The Minor Crop Farmer Alliance (MCFA) recently submitted comments to the Environmental Protection Agency (EPA) regarding EPA’s Draft Endangered Species Act Fungicide Strategy.
The MCFA is a national coalition that represents growers, shippers and processors of specialty crops to advocate for science-based government pesticide and regulatory policies.
The letter to EPA acknowledged improvements over previous endangered species proposals. At the same time, it urged additional refinements to ensure growers can continue to effectively manage crop diseases.
MCFA noted that fungicides are essential tools for specialty crop production and cautioned that some proposed restrictions could limit growers’ ability to use products when they are most needed.
The alliance called for more realistic risk-assessment modeling, greater recognition of drift-reduction technologies, additional flexibility for airblast applications and continued support for fungicide-treated seeds. The alliance also emphasized the need to refine overbroad pesticide use limitation areas (PULAs) and provide robust grower education and compliance resources as the strategy is implemented.
CITRUS-SPECIFIC ISSUE
MCFA specifically addressed an issue impacting citrus growers: spray drift buffers, particularly for growers using airblast delivery systems.
“It is believed the underlying drift modeling assumptions regarding airblast applications the agency is using are not reflective of many applications particularly for orchard crops,” MCFA wrote. “The default scenario for orchard airblast applications the agency apparently relies on is a sparse canopy that reflects young and/or dormant trees. This is not representative of the conditions for some orchard crops, such as citrus, which essentially are evergreen. Dense foliage is always present when a pesticide is applied. As such, the model’s assumption results in a very conservative and unrealistic assessment of the potential for drift.”
SUMMARY STATEMENT
“In summary, while representing significant improvement on the agency’s prior strategies, the draft strategy still has the potential to negatively affect growers who use fungicides and additional refinements are needed,” the MCFA letter concluded. “The agency has a responsibility to conduct the appropriate analysis based on the best available scientific and commercial information to determine whether additional labeling mitigation measures are needed regarding the use of fungicides, i.e., whether such measures are necessary to assure that the pesticide use is not likely to jeopardize the existence of listed species or adversely modify its critical habitat, i.e., population directed impacts. While this is clearly a difficult and time-consuming task, once conducted it can lead to a program that is more rationally based.”
The letter was signed by Michael J. Aerts, chair of the MCFA Technical Committee. Aerts is vice president of science and regulatory affairs for the Florida Fruit & Vegetable Association.
Source: MCFA
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