On January 24, the state of Louisiana formally petitioned the Environmental Protection Agency to reconsider its 1972 order cancelling the use of DDT on cotton. Cancellation of the pesticide, one of William Ruckelshaus' last acts as EPA Administrator, was upheld in December 1973, by the D.C. Circuit Court of Appeals.¹ That decision was the culmination of 10 years of legal action by environmentalists, particularly the Environmental Defense Fund, to convince the government that a ban on the chemical was necessary to protect both the environment and human health.

Louisiana's petition alleged that substantial new evidence, developed since the 1972 order, justified reopening the issue. According to the state, the tobacco budworm, a caterpillar that feeds on cotton plants, has become resistant to the organophosphate pesticides that EPA had said were acceptable alternatives to DDT and is now infesting Louisiana's cotton fields in epidemic proportions. The petition warned of major crop losses and substantial unemployment in the state's cotton-related industries unless the Administrator allowed the emergency use of DDT pursuant to §§3 and 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)² The state asserted that pound-per-acre yield of cotton has dropped substantially since the 1972 order took effect, although its only evidence in support of this contention was the testimony of a single cotton farmer that his per-acre yield of cotton in 1974 was one-half that of 1972, when he used DDT.