CLA submitted comments to the Environmental Protection Agency (EPA) on the draft insecticide strategy, part of EPA’s implementation of its Endangered Species Act (ESA) Workplan. CLA's comments express support for the flexibility of EPA’s proposed ESA mitigations, while raising concerns about overly conservative risk assessments. They suggested several refinements to the draft strategy, focusing on improving exposure modeling, further increasing mitigation flexibility, and incorporating more data from higher-tier studies and population models. The comments also address specific issues related to spray drift, runoff, and the determination of mitigation levels.

Read the full comments here.