Comment submitted by Oregonians for Food and Shelter (OFS)

Summary: Oregonians for Food and Shelter, a non-profit coalition, supports the EPA's population-level conservation approach but argues that the Draft Fungicide Strategy must account for the indirect effects of pesticide mitigation on agricultural landscapes. They advocate for evaluating habitat based on structural characteristics rather than broad crop classifications and emphasize the need for practical, lower-risk pest-management alternatives to maintain viable production systems that support the streaked horned lark.