Coinciding with the 2014 celebration of Earth Day, CropLife America (CLA) appreciates the opportunity to provide input and feedback on proposed approaches to improving the pesticide consultation process under the Endangered Species Act (ESA). EPA’s Office of Pesticide Programs, the U.S. Department of Agriculture (USDA), and the U.S. Fish and Wildlife Service and National Marine Fisheries Service (“the Services”), held a one-day workshop to provide a forum for stakeholders to offer scientific and technical feedback on the interim approaches that were issued in November 2013 by the EPA, USDA, and the Services in response to the National Academy of Sciences (NAS) report entitled, “Assessing Risks to Endangered and Threatened Species from Pesticides.” Scientists from CLA and several of its member companies participated in the workshop.

In the report, NAS determined that NMFS and FWS should work more closely with EPA and use a common approach in evaluating potential pesticide risks to threatened and endangered species. The report advocates a more streamlined process that minimizes independent risk assessments by the Services that unnecessarily duplicate EPA’s efforts.

“Nearly one year after NAS issued its recommendations for improving ESA consultations among federal regulatory agencies, and coincidentally on Earth Day 2014, we are pleased to see EPA, USDA and the Services moving forward on a public dialogue with all organizations who have a mutual desire for a more scientifically sound and transparent process,” said Jay Vroom, CLA’s president and CEO. “However, further discussion on scientific topics is needed. CLA looks forward to continuing scientific exchange with the government and other stakeholders involved in order to design a process that is mindful of federal resources and works for all parties, as well as for agriculture and listed species. If progress indeed has officially begun today, it is entirely appropriate that it begins on Earth Day.”

A 2013 report commissioned by CLA and prepared by Summit Consulting estimates that duplicative regulations on crop protection products could cost taxpayers an additional $474 million over the next 10 years. This unnecessary taxpayer expense would be incurred from increases to NMFS and FWS budgets and staffing levels that would be needed to complete the currently scheduled review of 744 pesticide registration dockets by fiscal year 2023.