Comment submitted by National Barley Growers Association (NBGA)

Summary: The National Barley Growers Association (NBGA) opposes the Draft Fungicide Strategy because it may impose unworkable restrictions on fungicide applications, particularly during critical windows for managing Fusarium Head Blight. They urge the EPA to consider cumulative compliance burdens, recognize existing conservation practices for mitigation credits, and ensure that new requirements do not reduce the availability of essential crop protection tools.