Last month NAAA submitted comments to the EPA on the National Marine Fisheries Service’s (NMFS) biological opinion (BiOp) on carbaryl and methomyl. A BiOp is part of the pesticide registration review process involving the consultation between the EPA and the NMFS (it can also include the Fish and Wildlife Service depending on the species involved) to ensure the pesticide undergoing registration review does not cause harm to endangered species or their habitat.
The BiOp discussed using buffer zones next to water bodies for both aerial and ground application. NAAA once again recommended the buffers zones be wind-directional so that they could be sprayed in their entirety when the wind was blowing away from the water body. NAAA also noted that the EPA itself suggested the use of wind-directional buffer zones in their recently released proposed interim decision (PID) for carbaryl.
Unfortunately, the BiOp also referenced a proposal to ban all aerial applications of carbaryl except for grasshopper control. This proposal was not in the PID, so NAAA inquired as to where it was made. The EPA referred NAAA to an appendix in a draft evaluation that was released at the same time as the PID which indicated this proposal came from carbaryl registrants. Regardless, NAAA objected to this restriction, pointing out that pest resistance and unusually wet weather can both result in an increased need for aerial application of carbaryl. NAAA also cautioned the EPA against similar proposed restrictions on the aerial application of methomyl, which recently went through a PID revision.
NAAA also reminded the EPA that all of the risk assessments being used to justify buffer zones and restrict usage of aerial application are based on the erroneous Tier 1 model in AgDRIFT. The next step in the process is for NMFS to consider the comments before issuing their final BiOp. NAAA will continue to monitor the registration review for both carbaryl and methomyl and fight for aerial application to remain an option for growers.
NAAA’s full comments on the carbaryl and methomyl BiOp can be read here.