The FIFRA Endangered Species Task Force (FESTF) has sent a letter to the National Academy of Sciences offering its experience and expertise to the NAS/National Research Council review panel reviewing risk assessments of FIFRA-Regulated Pesticides for species regulated by the Endangered Species Act.  Their letter explains that FESTF

was formed in 1997 as a limited liability, non-profit corporation to address EPA/OPP’s data requirements associated with pesticides and their potential impact on threatened and endangered (T&E) species. The foundation of FESTF’s effort is the development of work products that allow access to and facilitate use of best available scientific and commercial data on T&E species. FESTF members, comprised of 18 of the leading FIFRA-regulated companies in the United States, have spent 15 years and more than $10 million in research on the data needs related to the assessment of pesticide risk to endangered species. We have struggled with many of the challenges the NAS Panel on Ecological Risk Assessment Under FIFRA and ESA will be addressing, particularly with respect to geospatial information and important species and pesticide datasets. Do we have all the answers? No. Do we have experience helpful to share with the panel? Definitely yes.

Their letter further identifies several relevant FESTF work products:

• FESTF Information Management System (IMS) – a web-based tool whose basic function is to document and capture data and decisions that arise from the processes used by EPA/OPP to evaluate potential impacts of registered or reregistered products on T&E species. The IMS supports T&E evaluation in three important ways: (1) it provides county-level comparisons of T&E species locations with locations of potential pesticide use; (2) it provides a platform for compiling spatial, biological, and other information relevant to the potential for exposure of T&E species in each county; and (3) it is designed to store assessment findings and subsequent risk management decisions, for each species/county combination. The system also guides the user to provide intensive documentation regarding any findings related to the potential impact of a particular product on species of concern at the county level.  

• FESTF Multi-Jurisdictional Database (FESTF MJD) – a licensed data subset from NatureServe’s Multi-Jurisdictional Database that provides detailed multi-state data (both biological and spatial) on T&E species. The FESTF MJD provides access to data on T&E species (including sub-county location data) aggregated at the national level. Data provided has been pre-qualified for use in this setting in a manner that meets the “best available data” standard of the Endangered Species Act.

• FESTF supplemental data, gathered from federal and authoritative sources, on species proximity to locations of potential pesticide use, designated critical habitat, species presence by-county, species-specific dietary and dependency relationships, and similar data critical to the interpretation of the risk of pesticides to T&E species. FESTF data are just beginning to be peer reviewed and tested by EPA in their emerging Registration Review process. The Registration Review is charged with the reevaluation of all registered pesticides, but at this time it is the process development point for more formalized and transparent pesticide endangered species risk assessments. In the first applications of FESTF data to this type of assessment, EPA examined the herbicides clomazone and fomesafen in a national level assessment. This type of assessment is much more comprehensive than the litigation driven, single species, regional effects determinations that EPA has conducted and sent to the Services for consultation. It is imperative that the panel understand the context of the national level assessment in light of carrying out its charge, because this type of assessment will bring stability to the comprehensive scientific process for endangered species assessment addressing the nexus of FIFRA and ESA. 

CRE hopes the NAS/NRC panel takes advantage of FESTF’s experience and expertise.

Read FESTF letter attached below.