OFS received the following email from Alan Schreiber:

 If you are reading this email, I think you are connected to a minor crop or may have a crop with minor uses, or may be I just think you are a power broker…….

At a recent Commodity Liaison Committee meeting for the USDA IR-4 Project was shocked (which is hard to do to me anymore) to hear Jerry Baron describe what EPA was planning to do in regard to changing the definition of what a minor use is.  Further, I was angered when someone from EPA described what they wanted to do and how they went and are going about it.  What really sent me through the roof was when I asked the EPA staffer if they understood the consequences to agriculture of the Agency’s actions.  A blanker look, I have never seen.   Obviously, the consequences this proposed action to agriculture is nowhere on their minds.  [Hey, I voted for the guy in the White House, but this is not what I wanted.]  Specialty crops need to rise up and let EPA know that we do not support their proposal.

I am sure all of you get a lot of emails and a lot of requests for actions, but I am personally requesting you to take the time to respond to EPA on this.  If you want to skip the rest of this rant, here is the short story.  I have two attachments.  First is a one page from IR-4 that tells the short story and what to do.  IR-4 Public Interest Finding briefing    Second, I got a copy of IR-4′s response to EPA that is more in depth if you need more information.   IR-4 PRIA Exemption Comments0001   Do not let Jerry Baron signing his comments on the second document with a crayon detract from the message, as it is a powerful response to EPA’s misguided proposal.

I urge you to provide comments to the OPP Division Director, Steven Bradbury, by Wednesday, April 20.   Steve’s email address is Bradbury.Steven@epamail.epa.gov. 

EPA has requested comments on their proposal to change the way it determines whether an IR-4 request is in the public’s interest.  When asked why they are changing a policy that has been so successful we got an incomprehensible answer that “The PRIA Advisory Committee had asked them to look in to this issue.”   I have a different opinion of what is behind it, but an email going out to a group of people is not the place for my conspiracy theories.  Part of what EPA wants to do is change the definition of what counts as a minor use.  They want to start charging IR-4 PRIA fees (these are tens and tens of thousands of dollars in cost each) for submissions of crops that are over 300,000 acres is size.  The implications of the new policy are more far reaching than what one think it would be.  See the attachments for more details.  If this does pass it will essentially result in a seven figure reduction in IR-4′s budget (oh, and a seven figure increase in EPA’s budget.)

I am the Director for the Washington Blueberry Commission and the Washington Asparagus Commission.  Neither of these crops have over 300,000 acres in this country so there are not directly impacted by this action.  My problem is that this is just bad public policy.  I want to give you a few examples of what the impact of this could mean. 

• A few years ago, we needed generated residue data for dimethoate for peas (over 300,000 acres) for aphid control for reregistration.  This is a generic product, with many registrants, and none of them wanted to support the registration financially.  This was a use pattern of interest to Washington, Oregon and Idaho.  If this policy would have been place the cost of this project would have tripled.  

• A few years ago, we had a problem in eastern Washington and northern Idaho with voles on wheat (of course wheat is not a minor crop in terms of acres), but the pest problem involved a few hundred thousand acres, a generic product and only IR-4 could get the problem done.  This policy probably would have made this project impossible.

• The Columbia Basin of Washington and Oregon is one of the few places in the world where mites are a pest of potatoes.  This is a market was limited to a few tens of thousands of acres, limiting its potential value to registrants.  Thanks to IR-4, we got a registration, but it would have been questionable whether this effort would have been successful.

These are three examples of minor uses on major crops.

Here is something else to think about.  Think about crop groupings.  IR-4 makes tremendous gains using crop groupings…. if you want the root and tuber crop grouping you have to include potato, carrot and a couple of other crops; the rep crops are over 300,000 acres.  The new EPA policy would gut much of the gains we accrue via the crop grouping system.

Read the attached documents and please offer up some comments to EPA telling them to stick with the current policy.  Trust me there is nothing good for agriculture with this new EPA policy.

Feel free to pass this on to other interested parties.

Thank you

Alan Schreiber, Director

Washington Blueberry Commission and Washington Asparagus Commission