NAAA Secures Further Benefits for Aerial Applicators in EPA’s Final Insecticide Strategy

The insecticide strategy is the latest document from EPA focused on protecting endangered species and critical habitat covered by the Endangered Species Act (ESA). It follows the herbicide strategy, released in August of 2024. The herbicide strategy focused on protecting endangered species, primarily plants, from herbicide applications. The insecticide strategy has a similar goal – protecting endangered invertebrates, and in some cases other endangered species that rely on them, from potential harm caused by insecticide applications.

The proposed insecticide strategy, released in September of 2024, was mostly favorable for aerial applications. All proposed buffers were downwind only, meaning no buffer zone is needed if the wind is blowing away from a protected area. In addition, EPA finally acknowledged that the Tier 3 AgDRIFT model with more modern assumptions is more accurate for estimating drift from aerial applications. 

In March of this year EPA released the final insecticide strategy, which had even more victories for the aerial application industry. Based on comments from NAAA, EPA reduced the maximum possible downwind buffer distance for aerial applications from 500 feet to 400 feet. In addition, also based on comments from NAAA, EPA approved boom shutoffs to 50% of wingspan or rotor diameter as a mitigation option to reduce the distance of downwind buffer zones for aerial applications. Use of a 50% boom will reduce the required distance of a downwind buffer by 65% in winds less than 10 mph, and by 50% for winds 10 to 15 mph.

Finally, EPA increased the percentage that downwind buffer zones that can be reduced by using larger droplet sizes, once again based on comments submitted by NAAA. The reduction in buffer distance with the use of a coarse droplet spectrum increased from a 20% buffer zone reduction to a 40% reduction; the buffer reduction for a very coarse droplet spectrum increased from a 40% reduction to a 60% reduction. Since all mitigation measures are cumulative, use of a very coarse droplet size and a 50% boom shutoff in winds from 10 to 15 mph would mean the downwind buffer zone would be completely eliminated. 

Protecting the aerial application of pesticides from overly restrictive regulations is but one of many benefits provided by NAAA.