EPA’s draft herbicide strategy released July 23rd outlines another aspect of the Agency’s approach to addressing its obligations under the Endangered Species Act (ESA). The proposed framework aims to reduce the need for evaluations of chemicals and species on an individual basis, work which would take the agency decades to complete. EPA also suggests that this framework will increase efficiency in future ESA consultations with the U.S. Fish and Wildlife Service by identifying and mitigating potential impacts before the ESA consultation is completed.
Rather than evaluating individual pesticides against species and habitat, EPA is proposing broad mitigation plans that can be applied to areas with potential ESA habitats. The herbicide framework addresses agricultural uses only, and proposes a menu of mitigations to reduce spray drift, runoff, and erosion. Many of these mitigations are already widely utilized by producers (e.g., hooded sprayers, windbreaks, vegetative strips, water retention systems, cover crops, etc.).
Applicators would either find these mitigations on the product labels or would be directed to consult EPA’s ESA Bulletin system to understand the type and extent of mitigations needed. The proposed mitigations are associated with a point system with some mitigations scored higher than others. EPA will indicate the total points needed for a specific use, and applicators will choose from the available mitigation options to meet the needed points. The draft herbicide framework can be downloaded here, with accompanying documents available here. OFS will be submitting comments on this proposed framework.
Disclaimer: Articles featured on Oregon Report are the creation, responsibility and opinion of the authoring individual or organization which is featured at the top of every article.