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EPANonrulemakingEPA-HQ-OPP-2013-0676

Consideration of Spray Drift in Pesticide Risk Assessment

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Center for Biological Diversity filed 1 comment on this docket between May 2, 2014 and May 2, 2014. 29 other organizations filed here. The comment window closed 4472d ago.

What Center for Biological Diversity filed (1)

May 2, 2014· Comment submitted by Jonathan Evans, Staff Attorney, Center for Biological Diversity and Susan E. Kegley, Principal and Chief Executive Officer (CEO), Pesticide Research Institute· EPA-HQ-OPP-2013-0676-0098

The Center for Biological Diversity provides the attached comments on docket EPA-HQ-OPP-2013-0676, Consideration of Spray Drift in Pesticide Risk Assessment. We focus our comments here on document EPA-HQ-OPP-2013-0676-0002, Guidance on Modeling Offsite Deposition of Pesticides Via Spray Drift for Ecological and Drinking Water Assessments as it will affect ecological risk assessments for threatened and endangered (T&E) species. In the attached the Center for Biological Diversity describes two major concerns with the approach US EPA presents in this set of guidance documents. In summary: 1)The scope of the guidance is too narrow. By excluding from consideration long-range transport of driftable fine spray aerosols, the extent and potential impacts of drift are oversimplified and important information about impacts on the environment are omitted. As a result, the impacts of spray drift on T&E species will be underestimated if this guidance is adopted. 2)Recommendations from the 2013 National Research Council (NRC) report should be incorporated into this guidance before it is finalized. A number of recommendations were made by the NRC committee that should be applied to spray drift guidance, specifically: a) inclusion of an assessment of uncertainty and variability in model predictions; and b) use of site-specific habitat parameters (e.g., shallow water habitats instead of the standard farm pond) for Tier II or Tier III analysis. In addition, we provide some suggestions to improve readability and clarity of the document. Detailed comments are attached.

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