In Comments to EPA, Secretary Naig Raises Concerns With Endangered Species Act Herbicide Strategy

DES MOINES, Iowa (Oct. 23, 2023) – Iowa Secretary of Agriculture Mike Naig submitted comments to the U.S. Environmental Protection Agency (EPA) raising serious concerns about its draft Endangered Species Act draft herbicide strategy.

Given Iowa’s national leadership in crop production and the importance of agriculture in driving our state’s economy, Secretary Naig submitted the written comments from the perspective of Iowa farmers and the Iowa agriculture community, and as a partner with EPA in the regulation of pesticide use in the State of Iowa.

In the letter, Secretary Naig focuses his comments on areas where the EPA strategy will have an adverse impact on food production, conservation and the economy:

• While we appreciate EPA’s efforts to comply with the Endangered Species Act while still allowing farmers access to much needed crop protection tools, the proposed draft strategy for herbicides is overly complex. The draft strategy would be incredibly burdensome to farmers and pesticide applicators.
• The strategy of mandating conservation practices, as part of the mitigation menu, to be granted the privilege to use certain products threatens the interest and participation in our conservation programs, which are voluntary and non-regulatory. We do not want to lose momentum and progress.
• EPA must consider the economic impact that the proposed strategy will have on farmers, agribusinesses, and states. EPA should conduct a thorough and exhaustive economic analysis to better understand how this decision will impact farmers, pesticide applicators and regulatory officials tasked with enforcing the changes.
• EPA should take its time developing a final strategy and not rush through the process. EPA must be thorough in listening to and understanding the challenges and concerns of farmers and the agriculture community and commit to finding balanced and workable solutions.

“Iowa farmers have proven time and again that we can be productive while also setting conservation records, but this burdensome and confusing strategy jeopardizes both,” said Secretary Naig. “I am hopeful that EPA will carefully review stakeholder feedback, address the concerns of farmers and amend its strategy because we cannot impair our conservation momentum or limit farmers from using the tools they need to be productive.”

The full letter, which was submitted to EPA via Regulations.gov, can be found here.