CLA Submits Comments on Draft Biological Opinion on the Registration of Enlist One and Enlist Duo

CropLife America (CLA) submitted comments on the Draft Biological Opinion (BiOp) on the Registration of Enlist One and Enlist Duo Pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). BiOps are part of Fish and Wildlife Service’s (FWS) Endangered Species Act (ESA) consultation process and are based on EPA’s biological evaluations. Read the full comments here.

As a representative of developers, manufacturers, formulators, and distributors of pesticides for agriculture and pest management in the United States, CLA appreciates the opportunity to provide comments on the draft BiOp. We recognize the work that goes into such an effort and commend the EPA for the many improvements that have taken place in recent years regarding the ESA process. We also encourage EPA to establish a learning process towards becoming more realistic with their upfront mitigations; engage more with the Services; and continue engagement with registrants, growers, and the agricultural research community on mitigations and credit for existing practices. We intend the comments provided here to assist the EPA in moving towards an efficient and scientifically defensible process that is protective of species and is based on an appropriate risk assessment. We believe that there is a significant opportunity in front of us to collaboratively work towards achieving an efficient ESA process. We would request the Agency to consider the general improvements to the ESA process, and the draft BiOp.