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ARA Comments on ESA Workplan Update

Feb 14 2023

ARA filed comments to the U.S. Environmental Protection Agency (EPA) Office of Pesticide Programs regarding the Endangered Species Act (ESA) Workplan Update: nontarget species mitigation for registration review and other Federal Insecticide, Fungicide, and Rodenticide (FIFRA) actions. 

ARA agrees that it is important for the EPA to develop a work plan to fully comply with the agency's obligations under the ESA and the FIFRA. However, ARA believes the proposed additional modifications need to be made to the ESA Work Plan to ensure it does not cause severe disruptions to America's ag industry. 

Comments submitted by ARA align with the comments submitted by the Michigan Farm Bureau. View the proposed recommendations within the comments filed by ARA below.