Minor Crop Farmer Alliance Issues Letter to EPA

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The Minor Crop Farmer Alliance (MCFA), an alliance of national and regional organizations, is concerned about the U.S. Environmental Protection Agency’s (EPA) draft Herbicide Strategy Framework (HSF).

Letter to EPA

The alliance recently expressed its concerns in a letter to the EPA.

“If finalized as proposed, the approach reflected in the draft HSF will likely result in significant burdens for growers throughout the country because of having to address additional restrictions, including in some cases, being able to use the herbicide tools they need to address their weed problems because of their inability to feasibly reach the necessary mitigation point totals required by the draft HSF,” the letter stated.

The EPA released the draft Herbicide Strategy in July for public comment, a major milestone in the agency’s work to protect federally endangered and threatened (listed) species from conventional agricultural herbicides. In the press release, the Strategy describes proposed early mitigations for more than 900 listed species and designated critical habitats to reduce potential impacts from the agricultural use of these herbicides while helping to ensure the continued availability of these important pesticide tools.

Letter to EPA

The alliance stated in the letter that the draft HSF is “precautionary based,” and the agency is “overestimating the potential herbicide residue exposure to listed species.”

“As the agency has repeatedly been advised, many growers, particularly specialty crop growers, will not be able to adopt the listed mitigation measures. Significant impacts on their operations will occur,” the letter added. “The potential mitigations will affect not only the potential productivity and profitability of affected growers’ operations but also potential land values. Without adequate access to herbicides, growers must resort to increasing the workforce to control weeds.”

However, that is not a feasible option. Labor costs increased in 2023 and account for almost 40% of total cash expenses, according to the alliance. Specialty crop producers have the highest labor cost as a portion of their cash expenses.

“The agency needs to analyze what those impacts may be before proceeding in requiring additional ESA mitigation restrictions on herbicide labels,” the letter stated.

The MCFA is composed of national and regional organizations and individuals representing growers, shippers, packers, handlers and processors of various commodities, including food, fiber, turfgrass, nursery and landscape crops. The group’s farmers produce more than 500 types of fruit, vegetables and other specialty crops.

The Florida Fruit and Vegetable Association encourages its members that if they have any questions to contact Vice President of Science and Regulatory Affairs Mike Aerts.

Click here to read the letter.

Source: EPA