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Challenges remain the same as what we have discussed in our Using Pesticides Wisely and County Production Meetings over the last couple of years.  The potential for significant in-field buffers between treated areas within fields and potential habitat of an endangered or threatened species residing outside of your field is a huge concern. Secondly, mitigation measures that are being proposed for requirement ensuring the pesticide remains in the field – avoiding pesticide runoff, is also a huge concern.  

Specific topics needed to make scientifically sound regulations addressing in-field buffers and runoff mitigation measures currently include 1) understanding exactly where endangered/threatened species are located, 2) defining exactly where our fields are located relative to the species and their habitats, 3) the use rates of pesticides we apply as compared to the huge rates they assume we apply, 4) the sensitivity of these species to the pesticides we apply, and 5) the need for flexibility when implementing mitigation measures to prevent pesticide runoff (cover crops, terraces, grass waterways, etc.).

Thoughts/Comments that the U.S. EPA may find valuable from a farmer:

  1. Efforts/commitment to pesticide stewardship, making sure pesticides remain in the field.
  2. Importance of pesticides to family farm sustainability.
  3. Pest management and economic impact of having part or all of a field restricted from using a given pesticide.
  4. Impact on conservation tillage, soil health, etc. if herbicides are limited or removed. 
  5. Influence on labor requirements if pesticides were limited or removed.
  6. Commitment to the environment in which farmers live remains healthy.

Please click HERE to submit comments and to view information in regard to the Proposed Herbicide Framework Strategy. The deadline to submit is Sunday, October 22. Please let me know if you have questions.

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