The Center for Biological Diversity commented on the Endangered Species Act Section 7 Consultation Draft Biological Opinion for the Environmental Protection Agency’s Pesticide General Permit for Discharges from the Application of Pesticides (‘PGP”). CBD’s comments were very critical, and made the following claims:

● The PGP does not meet the ESA’s standards.

            –EPA’s PGP lacks the basic data necessary for analysis.

            –EPA’s FIFRA analysis does not address the PGP’s effect on species and their


● EPA cannot ensure the PGP will protect water quality and wildlife.

            –EPA’s permit structure demonstrates that permittees will not comply with the

            PGP to protect water quality and wildlife.

            –EPA’s proposal to reduce the PGP’s impacts are ineffective.

Read CBD’s comments here.