We are sure you are aware of the the June 3, 2020 decision by the United States Court of Appeals for the Ninth Circuit to immediately vacate the registration of three dicamba products (Xtendimax, Engenia and FeXapan) during the height of the application season.
This unprecedented action by the Court will cause severe economic damage to the nation’s agricultural retailers and their farmer customers. On behalf of our retailer and distributor members, the Agricultural Retailers Association (ARA) strongly urges you to contact the U.S. Environmental Protection Agency (EPA) and ask they immediately appeal this federal court ruling using all legal avenues available to obtain a Stay of this overreaching court order and to apply longstanding “existing stocks” procedures to the cancellation.
Feel free to edit the message to Administrator Wheeler to make it about you, your company, and your grower customers. Additional points that you might consider adding are:
** Production, distribution, and quality control measures on the Dicamba products at question take place months in advance of the growing season. Ag businesses take large financial positions on securing the products, and Crop Consultants make plans with growers on how to safely and efficiently put this cropping system to work.
** Farmers purchase the appropriate seed and plan their acres according to where this technology can most positively affect their weed control strategies. Removing the ability to use these products now would disrupt and negatively affect their profits.
** Decisions to remove these labels must be made an August/September timeframe so that the R&D companies, suppliers, distributors, consultants, and farmers can plan accordingly for the upcoming season and not be exposed to huge financial and agronomic risks.
Thank you for your review and consideration of this urgent request! We stand ready to work with you to find solutions.
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