Comment submitted by Michael Lorton

Summary: Dr. Michael D. Lorton, a private individual with medical and legal credentials, opposes the Draft Fungicide Strategy because he argues it uses "junk science" to mask individual organism harm through flawed population-level modeling. He contends that the strategy violates the Endangered Species Act by prioritizing macro-population stability over the protection of individual organisms and calls for the EPA to instead use its authority to compel registrants to provide comprehensive life-stage toxicity data.