Federal Mitigation Pilot Project to Protect Endangered Species from Pesticides

This project is a collaboration between EPA, the National Marine Fisheries Service (NMFS), U.S. Fish and Wildlife Service (FWS), and U.S. Department of Agriculture (USDA). Together, the agencies are developing approaches for identifying and implementing mitigation to minimize the effects of pesticides on listed species. This project will help federal agencies and stakeholders gain a common understanding of how to reduce exposures to listed species from pesticides by implementing feasible mitigations earlier in the FIFRA registration and registration review processes.

As of November 2022, FWS, NMFS, EPA and USDA have made progress discussing practical, flexible, feasible, and effective measures that are expected to reduce pesticide exposure to the pilot species. EPA has also applied the lessons learned through this collaboration in its ongoing ESA efforts.

Pilot Species 

For this pilot, FWS and NMFS selected a dozen species, and EPA selected an herbicide, an insecticide, and a fungicide (glyphosate, imidacloprid, and pyraclostrobin, respectively). Each of these pesticides may be used in areas where the pilot species identified by FWS and NMFS are present. FWS and NMFS selected this group of species because it represents a variety of species (e.g., fish, mussels, butterflies) that may live in different habitats and be exposed to pesticides in different ways. Further, several of the species may be particularly vulnerable to pesticides. Most of the listed species in this pilot are FWS species because the agency has jurisdiction over most listed species.

The selected pilot species under FWS jurisdiction are: 

• Poweshiek skipperling (Oarisma poweshiek)
• Mitchell’s satyr butterfly (Neonympha mitchellii mitchellii)
• Rusty patched bumble bee (Bombus affinis)
• Topeka shiner (Notropis topeka)
• Prairie bush clover (Lespedeza leptostachya)
• Santa Cruz long-toed salamander (Ambystoma macrodactylum croceum)
• Rayed bean (Villosa fabalis)
• Desert pupfish (Cyprinodon macularius)
• Fat threeridge (Amblema neislerii)
• Gulf moccasinshell (Medionidus penicillatus)

The selected pilot species under NMFS jurisdiction are:

• Chinook salmon (Oncorhynchus tshawytscha)
• Elkhorn coral (Acropora palmata)

Mitigation Measures

For each pilot species, EPA, FWS, NMFS, and USDA are developing an initial list of suitable mitigation measures to reduce the likelihood of future jeopardy to listed species or adverse modification of their critical habitat. These measures are also intended to minimize harmful effects (“take”) from glyphosate, imidacloprid, and pyraclostrobin. The initial list of mitigations will be based on existing mitigation measures that FWS and NMFS have developed, conservation actions in recovery plans, typical best practices for pesticides, and other conservation actions in listed species documents (e.g., 5-year status review, species status assessment). This list of mitigations will reflect input from conservation and agriculture experts, such as NMFS and FWS biologists, grower groups, professional crop consultants, pesticide registrants, and USDA scientists.

Based on this input, the four agencies will develop a list of suitable mitigation measures aimed at reducing the effects of the three pilot pesticides on the 12 species. When determining which mitigations to include, the agencies plan to consider:

• Feasible measures to avoid and minimize pesticide exposure to species with consideration of the impact on pesticide users and their existing pest control practices.
• Whether compensatory mitigation measures (offsets) are an option to protect or rehabilitate species populations and their habitat and, if so, which offset measures are most effective. 
• Areas to prioritize mitigations. 
• How long the effectiveness of different mitigations will last. 
• Any monitoring to assess the effectiveness of the mitigation.

EPA had planned to begin public outreach on identified mitigations with states, pesticide users, pesticide registrants, conservation organizations, and other stakeholders in fall 2022. However, there are several opportunities for public comment related to how EPA is implementing the workplan planned through calendar year 2022, including registration review pilots on methomyl, carbaryl, and rodenticides. These pilots are described in EPA’s ESA Workplan and are intended to help stakeholders better understand EPA’s ESA analyses and see how EPA identifies and proposes mitigations for a small number of species. EPA’s ESA Workplan Update also describes several opportunities for public comment. After EPA receives comments on these various actions, the agencies will determine the next steps for the federal pilot.