Memorandum to Open Docket for the Draft Fungicide Strategy

A group of 34 individuals submitted comments supporting the EPA's Draft Fungicide Strategy as a positive first step toward protecting endangered species. They argue for the inclusion of specific additional measures, such as accounting for fungicide seed treatments in usage data, assessing synergistic impacts, and requiring prescriptions for pesticide use.

The American Bird Conservancy and 40 other conservation groups support the EPA's Draft Fungicide Strategy as a positive first step toward protecting endangered species. They argue that the strategy should be strengthened by including specific species in risk assessments, accounting for synergistic impacts, and requiring prescriptions or avoidance of pesticide use.

The American Bird Conservancy supports the EPA's Draft Fungicide Strategy as a positive step but argues that it needs to more robustly address the risks posed by pesticide-coated seeds to endangered and threatened species. They recommend specific on-field and runoff mitigation measures, such as agronomist prescriptions, minimum planting depths, and spill clean-ups.

The Center for Biological Diversity supports the EPA's Draft Fungicide Strategy as a programmatic approach to protect endangered and threatened species, particularly through the use of Pesticide Use Limitation Areas (PULAs). However, they argue that the current mitigation menu and point system are too weak and complex, and they urge the EPA to adopt more stringent, objective, and geographically tailored conservation measures.

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.

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.

Oregonians for Food and Shelter, a non-profit coalition, supports the EPA's population-level conservation approach but argues that the Draft Fungicide Strategy must account for the indirect effects of pesticide mitigation on agricultural landscapes. They advocate for evaluating habitat based on structural characteristics rather than broad crop classifications and emphasize the need for practical, lower-risk pest-management alternatives to maintain viable production systems that support the streaked horned lark.

A coalition of environmental advocacy organizations (NRDC, Xerces Society, American Bird Conservancy, Prairie Rivers Network, and National Wildlife Federation) submitted joint comments urging the EPA to strengthen the Draft Fungicide Strategy. They argue that the Strategy underestimates fungicide use by omitting seed-treated acreage, fails to account for synergistic toxicities with insecticides, ignores "dust-off" as an exposure pathway, and should incorporate environmental monitoring data to validate risk assumptions.

Beyond Pesticides, representing 33 other organizations, opposes the Draft Fungicide Strategy, arguing it fails to meet statutory obligations under the Endangered Species Act. They contend that the strategy relies on insufficient mitigation measures and fails to adequately consider organic agriculture and other non-toxic practices as viable alternatives.

Tamas Houlihan, representing the Wisconsin Potato & Vegetable Growers Association, argues that the proposed fungicide mitigation measures—such as rigid droplet-size requirements and wind-speed limits—could hinder effective disease management for specialty crops. The association requests that the EPA preserve grower flexibility, recognize site-specific conditions, and account for existing stewardship practices to ensure food security and economic viability.