Memorandum to Open Docket for the Draft Fungicide Strategy

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 California Rice Commission provides technical information on rice growing practices, arguing that rice fields are managed to minimize runoff and provide critical habitat for migratory birds. They clarify that rice fields are not "waters of the state" and emphasize that fungicide use is limited and occurs during specific windows that minimize risk to pollinators and wildlife.

The National Alliance of Forest Owners (NAFO) supports the EPA's goal of reducing fungicide impacts on endangered species but cautions against regulations that could hinder tree seedling nursery productivity. They argue that nursery environments naturally mitigate exposure risks and that maintaining healthy seedling production is essential for the reforestation and habitat restoration required for species recovery.

Rex McCall, President of the Blue Ridge Apple Growers Association, opposes the Draft ESA Fungicide Strategy because it could impose impractical mitigation requirements on apple growers in western North Carolina. He argues that the strategy may lead to increased crop losses and threaten the economic viability of family farms due to the region's unique geography and disease pressure.

The Wild Blueberry Commission of Maine supports the Draft Fungicide Strategy, praising its focus on implementation flexibility and the expansion of the Mitigation Menu. They recommend refining exposure assessments to account for the unique perennial agroecosystem of wild blueberries and advocate for a transparent pathway to incorporate stakeholder-provided empirical data.

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.

The Oregon Seed Council opposes the EPA's proposed strategies to restrict or eliminate pesticide use in grass seed production, arguing that these practices are essential for crop success and actually create necessary habitat for the streaked horned lark. They request that the EPA avoid a "generalist approach" and instead consult with the Fish and Wildlife Service to develop specific, field-by-field mitigations that protect the lark without undermining the economic viability of the grass seed industry.

Bayer Crop Science supports the Draft Fungicide Strategy while advocating for science-based risk assessments that avoid unnecessary burdens on growers. They specifically recommend refining modeling parameters for treated seeds and runoff exposure to ensure mitigation measures are proportionate to actual field conditions.

The Illinois Farm Bureau supports the Draft Fungicide Strategy but emphasizes the need to maintain access to essential crop protection products and avoid overly complex or costly mitigation requirements. They advocate for the recognition of existing conservation programs, the use of best available scientific data for risk determination, and the preservation of the Treated Article Exemption for seed treatments.