June 15, 2012
RE: Support Farm Bill Amendment #2367 (eliminating water permits for pesticides)
Dear Senator
:
The undersigned organizations, representing pesticide users, stakeholders and state agencies, ask for your
support of Amendment #2367 (eliminating water permits for pesticides) to S.3240, the Agriculture
Reform, Food and Jobs Act of 2012 (2012 Farm Bill). The amendment is sponsored by Senators Hagan (DNC) and Crapo (R-ID), along with a host of bipartisan cosponsors.
Pesticide users are now subject to a new federal permit, which burdens them with additional paperwork while
threatening them with citizen suits and substantial penalties. The Environmental Protection Agency (EPA) and
delegated states have been forced to implement this new National Pollutant Discharge Elimination System
(NPDES) Pesticide General Permit (PGP) for the application of pesticides under the Clean Water Act (CWA)
since the 6th Circuit Court of Appeals (National Cotton Council of America v. EPA) overturned EPA’s own
regulation declaring that a permit was not required for the application of a pesticide regulated under the
Federal Insecticide Fungicide and Rodenticide Act (FIFRA).
Since the inception of the CWA in 1972, water quality concerns from pesticide applications have been
addressed during the registration and labeling process under the FIFRA. We believe that the Court got it wrong
regarding Congress’ intent, and we urge the Senate to take immediate action to affirm that water permits are
not required for FIFRA-regulated pesticide applications. There is no need for this redundant water permit to
protect the environment since the lawful use of a pesticide already includes water quality protections.
Amendment #2367 includes the text of HR 872 - the Reducing Regulatory Burdens Act - a bill that convincingly
passed the House of Representatives on the suspension calendar and the committee of jurisdiction in the
Senate, the Committee on Agriculture, Nutrition and Forestry, by voice vote. The amendment would clarify that
federal law does not require redundant water permits for lawful pesticide applications. We do not support
changes or second degree amendments to Amendment # 2367.
Thank you in advance for your timely consideration of our request to support the inclusion of the Hagan-Crapo
Amendment # 2367 (eliminating water permits for pesticides) in the 2012 Senate Farm Bill, S.3240.
Sincerely,
Agribusiness Council of Indiana
Agricultural Alliance of North Carolina
Agricultural Cooperative Council of Oregon
Agricultural Council of Arkansas
Agricultural Research Consulting
Agricultural Retailers Association
Alabama Golf Course Superintendents Association
Alta Irrigation District, CA
American Cranberry Growers Association
American Farm Bureau Federation
American Frozen Foods Institute
American Mosquito Control Association
American Nursery and Landscape Association
American Sugar Alliance
Aquatic Plant Management Society
Arkansas Golf Course Superintendents Association
Arkansas Rice Federation
Association of Virginia Potato & Vegetable Growers
Bayer CropScience
Bluegrass Golf Course Superintendents Association
Cactus & Pine Golf Course Superintendents Assn
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California Agricultural Commissioners & Sealers Assn
Georgia Urban Ag Council
California Cotton Growers and Ginners Assn
Golf Course Superintendents Association of America
California Golf Course Superintendents Association
Golf Course Superintendents Assn of Cape Cod
Calusa Golf Course Superintendents Association
Golf Course Superintendents Assn of New England
Cape Cod Cranberry Growers Association
Golf Course Superintendents Assn of New Jersey
Carolinas Golf Course Superintendents Association
Golf Course Superintendents Assn of Central
California
Central Florida Golf Course Superintendents Assn
Central Illinois Golf Course Superintendents Assn
Golf Course Superintendents Assn of Northern
California
Central Pennsylvania Golf Course Superintendents
Assn
Gowan Group
Greater Cincinnati Golf Course Superintendents Assn
Central Ohio Golf Course Superintendents Assn
GROWMARK
Central Texas Golf Course Superintendents Assn
Hawaii Cattlemen's Council
Chemtura Corporation
Hawaii Farm Bureau Federation
Chicagoland Assn of Golf Course Superintendents
Heart of America Golf Course Superintendents Assn
CHS, Inc.
Hi-Lo Desert Golf Course Superintendents Assn
Colorado Association of Wheat Growers
Idaho Golf Course Superintendents Association
Colorado Potato Administrative Committee
Idaho Grain Producers Association
Connecticut Environmental Council
Idaho Grower Shippers Association
Connecticut Assn of Golf Course Superintendents
Council of Producers & Distributors of Agrotechnology
Idaho Potato Commission
Idaho Water Users Association, Inc.
Cranberry Institute
Illinois Fertilizer & Chemical Association
Crescent Canal Company, CA
Illinois Turfgrass Foundation
CropLife America
Crop Protection Association NC
Imperial Irrigation District, CA
Delaware State Golf Association Green Section
Indiana Golf Course Superintendents Association
Eastern Shore Assn of Golf Course Superintendents
Inland Empire Golf Course Superintendents Assn
Edison Electric Institute
Intermountain Golf Course Superintendents Assn
Empire State Potato Growers
Iowa Golf Course Superintendents Association
Everglades Golf Course Superintendents Association
James Irrigation District, CA
Family Farm Alliance
Kaweah Delta Water Conservation District, CA
Finger Lakes Assn of Golf Course Superintendents
Kansas Agribusiness Retailers Association
Florida Fruit & Vegetable Association
Kansas Association of Wheat Growers
Florida Golf Course Superintendents Association
Kansas Cooperative Council
Florida Turfgrass Association
Land O'Lakes, Inc.
Florida West Coast Superintendents Association
Lone Star Golf Course Superintendents Association
Georgia Agribusiness Council
Long Beach Cranberry Association
Georgia Golf Course Superintendents Association
Long Island Golf Course Superintendents Association
Maine Golf Course Superintendents Association
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Maine Potato Board
Northwest Illinois Golf Course Superintendents Assn
Metropolitan Golf Course Superintendents Association
NC Agribusiness Association
Miami Valley Golf Course Superintendents Assn
NC Agribusiness Council, Inc.
Michigan Agri-Business Association
Northeastern Weed Science Society
Michigan Golf Course Superintendents Association
Peaks & Prairies Golf Course Superintendents Assn
Mid-Atlantic Assn of Golf Course Superintendents
Pennsylvania Co-operative Potato Growers, Inc.
Midwest Association of Golf Course Superintendents
Philadelphia Assn of Golf Course Superintendents
Minnesota Agri-Growth Council
Potato Growers of Michigan
Minnesota Golf Course Superintendents' Association
Professional Landcare Network
Modesto Irrigation District, CA
Ocean Spray Cranberries, Inc.
Montana Grain Growers
Ohio Professional Applicators for Responsible
Regulations
National Agricultural Aviation Association
Ohio Turfgrass Foundation
National Alliance of Forest Owners
Oklahoma Agribusiness Retailers Association
National Alliance of Independent Crop Consultants
Oklahoma Grain and Feed Association
National Association of Chemical Distributors
Oklahoma Wheat Growers Association
National Assn of State Departments of Agriculture
Oregon Potato Council
National Association of Wheat Growers
Oregon Golf Course Superintendents Association
National Barley Growers Association
Oregonians for Food & Shelter
National Corn Growers Association
Reed Ditch Company, CA
National Cotton Council
Rio Grande Golf Course Superintendents Association
National Council of Farmer Cooperatives
RISE (Responsible Industry for a Sound Environment)
National Farmers Union
Rocky Mountain Golf Course Superintendents Assn
National Pest Management Association
San Diego Golf Course Superintendents Association
National Potato Council
Sierra Nevada Golf Course Superintendents Assn
National Rural Electric Cooperative Association
Society of American Florists
National Water Resources Association
Nebraska Golf Course Superintendents Association
New Hampshire Golf Course Superintendents Assn
South Dakota Agri-Business Association
South Dakota Association of Cooperatives
South Dakota Wheat Growers
New Jersey Green Industry Council
New York Golf Course Superintendents Association
Southern Cotton Growers
Southern States Cooperative
North Carolina Small Grain Growers Association
South Texas Golf Course Superintendents Assn
North Central Weed Science
Southern California Golf Course Superintendents
Assn
North Dakota Grain Growers
North Florida Golf Course Superintendents Assn
Southern Weed Science
Northern Ohio Golf Course Superintendent Assn
South Texas Golf Course Superintendents Assn
Northern Plains Potato Growers Association
Tennessee Farmers’ Cooperative
North Texas Golf Course Superintendents Association
Texas Ag Industries Association
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Texas Gulf Coast Superintendents Association
Texas Vegetation Management Association
Texas Wheat Producers Association
Turlock Irrigation District, CA
The Far West Agribusiness Association
U.S. Apple Association
USA Rice Federation
US Rice Producers Association
United Fresh Produce Association
Upper Missouri Water Association
Virginia Agribusiness Council
Virginia Golf Course Superintendents Association
Vermont Golf Course Superintendents Association
Washington State Potato Commission
Weed Science Society of America
Western Growers
Western Society of Weed Science
West Texas Golf Course Superintendents Association
Wild Blueberry Commission
Wisconsin Agri-Business Association
Wisconsin Cranberry Growers Association
Wisconsin Golf Course Superintendents Association
Wisconsin Potato and Vegetable Growers Association
Wyoming Ag-Business Association
Wyoming Crop Improvement Association
Wyoming Farm Bureau Federation
Wyoming Wheat Growers Association
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