Lindsay Mitchell

Oct, 09, 2019  |  Legislation & Regulation

One way U.S. regulatory agencies draft rules to implement Congressional action is through a public comment period.  This process entails the agency publishing a draft rule, allowing the public to provide comments on why they believe the rule will or won't accomplish Congressional intent, and publishing a final rule.  Often there are many iterations of this draft rulemaking, public comment process.  

 

ICGA is very engaged in the public comment process and regularly intervenes on behalf of Illinois corn farmers when rulemaking impacts pesticide approvals, EPA regulation of biofuels, and other rulemaking that involved agricultural and the environment.

2019 Comments Submitted by ICGA

 

NAME

DOCKET

DATE

POSITION

DESCRIPTION

Modifications to Fuel Regulations To Provide Flexibility for E15;

Modifications to RFS RIN Market Regulations

EPA-HQ-OGC-2018-0775

3-21-19

Oppose

EPA’s proposed amendments to its RVP regulations are inconsistent with its proposed interpretation of the 1 psi RVP waiver.

Proposed Update to 7 CFR 340: Movement of Certain Genetically Engineered Organisms

APHIS-2018-0034-0037

8-5-19

support

Overall, we support and trust USDA’s scientifically based regulatory system, and appreciate the agency’s commitment to continuing to use such an approach.  We do have a few suggestions to improve the proposed rule.

Proposed Rule for the 2020 Volume Standards under the Renewable Fuel Standard (RFS)

EPA-HQ-OAR-2019-0136

8-30-19

oppose

We lack confidence in any volume released by the EPA because they are simply issuing exemptions to offset the allocation.

 

 

2018 Comments Submitted by ICGA

 

NAME

DOCKET

DATE

POSITION

DESCRIPTION

EPA’s Registration Review Neonicotinoid Risk Assessments; Neonicotinoid Benefits Assessments

EPA-HQ-OPP-2008-0844-1260

4-19-18

support

Urge EPA to approve Imidacloprid as a tool for farmers who prioritize environmental stewardship and safe and effective pest control.  Illinois corn farmers are committed to mitigating off target exposure to Imidacloprid

EPA’s Registration Review Neonicotinoid Risk Assessments; Neonicotinoid Benefits Assessments

EPA-HQ-OPP-2011-0865-0250

4-19-18

support

Urge EPA to approve Clothianidin as a tool for farmers who prioritize environmental stewardship and safe and effective pest control.  Illinois corn farmers are committed to mitigating off target exposure to Clothianidin

EPA’s Registration Review Neonicotinoid Risk Assessments; Neonicotinoid Benefits Assessments

EPA-HQ-OPP-2011-0581-0102

4-19-18

support

Urge EPA to approve Thiamethoxam

as a tool for farmers who prioritize environmental stewardship and safe and effective pest control.  Illinois corn farmers are committed to mitigating off target exposure to Thiamethoxam

SAFE Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks

NHTSA-2018-0067; EPA-HQ-OAR-2018-0283

10-26-18

 

Comments offer EPA suggestions for how to utilize ethanol as a cheaper, high octant fuel to address GHG emissions including setting a midlevel certification fuel.

Draft Human Health Risk Assessments for Atrazine

EPA-HQ-OPP-2013-0266-1161

11-21-18

support

The draft human health risk assessment updates more than a decade of careful, detailed, and scientifically comprehensive reviews that are an acknowledgment of atrazine’s safety when used according to the label.