Urge EPA to withdraw its harmful herbicide strategy

October 5, 2023

In an attempt to bring the Environmental Protection Agency's (EPA) pesticide program into compliance with the Endangered Species Act (ESA), the agency recently proposed a draft Endangered Species Act herbicide strategy. The proposed strategy is nothing more than a set of restrictions on agricultural herbicide use for all new and re-registered herbicide registrations moving forward.

While this proposal would apply to most agricultural herbicide users in the lower 48 states, farmers across four pesticide-use limitation areas (PULA) face greater restrictions due to alleged risks to certain endangered species (click here to see PULA map). The entire state of Iowa is located within PULA 4, meaning all farmers will likely be impacted and face heightened compliance burden and costs.

Comments to EPA on this proposal are due by Oct. 20, 2023. As a member of the Iowa Soybean Association, you are invited to share your concerns by electronically signing this letter urging the EPA to withdraw the draft herbicide strategy no later than 10:59 p.m. on Friday, Oct. 20 (use the form below to sign). Only a signer's name, city, and state will be included on the final letter.

In short, EPA’s restrictions and proposed mitigation procedures would be costly and entirely unworkable for Iowa farmers. Here are a handful of examples:

• Requiring herbicide users to attain "points" by adopting certain runoff reduction practices (reduced tillage, cover crops, vegetative filter strips, contour farming, etc.) to use most herbicides (most herbicides could require 6, 9, or more points to use);
• Downwind spray drift buffers as great as 500 feet for aerial application or 200 feet for ground application (these distances could be reduced by using coarser spray droplets or other mitigations);
• Runoff mitigation exemptions can apply for applications more than 1,000 feet from terrestrial or aquatic "habitat" ("habitat" definitions are very broad and few areas are likely to qualify for this exemption) or if you are under a field/site specific runoff conservation plan; and
• If you have subsurface drainage, you cannot comply with runoff reduction practice requirements. All subsurface drainage must be channeled into retention ponds or saturation buffer zones.

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