Implementing EPA’s Workplan to Protect Endangered and Threatened Species from Pesticides: Pilot Projects
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Pilot Projects Overview
In 2021, prompted by the escalating challenges of fulfilling its Endangered Species Act (ESA) obligations for pesticide decisions, EPA began developing a comprehensive, long-term approach to meeting those obligations. Informed by EPA’s past efforts and by its recent discussions with stakeholders, in 2021 EPA began holding a series of internal and external meetings on how the Agency could address its ESA obligations. These included quarterly ESA-FIFRA meetings with stakeholders and a widely attended January 2022 public listening session on improving the ESA-FIFRA process.
In April 2022, EPA released its workplan to address the complexity of meeting its ESA obligations for actions taken under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). This comprehensive workplan establishes four overall strategies and dozens of actions that EPA will adopt, in collaboration with other federal agencies, to improve protection for federally threatened and endangered (listed) species and meet our ESA obligations. In November 2022, EPA released an ESA Workplan Update (pdf) that details how EPA will pursue protections for nontarget species, including listed species, earlier in the process for pesticide registration review and other FIFRA actions.
The ESA Workplan identifies several pilot projects to provide earlier protections for listed species. These pilots include the “Federal Mitigation Pilot Project,” which is a collaboration across federal agencies, and the “EPA Vulnerable Species Pilot Project,” to identify early mitigation for listed species that EPA has determined are particularly vulnerable to pesticide effects. This webpage provides more information on both pilot projects, which focus on protections for specific species to help EPA meet its ESA obligations. See EPA’s workplan for information on other pilot projects that focus on protections for specific pesticides.
Federal Mitigation Pilot Project
This project is a collaboration between EPA, the National Marine Fisheries Service (NMFS), U.S. Fish and Wildlife Service (FWS), and U.S. Department of Agriculture (USDA). Together, the agencies are developing approaches for identifying and implementing mitigation to minimize the effects of pesticides on listed species. This project will help federal agencies and stakeholders gain a common understanding of how to reduce exposures to listed species from pesticides by implementing feasible mitigations earlier in the FIFRA registration and registration review processes.
As of November 2022, FWS, NMFS, EPA and USDA have made progress discussing practical, flexible, feasible, and effective measures that are expected to reduce pesticide exposure to the pilot species. EPA has also applied the lessons learned through this collaboration in its ongoing ESA efforts.
For this pilot, FWS and NMFS selected a dozen species, and EPA selected an herbicide, an insecticide, and a fungicide (glyphosate, imidacloprid, and pyraclostrobin, respectively). Each of these pesticides may be used in areas where the pilot species identified by FWS and NMFS are present. FWS and NMFS selected this group of species because it represents a variety of species (e.g., fish, mussels, butterflies) that may live in different habitats and be exposed to pesticides in different ways. Further, several of the species may be particularly vulnerable to pesticides. Most of the listed species in this pilot are FWS species because the agency has jurisdiction over most listed species.
The selected pilot species under FWS jurisdiction are:
- Poweshiek skipperling (Oarisma poweshiek)
- Mitchell’s satyr butterfly (Neonympha mitchellii mitchellii)
- Rusty patched bumble bee (Bombus affinis)
- Topeka shiner (Notropis topeka)
- Prairie bush clover (Lespedeza leptostachya)
- Santa Cruz long-toed salamander (Ambystoma macrodactylum croceum)
- Rayed bean (Villosa fabalis)
- Desert pupfish (Cyprinodon macularius)
- Fat threeridge (Amblema neislerii)
- Gulf moccasinshell (Medionidus penicillatus)
The selected pilot species under NMFS jurisdiction are:
- Chinook salmon (Oncorhynchus tshawytscha)
- Elkhorn coral (Acropora palmata)
For each pilot species, EPA, FWS, NMFS, and USDA are developing an initial list of suitable mitigation measures to reduce the likelihood of future jeopardy to listed species or adverse modification of their critical habitat. These measures are also intended to minimize harmful effects (“take”) from glyphosate, imidacloprid, and pyraclostrobin. The initial list of mitigations will be based on existing mitigation measures that FWS and NMFS have developed, conservation actions in recovery plans, typical best practices for pesticides, and other conservation actions in listed species documents (e.g., 5-year status review, species status assessment). This list of mitigations will reflect input from conservation and agriculture experts, such as NMFS and FWS biologists, grower groups, professional crop consultants, pesticide registrants, and USDA scientists.
Based on this input, the four agencies will develop a list of suitable mitigation measures aimed at reducing the effects of the three pilot pesticides on the 12 species. When determining which mitigations to include, the agencies plan to consider:
- Feasible measures to avoid and minimize pesticide exposure to species with consideration of the impact on pesticide users and their existing pest control practices.
- Whether compensatory mitigation measures (offsets) are an option to protect or rehabilitate species populations and their habitat and, if so, which offset measures are most effective.
- Areas to prioritize mitigations.
- How long the effectiveness of different mitigations will last.
- Any monitoring to assess the effectiveness of the mitigation.
EPA had planned to begin public outreach on identified mitigations with states, pesticide users, pesticide registrants, conservation organizations, and other stakeholders in fall 2022. However, there are several opportunities for public comment related to how EPA is implementing the workplan planned through calendar year 2022, including registration review pilots on methomyl, carbaryl, and rodenticides. These pilots are described in EPA’s ESA Workplan and are intended to help stakeholders better understand EPA’s ESA analyses and see how EPA identifies and proposes mitigations for a small number of species. EPA’s ESA Workplan Update also describes several opportunities for public comment. After EPA receives comments on these various actions, the agencies will determine the next steps for the federal pilot.
EPA’s Vulnerable Species Pilot Project
Through EPA’s Vulnerable Species Pilot, the Agency will identify certain vulnerable listed species, identify mitigations to protect them from pesticide exposure, and then implement these mitigations across different types of pesticides (e.g., herbicides, insecticides). This project will focus on implementing protections for multiple pesticides within a group to protect a particular species. For example, EPA may implement specific restrictions to protect the Taylor’s checkerspot butterfly from all insecticides used within or near the species range. This effort is intended to ensure that EPA begins to adopt meaningful protections for species likely to be affected by pesticide use by incorporating mitigations into applicable registration and registration review decisions, even if consultation with the FWS and NMFS has not been completed or even begun.
EPA identified the pilot species listed below using documentation from the Services (e.g., 5-year reviews, biological opinions) and spatial data for ranges. These data are on the FWS webpages accessible by clicking the species links. For the species that EPA identified for this pilot, FWS concluded that they have high or medium vulnerability to all relevant stressors and indicated that pesticides may be a potential stressor for the species. FWS also indicated that these pilot species have smaller ranges relative to other listed species, and many of their ranges or critical habitats overlap with those of other listed species. Therefore, protections for these species would benefit other listed species.
The initial set of priority species includes:
- Group of plant species in Lake Wales Ridge area of Florida (including Avon park harebells (Crotalaria avonensis), Garrett’s mint (Dicerandra christmanii), wireweed (Polygonella basiramea), scrub blazingstar (Liatris ohlingerae), short-leaved rosemary (Conradina brevifolia), scrub mint (Dicerandra frutescens), Florida ziziphus (Ziziphus celata), and several other species that occur in this area)
- Leedy’s roseroot (Rhodiola integrifolia ssp. leedyi)
- Mead’s milkweed (Asclepias meadii)
- Okeechobee gourd (Cucurbita okeechobeensis ssp. okeechobeensis)
- Palmate-bracted bird’s beak (Cordylanthus palmatus)
- White bluffs bladderpod (Physaria douglasii ssp. tuplashensis)
- Madison cave isopod (Antrolana lira)
- Ouachita rock pocketbook (Arkansia wheeleri)
- Rayed bean (Villosa fabalis; freshwater mussel)
- Scaleshell mussel (Leptodea leptodon)
- Winged mapleleaf (Quadrula fragosa)
- Riverside fairy shrimp (Streptocephalus woottoni) and San diego fairy shrimp (Branchinecta sandiegonensis)
- American burying beetle (Nicrophorus americanus)
- Poweshiek skipperling (Oarisma poweshiek)
- Rusty patched bumble bee (Bombus affinis)
- Taylor’s checkerspot (Euphydryas editha taylori)
- Ozark cavefish (Amblyopsis rosae)
- Attwater’s prairie chicken (Tympanuchus cupido attwateri)
- Buena vista lake ornate shrew (Sorex ornatus relictus)
- Wyoming toad (Bufo hemiophrys baxteri)
For each vulnerable species identified for the pilot, EPA will develop a list of recommended pesticide mitigations for groups of pesticides. Mitigations may differ based on the type of pesticide (e.g. insecticide, herbicide, etc.). Possible mitigations may include:
- Measures to minimize pesticide exposure to the species’ habitats.
- Measures could include use of equipment or practices that reduce spray drift (e.g., nozzles that produce larger spray droplets or reduce the amount of small droplets, use of swath offsets), no-spray buffers, or enhanced warning label language to limit drift onto species ranges.
- Measures could also include use of field conservation practices to reduce pesticide runoff.
- Measures to avoid pesticide exposure when and where it is needed to protect a species.
- Measures could include prohibiting pesticide applications within all or part of the range and/or critical habitat of a species.
In developing mitigations for an entire class of pesticides, such as a group of insecticides, EPA will generally focus on the pesticides within the class that have the greatest potential for effects to the listed species of interest.
By summer 2023, EPA plans to conduct public outreach on the mitigation measures identified for the first set of species in the Vulnerable Species Pilot and explain how EPA envisions applying those measures to certain applicable pesticide actions. By the end of calendar year 2023, EPA expects to complete this phase of the Pilot.
Expanding beyond the Pilot
The species included in this pilot represent an initial set of species. In 2023, EPA expects to begin developing a plan to expand the Vulnerable Species Pilot to include additional species based on lessons learned from incorporating mitigation measures for the initial pilot species. EPA will consider similarities and differences among species when determining which mitigation measures are relevant to additional species. For example, EPA may consider whether the mitigation measures developed for the pilot species apply to others in the same area (e.g., multiple mussels in the same river). As part of the outreach on the first set of vulnerable species (by summer 2023), EPA also plans to describe any proposed expansion of the pilot to include additional species. EPA expects to make a final determination in 2024 on whether and how it could expand the approach used in the Vulnerable Species Pilot to other selected vulnerable species.
StoryMaps for the Vulnerable Species Project
EPA has published a group of StoryMaps to raise public awareness about protecting endangered species from pesticides. These StoryMaps us an interactive format to describe 11 endangered and threatened (listed) species, their habitats, and why they are at risk from pesticide exposure. These StoryMaps offer the unique ability to convey geospatial information about the location of these species and the protections they need from pesticides. For example, users can zoom in on the maps to view specific locations that may be of interest to them (e.g., where pesticide protections will apply).
As mentioned above, EPA plans to propose mitigations and its implementation plan for all 27 pilot species in June 2023. At that time, the Agency will update the current set of StoryMaps to include mitigations and will release StoryMaps for the 16 remaining pilot species.