Letter
Dear Chair Murkowski and Ranking Member Merkley:
The National Association of State Departments of Agriculture (NASDA) commends the subcommittee for its work in support of farmers, ranchers, and rural communities. NASDA represents the Commissioners, Secretaries, and Directors of agriculture in all 50 states and 4 territories. NASDA members are co-regulators with the federal government and strong advocates for American agriculture.
As you begin the fiscal year (FY) 2027 appropriations process, NASDA asks you to prioritize the following programs that enhance farmers, ranchers, and rural communities and ensure a safe, affordable, and abundant food supply.
State and Tribal Assistance Grants (STAG)
Pesticide Enforcement: $24,500,000
Pesticide Program Implementation: $13,000,000
These two State and Tribal Assistance Grants provide states with vital cost-share funding to administer their co-regulatory implementation, use, and enforcement pesticide responsibilities as obligated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA). NASDA requests that the Pesticide Enforcement and Pesticide Program Implementation grants are funded at $24,500,000 and $13,000,000, respectively. These level of funding are critical as states must meet substantially increased pesticide enforcement and compliance burdens pertaining to EPA’s Endangered Species Act obligations.
These two STAG grants strengthen and support state lead agencies’ implementation of critical pesticide compliance and enforcement programs. Federal support through these grants facilitates uniformity, efficiency, and fiscal responsibility of inspection activities and of State Certification Plans that ensure restricted use pesticides are applied in accordance to the label. In addition, states’ abilities to conduct certain enforcement activities – such as producer establishment inspections or marketplace inspections – are predicated on the federal authorities provided through these grants. NASDA believes these STAG grants are critical for the uniform, efficient, National Association of State Departments of Agriculture and effective implementation of pesticide regulations as defined under FIFRA. Additionally, STAG funding supports the continued operation of the State FIFRA Issues Research & Evaluation Group (SFIREG), a vital forum for co-regulatory coordination between EPA and state pesticide enforcement agencies on regular and emerging issues.
Office of Pesticide Programs (OPP): $166,000,000
NASDA requests funding for EPA’s Office of Pesticide Programs (OPP) at least at its fully authorized level of $166,000,000, per the Pesticide Registration Improvement Act (PRIA) to ensure timely registration reviews and regulatory workload management. As OPP faces increasingly complex registration and registration review requirements, it is paramount that it receives the resources necessary to meet decision timelines. Adequate resources and support are
especially important in light of potential reorganization decisions in EPA that may place additional personnel in OPP. Since the enactment of PRIA, Congress has intended for industry fees to supplement annual appropriations. PRIA requires the termination of the fee program if a minimum level of appropriations is not provided.
U.S. Fish and Wildlife Service (USFWS)
NASDA supports funding for the U.S. Fish and Wildlife Service (USFWS) at least at its fully authorized level in order to meet its pesticide consultation obligations and to manage its Endangered Species Act (ESA) workloads promptly. The USFWS and the National Marine Fisheries Service (NMFS) have the primary authority to protect threatened and endangered species. The ESA also requires other federal agencies to consult USFWS and NMFS when any
action the agency carries out, funds, or authorizes may affect a species listed as threatened or endangered under the Act or any critical habitat designated for it. Courts have ruled that the process EPA has utilized to meet the consultation requirement is inadequate. This has resulted in the revocation of product registrations and uses. This additional funding would allow for additional full-time employees to be used for pesticide consultations, of which USFWS faces a
significant backlog in its current timeline.
NASDA thanks you for your careful consideration of these requests as you work to fund the programs that enhance farmers and ranchers and ensure a safe, affordable, and abundant food supply. If you have any questions, please contact RJ Karney, Senior Director Public Policy, RJ.Karney@nasda.org.
Sincerely,
Ted McKinney
Chief Executive Officer
NASDA
