Subject: EPA-HQ-OPP-2016-0187

Your Letter: I strongly oppose the approval of the use of dicamba on Monsanto’s dicamba resistant soybeans and cotton (Docket No. EPA-HQ-OPP-2016-0187). Monsanto’s genetically engineered Roundup Ready crops are planted on over 150 million acres nationwide. They have triggered a huge increase in the use of glyphosate (Roundup) herbicide, and an epidemic of glyphosate-resistant “superweeds.” Now, in a misguided effort to fix the weed resistance problem created by its Roundup Ready crops, Monsanto has genetically engineered soybeans and cotton to be resistant to more toxic herbicides like dicamba. If EPA approves this new use, millions more pounds of dicamba will be sprayed together with continuing heavy use of glyphosate. EPA’s proposed approval would significantly increase use of dicamba, creating the risk of weed resistance. Dicamba is an older herbicide that studies have linked to higher risk of cancers like non-Hodgkin’s lymphoma, as well as developmental toxicity; other tests indicate the potential for neurological impacts. Dicamba is soluble in water and moderately persistent, and so carries a large surface water and groundwater contamination risk. Dicamba is also volatile and can drift for miles. Dicamba drift has caused millions of dollars in damages to growers who have suffered crop losses due to herbicide drift onto their farms. The proposed approval would also damage and harm other crops and species, including threatened and endangered species, because dicamba is drift-prone and volatile. Inevitably, increased use of dicamba will generate new "superweeds" resistant to multiple herbicides, and the chemical arms race with weeds will continue. This means more pesticide pollution, more disease and environmental damage, and of course, increasing profits for firms like Monsanto that sell both dicamba-resistant seeds and the herbicides used with them. At a time when farmers, citizens, and government have worked hard to limit our use of, and exposure to, hazardous pesticides like dicamba, approving new use of dicamba for Monsanto’s dicamba resistant cotton and soybeans would take us backwards, seriously endangering human health and the environment. I urge you to reject this proposal.