Summary
Current proposed US Environmental Protection Agency (EPA) Re-Registration regulations for
fomesafen will cripple cotton and vegetable production in Georgia. These regulations in Georgia cotton
alone would potentially reduce farm gate values in excess of $156 million. Additionally, these
regulations would eliminate the most effective tool to manage Palmer amaranth and morningglory in 67%
of Georgia’s snap bean acreage (farm gate value of $22.6 million). These regulations will also eliminate
the benefits of fomesafen currently being developed for fruiting vegetables and cucurbits (farm gate value
exceeding $387 million), including its role as a key herbicide in the development of methyl bromide
alternative systems. These proposed regulations would negatively impact Georgia’s number 3 (cotton),
18 (watermelon), 19 (soybean), 20 (bell peppers), 31 (tomato), 38 (yellow and winter squash), 41 (snap
beans), 42 (cantaloupe), 43 (zucchini squash), 44 (eggplant), and 47th (other peppers) most valuable
agricultural commodities.
The EPA’s objective, to protect endangered species from any pesticide, including fomesafen, is
admirable, and the University of Georgia strongly supports this mission. However, we believe this
objective can be achieved without such detrimental regulations. Realistically, some Georgia growers
dependent on fomesafen will have only two options if these regulations are passed into law: 1) stop
producing the impacted crops or 2) producing these crops following current practices while ignoring the
law. Additionally, these regulations would likely prohibit The University of Georgia from 1) developing
alternatives to methyl bromide, 2) developing effective weed management programs for cotton and
soybean producers, and 3) hampering the adoption of new pesticides that are safer for the environment,
the applicator, and the end user. With these proposed regulations being similar for both clomazone and
fomesafen, one would anticipate similar proposed regulations for all herbicides (if not all pesticides) once
each product faces re-registration. Regulations such as those proposed by the EPA will not only greatly
restrict agricultural production in the United States, they will also restrict the ability of University and
Industry researchers from developing new and innovative technologies that are needed to feed the world.
The authors of this document are struggling to understand the validity of these proposed regulations.
First, how did the EPA determine “that the use of pesticides containing fomesafen is likely to adversely
affect a variety of listed species”? A literature search of many endangered plant species in Georgia and
their relationship with fomesafen showed little to no data results; this suggests to us that the sensitivity of
endangered plant species to fomesafen may not have been determined scientifically. Secondly, we
challenge the theory that an 850-foot buffer between a target area and a wetlands, waterway, or other
endangered species habitat, is needed with a herbicide such as fomesafen. The University of Georgia has
shown in this document that herbicide drift can be managed and, in some instances, avoided completely.
Thus, the logic of assigning a buffer zone distance of 850 feet, considering the diversity of application
techniques and environmental conditions, appears both non-scientific and unrealistic. The authors agree
that additional efforts should be made to eliminate, or at least greatly reduce, off-target pesticide
movement; however, the EPA should invest their efforts in working with manufactures and universities to
improve application techniques and understand herbicide movement and fate before imposing restrictions
that could regulate the American farmer out of business.
Obviously, no Georgia farmer wants any pesticide to move from the intended target area, and growers
would welcome new and innovative ways to limit pesticide movement. The University of Georgia is
willing to fully cooperate with the EPA and industry to conduct research to further understand the most
effective ways to mitigate herbicide spray drift and volatility. Additionally, the University of Georgia is
excited about using its Extension system to deliver new information on techniques that may eliminate off
target pesticide movement.