Memorandum to Open Docket for the Draft Fungicide Strategy

The Almond Alliance, representing California's almond industry, supports the EPA's efforts to develop a fungicide strategy to protect endangered species but requests more practical implementation details. They specifically advocate for updated spray drift modeling for air blast sprayers, recognition of existing state conservation programs for mitigation credits, and the inclusion of more diverse mitigation options like drone use and specific nozzle selections.

The Cherry Marketing Institute, Inc. (CMI), representing tart cherry growers and processors, supports the EPA's Draft Fungicide Strategy but urges the agency to ensure that proposed mitigations do not collapse the essential fungicide rotation required to manage disease and prevent resistance. They advocate for cherry-specific exposure data, a focus on hydrologic connectivity for runoff assessments, and the inclusion of airblast-specific spray data and credits.

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.

Sara M. Villani, an Associate Professor at North Carolina State University, opposes the Draft Fungicide Strategy because it could lead to suboptimal disease control, increased fungicide resistance, and fruit quality issues. She argues that the proposed mitigation measures—such as increasing droplet size, reducing application limits, and delaying applications until after rain—threaten the profitability and sustainability of the southeastern fruit industry.

The Illinois Soybean Growers, representing over 40,000 farmers, opposes the proposed Fungicide Strategy because they believe it could restrict access to essential crop protection tools, increase production costs, and reduce soybean productivity. They specifically argue against removing treated seeds from the Treated Article Exemption and urge the EPA to ensure that any mitigation measures are science-based, practical, and based on refined habitat maps rather than broad species ranges.

The Kentucky Soybean Association opposes the proposed Fungicide Strategy, arguing that it may impose unnecessary restrictions, overestimate exposure risks, and increase costs for soybean farmers. They advocate for a science-based approach that maintains access to critical fungicides while recognizing existing conservation practices and stewardship.

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.

Dr. Carl A. Bradley, a plant pathologist, supports the EPA's proposed fungicide strategy for protecting endangered species while emphasizing the need to maintain the efficacy and availability of fungicides for soybean and wheat production. He argues that any mitigation measures must account for disease epidemiology, fungicide resistance management, and the practicalities of agricultural disease management.

Acre Blitz, LLC, a company providing compliance infrastructure for agricultural platforms, supports the EPA's Draft Fungicide Strategy goals of mitigating risks to endangered species while providing flexible compliance options. They offer specific recommendations to improve the strategy's practical implementation, including favoring narrowly tailored timing restrictions, refining spray-drift adjuvant specifications, and removing treated seed from the strategy due to regulatory and enforcement complexities.

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.