16 Jul KARA joins coalition requesting EPA come to the table to discuss improvements to ESA
Kansas Agribusiness Retailers Association (KARA) joined nearly 200 organizations in sending a letter to the United States Environmental Protection Agency (EPA) requesting the agency engage with stakeholders to discuss improvements to its Endangered Species Act risk assessment process for pesticides.
The letter highlights why EPA has both a responsibility and would benefit from using more refined risk assessment processes, identifies potential improvements that could be used, and calls on the agency to expeditiously engage with stakeholders to improve its ESA risk assessment processes.
Under the ESA, all federal agencies, including EPA, are required to conduct risk assessments (called biological assessments or biological evaluations) to determine what effect, if any, an agency action may have on listed species or their critical habitats.
The data and processes that the agency uses (or does not use) are important in reaching that conclusion. Unfortunately, in conducting its ESA assessments for pesticides, EPA has generally used less refined models, has not used vital real-world data (e.g., how do pesticide users actually use pesticides?), and used unduly conservative assumptions that overstate risks to species and critical habitats.
As a result, EPA often concludes much greater restrictions on farmers/pesticide users are needed to mitigate those alleged risks than may be determined if EPA were to use more data-driven processes. This has been a great source of stakeholder frustration with recent ESA proposals, such as the draft Herbicide Strategy, among others.