The Weed Science Societies suggest nine additional ways to mitigate the impact of herbicides on listed species due to spray drift, which includes decreased buffers for ultra-coarse droplets, additional types of vegetation to intercept spray droplets and grower education. We also suggest six additional ways to mitigate herbicide runoff and erosion, which also includes grower education, more specific terminology for agricultural vs specialty crops as well as assigning more compensatory mitigation points for fields with subsurface drainage or cover crop practices. Most importantly, the Weed Science Societies want to stress that grower education will be the most effective way to implement EPA’s Herbicide Strategy. We recommend a minimum of a 3-5 year phase-in period for the herbicide strategy ESA mitigation practices, which corresponds to the 3-5 year interval that pesticide applicators must be recertified.
