[Pollinator] Attachment of SOCC report

Tue Mar 22 12:12:24 PDT 2016

*Attached and below:*

*Good morning,*

*It has been about a year since our last general update, but make no
mistake -- the Save Our Crops Coalition (SOCC) continues to diligently
pursue its mission of preventing crop injury from drift and volatilization
arising from the use of the new GMO technologies utilizing 2,4-D and
dicamba. *

*As you may have already guessed, SOCC has been waiting for EPA to make
further decisions regarding the use of dicamba.  In this instance, we
believe that waiting is good news for our membership.  There would seem to
be no reason for EPA to take such time to review these new dicamba uses,
except for pressure, from us and others, highlighting the long established
track record of off-target dicamba movement and crop injury to ensure that
any future and new use of dicamba products is safe.*

*In spite of this waiting period, we wanted to update you on a few top-line
items:*

*— First, as you may already know, dicamba tolerant soybean and cotton seed
have been approved for use in 2016, but dicamba HAS NOT been approved for
over-the-top use on soybeans or cotton in-season.  Advertisements and news
articles found in the agricultural press have not readily discussed the
commitments Monsanto and BASF have made to SOCC and to EPA regarding
labeling (such as the wind blowing away from certain sensitive crops) to
curtail certain high-risk uses of such products.  These commitments are
real, and we hope will be effective. *

*Presently, we do not, at this time, believe there is any chance that
in-season dicamba use will be approved in 2016, because EPA has not made
any preliminary determination and started any public comment periods.  Even
when approvals are granted, we do not believe such approvals will permit
the use of ‘tank mixes’, such as AMS or other adjuvants, of Monsanto's
Clarity with ‘Vapor Grip’ because of increased volatility.  Yet, we do
believe the reality is that it is likely applicators may continue to mix
other ingredients to make the sprays more effective, even when these mixes
are off-label.  SOCC is working to find solutions to make such off-label
use more difficult for unscrupulous applicators.*

*— Second, there remain very few residue tolerances for dicamba on food
crops.  SOCC petitioned for residue tolerances on food crops, and Monsanto
and BASF, in response, submitted applications for such tolerances,
unfortunately, we believe residue tolerance approvals are a long way away.*

*— Third, we have been made aware of a very dramatic off-target drift
incident so drastic that dicamba moved across the Mississippi River from
Arkansas into Mississippi.  We will keep you advised as we learn more but
fully believe this is potentially a harbinger of our futures when the
widespread use of Dicamba becomes a reality.*

*— Fourth, it may be worth taking a moment to reflect on what our situation
might have been like had Dow and SOCC not reached a mutually beneficial
agreement to curtail certain high-risk uses of 2,4-D.  Consider, for
instance, this last cropping season in Australia.  Australian cotton
farmers faced one of their worst growing seasons due, in significant part,
to herbicide damage related to the heavy use of generic 2,4-D in certain
cotton producing areas.  I am so thankful that SOCC made curtailing the use
of generic forms of 2,4-D one of its key priorities in its deal with Dow.
See the link below for more information regarding this last Australian
cropping season:*

*http://mobile.abc.net.au/news/2016-01-09/cotton-farmers-struggling-with-crops-due-to-pesticide/7078590
<http://mobile.abc.net.au/news/2016-01-09/cotton-farmers-struggling-with-crops-due-to-pesticide/7078590>*

*— Finally, a Colorado rancher is heading to jail for spraying pesticides
in contravention of a court order.  I mention this story only to underline
how drift incidents can create such ugly legal fights among neighbors.  I
tend to think of American agriculture, and its communities, as one large,
if sometimes rowdy, family.  Our goal should always be to ensure that our
policies do as much as possible, at the outset, to avoid such legal fights
among the ‘family' as possible.  See a link to this somewhat sad story
below:*

*http://www.denverpost.com/news/ci_29606831/colorado-rancher-jail-bound-spraying-mosquitoes-protect-wife
<http://www.denverpost.com/news/ci_29606831/colorado-rancher-jail-bound-spraying-mosquitoes-protect-wife>*

*SOCC will continue to monitor and represent the specialty crop industry
until these new uses are given final approval by the EPA.  We want to thank
all of you for your continued support as we enter the final phases of this
long journey.  Much progress has been made, but the journey is not
completed.  We stand ready to answer any questions or receive your guidance
or comments as we proceed.*

*Please let me know if you have questions or comments.*

*Sincerely,*

*Steve Smith*

*Chairman, Save Our Crops Coalition*

Laurie Davies Adams
Executive Director

Pollinator Partnership

423 Washington Street, 5th Floor

San Francisco, CA 94111

e:  lda at pollinator.org

w:  www.pollinator.org

p:  415.362.1137

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