Comment submitted by Steve Hoffman

Re: Draft Fungicide Strategy to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Fungicides; Docket ID No. EPA-HQ-OPP-2026-2973 I would like to suggest an additional mitigation to consider for addition to the mitigation menu for ESA pesticide applications. Modern agricultural sprayers are often equipped with automatic section control (also known as swath control). This technology uses GPS sensors along the sprayer boom to turn individual nozzles on or off during the spray application depending on their location within the field area when grassed waterways, field boundaries or other hazards have been physically mapped with GPS. This technology ensures that pesticides are not applied beyond the field borders or onto sensitive areas. Section control technology also ensures that overlap applications of pesticides do not occur because the sprayer actively records areas that have already received the application. Individual nozzles are turned off if the sprayer boom passes over areas that have already been sprayed. Sprayer booms are configured in straight lines. Field borders and restricted areas are commonly meandering features. Without automatic section control, a spray application will usually result in some overspray beyond the field borders or onto restricted features. Coupling the physical GPS mapping of restriction features with sprayer automatic section control will significantly reduce off-target pesticide delivery whether from overspray or due to runoff water delivery from grassed waterways. The industry average reduction in pesticide application to agricultural fields ranges from 5% to 10% depending on the field shape and presence of restricted features. I respectfully ask EPA to consider adding Sprayer Automatic Section Control at the individual nozzle level when application occurs with the use of GPS mapped field borders and in-field restrictions as a mitigation for agricultural pesticide applications. Thank you for your consideration, Steve Hoffman CPCC-I, CPAg, CCA President - InDepth Agronomy Manitowoc, WI