id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjel-3540	Mahoney, Michael	Perpetuating the Cycle: The Failure of APHIS and EPA to Consider the Cumulative Impact of Pairing Herbicides with Herbicide-Resistant Crops	2019	34	.pdf	application/pdf	11539	655	54	See id. MAHONEY-MACRO-[FINAL 6-19] (DO NOT DELETE) 6/22/2015 9:29 PM 208 COLUMBIA JOURNAL OF ENVIRONMENTAL LAW [Vol. 40:2 such as the development of 2,4-D resistant weeds.185 These are effects on the physical environment with a “reasonably close” relationship with the reregistration of 2,4-D and therefore EPA would need to analyze them if performing a NEPA analysis.186 B. EPA’s Registration of Enlist Duo™ EPA’s recent Final Registration of Enlist Duo™ Herbicide (“Enlist Duo Decision”) includes an analysis similar to the agency’s 2,4-D Decision.187 [Vol. 40:2 a. Alternatives EPA did not consider alternatives to the registration of Enlist Duo™ in the Enlist Duo Decision.201 EPA observed that the “emergence of herbicide resistant weeds is an increasing problem that has become a significant economic issue to growers.	cache/cjel-3540.pdf	txt/cjel-3540.txt