This week NAAA submitted comments to EPA on the biological evaluations (BE) for two neonicotinoid insecticides – acetamiprid and dinotefuran. A biological evaluation is the first step in the pesticide registration review process involving EPA’s compliance with the Endangered Species Act (ESA). Once completed, EPA sends their biological evaluations to the Fish and Wildlife Service and the National Marine Fisheries Service, who conduct their own ESA risk assessments.

 

The main point NAAA made when commenting on both BEs is that they are based on risk assessments conducted using the inaccurate Tier 1 model in AgDRIFT. NAAA informed EPA, as has been done on numerous prior occasions, that EPA should use the more accurate Tier 3 model in AgDRIFT with NAAA assumptions that better reflect the safety and accuracy of modern aerial applications.

 

Both BE’s also mentioned buffer zones that were not wind directional, meaning the buffer zone would apply regardless of whether the wind is blowing towards or away from an endangered species or its critical habitat. NAAA has been successful in the past convincing EPA to make buffer zones wind directional for important ESA related projects from the EPA, including the vulnerable species pilot project and the herbicide strategy.  In its comments on the BEs for acetamiprid and dinotefuran, NAAA reminded EPA of this reiterating that ag aircraft can use smokers and other technology to monitor wind direction and speed.

 

NAAA is optimistic that both Tier 3 AgDRIFT modeling and wind-directional buffers will become the standard for EPA’s pesticide registration and registration review processes. NAAA will continue to monitor and comment on all EPA activity that involves aerial applications.