Comment submitted by Northwest Horticultural Council (NHC)

Summary: The Northwest Horticultural Council (NHC), representing growers of apples, pears, and cherries, opposes the draft Fungicide Strategy due to proposed spray drift buffer zones that they claim are unworkable and would impose significant economic burdens on tree fruit growers. They argue that the proposed mitigations are not technically feasible for their specific crops and request more flexible, region-specific, and cost-effective options.