CRE Comments on Flaws in ESA Pesticide Models
On June 10, 2016, the Center for Regulatory Effectiveness filed comments on EPA’s Draft Biological Evaluations for chlorpyrifos, diazinon, and malathion. CRE’s comments included the following Executive Summary (footnotes omitted):
“CRE’s comments address Topic 1: flaws in the environmental models used in the draft BEs.
EPA, NMFS and FWS (“the agencies”) have not produced a public record demonstrating that the regulatory models (“ESA models”) that they used for the BEs are properly validated and meet the required quality standards. These standards include transparency and consistency of model predictions with observed field data.