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.

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.

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.

The USDA Office of Pest Management Policy supports the EPA's Draft Fungicide Strategy, particularly the iterative approach and engagement with stakeholders. They provide specific technical recommendations on seed treatments, drift reducing adjuvants (DRAs), and precision application technologies to ensure the strategy is practical for growers while meeting Endangered Species Act obligations.

The Arizona Pest Management Center at the University of Arizona supports the Draft Fungicide Strategy while advocating for flexible, grower-centered practices and clear guidelines on spray drift adjuvants. They argue that fungicide seed treatments pose extremely low risks to endangered species due to precision application and low active ingredient rates.

The Kansas Soybean Association opposes the proposed Fungicide Strategy, arguing that it may impose unnecessary restrictions, overestimate exposure risks, and increase costs for soybean farmers. They specifically advocate against removing treated seeds from the Treated Article Exemption and call for a more targeted, science-based approach to mitigation.

Marion Murray, representing Utah State University's Extension IPM Program, submits feedback based on a survey of experts and growers in the Intermountain West. The comment expresses opposition to the proposed Fungicide Strategy due to concerns over confusing terminology, high implementation costs, potential for increased plant disease, and potential impacts on crop yields.