It seems to us that the Environmental Protection Agency is making a perfunctory effort to take comments on its new national herbicide strategy, leading us to believe the fix is in.

In a court settlement with the Center for Biological Diversity and Pesticide Action Network, finalized in September in U.S. District Court for Northern California, the EPA committed to a series of “strategies” to regulate herbicides, insecticides, fungicides and rodenticides.

EPA is tackling herbicides first.

The strategy will introduce new off-label restrictions on applying conventional herbicides in the continental U.S. The EPA says the rules will protect more than 900 rare plants and animals that depend on the plants.

EPA has pledged to finalize the herbicide strategy by May 30. It has closed public comment on the strategy, and says it will address concerns raised by critics in the final document.

That’s not sitting well with critics, who note the proposed herbicide strategy is a complicated departure from the current regulations and demands more back-and-forth.

The strategy is “unreasonably complex” and enforcing it is “inconceivable,” according to the National Association of State Departments of Agriculture.

States were not involved in drafting the EPA’s herbicide strategy, but would be responsible for carrying it out.

NASDA public policy manager Josie Montoney-Crawford said the EPA herbicide strategy has provoked pointed criticisms and suggestions for improvement that shouldn’t evaporate “into nothingness.”

“I think right now we need more communication from the agency,” she said.

The U.S. Department of Agriculture, in its comments, noted EPA’s need for quick action.

“At the same time, USDA has substantial concerns about the Herbicide Strategy Framework insofar as it proposes complex, and potentially restrictive, mitigations for all outdoor uses of conventional herbicides prior to full consultation,” the USDA said in regards to the strategy.

“USDA believes that EPA can protect species and minimize adverse consequences to growers and will be more effective at doing so if sufficient public discussions and engagement opportunities are provided. And we believe many agricultural stakeholders will struggle to make sense of and comply with the complex mitigations described in the framework.”

Even the Center for Biological Diversity, a party to the settlement, says the EPA’s plan is too complicated to be practical.

Will any of these concerns be addressed, and if so, how?

We will set aside for the sake of argument the view of many critics, us included, that EPA’s settlement and the ensuing strategy are wrongheaded. EPA has already committed to that path.

Its settlement doesn’t commit it to a specific regulatory scheme. But by all accounts, the EPA is on the cusp of turning food production in the United States on its head.

Even on an expedited schedule, more collaboration with those who will enforce the rules and those who will have to live by them seems to be in order.

Stakeholders shouldn’t have to wait for the final rules to find out if their concerns have been heard and addressed.