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.
The Weed Science Societies also present the results of a survey of weed scientists from across the country that looked at the 13 crop scenarios for pesticide runoff and erosion mitigation points that the EPA provided, plus 2 additional crop scenarios. Alarmingly, only 2 of the 15 crop production scenarios, or 13%, could obtain the nine runoff/erosion mitigation points considered necessary to maintain existing weed control practices. We provide additional information on conservation specialists and programs in different states as well as a rationale for why EPA should create a database of the mitigation points needed by crop, pesticide use limitation area (PULA), and herbicide. We provide suggestions to enhance “Bulletins Live Two!” as well as a list of topics in dire need of research funding so we can best help protect T&E species and their critical habitat. Finally, we have provided a list of suggested education and training activities to successfully launch the ESA mitigation practices for pesticides.