ARA Weighs In on EPA's Draft Fungicide Strategy

ARA has submitted comments to EPA on its Draft Fungicide Strategy (Docket No. EPA-HQ-OPP-2026-2973), which would add new mitigation requirements to protect federally listed species from fungicide exposure. ARA supports the goal but pushed EPA to keep it workable in the field:

•    Don't layer fungicide rules on top of herbicide/insecticide requirements without clear guidance on tank mixes.
•    Credit existing conservation practices — not just narrow tile-drainage criteria — toward runoff/erosion requirements.
•    Avoid rate-reduction mitigation that could undercut resistance management.
•    Make sure timing restrictions reflect real disease-pressure windows.
•    Extend drift-reducing adjuvant credit to aerial applications.
•    Consolidate compliance across EPA's separate herbicide, insecticide, and fungicide strategies, and give retailers and applicators a full season's lead time before new rules are enforced.