On May 31, 2011, CRE filed comments with EPA on NMFS’ revised Biological Opinion for
the effects of Captan, Chlorothalonil, 2,4-D, Diuron, Linuron and Triclopyr BEE on Pacific salmon. CRE’s comments make the following points:
● The BiOp does not comply with NMFS’ Information Quality Act (“IQA”) Pre-Dissemination Review/Certification requirements.
● NMFS needs to conduct external peer review of its Population Effects Models to determine their compliance with EPA’s CREM Guidelines.
● NMFS needs to analyze journal articles and other studies that it uses to determine whether they meet IQA guidelines.
● NMFS needs to provide a public record of the above requested actions, and NMFS needs to respond in a public record to public comments.
● Finally, EPA cannot use NMFS’ BiOp because it does not comply with EPA’s IQA guidelines. EPA cannot use any BiOp that has the flaws discussed in CRE’s comments.
CRE’s BiOp comments are attached below.