September 5, 2025
Docket ID No. EPA-HQ-OPP-2024-0154
The Honorable Lee Zeldin, Administrator
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460
Dear Administrator Zeldin,
On behalf of the Nebraska Agri-Business Association (NeABA), a trade organization representing agricultural
retailers, distributors, and manufacturers of crop input products, I submit the following comments regarding
EPA’s proposed registration of over-the-top (OTT) dicamba uses on dicamba-tolerant soybeans and cotton.
Our member companies sell and apply crop protection products to Nebraska farmers and ranchers, who face
increasingly challenging, resistant weeds. Agriculture is Nebraska’s largest industry and a cornerstone of our
state’s economy. Effective weed management remains a top challenge to maintaining crop yields, and producers
need access to a diverse set of chemistries to sustain both productivity and long-term sustainability.
For these reasons, we strongly urge EPA to approve the OTT dicamba products under review. Dicamba is an
essential tool in managing resistant broadleaf weeds, and without it, farmers will face significant yield losses and
limited alternatives.
NeABA supports the label mitigations outlined in the proposed registration. We believe these measures strike an
appropriate balance between effective weed control and responsible stewardship. We are committed to working
with our state partners to support the applicator community with education and training, ensuring safe and
effective applications.
We encourage EPA to move forward with the registration of OTT dicamba products under the proposed label and
mitigation framework. Doing so will provide farmers with certainty, protect crop yields, support herbicide
resistance management, and promote responsible stewardship of these critical tools.
Thank you for the opportunity to provide comments. Please feel free to contact me if you have any questions or
need additional information.
Sincerely,
Scott Merritt
President
Nebraska Agri-Business Association