In a letter to Environmental Protection Agency Administrator Gina McCarthy today, the American Soybean Association (ASA) worked with a coalition of major farm groups in pressing the agency to withdraw its request to vacate the registration for Dow’s Enlist Duo herbicide, highlighting the urgent need for new modes of action to tackle resistant weeds on farms across the country.

“U.S. growers have an urgent need for a new mode of action as these regulatory delays have exacerbated the proliferation of hard-to-control weed populations. These delays are necessitating more intense weed control practices that complicate environmental management,” wrote the groups in the letter. “Herbicide tolerant cropping systems allow growers to more efficiently use active ingredients for weed control while providing environmental benefits like reduced tillage that improves soil heath and limits nutrient run-off. Additional herbicide modes of action will help proactively manage weed herbicide resistance.”

The groups cited the already-exhaustive review undertaken by both USDA and EPA on the Enlist family of products.

“Among the many new requirements for registration of Enlist Duo at EPA was an unprecedented review of the potential effects of the product on threatened and endangered species. After an exhaustive state-by-state review, EPA concluded that use of Enlist Duo in accordance with the product label, which imposed a 30-foot wind directional buffer zone, would have no effect on threatened and endangered species. This review took place on a product that simply combines two herbicides that have each been on the market for decades…” wrote the groups.

The groups also took issue with EPA’s reference to additional and new data in its decision to reevaluate Enlist Duo.

“There will always be new information to be considered about products EPA has registered. Congress has recognized this, and included in FIFRA several vehicles for reviewing products. But none of these vehicles authorize the agency to withdraw a previously approved product in the absence of an ‘imminent hazard,’” wrote the groups. “… No one has suggested that the information EPA now is considering with Enlist Duo comes close to meeting that threshold.”

Joining ASA on the letter is the American Farm Bureau Federation, National Corn Growers Association, National Cotton Council and the National Farmers Union.

For a full transcript of the letter, please click here.