The load of regulatory comments in the second quarter of 2022 although not as heavy as the first quarter was still steady. Below is a summary of the regulatory dockets that AZFB engaged in during the second quarter of 2022.

Environmental Protection Agency – Proposed Interim Decision for Several Pesticides – Iprodione – AZFB’s comments responded to EPA’s proposal to limit all outdoor uses, including agricultural uses, to one application per year. Outreach to those familiar with the products used in Arizona determined that the proposal would not inhibit current practices. 

Food and Drug Administration – Standards for Growing, Harvesting, Packing and Holding Produce for Human Consumption Relating to Agricultural Water – AZFB’s comments are supported and incorporated by reference to those prepared by AFBF. The comments highlighted various areas of the proposal that needed additional clarification and guidance related to the proposed rule that creates a pre-harvest agricultural water assessment, mitigation measures, and other revisions.


Bureau of Land Management – Use of Motorized Vehicles and Aircrafts in the Management of Wild Horses and Burros – AZFB joined a coalition of Western State Farm Bureaus to express collective support for the continued use of motorizes vehicles and aircraft to manage wild horse and burro populations in the West. 


U.S. Fish and Wildlife Services (FWS) – Draft Recovery Plan for the Mexican Wolf, Second Revision – A second round of revisions was made to the Mexican Wolf Recovery Plan in response to a court order directing the FWS to add site-specific management actions to address the threat of human-caused mortality. AZFB’s comments addressed specific management actions impacting livestock producers including outreach efforts and promoting flexibility with conflict avoidance practices.


Environmental Protection Agency – Notice of Intent to Suspend tetrachloroterephthalate (DCPA) – AZFB provided comments to EPA to highlight the important role DCPA plays as an herbicide in the production of certain crops in Arizona including broccoli, cabbage, cauliflower and other Cole crops, as well as onions. AZFB’s comments urged EPA to work cooperatively with the registrant of DCPA, AMVAC, to work through the issues that resulted in the Notice of Intent to Suspend DCPA. 


Environmental Protection Agency – Voluntary Cancellation of Certain Pesticide Registrations (Chlorpyrifos) – AZFB provided comments to EPA urging the agency to refrain from canceling the registration of chlorpyrifos in light of ongoing litigation regarding the retention of food tolerances for this product. 


USDA Agricultural Marketing Service - Preserving Trust Benefits Under the Packers and Stockyards Act – AZFB’s comments supported the comments prepared by AFBF, which noted support for creating a workable and effective livestock dealer trust that would provide recourse for unpaid sellers of livestock in the event of default. 


Securities and Exchange Commission – Enhancement and Standardization of Climate-Related Disclosures for Investors - AZFB’s comments supported AFBF’s technical comments which outlined the ways in which SEC’s proposed rule to enhance and standardize climate-related disclosures for investors should be modified to avoid negative impacts to the agricultural industry. The proposed rule in its current form would be excessively burdensome and costly for most farms to comply with. 


For more information about a specific comment letter, contact Ana Kennedy Otto at