On Nov. 15, USDA and EPA, along with the US Fish and Wildlife Service (FWS) and National Marines Fisheries Service (the Services), held a public stakeholder workshop to discuss their white paper outlining an interim three-step approach to assess the risks to endangered and threatened species associated with pesticide exposure.
The Endangered Species Act (ESA) requires federal agencies to consult with the Services if a federal action might result in harm to a listed species or its critical habitat. Pesticide registration is considered a federal action and, in a 2004 court ruling, EPA was mandated to consult on 37 pesticides and their potential impact on salmon species. For a number of reasons, to date, not a single consultation has been completed.
Consequently, EPA and the Services asked the National Academy of Sciences (NAS) to review the process and to make recommendations to improve it. NAS’ recommendations called for federal agencies to develop a common approach to endangered species risk assessments for pesticides.
The initial step results in a determination on whether a pesticide may affect or will have no effect on listed species; the second step will result in a determination that the pesticide is either likely or unlikely to adversely affect a listed species or designated critical habitat within the action area; and the third step calls for the appropriate service to make a "jeopardy" or "no jeopardy" determination for the listed species.
Don Brady, director of EPA’s Environmental Fate and Effects Division, said the agencies are working on a "more detailed document" that will outline how the agencies plan to address each recommendation included in the NAS report.
Rick Keigwin, director of EPA's Pesticide Reevaluation Division, described several additional details that the agencies will address during the initial consultations, including additional work on species range and action area, which is the area of potential effects in and around pesticide use sites. FWS field offices generally have the best available data on species range and the Services will need time to build a full national database on species range.
Other issues that will need to be worked out during the initial consultations include a specific approach for exposure models and a common weight of evidence approach for effects characterization.
It is hoped by both agricultural interests and industry that this exercise will streamline the pesticide consultation process and create a culture of collaboration within the four agencies tasked with protecting endangered species. The white paper on interim approaches for ESA assessments is at www.epa.gov/oppfead1/endanger/2013/interagency.pdf .
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