Comment submitted by Xerces Society for Invertebrate Conservation et al.
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Summary: A coalition of environmental advocacy organizations (NRDC, Xerces Society, American Bird Conservancy, Prairie Rivers Network, and National Wildlife Federation) submitted joint comments urging the EPA to strengthen the Draft Fungicide Strategy. They argue that the Strategy underestimates fungicide use by omitting seed-treated acreage, fails to account for synergistic toxicities with insecticides, ignores "dust-off" as an exposure pathway, and should incorporate environmental monitoring data to validate risk assumptions.
Please find attached joint comments on the draft Fungicide Strategy submitted by the Xerces Society for Invertebrate Conservation, American Bird Conservancy, Natural Resources Defense Council, National Wildlife Federation, and Prairie Rivers Network.
Our comments urge EPA to:
- Incorporate fungicide-treated seed acreage into analyses of fungicide use patterns and overlap with listed species.
- Address dust-off from treated seed planting as an exposure pathway within the Strategy.
- Account for synergistic effects between fungicides and insecticides, particularly those involving demethylation inhibitor (DMI) fungicides.
- Ensure that risks to vertebrate wildlife from pesticide-treated seed ingestion are addressed across the Strategies.
- Incorporate environmental monitoring to validate Strategy assumptions.
Thank you for the opportunity to comment.