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 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.

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 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 Arizona Farm Bureau Federation supports the Draft Fungicide Strategy but emphasizes that mitigation measures must be flexible, practical, and based on science to avoid increasing production costs or food waste. They specifically argue against additional requirements for treated seeds, request clearer definitions for adjuvants, and advocate for streamlined compliance and continued stakeholder engagement.

The American Sugarbeet Growers Association, the U.S. Beet Sugar Association, and the Beet Sugar Development Foundation oppose the Draft Fungicide Strategy, arguing it is unnecessarily stringent, lacks sufficient grower input, and will impose significant economic burdens on sugarbeet farmers. They request a more science-based, workable approach that includes cost-benefit analyses, peer reviews, and specific exemptions or refinements for sugarbeet seed production and spray drift mitigations.

The American Farm Bureau Federation supports the EPA's efforts to comply with the Endangered Species Act but urges the agency to prioritize flexibility, practical implementation, and the preservation of access to fungicides. They argue that overly burdensome regulations or worst-case assumptions regarding species exposure could cause significant economic harm to U.S. agriculture and food security.