NAAA Comments on Two Endangered Species Evaluations from EPA to Protect Aerial Applications

NAAA recently submitted comments to EPA on the biological evaluations (BE) for two pesticides: benzovindiflupyr and bicyclopyrone. A biological evaluation is the first step in assessing the risk a pesticide may present to endangered species and critical habitat. EPA sends the biological evaluation on the Fish and Wildlife Service and the National Marine Fisheries Service (the Services) so they can conduct their own analysis and issue a biological opinion. After that, EPA consults with the Services to determine appropriate mitigations to protect endangered species.

The BEs for both pesticides were conducted using the Tier 1 AgDRIFT model. EPA recently accepted NAAA’s recommendations to switch from the Tier 1 to the Tier 3 AgDRIFT model with most of NAAA’s suggested assumptions for the variables within the model. This more accurate model shows a reduced amount of drift from aerial applications, and NAAA asked EPA to consider this later in the consultation process when mitigations are proposed.

Another similarity between the two BEs was the mention of existing buffer zones on the labels for products containing the two pesticides. NAAA recommended that these buffer zones should be wind directional, similar to the buffer zones proposed in other recent endangered species strategies and registration review decisions from the EPA. The BE for bicyclopyrone recommended a wind speed limit of 10 mph; NAAA recommended increasing that to 15 mph citing the new Tier 3 model and numerous other recent EPA registration decisions that increased the wind speed limit from 10 to 15 mph based on NAAA’s input.