Major activities carried out during 2009.


The 2009 crop situation, especially the excessive rainfall during planting and harvest in the Mid-South, was monitored closely by the NCC which, in conjunction with the NCGA staff, developed “Recommendations For Handling Seed Cotton Exposed To Excessive Rainfall,” and made the document available on the NCC’s web site.

English and Spanish version PowerPoint presentations were added to the Quality Preservation page on the NCC’s web site, to provide additional information in the NCC’s  “Contamination Free Cotton: Keep It Clean and Pure” campaign.

The NCC-coordinated Beltwide Cotton Conferences offered an enhanced web site to provide information on all facets of the 2010 forum in New Orleans, including conference programming which featured beefed up workshops and the continuation of the Cotton Consultants Conference.

bad cotton

The NCC, in conjunction with the NCGA, developed “Recommendations For Handling Seed Cotton Exposed To Excessive Rainfall,” which was made available on the NCC’s website.


The NCC and other commodity organizations analyzed a U.S. Sixth Circuit Court of Appeal’s decision on EPA’s rule exempting certain applications of pesticides from the Clean Water Act requirement for a National Pollution Discharge Elimination System permit. A coalition of 22 farm organizations, including the NCC, sought a rehearing but EPA announced it would not request a rehearing but a 24-month extension in order to develop a permitting system for pesticide applications which previously had been regulated under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

NCC President/CEO Mark Lange had written to EPA Administrator Lisa Jackson urging her to seek a rehearing stating that the NCC believes the Court’s decision “overlooked agriculture’s exemptions in the Clean Water Act and will have significant detrimental impacts across U.S. agriculture. These additional burdens will be placed on farmers with no added water quality benefits that the FIFRA label does not already provide.” Later, after the Court denied industry’s petition for a rehearing, the NCC and other agricultural organizations filed a petition for certiorari to the U.S. Supreme Court seeking reversal of the Sixth Circuit decision.

The NCC urged its members to contact their Congressman and convey serious concerns regarding the H.R. 2749 food safety bill – and that it not be voted on until referred to the House Agriculture Committee for consideration. The bill would have expanded significantly the Food and Drug Administration’s authority to regulate and oversee on-farm production activities. The NCC continued to work with a coalition that included the American Farm Bureau Federation, commodity groups, other oilseed processors and the grain trade to address concerns of affected cotton industry processors as the bill went to the Senate.

In anticipation of Senate action on food safety legislation, the NCC and the NCGA signed a letter with 24 other agricultural organizations sent to the Senate Committee on Health, Education, Labor, and Pensions. The letter endorsed certain provisions of that legislation (S. 510) and recommended improvements. S. 510 eventually was passed by that panel but was not addressed by the full Senate before year’s end.

The NCC opposed the Chemical Facility Anti-Terrorism Act of 2009 introduced to amend the Homeland Security Act of 2002. The NCC and other agricultural groups were concerned about the impact to farms which utilize certain fertilizers and pesticides that might be considered a substance of concern.

Testifying at a Consumer Products Safety Commission (CPSC) hearing on behalf of a broad coalition of textile and apparel interests, including the NCC, former NCC technical staffer Dr. Phillip Wakelyn stated there was strong evidence from CPSC studies, the textile industry and others over the last 30 years indicating formaldehyde in textiles does not pose an unreasonable risk of injury to consumers. He noted that because of the federal, state and volunteer regulations/guidelines already in place concerning formaldehyde and textiles, there was no need for legislative or regulatory action unless the results of the General Accounting Office study, required by the Consumer Product Safety Improvement Act, indicate that action is necessary.

The NCC developed information for use by CCI, USDA-APHIS and USDA-FAS in negotiations to eliminate Egypt’s unnecessary fumigation requirement for baled cotton and facilitate shipment of U.S. cotton to Egyptian mills.

Pest Management

The NCC’s Boll Weevil Action Committee (BWAC) was informed by USDA Animal & Plant Health Inspection Service (APHIS) National Boll Weevil Eradication Program Coordinator Bill Grefenstette that the: 1) boll weevil has been eradicated from 97 percent of U.S. cotton acreage and 2) remaining significant populations of boll weevils in the Cotton Belt are concentrated in southern Texas. The BWAC approved a letter inquiring about possible USDA Agricultural Research Service (ARS) research funds to address additional research needs. The BWAC also made recommendations to APHIS on the allocation of federal boll weevil cost share funding as part of the Joint Cotton Pest Account, once approved by Congress.

boll weevil

The NCC’s Boll Weevil Action Committee was informed by USDA-APHIS that the boll weevil has been eradicated from 97 percent of U.S. cotton acreage.

The NCC conducted a survey to identify the pesticides currently important for cotton production. NCC staff also continued working with registrants to maintain these registrations after EPA published a list of 67 pesticide ingredients – both active and inert – subject to initial screening in 2009 under the Food Quality Protection Act-mandated Endocrine Disruptor Screening Program.

The NCC submitted comments to EPA regarding the agency’s draft Ecological Risk Assessment of Fomesafen. That is the active ingredient in Reflex, an important tool in the battle to manage resistant pigweed in the Mid-South and Southeast. Fomesafen is one of the first products evaluated under the EPA’s second cycle of re-registration. The NCC called on producers and interest organizations to submit similar comments urging EPA to use current agronomic practices and best scientific information to evaluate pesticides.

The NCC also submitted comments to EPA objecting to the agency’s approach in its registration review process. In its preliminary assessment of clomazone (Command), EPA used a worst case volatilization incident to establish a two-mile radius “action area” for the consideration of endangered species.

In concert with several other agricultural organizations, the NCC wrote Agriculture Secretary Tom Vilsack urging that USDA’s Office of Pest Management Policy (OPMP) not be downgraded. The groups specifically asked him to appoint a special assistant to the Secretary for Pest Management Policy; to fill the vacant position of director of the Office of Pest Management Policy; to ensure that the director reports directly to the Secretary or a designee of the Secretary; and to adequately fund and support the OPMP.  

Cotton Flow/Packaging

The Joint Cotton Industry Bale Packaging Committee (JCIBPC) re-approved the 2008 bale packaging specifications for consideration by USDA. The JCIBPC also reviewed 2008 experimental test programs and strongly encouraged gins using materials approved for use in experimental test programs to recess their bale ties. Gins also were urged to record and provide testing firms with a bale tag list when experimental test products are used – a step that is helping NCC staff monitor the tested materials’ performance.

A letter from JCIBPC Chairman Curtis Stewart alerted ginners to the NCC web site addition of a video, “Bale Packaging: Eliminating Broken Bale Ties.”

The NCC joined with other agricultural groups in a listening session with the Department of Transportation and the Federal Highway Administration to increase understanding of multiple transportation issues and awareness of transportation legislation that will affect U.S. agriculture.

The NCC also arranged for its members to participate in a webinar discussion regarding railroad market power over the U.S. cotton industry. The webinar included a confidential survey that allowed participants to relate their economic impact experience with rail carriers. The NCC, along with other agricultural organizations, pledged to work with Senators Herb Kohl (D-WI) and John Rockefeller (D-WV) to see that comprehensive railroad antitrust legislation was passed in 2009.

bales in truck

The NCC posted on its web site the “Manager’s Guide to Safe Trucking During Agricultural Planting and Harvest Season.”

The NCC and the NCGA joined 50 agriculture groups to express support for maintaining the agricultural hours-of-service (ag HOS) exemption during the transportation authorization debate. The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users exempted agricultural carriers from the HOS regulations if they operated only within a 100-mile radius from their central base of operation – much needed flexibility during busy planting and harvest seasons. Earlier, the NCC posted on its web site the “Manager’s Guide to Safe Trucking During Agricultural Planting and Harvest Season,” an effort initiated by the Agricultural and Food Transporters Conference of the American Trucking Associations.

At the NCC Cotton Flow Committee’s prompting, USDA honored two NCC requests: 1) expansion of data released in the quarterly cotton flow summary reports and 2) clarify and define the term, “Active Shipping Order,” would be addressed through rulemaking.

On other technical issues, the NCC:

  • promoted and cooperated in the conducting of the Southwest, Western and Stoneville ginner schools.
  • continued, along with the NCGA, to engage the Labor Department on the H-2A rulemaking process.
  • provided input to EPA, including on its Clean Water Act permitting prototype, at the Pesticide Policy Dialogue Committee through U.S. cotton industry representative Cannon Michael, a Los Banos, CA, producer.
  • expressed concern to the Agriculture Secretary’s office over the delay in granting Bayer CropScience’s GlyTol™ cotton trait technology deregulation status – a step that helped speed the granting of that status- to allow for the limited release of varieties containing the trait before the end of the 2009 planting season.