Anonymous public comment

EXECUTIVE SUMMARY: SCIENTIFIC OBJECTION TO REGISTRATION Attached Document: Full Scientific Testimony and Multi-Trophic Impact Analysis (PDF) As a scientist trained at the California Institute of Technology, I am submitting formal scientific testimony strongly objecting to the registration and tolerance establishments for epyrifenacil and diflufenican. The attached PDF document contains peer-reviewed scientific citations from high-impact journals (including Nature, PNAS, and Trends in Ecology & Evolution) showing conclusive evidence that these registrations present unreasonable risks to public health and ecological safety. This summary outlines the critical threats detailed in the attached full report: 1. Accelerated Insect Extinction Framework: The active exposure vectors for epyrifenacil and diflufenican pose immediate, acute hazards to honeybee populations (Apis mellifera), presenting dietary toxicity levels well above lethal thresholds. This chemical scaling directly accelerates global entomofauna collapse and threatens multi-trophic pollinator networks. 2. Multi-Generational Mammalian Toxicity & Oncogenesis: Toxicological profiles link protoporphyrinogen oxidase (PPO) inhibitors like epyrifenacil to multi-generational rodent liver tumors and hematopoietic damage. Furthermore, diflufenican presents marked endocrine-disrupting vectors. These repetitive, low-dose chemical insults correlate with the critical biometric shifts seen in rising early-onset colorectal and renal carcinomas among young adults. 3. Irreversible Soil and Groundwater Degradation: Diflufenican introduces an unacceptable soil half-life (DT₅₀) extending up to 3 years. Peer-reviewed data indicates these persistent residues dismantle the structural soil microbiome, suppress vital functional gene pathways (such as the nifH nitrogen-fixing gene), and yield highly mobile, water-soluble fluorinated PFAS degradates that permanently contaminate groundwater aquifers. 4. Institutional Malfeasance & Suppressed Alternatives: The continuous fast-tracking of ultra-persistent, fluorinated agrochemicals represents an institutional dependency designed for short-term chemical replacement cycles that benefit private investors at the expense of public health. The Agency’s approval process routinely fails to evaluate viable, high-yield agroecological alternatives. Conclusion: The approval of epyrifenacil and diflufenican forces an unmonitored chemical experiment on human biology and the biosphere. The risks presented here are destructive and far-reaching in our society, affecting soil microbes, fungi, plants, insects, fish, birds, amphibians, and people all over the world. Modern chemical agriculture prioritizes investor profit over public health. In this way, we betray the future for cheap food in the present. We are at a tipping point and I urge the EPA to fulfill its statutory duty to protect public health and the environment by denying these registrations. Please refer to the attached PDF file (Erkenbrack_EPA_Comment_2026.pdf) for the full-length argument, detailed toxicological analysis, and complete scientific Works Cited list.