Comment submitted by U.S. Canola Association (USCA)

Summary: The U.S. Canola Association (USCA) opposes the draft Fungicide Strategy because it proposes application timing restrictions that would eliminate the window for managing critical fungal diseases in canola crops. They argue that the strategy imposes an impractical cumulative compliance burden and urge the EPA to recognize existing conservation practices and ensure the continued availability of essential crop protection tools.