EPA has opened for public comment its draft Insecticide Strategy (IS), comments for which are due on September 23. EPA intends to use the draft IS to put in place a framework of runoff/erosion, spray drift, and in some cases on-field mitigations to reduce risks to endangered species and their critical habitats, aiming to bring its pesticide program into compliance with the Endangered Species Act. However, many who have reviewed the proposal are concerned with the cost, complexity, and reduced pest management effectiveness it could impose on U.S. agricultural users of insecticides. Attached is a petition-style letter intended for farmers, producers, applicators, and others to sign on to raise their concerns about the draft IS.

ADC Members, please feel free to sign on and share this petition with your growers/applicators/other farmers you know. Ask them if they would like to sign on. The deadline to sign will be Saturday, September 21 at 12:00 PM Eastern. Please encourage individuals to use this link to sign the petition.

View Petition Text Here

Some of the concerns with the draft IS raised in the petition include:

The draft IS is incredibly complex. Producers/applicators

• The draft IS is incredibly complex. Producers/applicators will need to determine their compliance obligations for every field under production, which include factors such as whether a field exists in one or more of ten pesticide user PULAs; runoff potential in counties in which you farm; the slope, soil type, or distance to unmanaged areas; crop type produced; what insecticides are being used and what pests are being treated; application type (foliar, soil, seed treatment, etc.); weather conditions, including humidity, wind speed, and direction; existing runoff/erosion or spray drift mitigations on a field; among other conditions.
• It is likely to be costly for many producers. It would require insecticide users to attain "points" by implementing certain runoff/erosion reduction practices (rate reductions, reduced tillage, cover crops, vegetative filter strips, contour farming, riparian areas, mulching, water retention systems, etc.) to use most insecticides. Many insecticides may require 6 or 9 points to use, depending on the crop produced and geography. These practices could cost growers or landowners hundreds to thousands of dollars per field annually to install and maintain.

• It will likely leave significant crop areas untreated and vulnerable to pests. The draft IS would require downwind spray drift buffers as great as 320 feet for aerial application or 230 feet for ground application (these distances could be reduced by using coarser spray droplets, partially treating a field, installing windbreaks, or other mitigations.) These significant buffers could leave large crop areas untreated. Untreated crops and edge-of-field practices may create pest refuges for reinfesting and damaging treated fields.