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Pesticide Labels, Endangered Species & What Growers Need to Know · Conservation Stories

• 0:00
  Speaker A: Foreign.
• 0:09
  Speaker B: Sims here again with another episode of Conservation Stories. Conservation Stories, as you know, is a put on a production by the Sand Hill Area Research Association, Sarah, as we like to call it. And we have another return guest with us today, and that can be Leah Doozy. And Leah was here earlier and we talked about pesticides, and it was actually wildly popular on YouTube. So we obviously had other things to discuss, which normally happens when we have guests on. So I'm so glad that you're back and I would love to hear what's going on. Let's give people a reminder, Leah, of who you are, who you work with, what you do, and. And then we'll roll into talking about some endangered species.
• 1:00
  Speaker A: That sounds great. Thank you. It's always a pleasure. It's great to be back. I'm Leah Doozy. I'm a principal consultant with Compliance Services International. We're an environmental and regulatory consulting company that works out of our. We're based out of Lakewood, Washington, but we also have an office in Scotland and we're kind of scattered across the United States. I am lucky to call Auburn, Alabama, home. So I am in the Southeast. Beautiful, which is where I've called home for a long time now. Most of my work is in the space of where pesticides and endangered species intersect. So working with pesticide companies to make sure that their labels are addressing the regulations that EPA has put forth as it relates to meeting their obligation under the Endangered Species Act. But I'm also an economist, which is sort of a strange, a strange thing to be in this space. And so I do a little bit of economics work as well.
• 1:56
  Speaker B: So. Well, I think it's actually, it's a great crossover because so much of the, the, you know, regulations can impact your, your bottom line. It really can.
• 2:11
  Speaker A: Well, and growers are, across the country are faced with really tight margins right now that the USDA AG Outlook is going on this week, and that's definitely a topic of conversation is what do, what did those, what do margins look like for growers going into this growing season? And so I think that how people address their expenses, which is right at the forefront of their mind. So if there's additional requirements to use products, use pesticides, then, and it's going to cost them additional dollars, then that's something that they're concerned with.
• 2:42
  Speaker B: Yeah, absolutely. Absolutely. So I'm excited. You mentioned while ago that you're gonna be at Commodity Classic, and we will be too excited. We'll be over there at the old NASA booth pretending we know something about Space.
• 2:55
  Speaker A: Well, I always like to come by and get the, the posters that you have at the NASA booth because they always, they're always a hit with my children.
• 3:04
  Speaker B: The swag is really cool at that base. Yes, it really, it's really fun. Last year they had some books. I brought a book home for my nieces and nephews. So fun. So fun. Really cool. Okay, so let's. There have been some changes recently and I think we, I looked back, we, I think we recorded probably early summer.
• 3:32
  Speaker A: Okay. Yep.
• 3:34
  Speaker B: Last year. And so we met and visited in April, so it was probably even maybe May ish when we actually recorded. But lots of changes have happened and even more just recently.
• 3:49
  Speaker A: Well, yeah, so we. EPA has been very busy over the last few months and they at the end of last year, so they finalized what they call their herbicide strategy, their insecticide strategy and their rodenticide strategy. And that's what they're now applying to pesticide labels that are being registered. So for people who are looking at the products that they're going to be using coming out of this for this next growing season, they may, especially for new products, they may start to see some different information and requirements on the labels than they have seen historically. And does this happen at the exchange?
• 4:27
  Speaker B: Does this, sorry, does this happen at the. Every time there's an administration change?
• 4:33
  Speaker A: It doesn't. No. This has been, this has actually been going on since 2022. Yeah. So this is just a continuation of what EPA was working through and a lot of it is driven by litigation. So there was a large mega suit that a decision came out in 23. So that's really driving. A lot of this is EPA's. They have to meet their obligations under the Endangered Species Act. And that is because registering pesticides, like I think I mentioned before, is a federal action. So because it's a federal action, that means EPA is obligated under the Endangered Species act to consult with Fish and Wildlife and the NOAA Marines Fisheries on any decision they make. So this is a continuation that started really in 22 and it's just kept moving because they have to meet these court, court appoint, court deadlines. Right? Yeah.
• 5:31
  Speaker B: So as, so I wonder if, like, as the administration changed, like those people have stayed. I mean, as much as we've had Doge go through, like some of those people left and other people have come in or like if that's impacted the final outcome.
• 5:48
  Speaker A: I don't think it's impacted the final outcome because the strategies, the strategies themselves had been in the works. So how they were going to register herbicides and how they were going to register insecticides. I think it probably impacted the speed. We did see a slowdown in some of the decisions that were coming out, but I think that things have continued to move, which is great. It's great for growers so they have access to the products that they need. But we have seen, we've seen some continue. It's just kind of continuing.
• 6:21
  Speaker B: That's nice to know. It's nice to know that there's some, some continuity even across, you know, as administrations change. That's good, because otherwise it's like you just never know what, what's, you know, gonna happen one year to the next or four years to the next.
• 6:36
  Speaker A: I think the workload on individuals, because there has been a reduction in force. And so I think the workload on people at EPA is. The people who are still there is heavy, but they are meeting, they are trying to meet their deadlines, which I appreciate.
• 6:51
  Speaker B: Yeah, that's cool. That's cool. So we earlier were talking about, like, what, what to tackle today in talking about things. So let's go back and revisit that with the, with people listening in now.
• 7:09
  Speaker A: Yeah, absolutely. So if you're, if, if the person listening is an, is a person that works with growers, I think that the best thing to do. And this is. We were at the national association of Independent Crop Consultants, or naicc, a couple of weeks ago, and so we did a lot of talking to consultants who work with growers, and it's really understanding what's coming. So you might not be using, say, Liberty Ultra, which has gone through the process, or some of the other products that have gone through this process and now have these mitigations on the labels, but knowing what they are. So go ahead, read those labels. Even if you don't think that your growers are going to use them, read those labels. Understand the changes. Understand what EPA is talking about when they talk about runoff and erosion mitigation points. Right. If you don't know what that means, ask the questions. There's a lot of resources out there from different organizations that are really working to help growers, applicators, crop consultants, understand that, like, that's one of the things that's really going to be highlighted at Commodity Classic next week. There's going to be different information at booths throughout the, throughout the conference about different parts of pesticide labels. So going to meetings, talking to people, it's in the popular press, so there are articles about it that have been coming out, I think that we've really seen it uptick in the information that's out there about the process and about the changes that we're going to start seeing on pesticide labels that are going to be on the shelf come spring with spring planting.
• 8:46
  Speaker B: So are these pretty major changes? What kind of changes are we talking about?
• 8:50
  Speaker A: So the first. So it depends on the product. So it's broken down into two different kind of components, three different components. The first is spray drift. And so I think a lot of growers are used to having buffers to. From sensitive areas. But now there's just different discussions about it. So there's ways that you can reduce those buffers. So if you're using new technology, say you're using new nozzles that have a coarse droplet size, or you're using a hooded sprayer, or you've invested in windbreaks around sensitive areas, you can reduce that buffer. So instead of having to have say a 200 foot buffer, maybe you can reduce that buffer that would include a drift reducing agent. So using an additive to those products to keep them from moving. So that's kind of the first component is drift. And I think a lot of growers and applicators in particular are very comfortable in that space. Right. They understand drift. Right. That's it's not new. They know nobody wants their product to leave their land because that's the losing.
• 9:52
  Speaker B: So. Right.
• 9:53
  Speaker A: I think that's, that's pretty standard. It's just a little bit different language. And then the biggest component that's new is runoff and erosion mitigation points. And so that's trying to get at how you manage your land, how you're applying the product on your land to keep your soil from moving. Right. So whether that's through water erosion or through, you know, moving off your field. So that would be things that we're familiar with like cover crops, conservation, tillage. So EPA basically based on the, the product, they'll assign a number of points. So it might be a three point product. It's not going to be any more than nine points. That would be the max. But products are going to have different points. And then they point you to what's called the EPA mitigation menu. And it gives you, they have tools to help you figure it out. It gives you a number of points. It gives you different activities that you can have, you can identify that you've already been doing to get to those points or maybe you might need to do more. And so for. I always like to use my family as an example, my family farms in Georgia, probably a little bit different than all of Texas, but we do have steamer land. We have highly erodible land. So part of the points are based on where you're located. So if you're located in a, in a county that doesn't have a huge runoff issue, you would get some, what they call mitigation relief points. So you may, that's. I think of it as your baseline. So you may start off at say three points, let's just say, or two points. So my family farms in a county where we're going to start off at two points.
• 11:33
  Speaker B: Okay.
• 11:33
  Speaker A: And then you add to that. So we look, we're already doing no till, so that would be more points. We're already doing cover crops, so that would be more points. So it's really based on how you're managing your operation of being able to get to those points.
• 11:47
  Speaker B: And each label will have a certain number and you have to get to that number. But when you're using it, it's like, okay, this is a number 12. Do you subit. Nine is probably the.
• 11:56
  Speaker A: Nine is the max.
• 11:57
  Speaker B: Okay, so nine is the max. So I'm using something that's a nine and. And I've started at a four. I've got to do five more things, basically.
• 12:07
  Speaker A: Yeah, they're all, all the mitigation practices are different levels of points. Right. So you might have like no tail, for example, would be three points. So that would be a three point practice. So, okay. It just depends. And not every product's going to have points. It really depends on. Okay, is. Is run. You know, we look, it seems like
• 12:26
  Speaker B: a simple, like a. This seems kind of smart. I don't know.
• 12:30
  Speaker A: That's. That's the approach that EPA is taking. And so it. Not every product will have points. Like if it doesn't. If runoff and erosion is not a route of exposure, that's a concern, then it wouldn't have those runoff points. So like both with drift and runoff. That's based on. Is. Does this is the potential for exposure from drift?
• 12:52
  Speaker B: Yes.
• 12:52
  Speaker A: Or runoff or a combination of both. So you could have spray drift buffers and runoff points on the same label.
• 12:59
  Speaker B: So.
• 12:59
  Speaker A: But it is product specific.
• 13:01
  Speaker B: Okay. And so, and so the, the drift also has a point system.
• 13:06
  Speaker A: No, it's. No, it's just a. It's a. It's a foot. Like. Okay, there are different. Different, different. I'm sorry, I'm stuttering over myself. Different distances. So it could be.
• 13:17
  Speaker B: Okay, okay, okay.
• 13:18
  Speaker A: So it could be a 10 foot buffer or a 30 foot buffer or 300 foot buffer.
• 13:23
  Speaker B: Right, right.
• 13:24
  Speaker A: So it just depends.
• 13:25
  Speaker B: Yeah.
• 13:25
  Speaker A: And then the third component is what we call geographically specific mitigations. And those are. There will be a statement on the label that tells you to go to Bulletins live too. And so it's a website that EPA has that it's been there for a long time because other previous products had geographically specific mitigations. And so you can go there, you zoom into your farm, you choose your product and you see if you have any additional mitigations that you might have to do above what's on the label to protect the species in that geographic area. Yep.
• 14:05
  Speaker B: And that's been there. That's. That's really interesting. So. Wow.
• 14:10
  Speaker A: I think the first ones, the first ones that were out there for. We call that. They're called Pesticide Use Limitation areas or people will say Pulas or Pulaski, but it's Pesticide Use Limitation Areas through bulletins Live to or blt. And I think the first ones to show up were. Were some rodenticides. That's when they first started using blt. It is a web app now. But at some point that's why it's BL Bulletins Live too. Like TW O is the second version. So there were paper bulletins to begin with, but now it's all online. So there have been the Pacific Northwest, California, they've had pesticide Use limitation areas specifically related to the salmon for a very long time. Like this isn't.
• 14:56
  Speaker B: Yeah.
• 14:56
  Speaker A: Yes. So this is, this is new. I think this is new to the central United States.
• 15:02
  Speaker B: Yes.
• 15:02
  Speaker A: It's not new to the coast. Right. They have been aware. Yeah.
• 15:07
  Speaker B: Yeah. Because they're the first that really. The first that were impacted and. And I guess the impact is felt faster there.
• 15:16
  Speaker A: Yes, yes. Yeah. They, they. And that's where. So they have a different. They have some different challenges, I would say, related to application and how they have to access EPA's documents and they have to look at both their. They have the pest. The bullet is live table is extremely important because they have a lot of pesticide use limitation areas and a number of products that reference that. So we expect to see the language to go to BLT on every outdoor use label. There may be some exceptions, but for the most part, almost whether or not there's a bulletin or not, whether or not there is a Pesticide Use limitation area, EPA wants people to go and check. So you can check you. This is. And this is really important. I think you ask what People can do, you can check six months in advance of application. So up to six months in advance. So you could think about what you're going to apply six months from now. You could go on and look that up right now, see if you have a pesticide use limitation area. I would save that document so that you can show, look, you can download it and then you're good for whatever that application is that you were going to do about product.
• 16:29
  Speaker B: So it's like I know we, we have pesticide license, pesticide use license and people have tech CEUs. And so just for people to know, like, it's like people aren't just like willy nilly throwing stuff out there.
• 16:43
  Speaker A: Yes. Right.
• 16:44
  Speaker B: And so, so farmers really have to be, they have to be educated and know how, trained how to use it and all kinds of pesticides and stuff. And so this is just part of that. Yes, they were ever audited. Is that the right word?
• 17:00
  Speaker A: Yeah, and a lot of that depends on, you know, EPA does. The EPA sets the regulation. Right. Like they're the ones who register that product. But pesticide labels are implemented, enforced at the state level. Right. So EPA is not the one enforcing those pesticide labels. That is done by the state lead agency. So in Texas, it's probably your Texas Department of Agriculture. So that's done by that state.
• 17:24
  Speaker B: That's who license. That's who. That's who the licenses come from.
• 17:27
  Speaker A: Yeah, yeah. And so those would be the people that would be verifying that pesticide applicators are, are meeting those requirements on the label. And that's been true forever. Right. Like that's ever since they had licensing. And so that's how it's done prior to this strategy. And yeah, so it's just this is people ask that question all the time like how is this going to be enforced? And it's like, well, it's going to be enforced how pesticide labels have always been enforced in your state. So this is on those state lead agencies to determine what kind of documentation growers need to keep, if any and then how they, how they enforce those labels.
• 18:06
  Speaker B: So and we may, I don't remember if we talked about this in the last podcast or not, if we have slept since then. But so to me part of drift is that's not within control of a farmer's hand is volatization. Yeah, like farmers really can't prevent that.
• 18:28
  Speaker A: They can depending on when they apply. So there are some there, especially on products that maybe have some issues with volatilization. There are some strategies that growers can use based on temperature, based on, you know, at nighttime, there's the risk of volatization. So there are best management strategies and you're going to see those on labels where you have volatization concerns or exposure through volatization is some of those best management practices that growers can do to help. There's new products that can be added called bras that help to reduce that volatization risk. So there are definitely best management. That is not my area of expertise, but I do know there are, there are, there are best management practices. And that is going to be showing up on labels where you have those validation issues.
• 19:20
  Speaker B: Okay, well, I know and I've seen some, some reports of, you know, some of those volatilization, some of those chemicals actually, you know, being in rainwater in our region, you know, and so I think it's important for people to, to recognize, you know, that it, you know, it really is, it does make a difference.
• 19:42
  Speaker A: Yes. Yeah. And I think those, that knowing what those best management practices are and applying them in a way that, and I think that's true for any use of products, but that's also true for fertilizer. It should be true for the people who use pesticides and fertilizers in their yard.
• 19:58
  Speaker B: In their yard.
• 19:58
  Speaker A: Like, yes, it, it should, it should be exactly applicable to everybody. Is that there are best. That's why the label has label language around, you know, ppe they have label language around when to use the product, when not to use the product. And that is regardless of use site. That doesn't matter if you're a farmer or a homeowner or a golf course.
• 20:21
  Speaker B: Right.
• 20:21
  Speaker A: They all have to meet those. We should be following those labor. They are the law.
• 20:27
  Speaker B: Right. Well, and, and a lot of times, like, I think people don't realize, like they think that pesticide, like the problems are out on the farm when actually they're more concentrated in, in town.
• 20:39
  Speaker A: I think that there's a, there's not as much of an understanding, I think, by the average homeowner, let's say, as there is by a grower, because they are, I am, if I want to go out and spray my poison ivy, I am unlikely to be checked. Right. I don't have to have a license. Nobody's going to come and check me. But for a grower, they do, they do have to have a license. They. Especially if they're using a restricted use pesticide. Rup. Then they definitely have to keep their records. So I think that the, the emphasis on following a label and the what growers and applicators have to go through to keep those records is very different than. And even for golf courses, they are. They have their own set of requirements around their best management practices. But I think for the homeowner space, and I will say if you're using a commercial applicator, like if you have a company come and spray your yard. Yes, they're, they have side license. They, they have to have all of those things. But I would say the average homeowner. Yes, I would be guessing. But my hypothesis is most homeowner owners don't open that. That label on the back of their product to see what PPE they should be wearing and what. How they should be applying that product. They should. I would encourage you. I get my neighbors to do it. But I don't think that most people under. Because they don't understand pesticide regulation. Right. Or registration. Why it's on the back of their product and it's on there to protect themselves and the, and the environment.
• 22:20
  Speaker B: Yeah. Yeah. That is, that's really, really interesting. And I think I didn't know and understand until recently. I was studying some water conservation efforts that are happening in the Snake River. Along the Snake river and there. And then also in, in Utah. There's a lake in Utah where I think. I can't remember. It's what, what river runs and basically ends in this lake in Utah. And the mercury that is in it's. And it's from runoff. I mean, like, you know, and so I guess, you know, most of my life I've gone, you know, like that's not a real deal. But then it's like, oh my goodness, like you can't eat the fish from this certain place because we've, you know, we have this ag. The runoff from these farms. And so they're, they are, you know, identifying those places and, and, and helping farmers convert.
• 23:24
  Speaker A: Yeah.
• 23:25
  Speaker B: To different types of irrigation. They're preventing that runoff. You know what I mean? And so there's great solutions for it. Yeah. I do think it is important to, you know, to be aware that there's labels. The labels aren't there because environmentalists are wackos. I mean, some people are environmentalist. Like some of them are, but, you know, but they're there because there's legit dangers around those things.
• 23:50
  Speaker A: Yeah. EPA has a long. I mean, that's why we have pesticide registration. Right. Is because EPA has a long history now of being able to make sure that those labels are protective. So the growers or whoever, whoever is the end user can still use those products safely, both for themselves, for the humans around them, for the environment, so that they can be. And there are definitely mitigation options to do that. I think, I think irrigation is a great option, a great example because I think there's this idea that runoff isn't that because you irrigate, it's somehow that runoff doesn't happen. And that's just not true. Right. Because you can over irrigate, you can cause erosion with irrigation. Right. Like, whereas with a dry land farmer, you're only going to have erosion if it rains. Right. But with an irrigated farmer, you can over irrigate to the point of saturation and then you are going to have runoff that you are actually causing. And so I think the, the strategies in another part of my life I do work in, I look at irrigation strategies to minimize runoff. And so looking at drop nozzles and using different technologies to determine exactly how much water you need and variable rate irrigation. There is a lot of really great technologies out there, but they also involve capital investment. Right. They say require you to invest in those. And I just, I don't know, I
• 25:13
  Speaker B: can't imagine having enough water to where if it was running off, you wouldn't be like.
• 25:22
  Speaker A: Yeah, I think it's very different in the western U. S than it is in the east, than it is in the eastern u.
• 25:27
  Speaker B: S. Yeah, yeah, yeah, it really is. Yeah. And and for us too, like we run. If something runs off, it's like it's just going to go down the bar ditch by the road. And I mean, it's not going into
• 25:37
  Speaker A: a lake, but it may, because we have watersheds, it can still make it into a body of ground, right?
• 25:43
  Speaker B: Well, it's still gonna get, It'll go into a playa, you, you know, and then it will, you know, but I think it'll be filtered by the time it, you know, I just, I don't. We just don't have that much water.
• 25:54
  Speaker A: It is. It. There's a. I haven't looked it up recently, but there's a website that you used to be able to go to where you could put a raindrop at a certain point and you could see where that raindrop would go, like how it would get to the ocean. And it was really fascinating. I don't, I can't remember the name of it, but it was a really fascinating application where you could, you could see how water moves from the upper midwest all the way down to the gulf or the Pacific or the. Or the, the Atlantic. Right. And so you could see how that water moves. Yeah. Because it's, I mean we want to think that it stops somewhere, but it really doesn't. Right. Like it, if I, if, if we have runoff in Auburn, Alabama, it's going to get to the, to the Gulf. Right. Like it will end up there at some point. And there are like mercury, for example, which isn't really used a lot in agriculture. So most of that's coming from manufacturing and the industrial side of things. But it's all. Those are persistent. Right. Like so those are, those are persistent.
• 26:59
  Speaker B: So is.
• 26:59
  Speaker A: It isn't there?
• 27:00
  Speaker B: But there's something that like causes certain type of algae bloom. The ag run off and then it got converts. Yeah. And then, and then it creates that. It converts, I guess the microbes eat that and it converts to mercury.
• 27:15
  Speaker A: I do not know that I, I
• 27:17
  Speaker B: don't have to look at what I thought. I mean, don't, don't call me.
• 27:22
  Speaker A: No, I won't. But I'm gonna have to look it up.
• 27:24
  Speaker B: So maybe wrong about that, but.
• 27:27
  Speaker A: Well, I listen, I'm all about like looking up something that I haven't heard of.
• 27:31
  Speaker B: But I thought that that was what they were pointing to. The salmon being contaminated was from the, the bloom, the algae bloom that actually then the microbes were eating that. And then of course then they, you know, discharge another chemical.
• 27:50
  Speaker A: Right. And so that is. I am fascinated. I'm going to have.
• 27:54
  Speaker B: I may be wrong, so email me and be like, you were totally wrong,
• 27:58
  Speaker A: but the algae bloom is real. Right. Like we, I mean, we know that what happens, the nitrogen that goes on fields in the upper Midwest makes its way down the Mississippi river and into the Gulf. And then we have algae blooms in the Gulf that are. That hypoxic zone. That's what it, it's. That's what they call it. And so that hypoxic zone is, is. You don't want it. Right. Like it's bad for the fish and the other, the other species in the Gulf. And so the Midwest, the upper Midwest has done a great job. Like Minnesota has a buffer law that you have to have a 60 foot buffer, I think what it is around all your waterways. And so they have really made a concerted effort to really try to reduce that as part of their contribution to trying to reduce that nitrogen. And those are the same practices. Right. So buffer strips, grass buffers, grass waterways, terraces, those are all practices that are also applicable to keeping pesticides where they're meant to be. Right. And so there Is this overlap between managing your nutrients in the water and also managing pesticides that are getting into the water. So it's that overlapping space of conservation practices that nrcs, the Natural Resources Conservation Service, the usda, a lot of your soil and water conservation districts and other groups have been putting in over the years for nutrient management, soil health. That's been a big one with COVID crops and. Right. Those are all things that are also mitigation measures that keep pesticides. So it all overlaps. And I think the more we, the more we talk about the fact that these are just good production practices to be doing, it doesn't matter. It doesn't really matter the reason. If you're doing it for nutrient manager or pest management or it's going to have a benefit to the water, to your terrestrial areas, there's going to be this benefit. And that's what we've been talking a lot about, is that these are concert. The things that are being required as part of pesticides, as part of the pesticide labels are things that a lot of growers are probably already doing because they're trying to address all the resource concerns on their farms.
• 30:11
  Speaker B: So what, as you're talking to growers, what is their, you know, do they. Is there a, like, kind of a preconceived idea about what's happening? And, and, and then are they surprised or are they frustrated with what feels like increased regulation?
• 30:30
  Speaker A: I think it's the initial shock, right. Is that I think change is always hard. Right. And so I think it's the initial shock, I think. And then once they kind of understand. And we've been having this discussion with growers at commodity classic since 22. And so we've really seen a change in understanding and a change in sort of opinion, I guess. And so I think when we first started talking to growers, it was, they were very, they were, they were a little bit worried, right? Not a little bit. Because when, when they first started talking about it, epa, it was a lot. There weren't a lot of options on how to get the points. And I think once EPA got feedback from the agricultural community of, listen, we're doing all of these things and you're not reflecting those, but they have the same benefit. I think that made growers a lot like, understand, okay, there are a lot more options of how we can address this runoff besides the very limited view of it when it first came out.
• 31:31
  Speaker B: Yeah. Because was it, I feel like it was kind of framed as they were going to get rid of all these pesticides. Like you weren't going to be able to use any of them, but that was really not the case. It's just like, no, you use them and you're probably already doing stuff to mitigate and if, you know. Yeah. So it seems like a pretty easy
• 31:49
  Speaker A: way to,
• 31:52
  Speaker B: to like, figure out if you're following. I mean, you know what I mean? Like that, that seems like a pretty simple way to figure out if you're following the.
• 31:58
  Speaker A: Yeah. I think the biggest challenge, and this is a challenge for a lot of growers, is that it is on a field by field basis. So it's not for your whole farm. It's field by field. So every field has to be meeting those points you. And this has been true for buffers forever. Every field has to have those buffers. And so it's the management part of it of, okay, we have to figure out the points for every single field. And that feels overwhelming when you could have 250, 300 fields, which is very common where I'm from, because we have small fields. Right. When you're faced with. And you also have to think about it, like, especially in the, in the western US where you have a lot of crops and you may be rotating crops every. Every six months or something, when you have your veggie crops, that is another. So I think it's not necessarily the requirements per se, but it's the complicating part of agriculture. Right. So in the Pacific Northwest, where you may move your potato, your potatoes can't grow in the same place every five, like you have to move them around every five years, I think somewhere in there. So you're going to be moving it. And it may not be land you control, it may be land that you rent to be able to get it back to the land that you own. So it's in those relationships with your renters and your landlords. So it's really the management of doing this that I think complicates it. And I think that where growers are. Yeah, where really it's not necessarily the mitigations themselves, but it's how do you. And this is true, I think, for pesticide labels in general and probably nutrient management is how do you manage it in the complex system that agriculture is in the United States, where we're not. Most growers outside of certain areas are not growing monocultures. Right. They're not growing one crop all the time. They're. I mean, that's not true for, you know, if you have tree crops. Right. So your, your orchards, your vineyards, that's going to stay put.
• 34:10
  Speaker B: Right.
• 34:11
  Speaker A: But for crops where you're having to move them around, I mean, my own family grows seven crops a year. So anywhere on the farm we could have seven different crops growing at any one point in time. Right. So how do we manage that?
• 34:25
  Speaker B: Right.
• 34:25
  Speaker A: From a. And what happens, I mean, this is the other thing. What happens if all of a sudden you have a pest outbreak that you've never had before, you go and get the product and it's a nine point product, but every other product that you've used is only a six point product. Right. So you've never. And so that's why we encourage people. Okay, just see if you can get, see if you can get to nine points on all your fields. Right. So make the effort upfront. Just try to get to nine points on all your fields. That way you're covered, you have it done. It's going to stay the same crap.
• 34:57
  Speaker B: So yeah. So man. So that can see because you're like, oh, I need to use this. But now I got to come up with a way to get three more points and it's like too late in the year for me to do any of them.
• 35:12
  Speaker A: Yeah.
• 35:13
  Speaker B: So I literally can't use this.
• 35:16
  Speaker A: So doing the work up front before you're ever faced with that situation of going ahead and figuring out. And there's ways to simplify it. Right. So for my family, because I know what our production systems are, I know where we have what it looks like, I can go ahead and say we have this production system. It doesn't matter what field I'm on, we're going to be growing it the same way. It's worth this many points. And I can go, I group my field. So I say I'm going to group all my non irrigated fields together. I'm going to group all my fields where I'm growing corn this year together, I try to come up with a way to say I want to go from 250 fields down to four production systems.
• 36:01
  Speaker B: So you said 250 fields.
• 36:03
  Speaker A: I don't know how many we have, but we have a lot. Yeah, yeah, we have a lot. But I did, I did work with a grower who had almost 300 fields. Individual fields. Yep. It's a lot because they. And they're not big. Some of them might only be 5 acres. Right. Some of them might be 35 acres. Some of them. But we're not, you know, the Southeast is not the Midwest or here.
• 36:26
  Speaker B: Yeah, yeah. I'm just like, I mean, that's kind of what it was in Poland. It was like, you know, there's like these 20 acre. And they rent, but they might, they'll have a different landlord for every 20 acres too.
• 36:36
  Speaker A: It is, it is possible. Yeah. And so, and we have such a high, not just in, just in the United States in general, we have a very high percentage of rented land that growers manage. And so, and then I think a conversation I had with aerial applicators is that, you know, they can handle the buffers, that's not a problem. But they need to know what the growers are doing on the ground because they can't.
• 37:00
  Speaker B: If, if the product requires nine points, they gotta know.
• 37:04
  Speaker A: They need to know if it requires points. So those are conversations that I think aerial applicators are already starting to have. I know I worked with some in Wisconsin. They're already starting to have those conversations with the people they fly with. So I think that there's a lot of tools out there. EPA's put out some tools. They have an Excel spreadsheet, they have a tool called Palm P A L M on their website that growers can go ahead and start if, if you know you're not using a product that's out there. If it's, if you, if you look at the label and it doesn't have mitigation points on it or it doesn't have the new spray drift language, if it, if it's not come out in the last, since like late 2024, then you can look at those and you can say, okay, I don't, I know I don't have these points, but I could go ahead and go into this tool and see how many points I could get for, say, let's say you're growing cotton and sorghum, right. And you do a winter fallow or you do wheat in the winter, whatever that looks like, you could go ahead and say, okay, if this is my system and I know that I'm doing no till, or I know that I'm doing that double crop, which we can do in the South. Right, right. In some parts of Texas, some parts might be too dry to do that double crop, but you can go ahead and set up that production system and you can go ahead and figure out those points based on the counties for your farming. So having those upfront conversations, yeah, that's
• 38:30
  Speaker B: just another, you know, maybe even multiple days of, of of research and management. But once it's done, it's, it's done, you know.
• 38:40
  Speaker A: Yep.
• 38:41
  Speaker B: Yeah, that's really interesting. So, man, that's complicated. And I can see now why they would say you won't be able to use certain. You're just not gonna be this. Not going to be able to use them anymore. But because they're not actually saying you can't use them, they're saying you can use them. But under these circumstances, which, which they've always have. But it's just a little more in depth now and so just a little different.
• 39:07
  Speaker A: It's just a different conversation. Y.
• 39:09
  Speaker B: Right. Yeah. Interesting. Golly.
• 39:11
  Speaker A: And I think, I mean, you know, there's always been these changes to labels. You know, we had the worker protection standards, there's always been these new things. As we gain more information, as we become more aware there's new, there's always going to be changes. And so I think that because this is not self implementing. Right. It's not like they're going to snap their fingers and this is going to be on every label. It is a slow roll.
• 39:34
  Speaker B: It's going to roll up slowly.
• 39:36
  Speaker A: So growers are going to see it. It's going to be first on new active ingredients. So not necessarily new products. So not necessarily products that are already registered. Like products that have active ingredients that are already registered, but it's going to be on new active ingredients. Yeah. So things that are just coming out. That's where it's going to, that's where it is showing up first would be products that are new to the shelf. Okay, so act at. And let me rephrase that. Active ingredients that are new to the shelf.
• 40:06
  Speaker B: Okay. Okay. So the, so the, the, the tool that EPA has, is it something where like a farmer could. I don't know. I just keep thinking with AI and all the things, like it'd be great to have like some kind of app that's like you implement the practice that you've done and then if you put in like here's what I'm gonna do, like something that's. Is it pretty simple and easy to like keep up with?
• 40:32
  Speaker A: And it is, they have, they have an Excel spreadsheet. They also have a PDF that you can just print out and write on. I think they're trying to meet the growers where they are of what's going to work best for them. The Palm tool is a web app. It's not necessarily an app for your phone. Yes, it's, it's a web app. But I do, I think that there are, without naming names, there are groups out there who are working, working on, developing on apps and different software that could be incorporated into your. You know, I think prop consultants are already using a lot of software that can give them information like the soil types in the field, the slope of the field. So I think that. I think that once people dive in and learn about it, then they can. They can find that out.
• 41:17
  Speaker B: Okay, great, man. This has been good. It's been great.
• 41:22
  Speaker A: Yeah, yeah, it's. This has been a great conversation. I appreciate it.
• 41:26
  Speaker B: It always is. And so we'll. I think we should just keep doing them because it's just so much fun
• 41:30
  Speaker A: and I always enjoy talking to you.
• 41:32
  Speaker B: I like. So I will see you probably on the next week. 5th, 24th.
• 41:40
  Speaker A: Yes, I'm. I'm. I'm flying in Monday, so I'm coming in a little bit early. I've got some meetings I have to do. But yes, I will be there. And I can't wait to meet you in person.
• 41:49
  Speaker B: It's gonna be great. It's gonna be great.
• 41:51
  Speaker A: Yes, Absolutely.
• 41:52
  Speaker B: Yep. Okay. Well, friends, thanks for joining us again for another conversation about pesticides, EPA and all the things that you need to know. So remember, even if you are going out to your shed and you're grabbing that weed, be gone. It has a label. You should read it. You should read it. We will see you next time. Thanks, friends.