[PCA] Request for comments on glyphosphate use on grasses

[Olivia Kwong]

USDA APHIS is seeking your assistance to determine the possible
environmental impacts of deregulating a transgenic creeping bentgrass that
is glyphosate tolerant ("Roundup Ready®").  This proposed Monsanto/Scotts
Co. product will be sold to golf courses for turfgrass applications.
Because an herbicide tolerant grass could change the vegetation management
practices on your managed lands, we would like information about your
program and how the product might impact that program.

Before making a decision about this proposed product, APHIS chose to
evaluate the potential environmental impacts within the context of an
Environmental Impact Statement (EIS).  Your contributions will inform
APHIS' EIS and the subsequent decision to approve this new engineered
grass.  APHIS published a request for information in the Federal Register
(V. 70, No. 196, Wednesday, October 12, 2005), inviting your contribution
that describes the use of glyphosate, how you manage grasses and your
assessment of potential impacts of the engineered grass.  We summarize
those information needs below.

Agrostis stolonifera (creeping bentgrass, or CBG) is a cool-season,
wind-pollinated, perennial species with about 13 relatives with which it
can cross in the United States.  CBG and about 33 other species of the
genus occur naturally across the continental U.S. The species occurs in
wet meadows, seepage areas, ditches, stream banks and along the margins of
ponds and lakes and on streambanks, in moist disturbed areas, various
grasslands (including upland prairies), mesic to rather dry upland
forests, on roadsides and railroad embankments.  Bentgrasses can spread
via dispersal of seed by wind, water, animals, and vegetatively via above
ground runners (stolons).  Common bentgrasses and rabbitsfoot grasses may
become glyphosate tolerant if pollen transmits the genes conferring
tolerance to glyphosate.  Other grasses in other genera could become
tolerant to glyphosate through selection following repeated use of the
herbicide on golf courses.

USDA APHIS information needs concerning glyphosate use for grasses include
the following:
(I) An overall description of the management program.
   (A) Whether the goals and purpose of the management program include
(for example):
     1. The control of invasive or noxious weeds (especially grasses).
     2. The recovery or management of habitat for federally listed
threatened or endangered species or other wildlife or species of concern.
     3. The restoration of ecosystem function.
     4. The maintenance of public use areas or rights-of-way.
   (B) If creeping bentgrass or its sexually compatible relatives are
present in the managed area:
     1. Herbicide combinations or formulations used that include
glyphosate.
     2. The total land area that is treated with glyphosate or a
formulation containing glyphosate.
     3. The method and frequency of application of these herbicide
formulations in the management plan.
(II) How management programs would change if glyphosate resistant species
were present.
   (A) Include potential changes in management strategies.
   (B) Changes in cost.
   (C) Changes in focus of program.
   (D) Legal restrictions on alternative vegetation management strategies.

Because the data and information that we seek is not generally available,
we are requesting this information in response to this notice. Descriptive
and application-specific information is most helpful. Floristic
assessments showing the prevalence of the cited grasses or sexually
compatible relatives are also of interest. Please let us know if we may
contact you for further information about your management activities. Your
contributions will be used within the EIS to evaluate possible
environmental impacts from engineered creeping bentgrass.

We send this survey to you because we believe that you would have an
understanding of the potential impacts of herbicide tolerant grass species
on natural and managed public lands, especially riparian areas and
meadows, should the engineered grass species become dispersed beyond golf
courses or the grass seed production sites. We are interested in specific
details and rationales for uses of glyphosate, especially as they pertain
to grasses.  If you want to redirect this survey to others that do your
IPM or pest control (or other facilities specialist), that would be
helpful.

We greatly appreciate your help, and encourage you to send us your
responses as soon as possible, preferably by November 14th (the closing
date for comments on the Federal Register Notice).  If more time is
needed, please let us know.

Resources that may be useful for you can be found in the addendum
following my signature.

ADDRESSES: You may submit comments by either of the following methods:

 - Federal eRulemaking Portal: Go to http://www.regulations.gov and, in
the "Search for Open Regulations" box, select "Animal and Plant Health
Inspection Service" from the agency drop-down menu, then click on
"Submit." In the Docket ID column, select APHIS-2005-0029 to submit or
view public comments on APHIS Docket ID 03-101-5.

 - Postal Mail/Commercial Delivery:
   Please send four copies of your comment (an original and three copies)
to:
   Docket No. 03-101-5,
   Regulatory Analysis and Development, PPD,
   APHIS, Station 3C71, 4700 River Road,
   Unit 118, Riverdale, MD 20737-1238.
   Please state that your comment refers to Docket No. 03-101-5.

        Many Thanks!

        Craig R. Roseland, Senior Biotechnologist,
        Biotechnology Regulatory Service, Unit 146
        4700 River Road
        Riverdale, MD 20737
        Phone: 301-734-7935
        Fax: 301-734-3135

        Email: craig.r.roseland at aphis.usda.gov


Additional Information

Links are provided below to information about the petition, the EIS
process, and other documents that might be useful for your understanding
of creeping bentgrass and its relatives, its distribution, and habitats,
and herbicides that might be used to control bentgrasses.

Resources Available on the Internet

Federal Register Notice of Intent to prepare an EIS, November 18, 2004, at
the USDA Biotechnology Regulatory Service Website:
http://www.aphis.usda.gov/brs/fedregister/BRS_20041118a.pdf

Public Comments to Federal Register Notices:
https://web01.aphis.usda.gov/Bentgrass.nsf.

The Monsanto/Scotts Petition (April, 2003) stating that glyphosate
tolerant creeping bentgrass, designated as event ASR368, should not be
regulated by APHIS because it does not present a plant pest risk. Go to:
http://www.aphis.usda.gov/brs/not_reg.html, then under Petitions for Non
regulated Status Pending, click on the link for the petition 03-104-01p.

Preliminary Risk Assessment of the Monsanto/Scotts Petition (December 2003
by BRS; includes lists of grass species and their ranges):
http://www.aphis.usda.gov/brs/aphisdocs/03_10401p_ra.pdf

Report by the Weed Science Society of America (February 2004)
"Determination of the potential impact from the release of glyphosate- and
glufosinate-resistant Agrostis stolonifera L. in various crop and non-crop
ecosystems".   Includes alternative herbicides that might be useful
against bentgrasses. See: http://www.wssa.net/society/bentgrass.pdf

Pesticide Product Label System database. Pesticide registrations are under
constant review by the U.S. Environmental Protection Agency (EPA). Use
only pesticides that bear the EPA registration number and carry the
appropriate directions.  The EPA Office of Pesticide Programs maintains a
searchable Pesticide Product Label System database at:
http://oaspub.epa.gov/pestlabl/ppls.home

Natural Resources Conservation Service PLANTS Database can be searched by
the common or scientific name for a plant species for information on the
taxonomy, distribution, and wetland indicator status.  Links are provided
in many cases to additional information about the species and its habitat.
Information is available on the distribution of creeping bentgrass
(Agrostis stolonifera) and other bentgrasses and for rabbitsfoot grasses
(Polypogon monspeliensis and P. viridis). The site also includes
information on federal and state noxious weed lists and invasive plants,
and threatened and endangered plants. http://plants.usda.gov/

Resources You Can Share With USDA APHIS

If you might have documents, such as agency guidelines for the use of
glyphosate, environmental or ecological risk assessments or environmental
impact statements, pesticide use reports, or similar documents that show
how your agency uses glyphosate, please let us know about them, and how we
might receive or have access to them.

Trade and company names are used in this publication solely to provide
specific information. Mention of a trade or company name does not
constitute a warranty or an endorsement by the U.S. Department of
Agriculture to the exclusion of other products or organizations not
mentioned.