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The loss of Atrazine Herbicide would be detrimental to Agriculture. Atrazine is a viable

component that is used as a foundation for weed control programs. Atrazine is a key

ingredient in herbicide mixtures because it acts synergistically with other herbicides to

increase the effectiveness of weed control programs. In this way, atrazine is a critical

resistance management tool for water hemp, palmer amaranth and other broadleaf and

grass weed control in corn, sorghum, and sugar cane.

Because of the limited choice of herbicides registered for use on sweet corn, this crop is

even more dependent on atrazine than field corn.


AAW supports efforts to keep America’s food supply safe and sustainable, including

the continued use of atrazine and the true intent of the Endangered Species Act.

The draft biological evaluation (BE) does not take into consideration all the scientific

comments received from the public. AAW asks that the most recent and best available

data be used to make sound scientific decisions. Once updated, the BE could be

available for public comment once again.

AAW supports that species be identified as a group and not as individual species that

are likely to be adversely affected.


On the broader issue of compliance with the Endangered Species Act, we feel that it is

critically important to focus on efforts that will preserve or improve critical habitat for

endangered and threatened species precisely where these habitats exist. This requires

the identification and mapping of critical habitats into a GIS system so that farmers and

land managers can apply needed pesticides to cropland while employing setback

strategies to protect critical habitat areas. Identifying critical habitat on a county wide

level does nothing to promote the improvement or development of critical habitat.

Once critical habitat areas are mapped into a Geospatial Information Systems (GIS)agencies such as National Resource Conservation Services (NRCS) could work with

landowners and farmers to maintain or improve critical habitats on the properties they

control on a voluntary basis. State level natural resource agencies and the Fish and

Wildlife Service could develop information about the specific critical habitat profile for

each listed species so that NRCS and landowners would have the information needed to

improve or develop critical habitat. Farmers are currently engaging in a new golden age

of land stewardship that will include soil health practices, nutrient trading, carbon

credits and improvement/development of critical habitat.

Relying on models to predict the effect of pesticides on a multitude of species will do

little to improve the amount and quality of critical habitat for endangered and

threatened species where they exist.


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