COMMENTS
Lindsay Mitchell
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.
2021 Comments Submitted by ICGA
| NAME | DOCKET | DATE | POSITION | DESCRIPTION |
| Draft Endangered Species Act Biological Evaluations: Atrazine | EPA-HQ-OPP-2020-0514 | 2-12-21 | N/A | ICGA recognizes the need for Atrazine and it's family of chemicals and their safety for wildlife. |
2020 Comments Submitted by ICGA
|
NAME |
DOCKET |
DATE |
POSITION |
DESCRIPTION |
|
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. |
|
|
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. |
| 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. |
|
EPA's Vehicle Test Procedure Adjustments for Tier 3 Test Fuel |
No. EPA-HQ-OAR-2016-0604 | 8-24-2020 | Opposes | The EPA seeks to penalize a test fuel, not because the fuel’s carbon emissions are too high, but because they are too low. EPA’s proposed Vehicle Test Procedure Adjustments for Tier 3 Certification Test Fuel rule would artificially inflate the CO2 emissions of vehicles certified with the Tier 3 E10 test fuel instead of the Tier 2 E0 test fuel. This distortion is perverse. Penalizing the E10 test fuel for producing fewer carbon emissions than other test fuels would deter innovation and thwart the CAA’s goal of reducing greenhouse gas emissions. |
| Neonicotinoid Pesticides | EPA-HQ-OPP-2020-0306 | 8-30-2020 | Supporting | ICGA supports the use of neonicotinoids as another tool to manage insect infestations and grow enough grain to feed and fuel our world. |
| Amonia Certification Deadline | 8 Ill. Admin. Code 215 | 10-13-20 | Opposes: We oppose the rush of the completition of the certification given the current circumstances and would like the date to be moved until April 1, 2022 |
| Metolachlor and S-Metolachlor | EPA-HQ-OPP-2014-0772 | 10-28-20 | Supporting | ICGA supports the reregistration of metolachlor and s-metolachlor. Metolachlor provides residual activity important for controlling weeds on Illinois farms beyond the immediate impacts of application. |
| Proposed Interim Registration Review Decision for metolachlor and s-metolachlor | EPA-HQ-OPP-2013-0779 | 12-23-20 | Supports | ICGA is pleased to submit comments in support of the reregistration of mesotrione. |
2019 Comments Submitted by ICGA
|
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. |
