuzin glyphosate 2,4 D dicamba

Pigweed spp. 2 (12) X X X X X

Velvetleaf (11)

Lambsquarters(10) X X X

Cocklebur (9) X X X

Common ragweed (7) X X X X X X

Smartweed spp. (6)

Morning glory (5)

Waterhemp (5) X X X X X X

Horesweed (marestail)

(3)

X X X

Giant ragweed (3) X X X X

Kochia (2) X X X X

Source: www.weedscience.org

1 Cross resistance is possible within a resistance group and/or chemistry class

2 Includes redroot pigweed and smooth pigweed

180
Managing Glyphosate-Resistant Weeds 

APHIS, recognizing that the need for additional weed management tools is the reason why MON 

88701 cotton and MON 87708 soybean have been developed, has considered whether the current 

impacts of the management practices for resistant weeds may also potentially contribute to the 

cumulative impacts of MON 87708 soybean and MON 88701 cotton. In 2012, the area of U.S. 

cropland infested with GR weeds expanded to 61 million acres, according to a survey conducted 

by Stratus Agri-Marketing (Farm Industry News, 2013). Table 27 and Table 28 lists horse weed 

species that have been identified as HR in (Farm Industry News, 2013)at least some part of their 

range in the U.S. The use of glyphosate on cotton and soybean is not expected to increase under 

any of the Alternatives because most cotton and soybean in the U.S. already has the GR trait and 

so glyphosate use is saturated on these crops. Between 2011 and 2014, HR soybean was planted 

on 93 to 94 percent of total soybean acres and HR cotton planted on 73 to 96 percent of total 

cotton acres The increase of GR weeds only makes glyphosate use less attractive, although as 

noted, glyphosate still controls large numbers of weeds (Monsanto, 2013a). From 2008 to 2011, 

acres to which glyphosate was applied were either stable or declined, but other herbicides 

(residuals applied to soil that persist for extended periods) applied increased by 177 percent

(Monsanto, 2013a). To manage glyphosate resistance, growers are not using more glyphosate, 

but are using more sites of action in addition to glyphosate.

Mid-South and possibly the Southeastern state soybean growers who previously adopted no-till 

production are now replacing that with increasingly aggressive tillage in their management 

programs (see Cumulative Impacts: Cotton and Soybean Agronomic Practices and Costs of 

Production. Changes in Tillage). In parts of the Heartland, GR waterhemp and marestail are 

widespread (Bowman, 2013). No-till practices are being maintained in many areas, but the 

presence of HR weeds and rapidly increasing presence of GR weeds in particular, sometimes 

necessitate the inclusion of tillage in weed control strategies (Arbuckle and Lasley, 2013). An 

Iowa poll disclosed that farmers there used mechanical weed control (i.e., cultivation) 25 percent

of the time, and 55 percent found it to be effective or very effective for weed control (Arbuckle 

and Lasley, 2013). Farmers apparently value soil cultivation for weed control, but practice it only 

to a limited extent (25 percent) at present.

Under the No Action Alternative, GR weeds are likely to be an increasingly serious concern in 

the Mid-South, and Southeast (Prince et al., 2012a) and Great Plains regions (Spaunhorst et al., 

2014). Multiply-resistant weeds have also begun to be discovered, and in Iowa, 88% of 2011 

waterhemp populations may be multiply resistant; imidazolinone herbicide weed resistance was 

the highest, with up to 92% of waterhemp in soybean having cross resistance, even though 

pressure on weeds with this herbicide was not maintained in recent years (Owen, 2014c). The 

availability of MON 87708 soybean and MON 88701 cotton under the Preferred Alternative 

(along with an EPA decision to register new herbicide formulations for these crops) would 

increase the herbicides available for postemergent weed control, allowing more selective control 

of weeds whose resistances are known. 

Under the No Action Alternative, growers would likely use increased conventional tillage or 

additional herbicides to control weeds. The further adoption of conservation tillage practices 

could be impeded as growers who have already adopted conservation tillage are forced to return 

181
to more aggressive tillage systems to maintain soybean yields (Conley, 2013). This practice is 

likely in a limited number of locations where alternative herbicides are not effective.

Under the Preferred Alternative, dicamba use is expected to increase relative to the No Action 

Alternative. However, increases in use of other herbicides such as chloroacetamides, glufosinate, 

ALS inhibitors, PPO inhibitors, and HPPD inhibitors are expected to be less than under the No 

Action Alternative because MON 87708 soybean and MON 88701 cotton will be adopted. The 

availability of inexpensive and effective herbicides (including new use of dicamba) combined 

with MON 87708 soybean and MON 88701 cotton may delay the adoption of non-chemical 

management strategies under the Preferred Alternative. Fewer growers would be expected to 

adopt aggressive tillage when herbicides remain effective for weed control. Selection of weeds 

resistant to glyphosate, auxins, chloroacetamides, ALS inhibitors, and glufosinate will still occur 

under the Preferred Alternative. The selection pressure for HR weeds under the Preferred 

Alternative relative to the No Action Alternative will depend on the management practices 

employed under each Alternative and cannot be predicted. APHIS concludes that more 

diversified herbicide choices, and other weed management practices will result in less selective 

pressure for resistance to any given herbicide or management technique.

Potential for Weed Resistance to M1691 or Other Dicamba Formulations 

Summary: Weed resistance is not a consequence of the use of herbicide resistant crops. 

APHIS under the Preferred Alternative concludes that the extent and types of resistant 

weeds depend on how growers either employ the techniques of weed management or 

ignore them. Growers are expected to rotate by using different herbicides and different 

rotation crops to deter development of new herbicide resistant weeds. 

There is a consensus among weed scientists that the best way to delay the development of 

weed resistance is to use multiple herbicides with different modes of action that are 

effective against a single weed species. Dicamba used post-emergent will provide another 

herbicide treatment option that is consistent with this strategy. However, for areas where 

glyphosate resistance is prevalent, the use of MON 87708 soybean and MON 88701 

cotton crops which will allow treatments with both glyphosate and dicamba, will not 

effectively delay the onset of resistance to these herbicides. If growers plant MON 

87708 soybean and MON 88701 cotton in areas with GR weeds without including 

multiply effective additional herbicides (in addition to dicamba and glufosinate) and 

diversified weed management methods as part of their practices, APHIS concludes that 

this may accelerate the development of weed resistance to dicamba. Therefore, best 

management practices that combine both herbicides and other weed control methods are 

essential components of a strategy to prevent the development of HR weeds and manage 

existing HR weed populations. Since dicamba only controls broadleaf weeds, this further 

emphasizes the need for a broad-based weed management system. 

Under the Preferred Alternative, APHIS notes that the EPA will have new regulatory 

mechanisms in place to oversee HR crops and to deter resistant weed development. 

APHIS expects the EPA to implement appropriate label requirements for registration of

the M1691 herbicide relevant to weed resistance management, as it has recently done for 

Dow Agrosciences’ Enlist Duo (glyphosate and 2,4-D premix) to be used on 2,4-D182
resistant soybean and corn. The EPA is also expected to require crop oversight by 

manufacturers for reporting and responding to new incidences of weed resistance. 

Monsanto will be required to take action to deal with such weed resistance in MON 

87708 soybean and MON 88701 cotton, following the pattern being established by the 

EPA for Dow Agrosciences for the continuing oversight of 2,4-D and Enlist crops.

The relative risk that a resistant weed biotype will be selected following herbicide exposure is 

highly correlated to the herbicide mechanism of action (Sammons et al., 2007). Herbicide 

families have been classified according to their risk of resistant weed development. Beckie 

(2006) lists ALS- and ACCase-inhibiting herbicides as high risk for selection of resistant 

biotypes, while glyphosate and auxin type herbicides are considered low risk. Weeds resistant to 

auxin herbicides have been slowly accumulating over the past seventy years, but none have 

become particularly problematic. As of 2013, there are 31 species listed that include biotypes 

that are resistant to auxin herbicides, eight of which are located in the United States (Table 28, 

prepared from data in (Heap, 2014b)). Of the 31 species found world-wide, seven are resistant to 

dicamba. Of these, two are found within the United States (Table 28, highlighted in gray) and 

five are found outside the United States (yellow starthistle, lambsquarters, common hempnettle, 

wild mustard, indian hedge mustard, kochia, and prickly lettuce). Of these, GR biotypes are 

found only for kochia and lambsquarters. Thus, the combination of glyphosate and dicamba 

currently controls a wide range of problem weeds. 

Despite the fact that glyphosate and auxin herbicides are considered low risk, resistant biotypes 

are being selected from the use of these herbicides. GR weeds in a few species such as Palmer 

amaranth, waterhemp, horseweed, ragweed, and giant ragweed, have become widely prevalent in 

certain areas and cropping systems, such as cotton and soybean, where glyphosate was the only 

herbicide used for weed control and sometimes continuous cropping and no-till farming was also 

practiced. The lack of diversity of weed management practices in such situations is believed to 

have contributed substantially to the selection of resistant biotypes. 

Though auxin HR weeds (e.g., 2,4-D and dicamba) have been relatively slow to develop and are 

not particularly widespread, some will note that the same was true for GR weeds prior to the 

widespread use of glyphosate on GR crops. The selection of GR weeds purportedly came about 

through the almost exclusive use of glyphosate for weed control in some crops such as cotton, 

corn and soybean without the adoption of best management practices, including employing a 

diversity of weed management practices. Therefore, selection of dicamba resistant weeds may be 

preventable depending on how glyphosate, dicamba, and other herbicides are used on MON 

88708 soybean, MON 88701 cotton and other crops.The likelihood of selection of dicambaresistant weeds is greater as the selection pressure for resistance increases. When considering 

cumulative impacts under the Preferred Alternative, selection pressure is expected to be greater 

than under the No Action Alternative because dicamba use is expected to be considerably higher 

(Appendix 4, Table 4-9 and 4-12) if the EPA registers the new use of dicamba on MON 88701 

cotton and MON 87708 soybean. To mitigate the increased selection pressure associated with the 

183
increased use of dicamba, Monsanto recommends19 the following practices for weed 

management and for herbicide selection:

• Actively growing weeds in fields compete with the crop, so should be eliminated prior to 

planting.

• Maintain good weed control until crop canopy can be an indicator of good weed control 

throughout the remainder of the season.

• Include two or more crops in a crop rotation and ideally rotate to a different crop each 

year.

• Use a broad spectrum soil active residual herbicide in the corn season of a crop rotation

and in soybeans when hard-to-control weeds are present.

• The addition of a non-glyphosate herbicide reduces the sole use of glyphosate which can 

decrease the risk of developing of weed resistance.

• Use the full, labeled rate of glyphosate based on the most difficult-to-control weed in the 

field.

• Control weeds before they reach four inches tall (in soybeans before eight inches tall).

• Reduce weed populations from year to year, allowing for more efficient use of herbicides 

and other cultural practices to control weeds.

• Tillage should be considered as an alternate weed control practice where appropriate.

The selection and distribution of dicamba-resistant weeds is impossible to predict because the 

extent to which growers will use best practices with these HR crops is uncertain. A 2010 grower 

survey (Prince et al., 2012b) observed that many growers were using practices targeted 

specifically at preventing or managing GR weeds, but that these practices were not new 

introductions to their weed management plans. Growers recognized that rotating herbicides, 

using tank mixes, and increasing tillage would be effective strategies to manage GR weeds but 

did not seem to recognize that HR weeds were the result of repeated use of a herbicide or 

herbicides with the same mode of action if additional weed management practices were not 

implemented (Prince et al., 2012b). Education efforts to increase grower awareness are ongoing 

and there appears to be an increase in grower perception of the effectiveness of practices 

recommended by the weed science community (Prince et al., 2012b). 

Modeling studies suggest that exclusive use of an herbicide can select for HR weeds in as little 

as five years (Neve et al., 2011). Because growers who adopt MON 87708 soybean or MON 

88701 cotton are expected to be those who have had the most difficulty with (Neve et al., 

2011)GR weeds, the selection of biotypes exhibiting multiple resistance to both glyphosate and 

dicamba is expected to be related to the probability of selecting resistance to just dicamba and 

not the product of selecting resistance to both sites of action. Thus, multiple resistance could be 

expected to appear in as little as five years if glyphosate and dicamba are used exclusively in 

some areas. The southernmost part of the Southeast (Region D) is expected to be a problem 

region because GR weeds are already reported to be present in greater than 90% of cropland 

(Farm Industry News, 2013). In this region, Palmer amaranth can no longer be controlled with 

19 Website, April 15, 2014: http://www.monsanto.com/weedmanagement/pages/field-management-guidelines.aspx

184

 
glyphosate and would be a particular risk for the selection of multiple resistant biotypes. In the 

Heartland (Regions C and G) and prairie states (Region I), HR waterhemp has been selected to 

several herbicides and a biotype resistant to four herbicides has been detected (Bell et al., 2013). 

Furthermore, biotypes with resistance to either dicamba or glyphosate have already appeared in 

Nebraska (Table 29). A multiply-resistant biotype could form by hybridization and 

dissemination. APHIS concludes that if MON 87708 soybean and MON 88701 cotton are 

exclusively used by growers for weed management, without appropriate use and coordination 

with use of other herbicide sites of action, independently arising weed biotypes that are multiply 

resistant to dicamba and other herbicides are likely to be selected. 

Table 29. Auxin-Resistant Weeds.

Species Year/Location Auxin Situation GR/GT 

1 Amaranthus 

tuberculatus 

Ameranthsyn. rudis)

2009 - USA (Nebraska) 2,4-D Pasture +

Common Waterhemp

2 Carduus nutans 1981 - New Zealand 2,4-D Pasture

Musk Thistle

3 Carduus pycnocephalus 1997 - New Zealand 2,4-D, MCPA, 

MCPB

Pasture

Italian Thistle

4 Centaurea cyanus 2012 – Poland Dicamba Winter wheat

5 Centaurea solstitialis 1988 - USA 

(Washington)

Picloram Roadsides

Yellow Starthistle

5 Chenopodium album 2005 - New Zealand Dicamba Corn

Lambsquarters

6 Cirsium arvense 1979 - Sweden MCPA Cropland

Canada thistle 1985 - Hungary 2,4-D and MCPA Pasture

8 Commelina diffusa 1957 - USA (Hawaii) 2,4-D Sugarcane

Spreading Dayflower

9 Daucus carota 1957 - Canada (Ontario) 2,4-D Roadsides

Wild Carrot 1993 - USA (Michigan) 2,4-D roadsides and 

cropland

1994 - USA (Ohio) 2,4-D soybean

10 Descurainia sophia 2011 - China MCPA winter wheat

Flixweed

11 Digitaria ischaemum 2002 - USA (California) quinclorac rice

Smooth Crabgrass

12 Echinochloa colona 2000 - Colombia quinclorac rice +

Junglerice

13 Echinochloa crus-galli 

var crus-galli

1998 - USA (Louisiana) quinclorac rice

Barnyardgrass 1999 - Brazil quinclorac rice

1999 - USA (Arkansas) 

*Multiple - 2 MOA's

propanil and 

quinclorac

rice

2000 - China quinclorac rice

2009 - Brazil *Multiple 

- 2 MOA's

bispyribac-sodium, 

imazethapyr, 

rice

185
Species Year/Location Auxin Situation GR/GT 

penoxsulam, and 

quinclorac

2013 - Uruguay quinclorac rice

14 Echinochloa crus-galli 

var. zelayensis

2013 - China quinclorac rice

15 Echinochloa cruspavonis1999 - Brazil quinclorac rice

Gulf Cockspur

16 Fimbristylis miliacea 1989 - Malaysia 2,4-D rice

Globe Fringerush

17 Galeopsis tetrahit 1998 - Canada (Alberta) dicamba, fluroxypyr, 

and MCPA

barley, 

cereals, 

cropland, 

wheat

Common Hempnettle

18 Galium spurium 1996 - Canada (Alberta) 

*Multiple - 2 MOA's

imazethapyr, 

metsulfuron-methyl, 

quinclorac, 

sulfometuronmethyl, 

thifensulfuronmethyl, triasulfuron, 

and tribenuronmethyl

cereals and 

wheat

False Cleavers

19 Kochia scoparia 1995 - USA (Montana) dicamba and 

fluroxypyr

cropland and 

wheat

+

Kochia 1995 - USA (ND) dicamba wheat

1997 - USA (Idaho) dicamba roadsides

1999- USA (Colorado) dicamba corn

2010 - USA (Nebraska) dicamba corn

20 Lactuca serriola 2007 - USA 

(Washington)

2,4-D, dicamba, 

MCPA

cereals

Prickly Lettuce

21 Limnocharis flava 1995 - Indonesia 2,4-D rice

Yellow bur-head 1998 - Malaysia 

*Multiple - 2 MOA's

2,4-D and 

bensulfuron-methyl

rice

22 Limnophila erecta 2002 - Malaysia 

*Multiple - 2 MOA's

2,4-D, cinosulfuron, 

mesosulfuronmethyl, and 

pyrazosulfuron-ethyl

rice

Marshweed

23 Papaver rhoeas 1993 - Spain *Multiple -

2 MOA's

2,4-D and 

tribenuron-methyl

cereals and 

wheat

Corn Poppy 1998 - Italy *Multiple -

2 MOA's

2,4-D, iodosulfuronmethyl-sodium, and wheat

186
Species Year/Location Auxin Situation GR/GT 

tribenuron-methyl

1998 - Italy 2,4-D wheat

24 Ranunculus acris 1988 - New Zealand MCPA Pastures

Tall Buttercup

25 Raphanus raphanistrum 1999 - Australia 

(Western Australia)

2,4-D cereals +

Wild Radish 2006 - Australia (South 

Australia) *Multiple - 3 

MOA's

2,4-D, diflufenican, 

MCPA, and 

triasulfuron

cereals

2009 - Australia 

(Victoria) *Multiple - 2 

MOA's

2,4-D, chlorsulfuron, 

and metosulam

barley and 

wheat

2010 - Australia 

(Western Australia) 

*Multiple - 4 MOA's

2,4-D, chlorsulfuron, 

diflufenican, 

glyphosate, 

imazethapyr, 

MCPA, metosulam, 

and sulfometuronmethyl

Fallow

2011 - Australia 

(Victoria)

2,4-D Barley and 

Wheat

2013 - Australia (New 

South Wales)

2,4-D Barley, Oats, 

and Wheat

26 Sinapis arvensis 1990 - Canada 

(Manitoba)

2,4-D, dicamba, 

dichlorprop, MCPA, 

mecoprop, and 

picloram

barley, 

cropland, and 

wheat

Wild Mustard 2008 - Turkey 

*Multiple - 2 MOA's

dicamba, 

propoxycarbazonesodium, 

thifensulfuronmethyl, triasulfuron, 

and tribenuronmethyl

not specified

27 Sisymbrium orientale 2005 - Australia (South 

Australia) *Multiple - 2 

MOA's

2,4-D, imazethapyr, 

MCPA, metosulam, 

and metsulfuronmethyl

cereals

Indian Hedge Mustard dicamba, 

propoxycarbazonesodium, 

thifensulfuronmethyl, triasulfuron, 

and tribenuronmethyl

28 Soliva sessilis 1999 - New Zealand clopyralid, picloram, 

and triclopyr

Golf courses

Carpet Burweed

29 Sphenoclea zeylanica 1983 - Philippines 2,4-D rice

Gooseweed 1995 - Malaysia 2,4-D rice

187
Species Year/Location Auxin Situation GR/GT 

2000 - Thailand 2,4-D rice

30 Stellaria media 1985 - United Kingdom mecoprop cereals and 

wheat

Common Chickweed 2010 - China fluroxypyr and 

MCPA

winter wheat

31 Tripleurospermum 

perforatum (=T. 

inodorum)

1975 – France 2,4-D cereals

Scentless Chamomile 1975 – United Kingdom 2,4-D cereals

Source: (Heap, 2014b)

U.S. dicamba resistance highlighted in gray.

Many types of resistance could potentially arise in weed populations; no predictions could be 

made for cross resistance by unknown new weed biotypes. As indicated in Table 29, weed 

resistance to both herbicides is rare, with only two known occurrences. 

Cumulative Impacts of Other HR Crops on MON 87708 Soybean and MON 88701 Cotton 

and on Weed Resistance

Summary: Other crops are currently being evaluated for nonregulated status by USDAAPHIS which, if determined as nonregulated, may have impacts with MON 87708 

soybean and MON 88701 cottonon the development of herbicide-resistant weeds. These 

crops include GE soybean, corn and cotton with resistance to the auxinic class herbicide 

2,4-D, and two GE soybean varieties with resistance to HPPD inhibitors. 

Weed resistance to auxin class herbicides is relatively limited compared to other 

herbicide classes. Nevertheless, there has been some detection of cross resistance in 

weed populations to more than one class of auxinic herbicide, including a few with 2,4-D 

and dicamba resistance. The extent and mode of such cross resistance has not been wellinvestigated. However, because of the potential for cross-resistance, growers will likely 

be cautioned not to plant 2,4-D-resistant and dicamba-resistant crops in successive years 

on the same fields. Under the Preferred Alternative, APHIS concludes that weed crossresistance should and will be monitored carefully. The EPA will likely mandate 

remediation, should such resistance develop. 

Newly available HR crops will facilitate recommendations from weed scientists that 

include rotation of herbicide chemistries to help reduce resistance development. HPPD 

inhibitor-resistant soybeans include one nonregulated soybean (isoxaflutole) cultivar and 

another in process of attaining non-regulated status (mesotrione and isoxaflutole). 

APHIS concludes that rotation of MON 87708 soybean and MON 88701 cottonwith these 

HR crops with auxinic activity would then add additional flexibility when these crops are 

also available to cotton and soybean growers. MON 887701 cotton also has resistance 

to glufosinate, which will offer breadth in mode of action chemistry. Other existing 

188
herbicide resistant crops include those with glufosinate resistance alone, and these also 

may enhance flexibility for sustainable weed management decisions.

Other crops with auxin class herbicide activity. In addition to glyphosate- and glufosinateresistant crops planted by growers, other HR crops have recently been determined as 

nonregulated and will become available. Along with dicamba-resistant MON 87708 soybean and 

MON 88701 cotton, growers will likely select from those with two new herbicide classes of 

activity. GE crops newly determined as nonregulated for 2,4-D-resistant corn and soybean. 2,4-

D, along with dicamba, are both synthetic auxins (auxinic class). If the petitions for 

determinations for nonregulated status are made by APHIS for dicamba resistant crops, use of 

both dicamba and 2,4-D is expected to increase above current usage.Still other crops now in 

development and field testing may culminate in requests for nonregulated status. These include a 

Monsanto corn variety that has resistance to dicamba, glyphosate and to glufosinate (Monsanto, 

2014a; 2014b)but this product is distant from even production of a petition and is only in Phase 3 

of four phases. APHIS is uncertain whether this corn variety will eventually be available to 

growers or not. An additional 2,4-D resistant cotton crop has been submitted by Dow 

Agrosciences as a petition for nonregulated status. Also, a cross-licensing agreement for 

Monsanto to use 2,4-D traits in corn has been negotiated (Farm-Industry-News, 2013) and if 

activated by new hybrids, could also provide additional crops with resistance to auxinic type 

herbicides. 

While it is clear that growers will be offered two auxinic class herbicides in several crops, and 

that both 2,4-D and dicamba will be used with greater frequency, weed scientists are generally 

appreciative of an additional herbicide resistance chemistry being available to growers (see 

comments by Norsworthy and Culpepper on this docket). Being highly aware of the need to avert 

development of new herbicide resistance engendered by HR crops, scientists state that these

products can help minimize selection pressure on weeds by providing a second effective mode of 

action (J. Norsworthy, public comment, this docket). In cotton, only highly limited modes of 

action are available to growers; dicamba resistant cotton could prolong the usefulness of these 

few remaining chemistries (S. Culpepper, public comment this docket). Speaking from close 

interactions with growers, Culpepper (public comment) declares that growers will not follow 

practices of over-dependence on dicamba when they know it will lead to “poor weed control and 

eventual crop failure.” APHIS agrees that the potential for weed resistance to dicamba is clear to 

growers and that with the continued advice and counsel of weed scientists and others, they will 

choose to make dicamba and 2,4-D sustaining tools for management of cotton and soybean 

weeds, and not create additional liabilities to crop production.

Weed resistance to auxinic class herbicides. Depending on how widely these crops are adopted 

and what weed control management practices are followed by growers, weed resistance to each 

herbicide could potentially increase, and weeds arise with resistance to both herbicides. A 

comparison of the history of resistance development by weeds to 2,4-D and to dicamba may 

provide some evidence for the likelihood of rapid development of such resistance (Feng and 

Brinker). Although both dicamba and 2,4-D have been used widely in agriculture for about five 

decades, only a limited number of resistant weeds have arisen compared to the number that have 

arisen to other herbicide modes of action (Mithila et al., 2011). Detected weed resistance to 

dicamba occurred in two species, although Kochia resistance arose in five locations (Table 29) 

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(Heap, 2014d). Kochia resistant to dicamba in Montana may also have low-level resistance to 

2,4-D. Weed resistance to 2,4-D occurred in four US species, only two of which occur in 

soybean and cotton production areas (Heap, 2014d). Two 2,4-D resistant weeds, wild mustard, 

Sinapis arvensis, and prickly lettuce, Lactuca serriola also have dicamba resistance, the first in 

Canada, the second in Washington (Heap, 2014d). Thus, only three weed species have arisen 

with resistance to both dicamba and 2,4-D in the United States and Canada. With 23 herbicides 

in the auxinic group (Heap, 2014d), the world list of resistant weeds in the group was either only 

29 populations (Mithila et al., 2011) or 31 populations (Heap, 2014d). 

That relatively few 2,4-D resistant weeds have developed over a long period in U.S. corn, 

soybean or cotton production indicates that high levels of new weed resistance can be avoided 

following determination of nonregulated status for MON 87708 soybean and MON 88701 

cotton, particularly if diversified weed management practices are implemented.. Agricultural 

usage of dicamba on all U.S. crops was increasing between 1990 and 1994, when it reached 9.4 

million pounds applied annually (Petition VIII-11) (Monsanto, 2012b). The frequency of annual 

use of dicamba was 1.00 for soybean (2006) 1.00 for cotton (2007) and 1.02 for corn (2005) 

(Table VIII-13 (Monsanto, 2012b)). Agricultural usage of 2,4-D averaged 30 million pounds in 

the period 1992-2000 in an earlier era when fewer herbicide choices were available (US-EPA, 

2005)

20, and would have been expected to result in high levels of resistant weed populations 

because of frequent use. Although usage of 2,4-D has declined considerably, as recently as 2004, 

according to USDA-NASS, usage was still between 21 to 33% for wheat, corn, cotton, and 

soybean crops (Mithila et al., 2011).

Additional considerations may influence the low incidence of weed resistance to 2,4-D and 

dicamba. One of these is a relatively low frequency of repeated exposures both historically and 

in current usage. Practical crop production issues limit the usefulness of 2,4-D treatments, and 

may have led to its replacement by other herbicides. For example, 2,4-D in soybean may be used 

in burndown treatments no less than15 to 30 days in advance of planting depending on rate of 

application (Nufarm, Undated), and this is a lengthy wait for a preplant herbicide. 2,4-D may be 

used once, pre-emergence, and then most likely, less frequently on emerged corn that is 8 inches 

or taller because it requires application by directed nozzles only (Nufarm, Undated). 2,4-D may 

not be used on cotton at all. Dicamba presently is used infrequently; in 2012, the herbicide was 

used on only 4% of corn, 5% of cotton and 0.3% of soybean in the United States (see Table 17). 

Dicamba on soybean may be applied 14 to 28 days before planting (dependent on rate) and then 

once on mature soybeans at pre-harvest. Cotton may receive a dicamba treatment as a pre-plant 

application, and later only as a pre-harvest treatment (BASF, 2010). On corn, dicamba may be 

used as a pre-plant (but not around the time of germination) or after the corn is more than 8 

inches tall (but with restrictions if soybean is planted nearby) (BASF, 2010).

Potential for development of weed herbicide resistance to dicamba. Resistance to one of the 

auxinic herbicides does not necessarily predispose resistance to another auxinic herbicide; for 

20 Current use on cotton, soybean and corn (2010-2012, most recent data (USDA-NASS, 2014d)) is 9.3 million 

pounds. Next most recent report of usage for these crops (2005-2007 most recent data, (USDA-NASS, 2014d)) is 6 

million pounds.

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example, yellow star thistle with 3-fold resistance to picloram has 4.4-fold resistance to dicamba, 

but no resistance to 2,4-D (Fuerst et al., 1996). Another recent report of 2,4-D resistance in 

waterhemp shows that for visual injury levels, field resistant water hemp had 19.2-fold resistance 

to 2,4-D, but had only 4.5-fold resistance to dicamba (Bernards et al., 2012). While there are 

three groups of auxinic herbicides, Beckie and Tardiff (2012) note, “the extent and level of cross 

resistance among classes varies widely by auxinic-resistant weed species and is currently 

unpredictable.” Some mechanisms may restrict the potential for resistance to these auxinic 

herbicides, including dicamba. Possibilities that may diminish resistance potential of weeds to 

2,4-D include fitness penalties for plants carrying resistance traits, complexities of the mode of 

action of auxin, or the rare occurrences of resistance alleles in the target weed populations 

(Mithila et al., 2011). Presumably, mechanisms of potential dicamba resistance are similar to 

2,4-D mechanisms and will also engender limited herbicide resistance development in weeds.

Other crops with new herbicide resistance. Other HR crops that exhibit resistance to different 

herbicide modes of action would provide rotational choices consistent with best management 

practices. Enlist 2,4-D-resistant crops may be of limited usefulness to growers that plant MON 

87708 soybean and MON 88701 cotton because both dicamba and 2,4-D have the same mode of 

action. Those other HR crops include one with nonregulated status and the other is a petition 

requesting nonregulated status, both of which are resistant to HPPD inhibitors: these are 

isoxaflutole-resistant and mesotrione-resistant soybean (USDA-APHIS, 2014f). With these 

alternative HR soybean varieties, the availability of MON 87708 soybean and MON 88701 

cottonwill accommodate rotations of auxinic and HPPD inhibitor herbicide chemistries from one 

season to another. Thus, sequential multi-season use of the HPPD inhibitors will help growers 

avoid the continued applications to fields of WSSA Class 4 herbicides (2,4-D and dicamba) 

which would be a risk factors for development of resistant weeds. It is difficult to decide whether 

the grower benefits of an additional mode of action in an herbicide resistant rotation crop will 

outweigh the concerns of having two simultaneous auxinic class herbicides that may additively 

increase the risk of HR weed development. Aside from glufosinate resistant cotton, no other HR 

cotton is available. However, since soybean is a rotation crop for cotton in about 8% of cotton 

acres, the soybean resistant to HPPD inhibitors may be of value in providing a diversity of 

herbicides that may reduce resistant weed development. APHIS concludes that MON 88701 

cotton and MON 87708 soybean will encourage the use of diverse herbicides for improved 

problem weed control, as long as other auxin class herbicides are not also used in successive 

crop rotations with these varieties.

Volunteer MON 87708 soybean and control options

Concerns were raised by one commenter that options for control of glyphosate resistant soybean 

volunteers were presently limited, and then with availability of dicamba resistant soybean, 

control options for these volunteers may further be reduced (CFS, Science Comments I). 

According to Georgia cotton extension specialists, volunteer soybean is uncommon, but can 

sometimes be observed following hurricane damage to soybean fields (York et al., 2005). If 

these volunteers are present, these weed scientists have shown that use of trifloxysulfuron

provides control when applied post-emergence, and that control can be accomplished at presently 

allowable rates.

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Biodiversity

Summary: While in general, herbicides do not promote biodiversity, the potential for 

biodiversity may be enhanced by availability of an additional herbicide chemistry in a 

resistant crop. The use of the new herbicide chemistry may lead to increased productivity 

and consequently, increased yield on existing agricultural land. APHIS concludes that 

the consequences of such yield increase could include a somewhat diminished demand 

for new conversion of CRP lands or other as yet unconverted nonagricultural lands, and 

thus to increased potential for maintaining animal and plant biodiversity.

As described in the No Action Alternative, agricultural practices can affect biodiversity in and 

around agricultural fields. Growers have the opportunity to choose many different practices to 

manage their operations. 

Agricultural practices have the potential to impact diversity at the farm level by affecting farm 

biota, including birds, wildlife, invertebrates, soil microorganisms, and weed populations. 

Conservation tillage leaves a higher rate of plant residue and increases soil organic matter 

(Hussain et al., 1999). This benefits soil biota by providing additional food sources (energy) 

(USDA-NRCS, 1996b) and increasing the diversity of soil microorganisms. It also benefits 

invertebrate detritivores, their predators, and ultimately, birds and other wildlife higher in the 

food chain (Towery and Werblow, 2010; Carpenter, 2011a). Ground-nesting and seed-eating 

birds, in particular, have been found to benefit from greater food and cover associated with 

conservation tillage (SOWAP, 2007).

Herbicide use in agricultural fields can impact biodiversity by decreasing weed quantities or 

causing a shift in weed species. This can affect insects, birds, and mammals that use these weeds. 

The quantity and type of herbicide use associated with conventional and GE crops depends on 

many variables, including cropping systems, type and abundance of weeds, production practices, 

and individual grower decisions.

As described in the No Action Alternative, agricultural practices can affect biodiversity in and 

around agricultural fields. Growers have the opportunity to choose many different practices to 

manage their operations. Both tillage and herbicide use patterns influence biodiversity. If MON 

88701 cotton and MON 87708 soybean are approved, it is likely that use of no-till management 

will remain the same or increase. Therefore, use of these products is likely to provide stability to

biodiversity, especially in fields where tillage is used currently to control GR weeds. In many 

regions tillage is used for purposes other than weed control, so in these areas only the changes in 

herbicide use patterns may influence biodiversity. Because many management choices affect 

farm level biodiversity, the magnitude of this impact on biodiversity is uncertain.

Habitat loss is the greatest direct impact that agriculture has on biodiversity (Ammann, 2005). 

Therefore, methods that increase crop yields have the potential to reduce impacts to biodiversity 

by reducing the amount of land converted to agriculture (Carpenter, 2011a). Gains in yields have 

generally not been obtained by HR cultivars unless higher yielding ones are modified to 

incorporate an HR trait (NRC, 2010b). APHIS concludes that nonregulated status for MON 

88701 cotton and MON 87708 soybean will have no effect on existent biodiversity.

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(USDA-NRCS, 1996b; Hussain et al., 1999; Ammann, 2005; SOWAP, 2007; NRC, 2010b; Towery and Werblow, 

2010; Carpenter, 2011a; Carpenter, 2011b)

5.6.6 Physical Environment

Summary: Potential cumulative impacts on the Physical Environment can mostly be 

ascribed to the use of dicamba on MON 87708 soybean and MON 88701 cotton. 

Dicamba-resistant crops may deter growers from returning to conventional tillage that 

may otherwise become necessary for controlling glyphosate-resistant weeds. Under the 

No Action Alternative, development of additional glyphosate-resistant and other 

herbicide-resistant weeds will likely continue; one response that growers may take would 

be to increase such tillage. The potential impacts on Soil, Water, Air Quality and Climate 

Change, which are directly affected by the increased use of tillage, would be diminished 

under the Preferred Alternative. Any direct and indirect impacts of dicamba use are 

being assessed by the EPA, and are outside the scope of this EIS.

After the EPA approves the proposed uses of dicamba and the Preferred Alternative is chosen by 

APHIS, there is an expectation that the use of dicamba will increase. This increase in dicamba 

use has the potential to impact natural resources. APHIS does not regulate the use of dicamba. 

The direct and indirect impacts which arise from this increased use are the result of the action

that the EPA is taking with respect to labeling dicamba (M1691) for use on MON 87708 soybean 

and MON 88701 cotton that are the subject of the two petitions being considered in this EIS. 

APHIS expects the EPA to implement appropriate label requirements for registration of the 

M1691, and has considered the cumulative impacts from changes in production practices that 

may arise from HR weeds.

Soil Quality

The major cotton and soybean regions in the U.S. also are areas where soil erosion exceeds 

replacement. Many of these intensively farmed areas are also on highly erodible lands. In some 

of these areas conservation tillage has been adopted as part of the management plan for 

controlling erosion. 

If conventional tillage increases to control glyphosate- and other herbicide-resistant weeds, there 

may be an impact on soil quality. Residue management that employs intensive tillage and leaves 

low amounts of crop residue on the surface results in greater losses of soil organic matter (SOM) 

(USDA-NRCS, 1996b). The total acreage that may be impacted by such an increase in tillage 

would be based on the extent of resistant weeds present in a field and the weed management 

strategy chosen by a grower. Adoption of MON 88701 cotton and MON 87708 soybean can 

provide growers with an alternative herbicide to glyphosate and glufosinate. Intensive use of 

glyphosate on GR crops has been associated with increased selection for GR weeds. Many 

growers have expressed a need for these crop events during the scoping comment period 

associated with this EIS because of their weed problems. 

Based on individual grower needs, these two events and the EPA approval of dicamba use on 

them could provide growers with an alternative to intensive tillage practices that may be used to 

address herbicide resistance issues. This could reduce the potential loss of SOM and soil erosion 

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that may result when more aggressive tillage practices are used to combat HR weeds under the 

No Action Alternative. However, the selection of weeds resistant to glyphosate, dicamba, and 

glufosinate will limit the use of this product and any benefit to soil that may arise. The 

magnitude of the benefit or the loss of the benefit is uncertain because growers individually 

make decisions on soil management practices. Therefore, each action could contribute 

incrementally to the problem of soil erosion.

Water Quality

Under the No Action Alternative, increased tillage to manage GR weeds may occur and lead to 

increased soil erosion and decreases in water quality from sedimentation and transport of 

nutrients and other chemicals to surface water. When considering the cumulative impacts of the 

Preferred Alternative, MON 87708 soybean and MON 88701 cotton cropping systems may help 

to preserve gains in conservation tillage in the short term. In the long term, selection of dicambaresistant weeds may result in similar aggressive tillage practices that are expected to occur under 

the No Action Alternative and negate the benefits mentioned above.

Air Quality

Under the No Action Alternative, increased tillage to manage GR weeds may occur and lead to 

decreased air quality from increased air particulates and exhaust from farm equipment. When 

considering the cumulative impacts of the Preferred Alternative, MON 87708 soybean and MON 

88701 cotton cropping systems for cotton and soybean may help to preserve gains in 

conservation tillage and benefit air quality in the short term. In the long term, selection of 

dicamba resistant weeds may result in similar aggressive tillage practices that are expected to 

occur under the No Action Alternative and negate the benefits mentioned above.

Climate Change

Under the No Action Alternative, there is a potential impact on climate change from increased 

herbicide use and more aggressive tillage regimes to control HR weeds, causing increased 

release of GHG from burning additional fossil fuels and soil disruption that releases sequestered 

carbon as GHGs. When considering the cumulative impacts of the Preferred Alternative, MON 

87708 soybean and MON 88701 cotton cropping systems for cotton and soybean may help to 

preserve gains in conservation tillage and reduce GHG contributions to climate change in the 

short term. In the long term, selection of dicamba resistant weeds may result in similar 

aggressive tillage practices that are expected to occur under the No Action and negate the 

benefits mentioned above.

5.7 Cumulative Impacts - Alternative 3

5.7.1 Agronomic Practices

Under Alternative 3, only MON 88701 cotton would no longer be subject to regulation by 

APHIS. MON 87708 soybean would continue to be regulated. Under this Alternative, 

supplementation of EPA’s registration for dicamba use on MON 88701 cotton, dicamba use is 

predicted to increase relative to the No Action Alternative (Appendix 4, Table 4-12), but is less 

than the increase expected under the Preferred Alternative. 

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The increased use of dicamba may increase the selection of dicamba-resistant weeds, which 

might increase the costs for weed control in cotton, sorghum, soybean, and fallow applications. 

The pressure for selecting dicamba-resistant weeds is expected to be lower in Alternative 3 than 

Alternative 2 because dicamba-resistant soybeans could not be commercially grown. Those 

regions where there is a higher percentage of cotton acreage and less of soybean will show less 

usage of dicamba and thus less likelihood of dicamba-resistant weeds, especially under 

Alternative 3 (Regions J, K, L). There would be one less tool for GR weeds in soybean if new 

formulations for MON 87708 soybean were not available for soybean applications, and under 

present management conditions, these GR weeds would potentially by more difficult to control.

5.7.2 Health and Safety Aspects for Livestock and Humans

No cumulative impacts from the changes in production practices were identified on human 

health for any of the Alternatives. APHIS expects the EPA to implement appropriate label 

requirements for registration of the M1691. The EPA considers the direct and indirect impacts 

from herbicide use on human health as part of their regulatory decision. Therefore, those impacts 

are outside the scope of this EIS.

5.7.3 Biological Resources 

Depending on the adoption rate of MON 88701 cotton as well as the management practices 

employed by growers, there may be an increase in the selection of dicamba-resistant weeds 

under Alternative 3 relative to the No Action Alternative. However, the selection of dicambaresistant weeds is expected to be less than under the Preferred Alternative. An increased level of 

resistant weeds would result in need for additional herbicide applications for their control, which 

could have impacts by drift to vegetation in the vicinity. Impacts on beneficial insects that 

typically may improve insect control on crops may be incurred because of the additional 

chemicals inadvertently applied to adjacent natural plants (Egan et al., 2014). The EPA considers 

the direct and indirect impacts from herbicide use on non-target organisms as part of their 

regulatory decisions. Therefore, those impacts are outside the scope of this EIS. The EPA is 

analyzing the potential impacts of the proposed new uses of dicamba on the environment, 

including non-target organisms. It is probable that the EPA will include label restrictions and 

requirements to limit off-site transport of dicamba as has been done with the proposed 

registration of Enlist Duo (US-EPA, 2014a). APHIS expects the EPA to implement biologically 

and environmentally protective label requirements for registration of the M1691.

5.7.4 Physical Environment

If conservation tillage practices were to decrease, natural resources could be impacted. However, 

cotton growers still have several effective herbicide chemistries to control GR weeds, including 

atrazine and chloroacetamides. Consequently, under Alternative 3, tillage practices for cotton 

growers are not expected to differ compared to the No Action Alternative. 

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5.8 Cumulative Impacts - Alternative 4

5.8.1 Agronomic Practices

Under Alternative 4, MON 87708 soybean would be granted nonregulated status but MON 

88701 cotton would continue to be regulated. If APHIS selects this Alternative and EPA 

approves the new use of dicamba on MON 87708 soybean, Monsanto estimates an increase in 

dicamba use associated with adoption of MON 87708 soybean (at peak adoption of 40%) to 

20.5 million (Table 4-9) or 5.4 times the dicamba use on all crops under the No Action 

Alternative (Appendix 4, Table 4-9). The increased use of dicamba may increase the selection of 

dicamba-resistant weeds which may eventually increase costs for weed control in cotton, 

sorghum, soybean, and fallow applications. APHIS expects the EPA to implement appropriate 

label requirements for registration of the M1691 regarding weed resistance management. The 

pressure for selecting dicamba-resistant weeds is expected to be lower in Alternative 4 than the 

Preferred Alternative. Those regions where soybean acres are high with respect to cotton

(Regions E, F, G, I, see Table 21) would show less overall dicamba use (since dicamba would be 

used at minimal levels in cotton), and less likelihood for development of dicamba-resistant 

weeds than in areas with high acreage of both cotton and soybean. Control of GR weeds in 

cotton would include herbicides other than dicamba, so less control over these weeds is a 

consequence of not having dicamba available for pre and post-emergent treatment of these 

weeds.

Those regions where there is a higher percentage of cotton acres and less of soybean will show 

less usage of dicamba and thus less likelihood of dicamba-resistant weeds, especially under 

Alternative 4 (Regions J, K, and L). No cumulative impacts were identified on Human Health for 

any of the Alternatives.

5.8.2 Health and Safety Aspects for Livestock and Humans

No cumulative impacts were identified on human health or livestock for any of the Alternatives. 

EPA considers the direct and indirect impacts from herbicide use on human health and non-target 

organisms as part of their regulatory decisions. Therefore, those impacts are outside the scope of 

this EIS.

5.8.3 Biological Resources

Depending on the adoption rate of MON 87708 soybean and the management practices used by 

growers, there may be an increase in the selection of dicamba-resistant weeds under Alternative 

4 relative to the No Action Alternative. The selection of dicamba-resistant weeds is expected to 

be less than under the Preferred Alternative. An increased level of resistant weeds would result in 

the need for additional herbicide applications for their control, which could impact non-target 

organisms in the vicinity. Impacts on beneficial insects that typical may improve insect control 

on crops may be incurred because of the additional chemicals inadvertently applied to adjacent 

natural plants (Egan et al., 2014). The EPA considers the direct and indirect impacts from 

herbicide use on non-target organisms as part of their regulatory decisions. Therefore, those 

impacts are outside the scope of this EIS. The EPA is analyzing the potential impacts of the 

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proposed new uses of dicamba on the environment, including non-target organisms. It is 

probable that the EPA will include label restrictions and requirements to limit off-site transport 

of dicamba as has been done with the proposed registration of Enlist Duo (US-EPA, 2014a).

5.8.4 Physical Environment

If conservation tillage practices were to decrease, natural resources could be impacted. Under the 

No Action Alternative, soybean growers are expected to use less conservation tillage in areas 

where GR weeds are poorly controlled by herbicides. Under Alternative 4, weed control by 

dicamba is expected to be more effective in soybean than under the No Action Alternative. 

Therefore, conservation tillage practices are expected to be more widely practiced under 

Alternative 4 than under the No Action Alternative and natural resources are less likely to be 

adversely impacted.

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6 OTHER IMPACTS AND MITIGATION MEASURES

This section describes other potential impacts associated with the implementation of the Action 

Alternatives, including unavoidable impacts; short-term versus long-term productivity of the 

environment; and irreversible/irretrievable commitment of resources. This section also describes 

potential impact mitigation measures, as applicable, beyond what is already built into the 

Alternatives.

6.1 Unavoidable Impacts

Unavoidable impacts are any adverse environmental effects which cannot be avoided should the 

proposal be implemented (40 CFR § 1502.16). Herbicides represent a tool that allows for the 

economical production of cotton and soybeans. As long as herbicides are used to produce cotton 

and soybean, weeds will develop resistance to the herbicides used. Under all four Alternatives, 

the selection of HR weeds is an unavoidable impact. Growers may mitigate the rate at which 

weeds develop resistance by adopting best management practices. APHIS does not have the 

authority to regulate grower management practices nor does APHIS have the authority to 

regulate herbicide use.

6.2 Short Term Versus Long Term Effects

In the short term, growers who adopt MON 87708 soybean or MON 88701 cotton are likely to 

experience more efficient and less costly control of GR weeds. Adopters may be better able to 

maintain conservation tillage programs on their farms. Growers of non-GE crops and other GE 

crops may experience a decline in the weed seed bank as overall weed control improves on 

neighboring farms.

Over the long term, as weeds develop resistance to dicamba or glufosinate, multiple resistance to 

these compounds and glyphosate, will likely reduce the efficiency of weed control. This will tend 

to increase weed management costs. Some growers may need to use more aggressive tillage to 

control resistant weeds. Adoption of conventional tillage would be expected to result in greater 

soil erosion, loss of organic matter, soil compaction, and reduced moisture holding capacity, as 

compared to conservation or reduced tillage methods. This would lead to an increase in potential 

sedimentation and turbidity in nearby surface waters during rain and irrigation events and 

adverse impacts to biological resources. Non-adopters and growers of non-GE crops will again 

be impacted by weeds from neighboring farms. Growers of small cereal crops will experience 

greater weed control costs as alternatives to these herbicides are likely to be more costly.

6.3 Irreversible Resource Commitments

Irreversible resource commitments represent a loss of future options. This applies primarily to 

the use of nonrenewable resources and to factors that are renewable only over long time spans, or 

to adverse impacts that cannot be reversed. An irretrievable commitment of resources represents 

opportunities that are lost for the period of the proposed action. It also includes the use of 

renewable resources, such as timber or human effort, as well as other utilization opportunities

that are foregone in favor of the proposed action. 

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No irreversible or irretrievable commitments of resources were identified with the Action 

Alternatives.

6.4 Mitigation Measures 

As defined in the CEQ regulations for implementing NEPA (40 CFR § 1508.20) mitigation 

includes:

• avoiding the impact altogether by not taking a certain action or parts of an action;

• minimizing impacts by limiting the degree or magnitude of the action and its 

implementation;

• rectifying the impact by repairing, rehabilitating, or restoring the affected 

environment;

• reducing or eliminating the impact over time by preservation and maintenance 

operations during the life of the action; and

• compensating for the impact by replacing or providing substitute resources or 

environments.

APHIS does not have the authority to regulate types of management practices or use of 

herbicides. Nevertheless, mitigation can occur by a number of means. First growers may 

voluntarily adopt best practices recommended by weed experts. Second, any grower who uses 

either MON 87708 soybean or MON 88701 cotton will be expected to follow a stewardship

agreement. APHIS assumes that there would be no binding enforcement mechanism to ensure 

that farmers follow the stewardship agreement but failure to do so could jeopardize a grower’s 

access to the technology. 

Mitigation measures to oversee the proper use of herbicides are determined by the EPA and are 

disseminated to the herbicide users through EPA-approved labels. Adherence to herbicide label 

requirements, including application rates and techniques and following industry herbicide 

stewardship programs, will largely minimize improper herbicide usage. The extent of herbicide 

drift will be mitigated by the requirement to use dicamba and glufosinate by conditions on the 

label that will require nozzles that limit drift and restrictions on when and how the herbicide can 

be applied. State and local governments may also impose restrictions on when and how 

herbicides can be applied (see Appendix 7).

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7 THREATENED AND ENDANGERED SPECIES

The Endangered Species Act (ESA) of 1973, as amended, is one of the most far-reaching 

wildlife conservation laws ever enacted by any nation. Congress passed the ESA to prevent 

extinctions facing many species of fish, wildlife and plants. The purpose of the ESA is to 

conserve endangered and threatened species (TES) and the ecosystems on which they depend as 

key components of America’s heritage. To implement the ESA, the U.S. Fish & Wildlife Service 

(USFWS) works in cooperation with the National Marine Fisheries Service (NMFS), other 

Federal, State, and local agencies, Tribes, non-governmental organizations, and private citizens. 

Before a plant or animal species can receive the protection provided by the ESA, it must first be 

added to the Federal list of threatened and endangered wildlife and plants.

A species is added to the list when it is determined by the USFWS/NMFS to be endangered or 

threatened because of any of the following factors:

• The present or threatened destruction, modification, or curtailment of its habitat or range;

• Overutilization for commercial, recreational, scientific, or educational purposes;

• Disease or predation;

• The inadequacy of existing regulatory mechanisms; and

• The natural or manmade factors affecting its survival.

Once an animal or plant is added to the list, protective measures apply to the species and its 

habitat. These measures include protection from adverse effects of federal activities. 

7.1 Requirements for Federal Agencies

Federal Section 7 (a)(2) of the ESA requires that federal agencies, in consultation with USFWS 

and/or the NMFS, ensure that any action they authorize, fund, or carry out is “not likely to 

jeopardize the continued existence of a listed species or result in the destruction or adverse 

modification of designated critical habitat.” It is the responsibility of the federal agency taking 

the action to assess the effects of their action and to consult with the USFWS and NMFS if it is 

determined that the action “may affect” listed species or designated critical habitat. To facilitate 

their ESA consultation requirements, APHIS met with the USFWS from 1999 to 2003 to discuss 

factors relevant to APHIS’ regulatory authority and effects analysis for petitions for nonregulated 

status and developed a process for conducting an effects determination consistent with the Plant 

Protection Act (PPA) of 2000 (Title IV of Public Law 106-224). APHIS uses this process to help 

fulfill its obligations and responsibilities under Section 7 of the ESA for biotechnology 

regulatory actions.

APHIS met with USFWS officials on June 15, 2011, to discuss whether APHIS has any 

obligations under the ESA regarding analyzing the effects of pesticide use associated with all GE 

crops on TES. As a result of these joint discussions, USFWS and APHIS have agreed that it is 

not necessary for APHIS to perform an ESA effects analysis on pesticide use associated with GE 

crops currently planted because the EPA has both regulatory authority over the labeling of 

pesticides and the necessary technical expertise to assess pesticide effects on the environment 

under FIFRA. APHIS has no statutory authority to authorize or regulate the use of dicamba, 

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glufosinate, or any other herbicide, by cotton and soybean growers. Under APHIS’ current Part 

340 regulations, APHIS only has the authority to regulate MON 87708 soybean and MON 88701 

cotton or any GE organism as long as APHIS believes they may pose a plant pest risk (7 CFR § 

340.1). APHIS has no regulatory jurisdiction over any other risks associated with GE organisms 

including risks resulting from the use of herbicides or other pesticides on those organisms.

After completing a plant pest risk analysis, if APHIS determines that MON 87708 soybean and 

MON 88701 cotton seeds, plants, or parts thereof is not likely to pose a plant pest risk, then these 

articles would no longer be subject to the plant pest provisions of the PPA or to the regulatory 

requirements of 7 CFR Part 340, and therefore, APHIS must reach a determination that these 

articles are no longer regulated. As part of its analysis, APHIS considered the potential effects of 

MON 87708 soybean and MON 88701 cotton on the environment including, as required by the 

ESA, any potential effects to threatened and endangered species and critical habitat. As part of 

this process, APHIS thoroughly reviews the GE product information and data related to the 

organism (generally a plant species, but may also be other GE organisms). For each 

transgene/transgenic plant, APHIS considers the following:

• A review of the biology and taxonomy of the crop plant and its sexually compatible 

relatives;

• Characterization of each transgene with respect to its structure and function and the 

nature of the organism from which it was obtained;

• A determination of where the new transgene and its products (if any) are produced in the 

plant and their quantity;

• A review of the agronomic performance of the plant, including disease and pest 

susceptibilities, weediness potential, and agronomic and environmental impacts;

• Determination of the concentrations of known plant toxicants (if any are known in the 

plant);

• Analysis to determine if the transgenic plant is sexually compatible with any TES of 

plants or a host of any TES; and

• Any other information that may inform the potential for an organism to pose a plant pest

risk.

7.2 Potential Effects of MON 88701 Cotton and MON 87708 Soybean on TES

In following this review process, APHIS, as described below, has evaluated the potential effects 

that a determination of nonregulated status of MON 87708 soybean and MON 88701 cotton may 

have, if any, on federally-listed TES species and species proposed for listing, as well as 

designated critical habitat and habitat proposed for designation. Based upon the scope of the EIS 

and production areas identified in the Affected Environment section of the EIS, APHIS reviewed 

the USFWS list of TES species (listed and proposed) for each state where soybean and cotton are 

commercially produced (USFWS, 2014a; 2014b).

Prior to this review, APHIS considered the potential for MON 87708 soybean and MON 88701 

cotton to extend the range of soybean production and also the potential to extend agricultural 

production into new natural areas. APHIS has determined that agronomic characteristics and 

cultivation practices required for MON 87708 soybean and MON 88701 cotton are essentially 

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indistinguishable from practices used to grow other cotton and soybean varieties, including other 

herbicide- resistant varieties (Monsanto, 2012a; 2012b; 2013a; USDA-APHIS, 2014d; 2014e).

Although MON 87708 soybean and MON 88701cotton may be expected to replace other 

varieties of cotton and soybean currently cultivated, APHIS does not expect the cultivation of 

these to result in new cotton or soybean acres to be planted in areas that are not already devoted 

to agriculture. Accordingly, the issues discussed herein focus on the potential environmental 

consequences of the determination of nonregulated status of MON 87708 soybean and MON 

88701 cotton on TES species in the areas where cotton and soybean are currently grown.

For its analysis on TES plants and critical habitat, APHIS focused on the agronomic differences 

between the regulated articles and cotton and soybean varieties currently grown; the potential for 

increased weediness; and the potential for gene movement to native plants, listed species, and 

species proposed for listing.

For its analysis of effects on TES animals, APHIS focused on the implications of exposure to the 

novel proteins expressed in the plants (Table 30) as a result of the transformation, and the ability 

of the plants to serve as a host for a TES.

Table 30. Novel Proteins Associated with MON 87708 Soybean and MON 88701 Cotton.

Regulated Article Protein Phenotypic Effects

MON 87708 soybean dicamba mono-oxygenase 

(DMO)

Resistance to the herbicide 

dicamba (3,6-dichloro-2-

methoxybenzoic acid).

MON 88701 cotton dicamba mono-oxygenase 

(DMO)

Resistance to the herbicide 

dicamba (3,6-dichloro-2-

methoxybenzoic acid).

phosphinothricin 

acetyltransferase (PAT)

Resistance to glufosinate

Source:(Monsanto, 2012a; 2012b)

7.2.1 Potential Effects of MON 88701 Cotton on TES Plant Species

Upland cotton (G. hirsutum) possesses few of the characteristics common to plants that are 

successful weeds (Baker, 1965; Keeler, 1989) and is not considered to be a serious or common 

weed in the U.S. It is not listed as a weed in the major weed references (Muenscher, 1939; 

Crockett, 1977; Holm et al., 1979), nor is it present on Federal or State lists of noxious weed 

species (USDA-APHIS, 2012; USDA-NRCS, 2012a). Modern Upland cotton is a domesticated 

perennial grown as an annual crop that is not generally persistent in unmanaged or undisturbed 

environments without human intervention. Modern cultivars are not frost tolerant and do not 

survive freezing winter conditions, do not produce abundant or long-lived seeds that can persist 

or lie dormant in soil, do not exhibit vegetative propagation or rapid vegetative growth, and do 

not compete effectively with other cultivated plants (OECD, 2008a). In areas where winter 

temperatures are mild and freezing does not occur, cotton plants can occur as volunteers in the 

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following growing season. These volunteers can be easily controlled by herbicides or mechanical 

means. Excepting dicamba and glufosinate, MON 88701 is expected to be sensitive to the same 

herbicides as other cotton varieties (USDA-APHIS, 2014d). Cotton can become locally feral or 

naturalized in suitable areas, such as southern Florida, Hawaii, and Puerto Rico (Fryxell 1984; 

Coile and Garland, 2003; Wunderlin and Hansen, 2008; USDA-NRCS, 2012c).

The agronomic and morphologic characteristics data provided by Monsanto were used in the 

APHIS analysis of the weediness potential for MON 88701 cotton, and evaluated for the 

potential to impact TES and critical habitat. Agronomic studies conducted by Monsanto tested 

the hypothesis that the weediness potential of MON 88701 cotton is unchanged with respect to 

conventional cotton (Monsanto, 2012b; 2013a). Monsanto collected agronomic data relevant to 

weedy traits such as plant vigor and height and seed yield from field experiments conducted in 

two studies at a total of 15 (Study 1) and 11 (Study 2) locations across the U.S. during the 2010 

growing season (Monsanto, 2012b). All locations in Study 2 were also included in Study 1. Data 

were collected for control Coker 130 cotton and MON 88701 cotton, as well as for MON 88701 

cotton treated with the herbicides glufosinate (0.5 lb a.i./acre at the 3 – 5 leaf stage) and dicamba 

(0.5 lb a.e./acre at the 6-10 leaf stage) to allow for assessment of MON 88701 under the 

agronomic system that it is expected to be used (Monsanto, 2012b). Data were also collected for 

11 (Study 1) and eight (Study 2) commercial reference varieties (four varieties grown per site) to 

establish statistical tolerance intervals for the various traits assessed (Monsanto, 2012b).

Plant vigor was assessed qualitatively. No differences in vigor were observed between MON 

88701 cotton and the Coker 130 control at 14 and 30 days after planting for 73 out of 74 

comparisons across all sites and treatments. At one site, MON 88701 cotton plants were slightly 

less vigorous than Coker 130 at 30 days after planting, but were within the range of vigor ratings 

of the commercial reference varieties (Monsanto, 2012b). Other agronomic data were assessed 

quantitatively. In the combined-site analysis, no statistically significant (p < 0.05) differences 

were observed between MON 88701 cotton and the Coker 130 control for stand count at 14 and 

30 days after planting, final stand count, seed cotton yield, number of immature seeds per boll, 

boll weight, or a variety of fiber characteristics (Monsanto, 2012b). In both studies, whether 

untreated or herbicide treated, MON 88701 cotton plants were shorter than Coker 130 control 

plants, took slightly longer to mature, produced more but smaller seed, and had a slightly 

increased fiber strength (Monsanto, 2012b). These differences were all small and in all cases the 

mean values for these characteristics were within the range observed for the commercial 

reference varieties (Monsanto, 2012b). Changes in disease or insect pest susceptibility or in 

response to abiotic stress were not observed in MON 88701 cotton relative to the control

(Monsanto, 2012b).

In summary, no differences were detected between MON 88701 cotton and non-transgenic 

cotton in growth, reproduction, or interactions with pests and diseases, other than the intended 

effect of resistance to the two herbicides (Monsanto, 2012b; USDA-APHIS, 2014d).

As part of its analysis of effects on species and habitat, APHIS evaluated the potential of MON 

88701 cotton to cross with wild relatives. Cultivated G. barbadense (Pima or Egyptian cotton), is 

grown in Arizona, California, New Mexico, and Texas (Pleasants and Wendell, 2005b; USDANASS, 2012e). Naturalized populations of G. barbadense grow in Puerto Rico, the Virgin 

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Islands and most of the major Hawaiian Islands (Fryxell 1984; Bates, 1990; USDA-NRCS, 

2012b). Two wild species of cotton are native to the U.S., G. thurberi and G. tomentosum, and 

grow in Arizona and Hawaii respectively (Fryxell 1984; USDA-NRCS, 2012b). G. hirsutum is 

tetraploid and thus effectively incompatible with diploid species such as G. thurberi. Plants from 

these two groups do not normally hybridize spontaneously and produce fertile offspring, and 

experimental crosses are difficult (OECD, 2008a). In contrast, G. hirsutum is sexually 

compatible with the tetraploids G. barbadense (cultivated Pima or Egyptian cotton) and G. 

tomentosum and can form viable and fertile progeny with both species (Brubaker CL et al., 1993; 

Saha et al., 2006; OECD, 2008a). Thus, unassisted outcrossing and gene introgression could 

potentially occur in areas where these species are co-located (USDA-APHIS, 2014d). 

For transgene introgression from MON 88701 cotton to occur there would have to be spatial 

proximity between MON 88701 cotton and the recipient variety or species; overlap in their 

flowering period; and because cotton is insect pollinated, they must share similar pollinators 

(Pleasants and Wendell, 2005b). Published studies report that there has been relatively little gene 

introgression from G. hirsutum into native or naturalized G. barbadense in Mesoamerica and the 

Caribbean, despite the fact that G. barbadense has been grown in the presence of the 

predominant G. hirsutum since prehistoric times (Wendel et al., 1992; Brubaker CL et al., 1993). 

In contrast, introgression from G. barbadense to native or naturalized G. hirsutum in these areas

has been relatively common (Wendel et al., 1992; Brubaker CL et al., 1993). Various 

mechanisms have been suggested to account for this difference (Percy and Wendel, 1990; 

Brubaker CL et al., 1993; Jiang et al., 2000; OGTR, 2008). While none of these mechanisms 

leads to complete isolation between the two species, the reported asymmetry in gene flow

suggests that gene introgression from cultivated G. hirsutum varieties such as MON 88701 to 

native or naturalized G. barbadense should be rare (USDA-APHIS, 2014d).

Natural populations of G. tomentosum are found on all Hawaiian Islands except Kauai and 

Hawaii. Populations are located on the drier, leeward coastal plains of the islands at low 

elevations, which are also the areas that are primarily used for agriculture (Pleasants and 

Wendell, 2005b). As discussed further in the PPRA, there is overlap in the timing of flowering 

(both seasonally and time of day), and potential pollinators with G. hirsutum (USDA-APHIS, 

2014d). However, G. hirsutum has not been grown as an agricultural commodity in Hawaii for 

decades, and, seed companies no longer use the Hawaiian Islands as a winter nursery for cotton

(Grace, 2012; USDA-APHIS, 2014d). Even if gene introgression into wild relatives were to 

occur, expression of the DMO and PAT proteins does not cause any major changes in the 

phenotype of cotton plants other than to confer resistance to the herbicides dicamba and 

glufosinate (Monsanto, 2012b; USDA-APHIS, 2014d). In the absence of treatment with these 

herbicides, the transgenic material in MON 88701 is unlikely to confer a selective advantage on 

any hybrid progeny that may result from outcrossing (USDA-APHIS, 2014d).

None of the relatives of cotton are Federally listed (or proposed) as endangered or threatened 

species (USFWS, 2014c). In Florida wild populations of upland cotton, G. hirsutum have been 

listed as endangered by the state (Coile and Garland, 2003). However, wild G. hirsutum is not 

present in the northwestern panhandle where cotton cultivation occurs, and cultivation of cotton 

is prohibited by the EPA in those areas of southern Florida where it is found (US-EPA, 2001; 

Coile and Garland, 2003; Wunderlin and Hansen, 2008). Thus, outcrossing from MON 88701

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cotton to naturalized G. hirsutum in Florida is highly unlikely. Accordingly, a determination of 

nonregulated status of MON 88701 cotton is not expected to impact state endangered feral cotton 

populations.

Based on agronomic field data, literature surveyed on cotton weediness potential, the biology of 

cotton, and no sexual compatibility of TES with cotton in areas where cotton is commercially 

grown, APHIS has concluded that MON 88701 cotton will have no effect on threatened or 

endangered plant species or on critical habitat

7.2.2 Potential Effects of MON 88701 Cotton on TES Animal Species

Threatened and endangered animal species that may be exposed to the gene products in MON 

88701 cotton would be those TES that inhabit cotton fields and feed on MON 88701 cotton. To 

identify potential effects on threatened and endangered animal species, APHIS evaluated the 

risks to threatened and endangered animals from consuming MON 88701 cotton.

Cotton plants contain the anti-nutrient gossypol that plays a role in defense of cotton against 

insect pests (Chan et al., 1978; Kong et al., 2010). Gossypol is a yellow polyphenolic pigment 

found in the cotton plant and in the small pigment glands in the seed (Ely and Guthrie, 2012). 

Studies indicate that on cotton bollworm (Helicoverpa armigera) higher levels of gossypol were 

fatal although lower levels were found to be beneficial to growth (Paz Celorio-Mancera et al., 

2011). Gossypol is harmful to monogastrics such as chickens, swine, and young ruminants (Ely 

and Guthrie, 2012). This defense seems to have little effect in reducing feeding by adult 

ruminants. In the North Carolina, 92% of cotton growers surveyed reported damage from whitetailed deer (North Carolina Department of Agriculture and Consumer Services, 2010). Whole 

cottonseed is often used by deer managers as a supplemental feed because it is cheaper than 

protein pellets and feral hogs and raccoons will not consume it (DeYoung, 2005; Taylor et al., 

2013). When doing so, managers generally stop feeding in June to allow time for plasma 

gossypol levels to reduce prior to entering the breeding season. Although feeding studies of 

whole cottonseed to whitetails is lacking, there is a general belief that feeding high 

concentrations, especially during breeding season, may reduce breeding success (Bullock et al., 

2010). Studies on European red deer indicate that bucks fed whole cottonseed had negative 

response in regard to body weight and antler growth (Brown et al., 2002). In studies of fallow 

deer, feeding whole cottonseed to bucks resulted in decreased body weight, body condition 

score, antler growth, and plasma testosterone concentration (Mapel, 2004).

Whole cottonseed is commonly used as a supplemental protein feed for cattle (Ely and 

Guthrie, 2012). However, care must be taken to not overfeed because of the possibility of 

gossypol toxicity. If fed too much whole cottonseed, even mature dairy cows have been 

known to become ill and fatalities have occurred when it was the sole diet (Ely and Guthrie, 

2012). Other domestic ruminants such as goats have also shown negative effects from 

consumption of whole cottonseed feed. However, some of the detrimental effects were 

attributed to the increased dietary intake of ether extract and neutral detergent fiber rather 

than gossypol (Luginbuhl et al., 2000). One study indicated that whole cottonseed 

introduced as 15% of the diet to Nubian buck kids had positive results in growth, but at 30%

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had increased red blood cell fragility and reduced reproductive performance (Solaiman, 

2007).

Perhaps partly because of the toxic effects of gossypol in cotton plants, especially in nonruminants, information on wildlife depredation of cotton other than whitetail deer is lacking. 

However, wildlife may use cotton fields as a food source, consuming the insects that live on and 

among the plants. Quall and some other birds are known to nest in grassy strips on the edge of 

cotton fields and will enter the fields to obtain food or grit (Palmer and Bromley, NoDate).

However, TES generally are found outside of agricultural fields in natural settings. Few if any 

TES are likely to use cotton fields because they do not provide suitable habitat. Only whooping 

crane (Grus americana), sandhill crane (Grus canadensis pulla), piping plover (Charadrius 

melodus), interior least tern (Sterna antillarum), and Sprague’s pipit (Anthus spragueii; a 

candidate species) occasionally feed in farmed sites (USFWS, 2011). These bird species may 

visit cotton fields during migratory periods, but would not be present during normal farming 

operations (Krapu et al., 2004; USFWS, 2011).

Monsanto has presented information comparing the compositional elements of MON 88701 

cotton variety with conventional varieties and evaluating the differences between varieties with 

and without herbicide applications (Monsanto, 2012b). The samples for compositional 

assessment were collected from eight locations in 2010, chosen to represent typical cotton 

growing regions of the U.S., and compared to a control variety, Coker 130 (Monsanto, 2012b). 

Analytes were assessed quantitatively and included 47 nutrients (proximates, fiber, amino acids, 

fatty acids, minerals, and vitamin E) and five anti-nutrients (fatty acids, gossypol). Statistically 

significant (p <0.05) differences in the combined-site nutrient levels were observed for 16 

nutrients in both herbicide treated and untreated MON 88701 cotton compared to the Coker 130 

control: the proximates ash, calories, carbohydrates, moisture, and total fat; acid detergent fiber, 

neutral detergent fiber, total dietary fiber; the amino acid arginine; the fatty acid 14:0 myristic 

acid; the minerals calcium, magnesium, manganese, potassium, and zinc; and vitamin E. Three 

additional nutrients were statistically significantly different in herbicide treated MON 88701 

cotton only (the amino acids methionine and proline, and the fatty acid 18:2 linoleic acid), while 

one additional nutrient was statistically significantly different in untreated MON 88701 cotton 

only (crude fiber) (Monsanto, 2012b). With the exception of calcium (increased 14% and 15%

relative to control in treated and untreated MON 88701 cotton respectively), all differences in 

nutrient levels were 10% or less. In addition, most of the statistically significant differences in 

nutrient levels were not consistently observed across locations, with the exception of calcium 

(statistically significant differences observed in seven of eight locations), ash (statistically 

significant differences observed at six (treated) and four (untreated) locations), 18:0 stearic acid 

(statistically significant differences observed at five locations), and manganese (statistically 

significant differences observed at five locations for untreated MON 88701 cotton only)

(Monsanto, 2012b). However, in all of these cases, the mean levels of all nutrients in MON 

88701 cotton were within the 99% tolerance interval established from the conventional 

commercial reference varieties (International-Life-Sciences-Institute, 2010). While the mean 

level of methionine in herbicide treated (but not untreated) MON 88701 were slightly outside of 

the 99% tolerance interval, the mean increase in methionine was less than 5%. The increase was 

not consistently observed across locations (a statistically significant difference was observed at 

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only one of the eight locations), and the mean level of methionine was within the natural 

variation observed for commercial cotton varieties (International-Life-Sciences-Institute, 2010).

Statistically significant (p <0.05) increases in combined-site anti-nutrient levels were observed 

for two anti-nutrients in both herbicide treated and untreated MON 88701 cotton: the 

cyclopropenoid dihydrosterculic acid and total gossypol. In addition, a statistically significant 

increase in free gossypol was observed in treated MON 88701 cotton. The increase was less than 

10% in all cases except dihydrosterculic acid in untreated MON 88701 cotton, which increased 

12.6% (Monsanto, 2012b). The increases were not consistently observed across locations and the 

anti-nutrient levels were all within the 99% tolerance interval established from the conventional 

commercial reference varieties (International-Life-Sciences-Institute, 2010).

The statistically significant changes observed for the above-mentioned nutrients and antinutrients are unlikely to make MON 88701 cotton more susceptible to pests and diseases, or to 

cause MON 88701 cotton to have a greater impact on non-target organisms, than existing cotton 

varieties (USDA-APHIS, 2014e). The disease, insect pest, arthropod abundance, and agronomic 

data presented for MON 88701 cotton did not indicate any statistically significant difference 

from the control variety (Monsanto, 2012b).

Monsanto used a multistep approach to characterize the novel DMO protein in MON 88701 

cotton to determine if DMO is safe for human and animal consumption. It was found that MON

88701 cotton DMO has no relevant amino acid sequence similarities with known allergens, 

gliadins, glutenins, toxins, and other biologically active proteins that may have adverse effects on 

mammals (Monsanto, 2013a). The DMO protein was rapidly degraded in simulated gastric and 

intestinal fluids and a high dose of this protein in a mouse acute oral toxicity evaluation 

demonstrated it is not acutely toxic, and does not cause any adverse effect (Monsanto, 2013a). 

The DMO enzyme present in MON 88701 cotton has sequence similarity and many catalytic and 

domain structural similarities with a wide variety of oxygenases found in numerous species of 

microorganisms widely distributed and prevalent in the environment (Chakraborty J et al., 2012). 

It also has similarity with oxygenases such as pheophorbide A oxygenase which are found in 

plants such as rice, maize, canola and pea (Rodoni et al., 1997; Yang M et al., 2004) that are 

consumed in a variety of food and feed sources which have a history of safe human 

consumption. Plants, animals and humans are extensively exposed to these types of enzymes

(Monsanto, 2012b). The PPRA, Petition, and the petitioner’s Environmental Report all support 

the conclusion that exposure to MON 88701 cotton DMO poses no meaningful risk to the 

environment, or human and animal health (Monsanto, 2012b; 2013a; USDA-APHIS, 2014e).

The PAT enzyme present in MON 88701 cotton is identical to the wild-type protein produced in 

S. hygroscopicus and is analogous to the PAT proteins in commercially available glufosinateresistant products in several crops including cotton, corn, soybean, and canola (USDA-APHIS, 

2014f). OECD recognizes PAT proteins produced from different genes to be equivalent with 

regard to function and safety (OECD, 1999). PAT proteins are structurally similar only to other 

acetyltransferases known to not cause adverse effects after consumption (Herouet et al., 2005). 

In 1997, a tolerance exemption was issued for PAT proteins by the EPA (40 CFR part 180, 1997; 

CFR Part 180.1151, 2005).

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On April 6, 2012, Monsanto submitted a safety and nutritional assessment summary document to 

the FDA to initiate a consultation on the food and feed safety and compositional assessment of 

MON 88701 cotton. Monsanto received a completed consultation letter from the FDA on April 

24, 2013 (US-FDA, 2013). FDA concluded: “food and feed derived from MON 88701 cotton are 

not materially different in composition, safety, and other relevant parameters from cottonseedderived food and feed currently on the market, and that GE MON 88701 cotton does not raise 

issues that would require premarket review or approval by FDA (US-FDA, 2013).” All 

indications are that the ingestion of the plant or plant parts is unlikely to affect threatened and 

endangered species. There is no allergenicity potential with MON 88701 cotton, and the slight 

increase in levels of gossypol in MON 88701 cotton is statistically insignificant. Therefore, 

there is no increased risk of direct or indirect toxicity or allergenicity impacts on animal species 

that feed on cotton or the associated biological food chain of organisms. Based on these 

analyses, APHIS concludes that, although unlikely, consumption of MON 88701 cotton would 

have no effect on any listed threatened or endangered animal species or animal species proposed 

for listing.

APHIS considered the possibility that MON 88701 cotton could serve a host plant for a 

threatened or endangered species (i.e., a listed insect or other organism that may use the cotton 

plant to complete its lifecycle). A review of the species list reveals that there are none that would 

use cotton as a host plant (USFWS, 2014b).

7.2.3 Summary of Potential Effects of MON 88701 Cotton on TES Species

After reviewing the possible effects of allowing the environmental release of MON 88701 

cotton, APHIS has not identified any stressor that could affect the reproduction, numbers, or 

distribution of a listed TES or species proposed for listing. As a result, a detailed exposure 

analysis for individual species is not necessary. APHIS also considered the potential effect of a 

determination of nonregulated status of MON 88701 cotton on designated critical habitat or 

habitat proposed for designation, and could identify no differences from effects that would occur 

from the production of other cotton varieties. Cotton is not considered a particularly competitive 

plant species and has been selected for domestication and cultivation under conditions not 

normally found in natural settings. Cotton is not sexually compatible with, nor does it serve as a 

host plant for any listed species or species proposed for listing. Consumption of MON 88701 

cotton by any listed species or species proposed for listing will not result in an allergic reaction 

or increase the risk of a toxic reaction. Based on these factors, APHIS has concluded that a 

determination of nonregulated status of MON 88701 cotton, and the corresponding 

environmental release of this cotton variety will have no effect on listed species or species 

proposed for listing, and would not affect designated habitat or habitat proposed for designation. 

Because of this no-effect determination, consultation under Section 7(a)(2) of the Act or the 

concurrence of the USFWS or NMFS is not required.

7.2.4 Potential Effects of MON 87708 Soybean on TES Plant Species

Soybean has been cultivated around the globe without any report that it is a serious weed or that 

it forms persistent feral populations (OECD, 2000). Soybean does not possess any of the 

attributes commonly associated with weeds (Baker, 1965), such as long persistence of seed in the 

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soil; the ability to disperse, invade, and become a dominant species in new or diverse landscapes;

or the ability to compete well with native vegetation. Furthermore, mature soybean seeds have no 

innate dormancy; germinating seedlings and plants are sensitive to cold, are not expected to 

survive in freezing winter conditions and do not vegetatively reproduce (Raper and Kramer, 

1987; OECD, 2000). Soybeans that volunteer from the previous year’s crop are rarely a 

management issue, as crop losses attributable to interference from soybean volunteers are 

minimal (Owen and Zelaya, 2005). However, volunteers can be a problem particularly in the 

South where winters are milder, and particularly if weather events lead to soybean seed loss prior 

to harvest (York et al., 2005).

The agronomic and morphologic characteristics data provided by Monsanto were used in the 

APHIS analysis of the weediness potential for MON 87708 soybean. Agronomic studies 

conducted by Monsanto tested the hypothesis that the weediness potential of MON 87708 

soybean is unchanged with respect to conventional soybean (Monsanto, 2013a). No differences 

were detected between MON 87708 soybean and nontransgenic soybean in growth, 

reproduction, or interactions with pests and diseases, other than the intended effect of herbicide 

resistance to dicamba (Monsanto, 2013a). MON 87708 also has slightly increased 

resistance/reduced sensitivity to three other phenoxy synthetic herbicides compared to the 

conventional control soybean A3525 (USDA-APHIS, 2014d). This increased resistance is not 

expected to substantially affect control of MON 87708 soybean volunteers. Excellent ratings are 

obtained for post-emergence control of volunteer soybeans in the rotational crops corn, sorghum, 

wheat, barley, oats, cotton and rice for one or more labeled herbicides with different modes of 

action than the synthetic auxins to which MON 87708 has acquired complete or partial resistance

(Monsanto, 2012a).

Based on analysis of the information provided by Monsanto, along with knowledge of soybean 

biology, APHIS has concluded that the expression of the DMO protein providing the herbicide 

resistance traits in MON 87708 soybean is unlikely to appreciably improve seedling 

establishment or increase weediness potential (Monsanto, 2012a; 2013a). APHIS has concluded 

that the approval of a petition of nonregulated status for MON 87708 soybean does not present a 

risk of weediness when compared to other currently cultivated soybean varieties (USDA-APHIS, 

2014d).

APHIS evaluated the potential of MON 87708 soybean to cross with listed species. APHIS has 

determined that there is no risk to unrelated plant species from the cultivation of MON 87708 

soybean. Soybean is highly self-pollinating and can only cross with other members of Glycine 

subgenus Soja (OECD, 2000). Wild soybean species are endemic in China, Korea, Japan, 

Taiwan and the former Union of Soviet Socialist Republics; in the U.S. there are no Glycine

species found outside of cultivation and there is no potential for outcrossing (OECD, 2000).

After reviewing the list of threatened and endangered plant species in the U.S. where soybean is 

grown, APHIS determined that MON 87708 soybean would not be sexually compatible with any 

listed threatened or endangered plant species proposed for listing, as none of these listed plants 

are in the same genus nor are known to cross pollinate with species of the genus Glycine

(USFWS, 2014c).

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Based on agronomic field data, literature surveyed on soybean weediness potential, lack of 

ability to disperse outside of agricultural fields, and no sexually compatibility with wild relatives 

or listed plants with soybean, APHIS has concluded that MON 87708 soybean will have no 

effect on threatened or endangered plant species or critical habitat.

7.2.5 Potential Effects of MON 87708 Soybean on TES Animal Species

Threatened and endangered animal species that may be exposed to the gene products in MON 

87708 soybean would be those TES that inhabit soybean fields and feed on MON 87708 

soybean. To identify potential effects on threatened and endangered animal species, APHIS 

evaluated the risks from consuming MON 87708 soybean.

Soybean is commonly used as a feed for livestock. Additionally, wildlife may use soybean fields 

as a food source, consuming the plant or insects that live on the plants, although, TES generally 

are found outside of agricultural fields. Few if any TES are likely to use soybean fields because 

they do not provide suitable habitat. Only whooping crane (Grus americana), sandhill crane 

(Grus canadensis pulla), piping plover (Charadrius melodus), interior least tern (Sterna 

antillarum), and Sprague’s pipit (Anthus spragueii; a candidate species) occasionally feed in 

farmed sites (USFWS, 2011). These bird species may visit soybean fields during migratory 

periods, but would not be present during normal farming operations (Krapu et al., 2004; 

USFWS, 2011). In a study of soybean consumption by wildlife in Nebraska, results indicated 

that soybeans do not provide the high energy food source needed by cranes and waterfowl 

(Krapu et al., 2004).

The Delmarva fox squirrel (Sciurus niger cinereus), which inhabits mature forests of mixed 

hardwoods and pines, may be found adjacent to agricultural areas of the Delmarva Peninsula 

(USFWS, 2008). The squirrel forages for food in woodlots and openings, such as farm fields, 

with a diet that mainly includes acorns, nuts/seeds of hickory, beech, walnut, and loblolly pine. 

They also feed on tree buds and flowers, fungi, insects, fruit, and seeds in the spring and mature, 

green pine cones in the summer and early fall (USFWS, 2008). The Louisiana black bear (Ursus 

americanus luteolus), occurring in Louisiana, Mississippi, and Texas, may occasionally forage

on soybean; however, other crops such as corn, sugarcane, and winter wheat are preferred by the 

species (Mississippi State University Extension Service, 1996).

APHIS has examined data on the food and feed safety of MON 87708 soybean, evaluating the 

agronomic and morphological characteristics, including compositional and nutritional 

characteristics, safety evaluations and toxicity tests, as compared to a conventional hybrid 

soybean variety grown at multiple sites (Monsanto, 2012a; 2013a). Nutrients assessed in this 

analysis included proximates (ash, carbohydrates by calculation, moisture, protein, and fat), 

fiber, amino acids (18 components), fatty acids (FA, C8-C22), and vitamin E (α-tochopherol) in 

seed, and proximates (ash, carbohydrates by calculation, moisture, protein, and fat) and fiber in 

forage. The anti-nutrients assessed in seed included raffinose, stachyose, lectin, phytic acid, 

trypsin inhibitors, and isoflavones (daidzein, genistein, and glycitein) (Monsanto, 2013a). The 

results confirmed that the differences observed in the analysis were not meaningful to food and 

feed safety or the nutritional quality of MON 87708 soybean (Monsanto, 2013a). In addition, the 

levels of assessed components in MON 87708 soybean were compositionally equivalent to the 

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conventional control and within the range of variability of the commercial reference varieties 

that were grown concurrently in the same field trial (Monsanto, 2013a). This indicates that the 

only statistically significant compositional difference between MON 87708 soybean and 

conventional hybrid soybean is the expression of the DMO proteins.

Monsanto used a multistep approach to characterize the novel DMO proteins in MON 87708 

soybean to determine if DMO is safe for human and animal consumption. It was found that 

MON 87708 soybean DMO has no relevant amino acid sequence similarities with known 

allergens, gliadins, glutenins, toxins, and other biologically active proteins that may have adverse 

effects on mammals (Monsanto, 2013a). MON 87708 soybean DMO was rapidly degraded in 

simulated gastric and intestinal fluids and a high dose of this protein in a mouse acute oral 

toxicity evaluation demonstrated that it is not acutely toxic, and does not cause any adverse 

effect (Monsanto, 2013a). The safety assessment supports the conclusion that exposure to MON

87708 soybean DMO poses no meaningful risk to the environment, or human and animal health.

On November 9, 2010 Monsanto submitted a safety and nutritional assessment summary 

document to the FDA to initiate a consultation on the food and feed safety and compositional 

assessment of MON 87708 soybean (Monsanto, 2012a). Monsanto received a completed 

consultation letter from the FDA on October 11, 2011 (US-FDA, 2011b). FDA concluded: “food 

and feed derived from MON 87708 soybean are not materially different in composition, safety, 

and other relevant parameters from soybean-derived food and feed currently on the market, and 

that the GE MON 87708 soybean do not raise issues that would require premarket review or 

approval by FDA” (US-FDA, 2011b). Therefore, the ingestion of the plant or plant parts is 

unlikely to affect threatened and endangered species. Because there is no toxicity or allergenicity 

potential with MON 87708 soybean, there would be no direct or indirect toxicity or allergenicity 

impacts on animal species that feed on soybean or the associated biological food chain of 

organisms. Therefore, based on these analyses, APHIS concludes that, although unlikely, 

consumption of MON 87708 soybean would have no effect on any listed threatened or 

endangered animal species or animal species proposed for listing.

APHIS considered the possibility that MON 87708 soybean could serve as a host plant for a 

threatened or endangered species (i.e., a listed insect or other organism that may use the soybean 

plant to complete its lifecycle). A review of the species list reveals that there are no members of 

the genus Glycine that serve as a host plant for any threatened or endangered species (USFWS, 

2014c).

Combining the above information, cultivation of MON 87708 soybean and their progeny are 

expected to have no effect on threatened or endangered animals or those proposed for listing.

7.2.6 Summary of Potential Effects of MON 87708 Soybean on TES

After reviewing the possible effects of allowing the environmental release of MON 87708 

soybean, APHIS has not identified any stressor that could affect the reproduction, numbers, or 

distribution of a listed TES or species proposed for listing. APHIS also considered the potential 

effect of a determination of nonregulated status of MON 87708 soybean on designated critical 

habitat or habitat proposed for designation, and could identify no differences from effects that 

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would occur from the production of other soybean varieties. Soybean is not considered a 

particularly competitive plant species and has been selected for domestication and cultivation 

under conditions not normally found in natural settings. Soybean is not sexually compatible with, 

or serves as a host species for, any listed species or species proposed for listing. Consumption of 

MON 87708 soybean by any listed species or species proposed for listing will not result in a 

toxic or allergic reaction. Based on these factors, APHIS has concluded that a determination of 

nonregulated status of MON 87708 soybean, and the corresponding environmental release of this 

soybean variety will have no effect on listed species or species proposed for listing, and would 

not affect designated habitat or habitat proposed for designation. Because of this no-effect 

determination, consultation under Section 7(a)(2) of the Act or the concurrences of the USFWS 

or NMFS is not required

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8 CONSIDERATION OF EXECUTIVE ORDERS, STANDARDS, AND

TREATIES RELATING TO ENVIRONMENTAL IMPACTS

8.1 Executive Orders with Domestic Implications

The following executive orders require consideration of the potential impacts of the Federal 

action to various segments of the population.

• Executive Order (EO) 12898 (US-NARA, 2013), "Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations," requires 

Federal agencies to conduct their programs, policies, and activities that substantially affect 

human health or the environment in a manner so as not to exclude persons and populations 

from participation in or benefiting from such programs. It also enforces existing statutes to 

prevent minority and low-income communities from being subjected to disproportionately 

high and adverse human health or environmental effects. 

• EO 13045 (US-NARA, 2013), “Protection of Children from Environmental Health Risks 

and Safety Risks,” acknowledges that children may suffer disproportionately from 

environmental health and safety risks because of their developmental stage, greater metabolic 

activity levels, and behavior patterns, as compared to adults. The EO (to the extent permitted 

by law and consistent with the Agency’s mission) requires each Federal agency to identify, 

assess, and address environmental health risks and safety risks that may disproportionately 

affect children.

The No Action and Preferred Alternatives were analyzed with respect to EO 12898 and EO 

13045. None of the Alternatives are expected to have a disproportionate adverse effect on 

minorities, low-income populations, or children.

FDA completed new protein and biotechnology consultations with Monsanto on MON 87708 

soybean and MON 88701 cotton (US-FDA, 2011b; 2013). As part of the evaluations for these 

events, FDA reviewed the safety and nutritional assessments submitted by Monsanto concluding 

that food and feed derived from MON 87708 soybean and MON 88701 cotton are not materially 

different in composition, safety, and other relevant parameters from soybean- and cotton-derived 

food and feed currently on the market.

Monsanto conducted compositional analyses to establish the nutritional adequacy of forage- and 

grain-derived products from MON 87708 soybean and MON 88701 cotton in comparison to 

conventional counterparts. The studies compared data on key nutrients, secondary metabolites, 

and anti-nutrients for MON 87708 soybean and MON 88701 cotton forage and grain samples 

and the conventional variety controls. According to Monsanto, the measured parameters were 

within the combined literature range for soybean and cotton and the comparisons indicated no 

biologically meaningful differences for food and feed safety and nutrition (US-FDA, 2011b; 

2013).

The DMO protein in MON 87708 soybean and MON 88701 cotton was investigated for its 

potential to be a toxin or allergen. Bioinformatics studies confirmed the absence of any 

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biologically statistically significant amino acid sequence similarity to known protein toxins or 

allergens. Digestibility studies demonstrated that this protein would be rapidly degraded 

following ingestion, similar to other dietary proteins. Enzymatic activity of the DMO protein was 

shown to be eliminated under all heating conditions (US-FDA, 2011b; 2013).

Acute oral mouse toxicity studies were performed for the DMO protein, as ingestion represents 

the most likely route of human exposure to these proteins. No clinical signs of toxicity were 

observed in any of the test animals.

Monsanto indicated in their submission to FDA that the PAT protein in MON 88701 cotton was 

shown to be equivalent to that produced in other transgenic crops and previous assessments have 

shown it is non-toxic to mammals and does not exhibit any potential to be allergenic to humans. 

A biotechnology consultation on cotton lines containing the PAT protein was completed on June 

5, 2003 (US-FDA, 2003) and also was evaluated as part of the consultation on MON 88701 

cotton completed in 2013 (US-FDA, 2013). As with the DMO protein, Monsanto evaluated the 

allergenicity of the PAT protein inserted in MON 88701 cotton through bioinformatics analyses. 

No meaningful homologies to known or reputed allergens or toxins were identified.

Taken together, the evidence indicates that the DMO and PAT proteins are not toxic or not likely 

to be allergenic to humans.

Additionally, both Food Standards Australia New Zealand (FSANZ) and Health Canada have 

evaluated the food safety of MON 87708 soybean (FSANZ, 2012; Health-Canada, 2014) and 

FSANZ has evaluated the food safety of MON 88701 cotton (FSANZ, 2013). FSANZ did not 

identify any potential public health and safety concerns and concluded that food derived from 

MON 87708 soybean and MON 88701 cotton “is considered to be as safe for human 

consumption as food derived from conventional soybean or cotton cultivars” (FSANZ, 2012; 

2013). Health Canada has granted food safety approval for MON 87708 soybean in 2012 

(Health-Canada, 2014).

Based on the information submitted by the applicant and reviewed by APHIS, MON 87708

soybean and MON 88701 cotton are agronomically, phenotypically, and biochemically 

comparable to conventional soybean and cotton grown, marketed, and consumed except for the 

inserted proteins DMO and PAT proteins. The results of available mammalian toxicity studies 

associated with the DMO and PAT proteins establish the safety of MON 87708 soybean and 

MON 88701 cotton and associated products to humans, including minorities, low-income 

populations, and children who might be exposed to them through agricultural production and/or 

processing. No additional safety precautions would need to be taken with nonregulated MON

87708 soybean and MON 88701 cotton. Based on these factors, a determination of nonregulated 

status to MON 87708 soybean and MON 88701 cotton is not expected to have a disproportionate 

adverse effect on minorities, low-income populations, or children.

Agricultural workers, which may include children, minorities, and low-income populations, 

could come into contact with the deregulated Xtend crops being grown. Common agricultural 

practices that would be used with the MON 87708 soybean MON 88701 cotton are no different 

than those utilized on current conventional and GE crops. If EPA approves the additional new 

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uses of dicamba on MON 87708 soybean MON 88701 cotton, dicamba use patterns on these 

cotton and soybean varieties would be different than is currently allowed. As a result, the use of 

dicamba is expected to increase.

EPA regulates the use of herbicides under FIFRA and is making a separate decision which may 

or may not allow the additional use of dicamba on these plants. EPA considers the toxicity of 

pesticides to humans, including sensitive population, such as children, in its pesticide registration

and registration reviews. 

Currently, the EPA is proposing to revise the existing Worker Protection Standard (WPS) at 40 

CFR part 170 to reduce the incidence of occupational pesticide exposure and related illness 

among agricultural workers (workers) and pesticide handlers (handlers) covered by the rule. EPA 

is proposing to strengthen the protections provided to agricultural workers and handlers under 

the WPS by improving elements of the existing regulation, such as training, notification, 

communication materials, use of personal protective equipment, and decontamination supplies. 

The EPA expects the revisions, once final, to prevent unreasonable adverse effects from 

exposure to pesticides among agricultural workers and pesticide handlers; vulnerable groups, 

such as minority and low-income populations, child farmworkers, and farmworker families; and 

the general public. This regulation, in combination with other components of EPA’s pesticide 

regulatory program, is intended to prevent unreasonable adverse effects of pesticides among 

pesticide applicators, workers, handlers, the general public, and vulnerable groups, such as 

minority and low‐income populations.

Further, the increased cost of seed for HR crops such as MON 87708 soybean MON 88701 

cotton relative to conventional seeds is not a barrier to low income producers, since net returns 

for HR soybean and corn were in the aggregate no different (Fernandez-Cornejo et al., 2014a). 

Regardless of seed premiums charged for GE seeds, such as MON 87708 soybean MON 88701 

cotton, growers select GE herbicide resistant seeds because they are associated with certain 

conveniences in the production of the crop, such simplifying herbicide practices and gaining 

ability to spray herbicides at different times in the developmental stages of the crop.

The following executive order addresses Federal responsibilities regarding the introduction and 

effects of invasive species:

EO 13112 (US-NARA, 2013), “Invasive Species,” states that Federal agencies take 

action to prevent the introduction of invasive species, to provide for their control, and to 

minimize the economic, ecological, and human health impacts that invasive species 

cause.

Neither soybean nor cotton is listed in the U.S. as a noxious weed species by the Federal 

government (USDA-NRCS, 2013c), nor are these crops listed as invasive species by major 

invasive plant data bases (University of Georgia and USDOI-NPS, 2012; Global-RestorationNetwork, 2014).

While pollen-mediated gene transfer can occur, there are no differences in the potential for gene 

flow and weediness from conventional or other GE varieties. Outcrossing and weediness are 

215
addressed in the PPRAs (USDA-APHIS, 2014d; 2014e) and MON 87708 soybean and MON

88701 cotton are similar to other HR-soybean or HR-cotton varieties. The risk of gene flow and 

weediness of MON 87708 soybean and MON 88701 cotton is no greater than that of other 

nonregulated, HR soybean or cotton varieties.

The following executive order requires the protection of migratory bird populations:

EO 13186 (US-NARA, 2013), “Responsibilities of Federal Agencies to Protect 

Migratory Birds,” states that federal agencies taking actions that have, or are likely to 

have, a measurable negative effect on migratory bird populations are directed to develop 

and implement, within two years, a Memorandum of Understanding (MOU) with the Fish 

and Wildlife Service that shall promote the conservation of migratory bird populations.

Data submitted by the applicant has shown no substantial difference in compositional and 

nutritional quality of MON 87708 soybean compared with other GE soybean or non-GE 

soybean, apart from the presence of the DMO protein. Similarly, except for the presence of the 

inserted proteins, MON 88701 cotton has been found to be compositionally and nutritionally 

comparable to other GE cotton or non-GE cotton varieties. Additionally, the PAT protein has 

been cultivated in commercial cotton strains since 2003. The migratory birds that forage in 

soybean and cotton fields are unlikely to be affected adversely by ingesting MON 87708 soybean 

or MON 88701 cotton and their associated products.

EPA considers the toxicity of pesticides to birds in its pesticide registration and registration 

reviews.

8.2 International Implications

EO 12114 (US-NARA, 2013), “Environmental Effects Abroad of Major Federal 

Actions” requires federal officials to take into consideration any potential environmental 

effects outside the U.S., its territories, and possessions that result from actions being 

taken.

APHIS has given this EO careful consideration and does not expect any major environmental 

impact outside the United States in the event of a determination of nonregulated status of MON

87708 soybean and MON 88701 cotton. All existing national and international regulatory 

authorities and phytosanitary regimes that currently apply to introductions of new soybean and 

cotton cultivars internationally apply equally to those covered by an APHIS determination of 

nonregulated status under 7 CFR part 340.

Any international trade of MON 87708 soybean and MON 88701 cotton subsequent to a 

determination of nonregulated status of the product would be fully subject to national 

phytosanitary requirements and be in accordance with phytosanitary standards developed under 

the International Plant Protection Convention (IPPC) (International-Plant-Protection-Convention, 

2011). The purpose of the IPPC “is to secure a common and effective action to prevent the 

spread and introduction of pests of plants and plant products and to promote appropriate 

measures for their control” (International-Plant-Protection-Convention, 2011). The protection it 

216
affords extends to natural flora and plant products and includes both direct and indirect damage 

by pests, including weeds.

The IPPC establishes a standard for the reciprocal acceptance of phytosanitary certification 

among the nations that have signed or acceded to the Convention (172 countries as of March 

2010). In April 2004, a standard for PRA of living modified organisms (LMOs) was adopted at a 

meeting of the governing body of the IPPC as a supplement to an existing standard, International 

Standard for Phytosanitary Measures No. 11 (ISPM-11, Pest Risk Analysis for Quarantine 

Pests). The standard acknowledges that all LMOs will not present a pest risk and that a 

determination needs to be made early in the PRA for importation as to whether the LMO poses a 

potential pest risk resulting from the genetic modification. APHIS pest risk assessment

procedures for GE organisms are consistent with the guidance developed under the IPPC. In 

addition, issues that may relate to commercialization and transboundary movement of particular 

agricultural commodities produced through biotechnology are being addressed in other 

international forums and through national regulations.

The Cartagena Protocol on Biosafety is a treaty under the United Nations Convention on 

Biological Diversity (CBD) that established a framework for the safe transboundary movement, 

with respect to the environment and biodiversity, of LMOs, which include those modified 

through biotechnology. The Protocol came into force on September 11, 2003, and 160 countries 

are Parties to it as of December 2010 (CBD, 2012). Although the U.S. is not a party to the CBD, 

and thus not a party to the Cartagena Protocol on Biosafety, U.S. exporters will still need to 

comply with those regulations that importing countries which are Parties to the Protocol have 

promulgated to comply with their obligations. The first intentional transboundary movement of 

LMOs intended for environmental release (field trials or commercial planting) will require 

consent from the importing country under an advanced informed agreement (AIA) provision, 

which includes a requirement for a risk assessment consistent with Annex III of the Protocol and 

the required documentation.

LMOs imported for food, feed, or processing (FFP) are exempt from the AIA procedure and are 

covered under Article 11 and Annex II of the Protocol. Under Article 11, Parties must post 

decisions to the Biosafety Clearinghouse database on domestic use of LMOs for FFP that may be 

subject to transboundary movement. To facilitate compliance with obligations to this protocol, 

the U.S. Government has developed a website that provides the status of all regulatory reviews 

completed for different uses of bioengineered products (NBII, 2010). These data will be 

available to the Biosafety Clearinghouse.

APHIS continues to work toward harmonization of biosafety and biotechnology consensus 

documents, guidelines, and regulations, including within the North American Plant Protection 

Organization (NAPPO), which includes Mexico, Canada, and the U.S., and within the 

Organisation for Economic Cooperation and Development (OECD). NAPPO has completed 

three modules of the Regional Standards for Phytosanitary Measures (RSPM) No. 14, 

Importation and Release into the Environment of Transgenic Plants in NAPPO Member 

Countries (North American Plant Protection Organization, 2003).

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APHIS also participates in the North American Biotechnology Initiative (NABI), a forum for 

information exchange and cooperation on agricultural biotechnology issues for the U.S., Mexico, 

and Canada. In addition, bilateral discussions on biotechnology regulatory issues are held 

regularly with other countries including Argentina, Brazil, Japan, China, and Korea.

8.3 Compliance with Clean Water Act and Clean Air Act

This EIS evaluated the potential changes in soybean and cotton production associated with 

approving the petition for a determination of nonregulated status to MON 87708 soybean and 

MON 88701 cotton (see, 4.2.1) and determined that the cultivation of MON 87708 soybean and 

MON 88701 cotton would not lead to the increase in or expand the area of soybean and cotton 

production that could impact water resources or air quality any differently than currently 

cultivated soybean and cotton varieties. The herbicide resistance conferred by the genetic 

modification of MON 87708 soybean and MON 88701 cotton is not expected to result in any 

changes in water usage for cultivation compared to current soybean and cotton production. Based 

on these analyses, APHIS concludes that an extension of a determination of nonregulated status 

to MON 87708 soybean and MON 88701 cotton would comply with the CWA and the CAA.

8.4 Impacts on Unique Characteristics of Geographic Areas

Approving the petition for a determination of nonregulated status to MON 87708 soybean and 

MON 88701 cotton is not expected to impact unique characteristics of geographic areas such as 

parklands, prime farmlands, wetlands, wild and scenic areas, or ecologically critical areas.

Monsanto has presented results of agronomic field trials for MON 87708 soybean and MON

88701 cotton that demonstrate there are no differences in agronomic practices, between MON

87708 soybean and currently available HR-soybean varieties or between MON 88701 cotton and 

currently available HR-cotton varieties. The common agricultural practices that would be carried 

out in the cultivation of MON 87708 soybean and MON 88701 cotton are not expected to deviate 

from current practices. The product is expected to be cultivated by growers on agricultural land 

currently suitable for production of soybean or cotton, and is not anticipated to expand the 

cultivation of soybean or cotton to new, natural areas.

The Preferred Alternative for MON 87708 soybean and MON 88701 cotton does not propose 

major ground disturbances or new physical destruction or damage to property, or any alterations 

of property, wildlife habitat, or landscapes. Likewise, no prescribed sale, lease, or transfer of 

ownership of any property is expected as a direct result of a determination of nonregulated status 

for MON 87708 soybean and MON 88701 cotton. This action would not convert land use to 

nonagricultural use and, therefore, would have no adverse impact on prime farmland. Standard 

agricultural practices for land preparation, planting, irrigation, and harvesting of plants would be 

used on agricultural lands planted to MON 87708 soybean and MON 88701 cotton, including the 

use of EPA-registered pesticides. 

Based on these findings, including the assumption that pesticide label use restrictions are in place 

to protect unique geographic areas and that those label use restrictions are adhered to, approving 

the petition for a determination of nonregulated status to MON 87708 soybean and MON 88701 

218
cotton is not expected to impact unique characteristics of geographic areas such as park lands, 

prime farm lands, wetlands, wild and scenic areas, or ecologically critical areas any differently 

than soybean and cotton varieties already in commercial agriculture.

8.5 National Historic Preservation Act (NHPA) of 1966 as Amended 

The NHPA of 1966 and its implementing regulations (36 CFR 800) require Federal agencies to: 

1) determine whether activities they propose constitute "undertakings" that have the potential to 

cause effects on historic properties; 2) if so, to evaluate the effects of such undertakings on such 

historic resources and consult with the Advisory Council on Historic Preservation (i.e., State 

Historic Preservation Office, Tribal Historic Preservation Officers), as appropriate.

The APHIS proposed action, a determination of nonregulated status of MON 87708 soybean and 

MON 88701 cotton is not expected to adversely impact cultural resources on tribal properties.

Any farming activity that may be taken by farmers on tribal lands would only be conducted at 

the tribe’s request. Thus, the tribes would have control over any potential conflict with cultural 

resources on tribal properties.

The APHIS Preferred Alternative would neither impact districts, sites, highways, structures, or 

objects listed in or eligible for listing in the National Register of Historic Places, nor would it 

likely cause any loss or destruction of important scientific, cultural, or historical resources. This 

action is limited to a determination of nonregulated status of MON 87708 soybean and MON

88701 cotton.

The APHIS proposed action is not an undertaking that may directly or indirectly cause alteration 

in the character or use of historic properties protected under the NHPA. In general, common 

agricultural activities conducted under this action do not have the potential to introduce visual, 

atmospheric, or noise elements to areas in which they are used that could result in effects on the 

character or use of historic properties. For example, there is potential for increased noise on the 

use and enjoyment of a historic property during the operation of tractors and other mechanical 

equipment close to such sites. A built-in mitigating factor for this issue is that virtually all of the 

methods involved would only have temporary effects on the audible nature of a site and can be 

ended at any time to restore the audible qualities of such sites to their original condition with no 

further adverse effects. These cultivation practices are already being conducted throughout the 

soybean and cotton production regions. The cultivation of MON 87708 soybean and MON

88701 cotton is not expected to change any of these agronomic practices that would result in an 

adverse impact under the NHPA.

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9 LIST OF PREPARERS

Name, Title, Project 

Function Education and Experience

APHIS

Sidney W. Abel III

Assistant Deputy 

Administrator

Reviewer

 M.S., Environmental Sciences – Chemistry, The George 

Washington University

 B.S., Special Studies – Environmental Chemistry, 

University of Maryland

 25 years of professional experience in developing and 

conducting environmental risk assessments specializing 

in the fate, transport, and effects of physical, chemical, 

and biological substances.

Michael P. Blanchette

Senior Environmental 

Protection Specialist

Threatened and Endangered 

Species Analysis

 B.S., Entomology, University of New Hampshire

 24 years of professional experience as an Environmental 

Protection Specialist

 10 years evaluating plant pest and environmental 

impacts of genetically engineered crops, including 

effects to threatened and endangered species and critical 

habitat.

Omar Gardner

Environmental Protection 

Specialist

Environmental Consequences

 M.S., Environmental Science & Policy, Johns Hopkins 

University.

 B.S., Environmental Science, CUNY Medgar Evers 

College

 1 year of professional experience in environmental risk 

assessment of genetically engineered organisms.

220
Name, Title, Project 

Function Education and Experience

Ron Hardman  Ph.D., Inegrated Toxicology and Environmental Health, 

Duke University

 M.S., Marine Science/Oceans and Human Health, 

University of North Carolina at Wilmington

 B.S., Biology, Adelphi Universtiy

 18 years of experience in molecular and cellular biology.

 14 years of experience in environmental and human 

health risk assessment.

 12 years experience in environmental regulatory anaylsis 

and compliance

Neil E. Hoffman

Science Advisor

 Ph.D., Plant Physiology, University of California, Davis

 B.S., Plant Biology, Cornell University

 30 years of professional experience in plant biochemistry 

and molecular biology.

 10 years of professional experience in environmental 

risk assessment of genetically engineered organisms.

Andrea Lemay

Biological Scientist

 M.S., Plant Pathology, North Carolina State University

 B.S., Plant and Soil Science, University of 

Massachusetts

 12 years of professional experience in risk analysis

 12 years of professional experience conducting NEPA

analysis.

Elizabeth Nelson

Acting Branch Chief – Senior 

Environmental Protection 

Specialist

 MBA, University of Maryland University College

 M.S., Health Care Administration, University of 

Maryland University College

 B.S., Biology, Bowie State University

 14 years of professional experience in environmental 

compliance, policy, and management, including 

preparation of NEPA documentation.

221
Name, Title, Project 

Function Education and Experience

LaKisha J. Odom

AAAS Fellow

 Ph.D., Integrative Biosciences, Tuskegee University

 M.A., Environmental and Natural Resource Policy The 

George Washington University

 B.S., Environmental Science, Tuskegee University

 5 years of professional experience as an Environmental 

Protection Specialist.

 4 years evaluating plant pest and environmental impacts 

of genetically engineered cotton.

Alan Pearson

Biotechnologist

 Ph.D., Biology, Massachusetts Institute of Technology

 B.A., Biochemistry, Brandeis University

 5 years of professional experience in environmental risk 

assessment of genetically engineered organisms.

 15 years of professional experience in molecular and 

cellular biology.

Kari Perez

Environmental Protection 

Specialist

 Ph.D., Plant Breeding and Genetics, Cornell University

 9 years experience agricultural biology research

 2 year experience in environmental risk assessment of 

genetically engineered organisms

Craig Roseland

Senior Environmental 

Protection Specialist

 Ph.D., Developmental and Cell Biology, University of 

California, Irvine

 B.S., Biological Sciences, University of California, 

Irvine

 11 years of experience in environmental risk assessment

and regulatory analysis.

222
Name, Title, Project 

Function Education and Experience

Joanne Serrels

Environmental Protection 

Specialist

 M.S., Environmental Science & Policy, Johns Hopkins 

University.

 B.S., Wildlife Biology and Management, University of 

Rhode Island

 7 years of professional experience conducting NEPA

analyses.

 2 years of professional experience in environmental risk 

assessment of genetically engineered organisms.

Diane Sinkowski

Environmental Protection 

Specialist

 M.E., Environmental Engineering Sciences, University 

of Florida

 B.S., Nuclear Engineering Sciences (Health Physics), 

Minor in Environmental Studies, University of Florida

 20 years of professional experience assessing 

environmental impacts, evaluating human and 

environmental exposures, and conducting risk 

assessments.

 10 years of professional experience conducting NEPA

analyses.

 4 years of professional experience in environmental risk 

assessment of genetically engineered organisms.

Eileen Sutker

Environmental Protection 

Specialist

 Ph.D. Plant Pathology, North Carolina State University

 M.S. Plant Pathology University of Georgia

 B.S. Botany, The Ohio State University

 J.D., Cleveland-Marshall College of Law

 12 years of professional experience in Pest Permitting, 

NEPA analysis, pest and environmental risk assessment.

223
Name, Title, Project 

Function Education and Experience

Kham Vongpaseuth 

Environmental Protection 

Specialist

 Ph.D. Plant Biology, University of Massachusetts 

Amherst

 M.Sc. Botany, University College Dublin, Ireland

 B.S. Biology, The College of New Jersey

 4 years of professional experience in environmental risk 

assessment of genetically engineered organisms.

Joseph Vorgetts

Senior Environmental 

Protection Specialist

 Ph.D., Entomology, Clemson University

 M.S., Entomology, Rutgers University

 B.S., Environmental Science, Rutgers University

 13 years of experience in environmental risk assessment

and regulatory development and analysis.

 25 years of experience in insect survey, suppression and 

management with pesticides and biological control 

organisms.

 2 years of professional experience in environmental risk 

assessment of genetically engineered organisms.

Karen Walker

Environmental Protection 

Specialist

 Ph.D., Entomology, Virginia Tech

 M.S., Biology, George Mason University

 B.S., Biology, George Mason University

 13 years of experience in environmental risk assessment

and regulatory development and analysis.

 8 years of experience in insect survey and suppression 

management.

 1 year of professional experience in environmental risk 

assessment of genetically engineered organisms.

224
10 DISTRIBUTION LIST FOR THIS FEIS

Distribution of This Final EIS to Contacts in EPA Regions:

Robert Koethe

US EPA Region 1

Mail Code OES05-4

5 Post Office Square, Suite 100

Boston, MA 02109-3912

Grace Musumeci

US EPA, Region 2

290 Broadway

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US EPA, Region 4

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NEPA Program

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Mail Code: ETTA-088

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Distribution to Contacts Requesting a Copy of This Final EIS

David Ortman

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Senior Scientist, Pesticide Action Network

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Food & Water Watch

1616 P Street NW, Suite 300

Washington, DC 20036

National Cotton Council of America

225
1521 New Hampshire Ave NW

Washington DC 20036-1205

Steve Smith

Save Our Crops Coalition

ssmith@redgold.com

Sharon Pratt

Center for Food Safety

660 Pennsylvania Ave.

Suite 302

Washington, DC 20003

General Distribution of This Final EIS

In addition to the contacts in the above distribution lists, APHIS notified all of its stakeholders of 

the availability of this final EIS.

226
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12 INDEX

acreage, 25, 32, 53, 56, 57, 61, 84, 100, 103, 

127, 146, 222, 251, 263

air quality, vii, x, 23, 25, 33, 47, 48, 49, 50, 

126, 136, 198, 222, 233

alternatives, 1, v, vi, vii, x, 12, 17, 19, 26, 

102, 117, 122, 125, 130, 135, 154, 157, 

163, 166, 168, 169, 170, 171, 181, 186, 

195, 197, 198

beef production, 29, 94, 121, 235, 244

buffer zones, 88, 155

climate change, 25, 50, 51, 52, 53, 126, 136, 

198, 262

cotton, conventional, 105, 130, 220

cotton, organic, 19, 89, 90, 117, 130, 131

cotton, volunteer, 86, 124

cover crops, viii, 50, 74, 76, 77, 89, 111, 

114, 118, 122, 175, 179

critical habitat, 204, 205, 206, 207, 209, 212, 

214, 216, 224

crop rotation, ix, 29, 61, 70, 71, 73, 74, 75, 

76, 77, 80, 89, 92, 111, 113, 114, 117, 

118, 130, 145, 157, 176, 177, 188, 195, 

265

cross-pollination, 90, 92, 118

cultivation practices, 51, 117, 119, 206, 223

cumulative impacts, vii, ix, 10, 11, 12, 17, 

134, 135, 137, 138, 139, 141, 160, 165, 

168, 175, 176, 185, 187, 197, 198, 199, 

200

dairy production, 29, 56, 58, 94, 121, 210, 

237

economic environment, 1, 18, 107, 110, 127, 

144, 220

endangered species, xxiii, 97, 205, 212, 215, 

224

environmental consequences, 14, 17, 102, 

206

exports, 18, 25, 91, 103, 106, 107, 127

Federal Food, Drug and Cosmetic Act, ii, 

xxi, 8, 95, 96, 99, 119, 121

Federal Insecticide, Fungicide and 

Rodenticide Act, ii, vii, xxi, 7, 8, 11, 97, 

122, 131, 134, 135, 136, 137, 139, 140, 

204, 219

food and feed, ii, 18, 25, 95, 96, 99, 100, 

119, 121, 131, 132, 133, 211, 212, 214, 

215, 217, 257

Food Quality Protection Act, xxi, 8, 99, 135

forage, 4, 29, 51, 56, 57, 63, 75, 94, 121, 

133, 164, 165, 214, 215, 217, 220, 250

gene flow, 90, 208, 220, 259, 277

grazing, 29, 51, 57, 58, 94, 121, 164

greenhouse gases, xxii, 50, 51, 52, 100, 101, 

126, 198, 267

groundwater, x, 41, 42, 44, 45, 46, 47, 87, 

126, 135, 139, 264

hay production, 4, 29, 54, 55, 56, 57, 61, 94, 

121

herbicide use, ii, vii, 10, 11, 20, 80, 81, 82, 

102, 105, 116, 131, 134, 144, 145, 147, 

148, 149, 150, 151, 153, 154, 168, 173, 

175, 176, 177, 187, 196, 198, 199, 200, 

201, 202, 203

human health, 8, 10, 20, 25, 95, 98, 99, 102, 

131, 133, 137, 138, 140, 175, 199, 200, 

217, 219, 225

human safety, 82, 84, 98, 122

irrigation, 22, 26, 41, 42, 44, 45, 46, 47, 49, 

50, 70, 73, 75, 84, 85, 86, 87, 100, 125, 

202, 222, 255, 256, 260

isolation distances, 16, 17, 118

land use, 25, 32, 53, 56, 57, 61, 84, 100, 

103, 127, 146, 222, 251, 263

National Environmental Policy Act, iv, xxii, 

1, 2, 9, 10, 203, 225, 226, 227, 228, 230, 

232, 254

National Organic Program, xxii, 87, 88, 91, 

117, 118

notifications, xxi, 97, 136, 137, 219

organic farming, 87

pesticide registration, 96, 98, 122, 219, 220

pesticide tolerance, 8, 99

physical environment, 25, 33

plant diseases, i, 70, 82, 261

plant pest risk analysis, i, iii, vi, xxii, 2, 17, 

208, 211

276
plant pests, i, iii, iv, v, vi, vii, xxii, 1, 2, 3, 5, 

6, 7, 9, 11, 14, 15, 16, 17, 21, 25, 68, 179, 

205, 224, 226, 232

pollination, 90, 92, 130

polymerase chain reaction, 89

production costs, 26, 90, 105, 113

production practices, 25, 51, 91, 118, 136, 

141, 173, 179, 196, 197, 199

registered pesticide, 7, 119, 122, 133, 223

risk assessment, xxii, 2, 11, 15, 64, 97, 98, 

99, 133, 139, 140, 221, 224, 225, 226, 

227, 228, 229, 266

scoping, iv, 10, 197

seed production, 28, 94, 117, 121

silage, 29, 94, 103, 121

socioeconomic impacts, 9, 12, 141

soil quality, x, 22, 71, 72, 73, 134, 197

soybean, conventional, vii, 16, 17, 220

soybean, organic, 19, 90, 91, 92, 130

soybean, volunteers, 124, 195, 213

spray drift, 47, 92, 135, 155, 242

stewardship, 71, 111, 114, 116, 141, 157, 

179, 203, 261

tillage practices, vii, ix, x, 19, 22, 51, 62, 70, 

72, 73, 74, 122, 134, 143, 145, 147, 156, 

157, 179, 185, 198, 200, 201, 278

unreasonable adverse effects, 7, 8, 11, 97, 

139, 176, 219

water resources, 22, 33, 44, 46, 47, 52, 53, 

222

weediness, 74, 205, 206, 207, 209, 213, 214, 

220

worker health, 96, 98

worker safety, 25, 93, 94, 97, 120, 131

277