NAAA submitted comments today opposing an EPA proposed stipulated injunction that would reinstitute streamside, no-spray buffer zones in an attempt to protect endangered or threatened Pacific salmon and steelhead in California, Oregon and Washington State for the five broad-spectrum insecticides of carbaryl, chlorpyrifos, diazinon, malathion and methomyl. The buffers proposed would prohibit aerial pesticide applications within 300 feet of a salmon stream and ground application within 60 feet of a salmon stream. The stipulated injunction would settle litigation brought against EPA by environmental activist groups in U.S. District Court in Washington State, which in 2004 resulted in a federal judge in Seattle issuing an injunction imposing similar buffers to the EPA proposal.  The U.S. District Court ordered injunction recently expired.

NAAA’s comments to the EPA questioned the need for such an aerial buffer, especially such an arbitrary, uncompromisable buffer length.  NAAA referenced the advanced nozzles and other on-board technologies, aircraft set-up procedures, and in-flight maneuvers used by NAAA’s professional member pilots today that significantly increase droplet size, reduce the relative fraction of driftable droplets, and control the precision and width of the spray swath, thereby lowering spray drift potential. NAAA’s comments may be accessed by clicking here.