CropLife America Stresses Need for Balanced Approach in EPA's Final Herbicide Strategy

ARLINGTON, VA – This week, CropLife America (CLA) sent a letter to the U.S. Environmental Protection Agency (EPA) addressing the Office of Pesticide Program’s April 2024 Update on the Agency’s Draft Herbicide Strategy. This update is part of EPA’s framework to meet its obligations under the Endangered Species Act (ESA). CLA’s letter lauds the Agency’s issuance of the Draft Herbicide Strategy and the extent to which it reflects significant input from interested stakeholders. Additionally, the letter offers recommendations on how the Draft Herbicide Strategy can be successfully finalized and implemented.  

CLA emphasizes the necessity of pesticide use with the importance of protecting endangered species and their habitats, urging EPA to take realistic farming practices into consideration. Measures such as updating spray drift calculations for modern agricultural processes to add realism to application assumptions through geo-spatial information, crop layer, and usage data will help ensure EPA’s proposed mitigations are realistic and protect intended species as well as allow farmers to do their jobs.

“We appreciate the opportunity to provide input on measures that will impact the entire agricultural community. Understanding the needs and demands of our nation’s growers is imperative to the success of the ESA, and EPA continuing to provide opportunities for stakeholder feedback is vital. Any mitigations put in place will only work if real-world implications of how we farm are considered,” said Alexandra Dunn, CLA president and CEO. “Our comments are aimed at helping ensure that the EPA's plan is both practical and scientifically sound.”

Other key topics addressed in the letter include: 

• Overly conservative assumptions will drive unworkable mitigations with no environmental benefit for listed species when making refinements to the risk assessment.

• Greater flexibility for growers and applicators with recognition of ongoing conditions and practices through the geography and topography of their farms, their compliance with state or local regulation, best practices or conservation programs, etc.

• Clarity and certainty to maintain efficiency and timeliness for new product registrations.

• Expanded public engagement to help identify issues and solutions that will aid in successful implementation of the EPA ESA Workplan.

CLA looks forward to continuing to work with EPA and other stakeholders as there are developments. EPA’s Herbicide Strategy is expected to be released to the public at the end of August 2024.