CLA Submits Comments for EPA’s Vulnerable Species Pilot Project
Read CropLife America (CLA) full comement’s on the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Program’s Vulnerable Species Pilot Project (Pilot) and the accompanying Draft Technical Support document here.
CLA supports our members’ technical concerns about the use of the best available science, transparency, validated methodology, and data quality standards in making decisions regarding the protection of endangered species. CLA echoes the concerns of our member companies and other key stakeholders that the VSPP represents an alarming and precautionary departure from EPA’s established risk- and exposure-based environmental protection under both FIFRA and ESA. We also understand the concerns expressed by the user community and recognize the difficulty or inability to sustain farming operations or other livelihoods which rely on pesticide applications should the majority of the mitigations within the VSPP be implemented. We remind the Agency that the potential impact of these restrictions will go far beyond pesticide users and the local communities in which they operate. Pesticides are a vital tool in securing a safe and equitable food supply, public health programs, maintaining wildlife habitat and protecting critical infrastructures. The effective pesticide ban proposed by the VSPP will detrimentally affect each of these components of our society.
The comments we present here focus on procedures and policy and how the VSPP should be rethought, improved, or heavily amended before any implementation or expansion is finalized. CLA appreciates the need for interim mitigation measures while consultation moves forward, but it is not likely that all runoff, spray drift, and avoidance practices described at this draft stage will be required universally for all pesticides when an individual product’s risk and exposure are fully addressed. As drafted, the VSPP proposes temporary measures that will involve significant efforts and lost uses, on the grower, applicator, landowner, retailer, state enforcement agencies, and the registrant. Such direct and heavy impact on the user community, through an arbitrary departure from current FIFRA and ESA implementation policies, and without careful consideration of existing best management and conservation practices, resistance management, and the vagaries of pest outbreaks, could be devastating to the protection of crops, structures, human health and animal welfare in the areas proscribed around the listed species used in this pilot, and should not be extended to more species or areas without more specificity and dedicated user input.
CLA remains commited to support improvements to the ESA review for pesticide registration decisions. In that spirit, we have offered the enclosed comments and recommendations above on overall improvements to the ESA process and specific comments on the VSPP and supporting technical document. CLA recommends that the Agency resolve the outstanding questions, requests for clarity and refinement, inconsistencies between parallel programs and collect adequate stakeholder input on the resolutions.