NAAA Helps Ensure Aerial Applications of Methomyl Can Continue

Last week NAAA submitted comments to the EPA on the biological opinion (BiOp) for methomyl. A BiOp is part of the pesticide registration review process and evaluates the potential threats a pesticide represents to endangered species and their critical habitat. Decisions from the BiOp are incorporated into the final registration review decision and label language.

Once again NAAA commented that all risk assessments for drift from aerial applications were based on the inaccurate Tier 1 model in AgDRIFT and that EPA should move to the Tier 3 model. While EPA has publicly stated both in person and in writing that they intend to move forward with NAAA’s recommendations, NAAA wants to be on record for every document for which the Tier 1 model is used.

NAAA also stressed to EPA that all buffer zones need to be wind directional. Having an upwind buffer zone effectively removes agricultural land from being productive and does nothing to protect an endangered species because drift doesn’t move upwind. NAAA opposed the proposal in the BiOp to potentially reduce the application rate for methomyl, stating resistance as a major concern when pesticide rates are reduced.

Finally, NAAA cautioned EPA against banning aerial applications of methomyl or any other pesticide in Hawaii simply because aerial application is rare in the state. The spread of exotic pests, which can represent both a threat to agriculture and the very species the BiOp is trying to protect, can quickly change the need to employ aerial applications. To read NAAA’s full comments, click here.