Presentation of the Atrazine Reevaluation Plan

The National Agricultural Aviation Association (NAAA) appreciates the opportunity to comment on the Environmental Protection Agency's recent decision to reassess the crop protection product atrazine through a Scientific Advisory Panel (SAP). NAAA represents more than 1,500 members in 46 states. NAAA supports the interests of small business owners and pilots licensed as commercial applicators that use aircraft to enhance food, fiber and bio-fuel production, protect forestry and control health-threatening pests. Furthermore, through its affiliation with the National Agricultural Aviation Research & Education Foundation (NAAREF), the NAAA contributes to research and educational programs focused on enhancing the efficacy, security and safety of aerial application. NAAA recognizes the importance of EPA's crop protection product assessments in accordance with the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Having said that, NAAA believes the Agency should use the most current and accurate data and industry practices available when making these assessments and determining the risks involved with the use of certain crop protection products. NAAA also encourages the Agency to take into account the benefits these products offer our nation's farmers in the production of an abundant supply of food, fiber and bio-fuels. Atrazine is an important tool in managing weed resistance and producing healthy and substantial crop yields. Atrazine is relied upon for its cost-effective, broadleaf weed control in corn, grain sorghum, sugar cane and other crops. EPA estimates atrazine's value to corn farmers at $28 per acre. In combined data from 236 university corn field trials from 1986-2005, atrazine treatments showed an average increased yield of 5.7 bushels per acre over alternative herbicide treatments. Combining atrazine with other herbicides enhances control of targeted weeds at minimum application rates. Atrazine is not subject to volatile drift from the applicatio