EPA’s Endangered Species Insecticide Strategy Ensures Aerial Applications of Insecticides Can Continue Thanks to NAAA’s Efforts

Earlier this week NAAA commented on EPA’s Insecticide Strategy (IS), a key part of EPA’s endangered species workplan. Lawsuits by numerous environmental activist groups forced EPA to act on bringing the pesticide registration and registration review process into compliance with the Endangered Species Act (ESA). Earlier efforts from EPA include the ESA work plan update, the vulnerable species pilot project (VSPP), and the ESA herbicide strategy (HS).

The IS is intended to protect ESA listed invertebrate species as well as those endangered species who rely on insects for their survival. The IS will be used in registration and registration review ESA risk assessments and decisions. The good news for aerial applicators is that, similar to the HS, there is absolutely no mention of a ban on aerial applications to protect ESA listed species.

For each pesticide and listed species group a risk level will be calculated, and then a downwind buffer zone distance between 0 and 320 feet will be assigned based on the level of risk. If the wind is blowing away from a protected area, then no buffer zone is required. Buffer distances can be reduced by using a larger droplet size, reducing application rate, applying in relative humidity greater than 60%, presence of a windbreak, and applying to a small field. The IS will utilize the Bulletins Live! Two website to show where pesticide use limitation areas (PULA) are located and the bulletins that contain the buffer zone distances.

NAAA commented on the IS, supporting the use of wind-directional buffers and methods to reduce them. NAAA expressed concerns on the overall complexity detailed in the IS and the potential to have more areas protected then is necessary to protect ESA listed species. NAAA also stressed the importance of making sure the process for aerial applicators to use the BLT system is as efficient as possible and easy to interpret. To read NAAA’s full comments, click here.