ENVIRONMENT & STEWARDSHIP
Agricultural retailers continually strive to be environmental stewards of land and water resources. Agricultural retailers provide scientifically environmentally safe chemicals to farmers to increase crop yields, while preserving the environment. Retailers apply these production chemicals as the label advises to avoid any unintended consequences. Retailers also help farmers manage soil nutrition and runoff by developing nutrient management plans and using global positioning systems (GPS) on application equipment. Retailers design their facilities and chemical storage to ensure that products are held safely and securely. The Environmental Protection Agency regulates the use of pesticides under the authority of two federal statutes: the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA).
• Work with EPA to ensure FIFRA compliant aquatic pesticide applications are not subject to the Clean Water Act NPDES permit.
• Work with EPA on their Spray Drift Guidance document to ensure that the FIFRA standard is held and oppose ambiguous standards like “may cause adverse effects” or “zero drift” policies.
• Work with EPA to clarify their new Emergency Planning and Community Right-to-Know Act interpretation of fertilizer retailer to exclude facilities that blend fertilizer.
• Support voluntary Best Management Practices (BMPs) for retailers to utilize in the application of crop input materials (both fertilizer and pesticides) to ensure sustainable and productive agricultural land.
• Work to provide sound science for nutrient criteria and support states as the lead jurisdiction on any nutrient water criteria
• Support private sector web-distributed labeling and discourage federal mandatory proposals that are duplicative and unnecessary.
• Support a scientific basis for initiatives to manage water resources.
• Support the use of documented science as the sole criteria in the establishment of environmental policies.
• Work with Congress to stop efforts to regulate greenhouse gas emissions under the Clean Air Act.
• Oppose overly stringent Clean Air Act ambient requirements for dust.
• Promote stewardship and applicator training and guidance.
• Work to ensure that any sustainable practices within the agricultural sector are outcome-based rather than practice-based approaches.
• Work with industry coalition to promote the use of biotechnology, which have helped farmers increase their production and income while reducing their environmental footprint.
• Work to support native pollinators while challenging unsubstantiated data and opinion that would incorrectly identify purported causes of colony collapse disorder.
• Support conservation programs and technical assistance programs that promote the use of precision agriculture technologies by agricultural retailers and their farmer customers.
In the aftermath of September 11, 2001, concerns were raised about agricultural retailers and the chemicals that they store and apply. Federal regulatory agencies and lawmakers are issuing new rules as part of a continuing effort to strengthen homeland security, many which directly impact the crop input sector. Due to the passage of the Department of Homeland Security Act Appropriations bill (H.R. 5441) in 2006, the U.S. Department of Homeland Security (DHS) has the authority to enforce and regulate new security standards on “high risk” chemical facilities which could include agricultural retailers and distributors. ARA continues to work with Congress and DHS on chemical security laws that ensure the security of agricultural chemical facilities, while protecting agricultural retailers’ business interests.
• Support a permanent reauthorization of the current DHS Chemical Facilities Anti-Terrorism Standards (CFATS) program.
• Oppose any legislative or regulatory proposal that includes an inherently safer technology (IST) requirement, citizen enforcement provisions, and weakening of federal preemption.
• Work with DHS and TFI on the implementation of new ammonium nitrate registration regulations.
• Maintain active participation on the Chemical Sector Coordinating Council
• Work with USDA on anti-Meth grant programs and maintain involvement in Fertilizer Anti-Meth Task Force.
• Work with appropriate government agencies to promote education and training for federal regulations related to the storage and security of anhydrous ammonia.
Transportation is an essential component of the U.S. economy and rural communities. An economically efficient and effective intermodal transportation system is important for the financial well-being of agribusinesses and rural communities throughout the United States. Congress and the Administration need to support federal policies that build upon the strengths of each mode of transportation. Such a system will enhance the competitiveness of the United States in an increasingly global economy.
• Work to ensure that movements of all farm supplies throughout the distribution chain (wholesale to retail to farm) are covered by the Hours of Service Agricultural Exemption.
• Extend HOS Ag exemption to 150 air miles.
• Support streamlining and standardizing security background checks and duplicative security credentials, support measures that would increase the number of eligible CDL drivers.
• Support DOT authority to preempt of states and local regulations.
• Support testing of all nurse tanks, including the incorporation of SP 13554 and SP 10950 into the regulations, and supporting efforts to define criteria describing a company’s fitness to participate in the special permit and approval programs.
• Support DOT in setting the CSA safety fitness determination (SFD) for interventions and unfit so that the system is clear and fair to the agricultural distributor and retailer.
• Support efforts to reform the Surface Transportation Board that will ensure fair and reasonable rail shipping practices and rates and oppose efforts to shift liability for toxic by inhalation chemicals away from the railroad.
TAX, FINANCE, & TRADE
• Work with Congress to extend the Agricultural Chemical Security Tax Credit beyond Dec. 31, 2012.
• Support full repeal of the federal estate tax.
• Support permanent extension of 2001 and 2003 Bush tax relief provisions that benefit the agricultural sector.
• Work with CFTC and other regulators on derivatives regulatory proposals for end-users, minimizing volatility in the marketplace, while not inhibiting the ability to legitimately hedge risk. Participate as a member of the Coalition for Derivatives End-Users.
• Support efforts to establish uniform state fertilizer registration regulations and state tonnage reporting and fees.
• Support policies that promote Free Trade of agricultural products and crop input materials (pesticides, fertilizers, seeds).
• Support pension funding relief that provides agribusinesses more time to address their long-term financial obligations.
• Support the development of voluntary risk management tools (ex. ARA Model Fertilizer Contract).
• Support repeal of the Patient Protection and Affordable Care Act (PPACA) and replace with reasonable health care solutions that more adequately addresses the needs of agribusinesses and their employees.
LABOR & OSHA
• Support a comprehensive immigration reform policy that provides for a usable ag guest worker program, a reliable verification system, secured borders, and the opportunity for current farm workers with the support of an employer sponsor to apply for legal status.
• Oppose Card Check legislation which removes secret ballots for workers.
• Support agricultural retail dealer education and training programs which enhance health and safety in the workplace.
• Support voluntary work-based incentives, provide exemptions from random inspections, and offer penalty reductions for employers which utilize a third party consultation program or have a safety and health program and an exemplary safety record.
• Oppose the use of results from voluntary audits in agency enforcement actions.
• Support OSHA policies that provide increased flexibility for inspectors to develop cooperative relationships with small employers that result in reduced hazards, fewer violations, and fewer penalties.
• Support federal energy policies that increase domestic natural gas supplies and help reduce production costs for crop input materials manufactured in the U.S.
• Work with industry coalitions to continue to promote development and use of renewable fuels to reduce U.S. dependence on foreign sources of energy.