To read OFB's comments in full, please download the PDF above. For a quicker read, below is a summary of each major point the letter highlights.
1. Questionable Habitat Identification
The EPA has designated areas as critical habitats for vulnerable species. These areas, however, are integral to our state's agricultural and recreational vitality. The Oregon Farm Bureau questions the accuracy of these designations, especially when they overlap with land vital for our livelihoods.
2. Impact on Agricultural and Forestry Practices
The proposed restrictions on pest and weed management are alarming. They could severely limit or even prohibit the outdoor use of vital products for agriculture and forestry. This contradicts existing federal plans that recommend certain herbicides for crop protection. We're advocating for a balance between environmental protection and agricultural productivity.
3. Implementation Challenges
The proposal's broad restrictions could inadvertently affect not just farming but also livestock management and public health measures. Compliance complexities and potential legal challenges are concerns that need addressing to avoid unintended consequences for our community's essential activities.
4. Misconceptions about Pesticides
The assumption that all organic-approved pesticides are safe for vulnerable species and all conventional ones are harmful is overly simplistic. Many conventional pesticides have a minimal impact on these species, and some organic options might be harmful. We believe in a nuanced, science-based approach to pesticide regulation.
5. The Call for Practical Collaboration
We are advocating for solutions that consider the insights and needs of all stakeholders, including farmers, landowners, and conservationists. A collaborative approach is vital to develop practical, effective strategies for species protection that also respect the realities of agricultural and forestry operations.
6. The Importance of Oregon's Specialty Seed Industry
Our state is a leading producer of specialty seeds, a sector that could be significantly affected by these proposals. Moreover, the evidence of vulnerable species in these proposed critical habitats is not as clear-cut as presented. Protecting our industry's integrity while contributing to conservation efforts is a priority.