Thank you Chairman Goodlatte. My name is Mike Randall. I farm near Dell Rapids, South Dakota and serve as the Vice Chair of the National Corn Growers Association’s (NCGA) Public Policy Action Team and Chairman of the South Dakota Corn Growers Association. I raise corn, soybeans, alfalfa, and dairy heifers in my operation. My testimony today is also presented on behalf of the American Soybean Association. Thank you for the opportunity to testify today.

The NCGA represents over 30,000 corn farmers in 25 affiliated states. Our members are dependent upon a variety of crop protection products to be successful in their farming operations. These products allow for a more healthy crop, providing a higher yield due to protection from pests and weeds.

NCGA supported the Food Quality Protection Act (FQPA) when the law was passed in 1996, and we remain committed to the law. We agree with the fundamental goals of the law, particularly the special emphasis on protecting children and the establishment of a uniform public health standard. We feel that review of pesticides using reliable data, as stipulated in the law, will ensure the public health and the safety of children. NCGA does, however, remain concerned about the manner in which the Environmental Protection Agency and the U.S. Department of Agriculture are implementing FQPA.

NCGA is concerned about the lack of information regarding the implementation of FQPA as well as the rumors of unreasonable blanket cancellation of products without consideration of the impact on farmers and our safe, abundant U.S. food supply. We are very concerned about EPA’s failure to register new products in a timely manner. The lack of transparency in the implementation process and the virtual embargo of new registrations are the cause of our concerns.

To more clearly articulate our concerns, farmers, farm and food groups, pest management and manufacturing organizations formed the Implementation Working Group (IWG). NCGA is a primary sponsor of the IWG’s "Framework for Implementing the FQPA" or "Road Map" document. This document provides a series of workable recommendations for implementing the law. This document represents the consensus of a variety of affected parties as to how we believe FQPA can be implemented fairly and effectively. We are pleased to be able to offer solutions to what we feel is a system that is not currently working properly, nor as envisioned when FQPA was passed. We believe that the EPA simply needs to follow our Road Map to achieve implementation success.

NCGA is also involved in the FQPA Tolerance Reassessment Advisory Committee (TRAC) created by the EPA and USDA, with Jim Czub, a farmer and member of NCGA’s Board of Directors, as a participant. We support the purpose of the TRAC and look forward to continuing to participate in the process. However, we see this as just one step in the implementation process. This advisory committee does not replace the need for sufficient information to U.S. farmers from EPA and USDA on the implementation process and valid scientific data behind tolerance reassessment decisions.

Corn farmers employ a variety of crop protection methods to grow a safe, healthy, food supply with their crops and to reduce damage to the crops. The most common production method employed might be the traditional corn/soybean crop rotation to limit corn root worms and other pest pressure. Unfortunately, in areas of Illinois and Indiana, we are seeing root worms that are beginning to develop resistance to this traditional crop rotation method. If these developments continue to occur, the use of various crop protection products is even more critical to successful crop production. In irrigated corn country, crop rotation is often not an effective option and insecticides are even more vital for corn production. In addition, crop protection products are often used in concert with conservation tillage efforts to preserve the soil, such as no till farming.

When using various crop protection measures, farmers take into account many different elements, including choice of crop, seed technologies and products, soil, climate and rainfall, historical weed and pest pressure in the field. These same elements influence my decisions on pre-emergent and post-emergent application of crop protection tools. The application of any pesticide is done with great analysis of each aspect of these elements for optimum crop yield and most importantly cost. Growers seldom apply the maximum application dose at the maximum application rate for the sheer factor of cost.

Corn growers are the largest users of organophosphates (OPs) in the agriculture community. According to Mr. Leonard Gianessi’s data, 68% of the corn acres treated with pesticides are treated with OPs (The Uses and Benefits of Organophosphate and Carbamate Insecticides in U.S. Crop Production, December 1997). We have a great deal at stake as OPs, carbamates and pyrethroid tolerances are reassessed between now and August 1999. We are concerned about the EPA’s implementation of the law, not only because we have the potential to lose important products if reliable data are not considered, but because we are not being informed about the process behind implementation of the law. Let me make myself clear, we are not concerned only about OPs, we must have a roadmap to implementation that is transparent, reliable and repeatable.

Following the reassessment of the first third of products by August of 1999 comes another third and another third. What type of process is being defined now that will carryover to the reassessment of the remaining two-thirds of products after 1999? The need for a clearly defined tolerance reassessment process reaches far beyond the reassessment of organophosphates, carbamates and pyrethroids. It is essential to define this process for the public to understand the criteria used to assess risk and how reassessment decisions are reached.

EPA must use accurate scientific data, not unreasonable default assumptions for decisions during tolerance reassessment. The EPA must recognize that pesticides are applied in varying dosages and frequency in various areas of the country for a myriad of reasons. Thus it is unreasonable to assume that 100 percent of acres are treated at full dosage and maximum intervals. And most importantly, we want to ensure that EPA is cognizant of current production practices and modern farming methods regarding use of these chemicals as these decisions are being made. Do not let these products be lost for failure to recognize realities of production agriculture. A good example of this is soil insecticides that are applied at corn planting and six months pass before harvest.

NCGA is encouraging farmers to provide the most accurate data on their use levels to the USDA and the department’s agencies that conduct research and coordinate with the land grant universities. We feel that this is the route to ensure that data is collected in a manner that can be used by EPA. However, we have not heard a clear message of consensus between the EPA and USDA on where data gaps for corn products exist. Without that consensus, there is little we can do as an association to close that data gap. We appreciate the recent gains made by USDA in being at the table in this process, but the agency still has a long way to go.

As the August 1999 deadline approaches for the reassessment of the first third of products under FQPA, NCGA is very alarmed that corn growers are failing to see the registration of new products for corn that meet the new scientific requirements of the law. For example, two herbicides, AIM an FMC product and BALANCE, a Rhone Poulenc product for use on corn have faced registration delays. It is clear from following the registration of these two potential new products for corn, that this registration process must be clearly defined as well. Both of these products have faced delays and untimely responses to data submitted to the Agency. Now both of these products have been lost for the 1998 season. NCGA is concerned that adequate resource allocation within EPA is not being given to the registration of new products during the implementation of FQPA. We acknowledge that uses of existing chemicals may be altered under the stricter standards of FQPA, but growers rely on new products with new science to be registered in a timely manner under FQPA. Everyone agrees that new, safer products are vitally important to the success of the law. We cannot be successful if alternative products become trapped in the registration process. Given competitive, equally efficacious crop protection products, farmers like myself will always choose the safer product.

If corn growers are not provided sufficient options for crop protection, U.S. corn production will be at a competitive disadvantage. U.S. corn growers rely upon the latest technologies for all aspects of their farm business, and value and evaluate current and new technologies constantly to choose the best products for their operation. Currently, the U.S. is the leader in corn production throughout the world. In 1996, NCGA supported the Federal Agricultural Improvement and Reform Act (FAIR) to transition from supply management farm programs to a market created farm economy. The FAIR Act allows me the flexibility to grow crops that make conservation, production and economic sense for my land. To do so, the U.S. farmer needs to have the regulatory process to support an environment of product choice based on sound science and realistic agronomic practices. NCGA monitors closely corn production in other areas of the world and most specifically our closest low cost competitor, Argentina. If other countries can produce and transport corn at lower costs than the United States, we have the potential to lose our export markets and may suffer domestic market disruption. The U.S. government must assist the U.S. farmer to remain competitive in the world market and not restrict our competitiveness through unnecessary and unreasonable regulation.

Right now, while corn prices are fluctuating and are volatile due to weakened and bleak export demand, this concern hits very close to home. The U.S. least-cost production of corn is essential to retaining domestic and international markets. If corn farmers have reduced options for crop protection - herbicides or pesticides - the prices of these produces will undoubtedly rise. If prices become cost prohibitive, corn farmers will be unable to provide an abundant supply of food.

One of the basic perceptions of the FAIR Act was a balance sheet. Reduced farm program payments offset by a more flexible farm program, tax reform and regulatory relief. The manner in which FQPA is being implemented is inconsistent with that balance sheet provided by Congress in the farm bill. Mr. Chairman, members of the Committee, I would encourage you to keep that balance sheet in mind as you exercise your oversight authority on this process.

Mr. Chairman, I want to thank you for holding this oversight hearing today and providing this forum for agriculture to voice our concerns over the implementation of the Food Quality Protection Act. NCGA will continue to work with EPA and USDA and through public forums to ensure that the impacts of this law on production agriculture are fully realized. We believe that the IWG has developed a very balanced and workable implementation document in the Road Map and would urge the EPA to seriously consider following the recommendations in the document. With transparency during the implementation of the law, use of reliable information and taking into account how this law impacts agriculture - alterations in farming practices, actual pesticide use and the need for new products - FQPA will meet the goals set by Congress.