Lindsay Mitchell

Nov 27, 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.

 

2020 Comments Submitted by ICGA

 

 

 

NAME

DOCKET

DATE

POSITION

DESCRIPTION

2020 Environmental Protection Agency Preliminary Interim Decision (PID) for atrazine, propazine, and simazine

 EPA-HQ-OPP-2013-0266 

 

3-2-2020

Support with modifications

ICGA supports EPAs use of sound science in this review, but requests poor science be removed from the docket or that quality science be given more weight.  This review sets precedence for other reviews.

 

NRCS Soil Health Strategy

 

  5-12-2020 Support with modifications ICGA supports this strategy but requests using partner groups, increasing county level support, and utilizing ISAP. The comments also reflect clearly defining what soil health means.

Regional Conservation Partnership Program RCPP

 NRCS-2019-0012-0001 5-13-2020 Support with modifications ICGA supports this program and attributes it to the success of cover crops and other conservation practices across the state. We desire more flexibility within the Technical Service Provider (TSP) portion of the program. 

 

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.

 

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

EPA-HQ-OAR-2019-0136

11-27-19

Oppose

We simply ask the EPA to honor the commitment made by President Trump on October 4 – to reallocate the actually waived gallons in future RVO numbers.

Paraquat Draft Human Health and Ecological Risk Assessments

EPA-HQ-OPP-2011-0855

12-16-19

Support

We support the reregistration of Paraquat as an important tool in the Illinois corn farmer’s toolbox – especially to empower farmers to plant more cover crops and utilize more minimum tillage practices.

 

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.