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NMFS’ Delivers Draft Proposal To EPA On Protecting Listed Salmon From Certain Pesticides
Posted on Friday, March 04, 2011 (PST)

The Environmental Protection Agency is seeking comment on the National Marine Fisheries Service’s draft plan to protect Pacific salmon from six pesticides.


EPA is seeking comments from pesticide users, registrants, and other interested parties on the draft Reasonable and Prudent Measures and Alternatives included in the 1,000-page draft biological opinion, which can be found at


The draft biological opinion, released this week, addresses the potential effects from six pesticides on 28 Pacific salmon and steelhead species listed as endangered or threatened under the Endangered Species Act. The six pesticides are: captan, chlorothalonil, 2,4-D, diuron, linuron, and triclopyr BEE.


“After considering the status of the listed resources,” said NMFS in delivering the draft BiOp to EPA, “the environmental baseline, and the direct, indirect, and cumulative effects of EPA’s proposed action on listed species, NMFS preliminarily concludes that pesticide products containing triclopyr BEE, linuron, and captan are not likely to jeopardize the continuing existence of any listed Pacific salmonids…”


But NMFS did conclude that the “effects of products containing diruron will destroy or adversely modify designated critical habitat for some listed Pacific salmonids.”


And the agency concluded that “the effects of products containing 2-4-D, and chlorothalonil “are likely to jeopardize the continued existence of some listed Pacific salmonids and to destroy or adversely modify designated habitat . . . .”


EPA is also encouraging input from state, tribal, and local governments on the draft RPMs and RPAs to determine whether the alternatives or measures can be reasonably implemented and whether there are different measures that may provide adequate protection but result in less impact on pesticide users.


Comments on the draft RPMs and RPAs must be submitted by April 5.


Comments received by EPA on other aspects of the draft BiOp will be forwarded to NMFS for its consideration. No extensions to this comment period will be provided because NMFS has a legal deadline to issue the final BiOp by April 30.


Key elements in the draft BiOp include:


-- In the proposed RPA, NMFS does not attempt to ensure there is no take of listed species. NMFS believes take will occur, and has provided an incidental take statement exempting that take from the take prohibitions, “so long as the action is conducted according to the RPA and reasonable and prudent measures. Avoiding take altogether would most likely entail canceling registration, or prohibiting use in watersheds inhabited by salmonids. The goal of the RPA is to reduce exposure to ensure that the action is not likely to jeopardize listed species, destroy or adversely modify critical habitat.”


-- Do not apply pesticide products containing 2,4-D, diuron, or chlorothalonil when wind speeds are greater than or equal to 10 mph.


--  Do not apply pesticide products containing 2,4-D, diuron, or chlorothalonil when soil moisture is at field capacity, or when a storm event likely to produce runoff from the treated area is forecasted by to occur within 48 hours following the application.


--  Do not apply 2,4-D directly to salmonid habitats except to control non-native (exotic) invasive species; outside of timing windows to be developed by NMFS for each ESU/DPS; and when the control of non-native (exotic) invasive species cannot be accomplished without adverse effects to native aquatic plants. NMFS “reserves the right to make alterations to spray timing windows as new information becomes available on listed species spatial and temporal distributions.”


--  Within the ESU/DPSs boundary of Upper Willamette River Chinook, Central Valley Spring-Run Chinook, Sacrament River Winter-Run Chinook, Upper Willamette River Steelhead, Central California Coast Steelhead, and California Central Valley Steelhead. do not apply 2,4-D directly to riparian habitat where applications will decrease shading to aquatic habitat, decrease bank stability, or increase erosion.


--  EPA will implement NMFS approved risk reduction measures to address effects from turf and agricultural uses of chlorothalonil products.” 


-- Report all incidents of fish mortality that occur within the vicinity of the treatment area, including areas downstream and downwind, in the four days following application


-- Alternatively, these incidents may be reported to the pesticide manufacturer through the phone number on the product label.


-- In addition to the labeling requirements above, EPA shall develop and implement a NMFS-approved effectiveness monitoring plan for floodplain habitats, and produce annual reports of the results. The plan shall identify representative floodplain habitats prone to drift and runoff of pesticides within agricultural areas. The representative floodplain habitat sampling sites shall include floodplain habitats currently used by threatened and endangered Pacific salmonids, as identified by NMFS biologists. Sampling sites include at least two sites for each general species (i.e., coho salmon, chum salmon, steelhead, sockeye salmon, and ocean-type chinook and stream-type chinook salmon). Sampling shall consist of daily collection of surface water samples for seven consecutive days during three periods of high application for 2,4-D, diuron, and chlorothalonil. The report shall be submitted to NMFS OPR and will summarize annual monitoring data and provide all raw data.


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