Comment submitted by Oregon Seed Council

Summary: The Oregon Seed Council opposes the EPA's proposed strategies to restrict or eliminate pesticide use in grass seed production, arguing that these practices are essential for crop success and actually create necessary habitat for the streaked horned lark. They request that the EPA avoid a "generalist approach" and instead consult with the Fish and Wildlife Service to develop specific, field-by-field mitigations that protect the lark without undermining the economic viability of the grass seed industry.