Comment on FR Doc # 2026-11327

Edaphix, LLCSupportBusiness
Summary: The commenter is a developer of a micronutrient-rich fertilizer (NutraFix) who argues that the proposed revisions to the National Handbook of Conservation Practices should include non-traditional fertilization methods. They provide evidence that increasing micronutrient fertility can successfully outcompete invasive plants and improve forage quality for livestock and wildlife.
Soil fertility is critical to the quality of forage, suitability for livestock and wildlife, exclusion of invasive plants and prevention of wildfire from annual grasses. This is especially true for micronutrients. Most fertility treatments and soil sampling for nutrients focus on nitrogen. While nitrogen is an important nutrient the associated micronutrients are underappreciated. As the developer of a micronutrient-rich fertilizer (tradename NutraFix) we have performed many tests with collaborators and early adopters across the western U.S. that shows surprisingly powerful vegetation responses from increasing micronutrient fertility. These soil treatments allow preferred rangeland perennial plants to thrive while invasive plants such as cheatgrass are outcompeted. These trials have been performed with NRCS, university faculty (Montana State), State agencies, County government, large ranch owners and others over the past decade. These third party efforts show that by increasing the density of soil micronutrients shifts in the plant community result that are analogous to the types of conservation practices envisioned by Conservation Practice Standard 315 Herbaceous Weed Treatment, yet not described in the revised practice. This comment is intended to raise Agency awareness of this important innovation in modifying soil fertility to the benefit of desired vegetation types through emphasizing micronutrient fertility. Further information is available on the product website: https://www.nutrafixsoils.com/. The NutraFix formulation is 1-4-1 plus micronutrients. Several photos are attached as demonstrations of the technology. The photo file NutraFix vs Rejuvra photo pair 4 years after install shows a side by side comparison of soil fertilization with NutraFix in 2021 at a large Wyoming coal mine compared to leading cheatgrass herbicide Rejuvra installed at the same time. Quantitative monitoring is not available, however the photos provided by mine personnel show the compelling difference between approaches. After 4 years the herbicide treatment shows diminished performance while invasive cheatgrass has become reestablished and become common in the treated plot. In contrast the NutraFix micronutrient fertilizer (photo taken on the same day) shows dark green, lush native grasses and only a trace of cheatgrass. Furthermore winter grazing during the winter of 2025-2026 by livestock, elk, antelope and mule deer resulted in extreme utilization of the unfenced NutraFix test area judged by the plant stubble and manure left behind suggesting highly palatable forage conditions preferred by grazers and observed in May 2026. No evidence of wildlife or livestock grazing outside the NutraFix plot were noted. The photo labeled Untreated vs NutraFix April 2026 was provided by a USDA/ARS researcher in Nevada testing the efficacy of NutraFix micronutrient fertilizer in cheatgrass affected rangeland. These test plots were installed in summer 2025. The photo labeled Russian knapweed NutraFix Soil Health Montrose CO shows an example of a depleted soil that became colonized by invasive Russian knapweed. The landowner, intent on reinvigorating soil health, applied NutraFix micronutrient fertilizer after burning decadent weeds. The site was seeded with barley, oats and triticale which grew with sufficient vigor the rancher baled the cover crop and fed it to his cattle. These examples highlight the importance of non-traditional fertilization using micronutrient fertilizer not contemplated in conservation practice standards, however very useful in attaining the highlighted priorities stated in the revisions.

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