Comment submitted by National Association of Wheat Growers (NAWG)

Summary: The National Association of Wheat Growers (NAWG) opposes certain aspects of the Draft Fungicide Strategy, arguing that proposed spray drift buffer requirements and mitigation measures may impose significant economic and operational burdens on wheat farmers. They advocate for a more science-based approach that accounts for modern application technologies, existing stewardship programs, and the specific agronomic realities of wheat farming.