This week, your association submitted comments regarding EPA docket number EPA-HQ-OPP-2014-0805, the EPA Proposal to Improve Corn Rootworm (CRW) Resistance Management.
This proposal is in response to CRW resistance reported by farmers in regions across the nation.
Within our comments, ICGA stated, “ICGA completely supports the effort to determine best management practices that preserve the viability of Bt technology. We are concerned about elements of the EPA proposal related to corn rootworm resistance management for registrations of plant-incorporated protectants (PIPs) in corn under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).”
One of the concerns on record on behalf of Illinois farmers is the idea of mandatory crop rotation. ICGA could not support mandatory crop rotation. In Illinois, the corn rootworm has adapted to a crop rotation plan and lays eggs that lay dormant in the soil through a soybean rotation. We have also documented cases where the rootworm lays eggs in a soybean field to position larvae for the following year’s corn crop. In these cases, farmers actually need to move away from crop rotation in order to break this cycle.
Additionally, mandatory crop rotation violates the farmers’ freedom to farm.
Secondly, the proposed ban on soil-applied insecticides (SAI) over Bt products is a significant concern. These products are needed for secondary insects in many situations; they are often used for pests other than corn rootworm. It is not realistic or feasible to deny farmers this critical pest management tool.
Illinois corn farmers are some of the most productive in the country and are proud to be both efficient and environmentally sound in their agricultural practices.
ICGA has asked the EPA to please make the necessary changes to their proposed rule such that it continues to allow farmers the freedom to farm using the most innovative technologies, while still addressing CRW resistance in an effective manner.
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