NBGA Comments on EPA's Vulnerable Species Pilot Project
The past few months have seen the release of EPA’s Vulnerable Species Pilot Project and the Herbicide Strategy. This all started in 2021 in response to the escalating challenges of EPA fulfilling its Endangered Species Act (ESA) obligations for pesticide decisions. 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 to improve protection for federally threatened and endangered (listed) species and meet ESA obligations.
The ESA Workplan identifies several pilot projects to provide earlier protections for listed species. These pilots include the “EPA Vulnerable Species Pilot Project,” to identify early mitigation for listed species that EPA has determined are particularly vulnerable to pesticide effects. In late June 2023 EPA released a draft white paper on the Vulnerable Species Pilot. The draft describes how EPA: 1) selected these listed species, 2) developed and evaluated proposed mitigations, and 3) developed an implementation plan to reduce their exposure to outdoor uses of conventional pesticides. It also describes EPA’s current thinking on a potential future expansion plan of this approach to additional listed species.
NBGA comments can be viewed here.
More information on the pilot projects can be found here: Implementing EPA’s Workplan to Protect Endangered and Threatened Species from Pesticides: Pilot Projects | US EPA
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