Memorandum to Open Docket for the Draft Fungicide Strategy

Dr. Javier G. Illan, representing the Western IPM Center, supports the Draft Fungicide Strategy but urges the EPA to place a greater emphasis on Integrated Pest Management (IPM) as a foundational component of fungicide stewardship. He argues that the strategy should recognize existing IPM practices as valid risk-reduction measures and ensure that mitigation requirements remain flexible and science-based.

The National Agricultural Aviation Association (NAAA) supports the EPA's Draft Fungicide Strategy, specifically advocating for the use of wind-directional buffers and various drift mitigation measures. They argue that aerial application is a critical, high-yield method for agriculture and provide data on their industry's safety and education programs.

The Minor Crop Farmer Alliance (MCFA) opposes the Draft Fungicide Strategy, arguing that it relies on unrealistic, overly conservative exposure models and could impose significant economic burdens and impractical restrictions on specialty crop growers. They advocate for refining risk assessments using higher-tier scientific data and requesting more practical mitigation options for spray drift and runoff.

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.

The National Alliance of Independent Crop Consultants supports the Draft Fungicide Strategy and requests that the EPA expand mitigation options to include automatic section control (ASC) technology. They also advocate for the development of a GPS-based digital application to help growers manage compliance and suggest that the seed sector move toward custom seed treatment packages.

Steve Hoffman, President of InDepth Agronomy, suggests that the EPA include "Sprayer Automatic Section Control" as a mitigation measure in the Draft Fungicide Strategy. He argues that this GPS-based technology can significantly reduce off-target pesticide application by automatically turning off nozzles near field boundaries and sensitive areas.

GROWMARK, an agricultural cooperative, supports the EPA's fungicide strategy to reduce species exposure while advocating for practical implementation. They specifically request expanded mitigation credits for aerial applications and polymer DRAs, argue against duplicative seed treatment registrations, and suggest developing accessible training tools for applicators.

The Missouri Soybean Association opposes the draft Fungicide Strategy, arguing that it could increase production costs, reduce grower profitability, and unnecessarily restrict access to critical crop protection tools like seed treatments. They advocate for a science-based approach that considers existing grower stewardship practices and suggests expanding the mitigation menu to include a broader range of conservation practices.

The Oregon Wheat Growers League, a trade association representing wheat producers, supports the EPA's goals of protecting endangered species while advocating for practical, science-based fungicide regulations. They emphasize the need for fungicide access for disease management and argue that regulations should account for modern application technologies and realistic farming practices.

The National Association of Wheat Growers (NAWG) opposes certain aspects of the Draft Fungicide Strategy, arguing that proposed spray drift buffer requirements and mitigation measures may impose significant economic and operational burdens on wheat farmers. They advocate for a more science-based approach that accounts for modern application technologies, existing stewardship programs, and the specific agronomic realities of wheat farming.