Comment submitted by Bayer Crop Science LLC
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Summary: Bayer Crop Science supports the Draft Fungicide Strategy while advocating for science-based risk assessments that avoid unnecessary burdens on growers. They specifically recommend refining modeling parameters for treated seeds and runoff exposure to ensure mitigation measures are proportionate to actual field conditions.
Bayer Crop Science appreciates the Agency’s ongoing efforts to address the challenges associated with fulfilling its obligations under the Endangered Species Act (ESA) for actions taken pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). We are committed to working collaboratively with EPA and other stakeholders to help advance a process that both ensures growers have timely access to essential tools and achieves protection of endangered species in a manner consistent with ESA and FIFRA requirements. Bayer remains dedicated to product stewardship and pesticide safety, and we value the opportunity to provide comments on the Draft Fungicide Strategy in the attached document.