(Beyond Pesticides, May 13, 2025) A study in Environmental Pollution examines ecological and health risks in farmland soil with pesticide contamination. “Although agricultural soil pesticide residues have long threatened the environment, a relatively complete system for evaluating their health and ecological risks has not yet been developed,” the authors state. In addressing this research gap, the study finds that “more than ten pesticides were detected in 98.62% of the soil samples, which changed the soil environment” and threatens the health of the soil microbiome. The authors continue, “This study investigated the correlation between pesticide residue risks and soil ecological security and human health, revealed the response characteristics of soil microbial communities under pesticide stress, and identified microbes strongly related to pesticide ecological risks.” Pesticides, as the authors emphasize, “inevitably pollute agricultural soil, affect the ecological environment, and pose a threat to human health.” (See studies here, here, and here.) With this in mind, they assess 50 selected pesticides in 145 soil samples from agricultural land in Zhejiang Province, China and calculate the associated risks to ecosystems and public health. In describing the importance of this research, the authors explain: “Pesticides are prone to leakage and drift in environmental media, turning […]

(Beyond Pesticides, May 9, 2025) Research in Advances in Modern Agriculture showcases how pesticide residues can threaten the health of soil nematodes and cause phytotoxic effects in cucumber plants. In assessing both the sprayed vegetables and the organisms within the soil, the authors find a negative correlation between pesticide exposure and soil nematode populations that is proportional to the application rates of the chemicals, as well as alterations in plant development. These impacts highlight potential wider effects on crop productivity, biodiversity, and human health. “Nematodes, which are microscopic worms inhabiting the soil, are vital contributors to soil vitality and the cycling of nutrients,” the authors share. “Nonetheless, the non-selective and widespread application of pesticides can negatively impact these organisms, leading to potential detriments in soil quality and plant vitality.” “Pesticide residues have the propensity to be absorbed and progressively accumulate as they traverse from soil to plants and subsequently to humans,” the researchers state. They continue, “The specific characteristics of the pesticide and its interactions with the body across different levels dictate whether it will be excreted without causing significant harm or if it will accumulate, potentially leading to enduring subclinical and clinical ramifications.” The impacts vary widely between organisms […]

(Beyond Pesticides, May 6, 2025) A study in Ecology Letters finds “severe degradation of ecosystem functioning in the form of loss of organic matter consumption and dramatic shifts in primary productivity,” the researchers state, after performing an experiment with “36 naturally established freshwater ecosystems exposed to increasing field-realistic concentrations of the neonicotinoid thiacloprid.” Aquatic communities contribute to overall biodiversity and are crucial in maintaining healthy ecosystems; without them, the entire food web and vital ecosystem services, such as nutrient cycling, water filtration, and climate regulation, are threatened. As the authors reference, there is a current unprecedented decline in biodiversity that can be attributed to anthropogenic impacts. A multitude of studies connect pesticides, and more specifically neonicotinoid insecticides, to impacts on aquatic ecosystems. (See studies here and here.) “Since the community of organisms locally present is responsible for the functioning of the local ecosystems,” the researchers begin, “this begs the question: do neonicotinoid-induced shifts in community composition result in a degradation of ecosystem functioning?” Previous research finds that neonicotinoids can “impede several freshwater ecosystem processes such as organic matter (‘OM’) decomposition, primary production or biomass transfer to neighbouring ecosystems,” the authors say. (See studies here, here, and here.) They continue: “However, […]

* This article was cross-posted with permission from the Ecological Landscape Alliance, which was originally published on April 30, 2025. A link will be shared once it is made available. (Beyond Pesticides, May 2, 2025) With the current existential health, biodiversity, and climate threats, organic land management is a bright spot for the sustainable future envisioned by Beyond Pesticides. Founded in 1981, Beyond Pesticides began tracking the science of pesticide hazards and questioning dependency on toxic, fossil fuel-based pesticides as unnecessary to achieving effective land management, both in agricultural and nonagricultural contexts. The organization, which grew out of a series of site visits and field hearings to document the limitations of labor standards necessary to protect farmworkers, was created to bring together environmentalists, public health practitioners, farmers, land managers, farmworkers, and consumers.  Nearly a decade before its founding and less than 20 years after the publication of Silent Spring, many important laws governing clean air, water, food safety, and pesticides had been adopted. However, these statutes’ focus on mitigating risks of harm to health and the environment has fallen short, according to Beyond Pesticides. Instead, the organization pursues a precautionary approach that is codified in organic standards that grow out of […]

(Beyond Pesticides, April 29, 2025) A study in Environment International finds pesticide-induced alterations in the gut microbiota of a farmland raptor species. In collecting blood and cloacal samples from Montagu’s harrier (Circus pygargus) nestlings, the authors “shed light on an overlooked collateral effect of pesticides, i.e., a general modification of gut bacterial assemblages,” which can lead to an imbalance of microorganisms (dysbiosis) and the promotion of potential pathogens, as well as negatively impact the health of birds of prey. “Additionally, our findings support the ‘One Health‘ framework, stressing the interconnectedness of wildlife, ecosystem, and human health, particularly in pesticide-affected agricultural areas,” the researchers share. “The gut microbiota is crucial for host health and can be impacted by various environmental disruptions, yet the effects of multiple pesticide exposures on farmland organisms’ microbiomes remain largely unexplored,” the authors state. In the study, they “assessed microbiota changes in a wild apex predator exposed to multiple pesticides in agricultural landscapes,” which “provides evidence of pesticide impacts on wildlife gut microbiota, highlighting links between pesticide exposure and changes in microbiota composition,” the researchers note. The Montagu’s harrier, as an apex predator, serves as a ‘bio-sentinel’ or bioindicator species for assessing ecosystem health. “As top-level predators […]

(Beyond Pesticides, April 25, 2025) A novel study in Chemosphere finds impacts on male fertility in a bee species (Osmia bicornis) with exposure to sulfoxaflor, a systemic sulfoximine insecticide with similar mechanisms to neonicotinoids. “For the first time, we demonstrate that short-term chronic, field-realistic exposure to a common pesticide reduced pre-copulatory display (36%) and sounds (27%) [courtship behaviors], increased the number of copulations (+110%) and the mating duration (+166%), while finally reducing sperm quantity (25%) and mating success (43%),” the researchers report. They continue, “Our research raises considerable concern on the impact of field-realistic, low sublethal pesticide levels on the fertility and reproductive success of pollinators.” Mating behaviors and the ability to successfully reproduce determines the survival of species. As the authors state: “Mating disorders may therefore contribute to the recent decline in insect and pollinators’ health worldwide. While the impact of pesticides on pollinators is widely considered as a driving factor for reducing pollinators’ health, their effect on mating behaviour and male fertility remains widely overlooked.” The red mason bee (O. bicornis) can “provide essential pollination service for both crops and wild plants sustaining food production and biodiversity while serving as a bioindicator of environmental health.” The abundance and […]

(Beyond Pesticides, April 15, 2025) A study in Communications Earth & Environment, through field, greenhouse, and laboratory experiments involving three plant bug species, finds both species-specific and sex-specific sensitivity responses to neonicotinoid insecticide exposure—highlighting the threats to grassland insect communities that are disregarded in risk assessments. By assessing the effects of Mospilan®SG, with the active ingredient acetamiprid, the researchers determine that nontarget plant bug species are highly sensitive to neonicotinoids and face community-level harm with exposure. As systemic insecticides, neonicotinoids move through the vascular system of plants, expressing the poison through pollen, nectar, and guttation droplets. As persistent pesticides, these chemicals indiscriminately poison insects and organisms in the soil. “Although pesticides have been proposed as one of the main causes of insect decline, there are still few studies assessing their effects on non-target species under field conditions,” the authors state. They continue: “In this study, we address the existing research gap on insecticide exposure of non-target herbivorous insects, focusing on two main aspects: (1) realistic exposure scenarios, (2) community-level effects, i.e., differential sensitivity between closely related species and between sexes of the same species. We chose plant bugs (Heteroptera: Miridae) as a model group because they are one of the […]

(Beyond Pesticides, March 27, 2025) In Ecotoxicology, results of a study on Nile tilapia (Oreochromis niloticus) exposed to florpyrauxifen-benzyl (FPX) suggest the new herbicide causes oxidative stress (imbalances affecting the body’s detoxification abilities that lead to cell and tissue damage), with specific genotoxic (damage to genetic material) and hepatotoxic (damage to the liver) effects on nontarget species. The authors state: “According to the available literature, no data exist on the toxicity of FPX in fish. Therefore, this study aims to investigate, for the first time, the potential toxicity and associated mechanistic effects of the pyridine-carboxylic acid herbicide (FPX) on the non-target species, Nile tilapia.” According to the Wisconsin Department of Natural Resources, “Florpyrauxifen-benzyl is a systemic herbicide (i.e., it moves throughout the plant tissue). It is a WSSA Group 4 herbicide, meaning that the mechanism of action is by mimicking the plant growth hormone auxin and causing excessive elongation of plant cells, ultimately killing the plant.” The researchers, from Menoufia University, the Agricultural Research Center, and Cairo University in Egypt, focus on FPX as it is the active ingredient in Divixton 2.5% EC, a newly released herbicide used in rice fields and applied directly to freshwater aquatic bodies for emergent […]

(Beyond Pesticides, March 20, 2025) An article, published by the National Audubon Society, titled “A Sweeping New Report Shows U.S. Birds Declining Sharply Across a Range of Habitats” reviews the latest State of the Birds 2025 report and finds concerning news for bird species across the country. As the article says: “Whether they hop around the prairie, dabble in wetlands, flit through forests, or forage along the shore, birds are suffering rapid population declines across the United States… If these habitats are struggling to support bird species, it’s a sign that they’re not healthy for other wildlife, or even humans—but working to restore them will have benefits across ecosystems.” The 2025 edition of the State of the Birds report, showcasing a status assessment of the health of the nation’s bird populations, was cultivated by scientists from bird conservation groups through the U.S. Committee of the North American Bird Conservation Initiative (NABCI). The report notes, “Despite ample evidence that conservation can work, the status quo approach to conservation is not turning bird populations around.” As NABCI shares, the report contains “[s]obering evidence that America’s birds continue to decline across the board.” They continue, saying: “Birds are telling us that the habitats […]

(Beyond Pesticides, March 18, 2025) The November 2024 press release by the U.S. Environmental Protection Agency (EPA) for its Rodenticide Strategy includes the final biological evaluation (BE) of 11 rodenticides. Prior to the finalization of the BE, Beyond Pesticides commented to EPA’s Office of Pesticide Programs in early 2024, disagreeing with the categorical no effect (NE) determinations for all freshwater and marine fish, aquatic mammals, aquatic amphibians, aquatic reptiles, and aquatic invertebrates. (See related Daily News and Action of the Week.) The latest scientific literature highlights the impacts of rodenticides on nontarget organisms, including aquatic organisms that the agency failed to evaluate due to harm that was, as EPA says, “not reasonably certain to occur.” Many rodenticides, intended to target rats, mice, squirrels, nutria, and more, are anticoagulants and stop normal blood clotting. Active ingredients in these pesticides can include bromadiolone, chlorophacinone, difethialone, brodifacoum, and warfarin. Anticoagulant rodenticides (ARs), contrary to the agency’s assertions, can be transported to aquatic ecosystems, including both freshwater and marine environments. As mentioned in Beyond Pesticides’ comments, ARs have been detected in raw and treated wastewater, sewage sludge, estuarine sediments, suspended particulate matter, and liver tissues of sampled fish, demonstrating that the aquatic environment experiences […]

(Beyond Pesticides, February 24, 2025) The sweeping firing of federal workers, including an estimated 200,000 probationary employees (under one to two years of employment), will have a broad impact on programs to protect health and safety as well as the environment, leaving a critical need for local and state government to fill some of the gaps in critical programs, where possible. A headline in Science magazine warns, “Mass firings decimate U.S. science agencies,” and the dean of the College of Agricultural Sciences at Oregon State University told Oregon Public Broadcasting, “We’ve lost half of our teams, and all of these up-and-coming young scientists. . .so it’s like we’ve lost the next generation of scientists in agriculture and natural resources.” The same applies to important positions across the federal government, affecting every aspect of work necessary to protect public health and biodiversity and address the climate crisis. In response to President Trump’s executive orders and actions, there has been, as The New York Times reports, “new lawsuits and fresh rulings emerging day and night,” raising what experts fear may become a constitutional crisis. With the upheaval in the federal government, attention turns to the importance of state and local policies and […]

(Beyond Pesticides, February 21, 2025) The prospects for rational environmental policies in the U.S., including commitments to biodiversity and public health protections, are in disarray as the Trump administration sweeps through the federal government without any evaluation of program importance or effectiveness. At the U.S. Environmental Protection Agency (EPA), the destruction is likely to derail or reverse reasonable decisions to ban or restrict numerous toxic chemicals and to bury concern for ecosystem-wide harms. On biodiversity, President Trump has killed a major report, the National Nature Assessment, that had been due for completion on February 11. The assessment is part of the U.S. Global Change Research Program, which produces the national climate assessment, but it was created by an executive order issued under President Biden rather than by Congress. More than 150 experts, including federal employees and volunteers from academia, nonprofits, and businesses, reviewed the state of the nation’s lands, water, and wildlife. The assessment is a U.S.-specific version of a recent global report from the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), covered here by Beyond Pesticides. The IPBES details the many steps that can be taken at every level of the problem to preserve the ecosystem services […]

(Beyond Pesticides, February 19, 2025) In Global Ecology and Conservation, a study of bat species in organic desert date palm plantations highlights the invaluable ecosystem services these beneficial organisms provide. “Bats are crucial in suppressing pest arthropods in agroecosystems, contributing vitally to sustainable agriculture,” the study authors share, which makes supporting bat populations important not just for biodiversity but to help enhance their roles in pest management.    There are various studies connecting organic agriculture and the value it provides for bats and their ecosystem services. (See studies here, here, and here.) While many studies also recognize bat species threatened by pesticides, habitat loss, and climate change, “the importance of bats in agriculture in extreme environments, such as deserts, has received far less attention,” the researchers state. (See previous coverage on pesticide exposure and bats here and here.) They continue, “Date palm plantations represent one of the few productive systems in hyper-arid regions,” noting the study’s novel design. The date palm, primarily grown throughout the Middle East and North Africa, is one of the earliest domesticated fruit trees. “The date palm cultivation’s monocultural nature increases susceptibility to pest infestations due to limited plant diversity, involving 112 mite and insect species.” […]

(Beyond Pesticides, January 30, 2025) A research article in Biology Letters, published by The Royal Society, finds that the neonicotinoid insecticide imidacloprid disrupts survival and reproductive patterns in Bombus impatiens bumblebees. The study adds to the wide body of science highlighting how exposure to pesticides “can result in immediate mortality or cause long-term detrimental effects on pollinators‘ health, lifespan and reproductive success,” the authors state. The researchers performed two experiments to assess the effects of various concentrations of imidacloprid, one of which focuses on bees during diapause, a period of dormancy. “Wild bees, which provide the majority of pollination services worldwide, undergo an annual life cycle that includes a winter diapause, that can span over 75% of their life cycle and during which their metabolism, growth and development are halted,” the authors note. They continue: “The time spent in diapause can have lasting effects on pollinator fitness and their ability to establish nests or colonies in the following spring. This period is especially critical for social bee colonies, which are founded by a single queen after diapause and play a vital role in large-scale pollination.” Exposure to pesticides during diapause can occur while bee species overwinter in contaminated soils. In […]

(Beyond Pesticides, January 28, 2025) Beyond Pesticides is urging the U.S. Environmental Protection Agency (EPA) to move more cautiously in  its proposal for “streamlined . . . registration review decisions for several biopesticides,” subject to a public comment period through February 10, 2025. The organization is raising EPA review process concerns. The organization states: “Although the biopesticides listed in EPA’s proposal for streamlining the registration review process for ‘low risk biopesticides’ can be considered relatively low risk compared to conventional pesticides, the precedent for relying on the original or previous registration data and review is troublesome. EPA’s rationale for registration review—that ‘science is constantly evolving, and new scientific information can come to light at any time and change our understanding of potential effects from pesticides,’ should guide the agency in its decisions—especially when previous decisions have depended on limited actual data, data waiver request rationales, and purported absence of new data or adverse incidents reported.”  While Beyond Pesticides advocates for allowance of pesticides compatible with organic standards that are protective of human health, biodiversity, and healthy ecosystems, it urges EPA to establish rigorous standards in its registration review of these materials. The issue of biopesticide review is made complicated by the […]

(Beyond Pesticides, January 27, 2025) A public comment period ends today, January 27, 2025, on the U.S. Fish and Wildlife Service’s (FWS) proposed critical habitat rule to protect the rusty patched bumble bee under the Endangered Species Act (ESA). This proposal is responsive to the agency’s 2024 stipulated settlement agreement resulting from years of advocacy and government review and a 2023 court order (NRDC et al. v. U.S. Fish and Wildlife Service, et al.). The proposal follows a 2017 determination by the agency that lists the bumble bee as an endangered species. (See previous Daily News here, here, here, here, and here.) >> Tell the U.S. Fish and Wildlife Service to fully protect the endangered rusty patched bumble bee by finalizing its proposed critical habitat rule with strengthening provisions. The FWS proposal grows out of a species status assessment (SSA) conducted by “15 scientists with expertise in bumble bee biology, habitat management, and stressors (factors negatively affecting the species).” University of Illinois Urbana-Champaign insect ecologist Jason Robinson, PhD concludes in his paper, “Project-specific bumble bee habitat quality assessment,” “As the first social insect listed under the ESA, the listing of RPBB has required new methods for biological assessment. This species has a complex life cycle requiring a mosaic of different habitat types, […]

(Beyond Pesticides, January 22, 2025) A study published in Nature Scientific Reports in December 2024 sheds light on how people value the benefits of reducing or eliminating pesticide exposures. The study, based on economic concepts, is a meta-analysis of studies that have attempted to discern what that value is in monetary terms. This study shows the difficulty in gleaning from the existing literature an assignment of true value of social costs associated with pesticide contamination and poisoning, however, was able to glean several points of interest: People’s “willingness to pay” (WTP) is higher for health benefits than ecological ones. In studies that included pesticide risks associated with cancer, the social cost (WTP) tripled. People’s WTP is higher to prevent or ameliorate chronic diseases than to treat or avoid acute exposures. If the study did not specify a pesticide type—even general categories such as herbicide, insecticide and fungicide, and most studies fell into this category—the WTP is significantly higher. In ecosystem terms, use of the term “biodiversity” results in higher WTPs compared to other aspects such as groundwater or aquatic organism health. Consumers are more risk-averse than farmers. The higher the income, the higher the WTP. Social cost is distinguished from the […]

(Beyond Pesticides, January 7, 2025) A report, released in December 2024 from the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), confronts the problem of “siloing” environmental elements—food, health, water, biodiversity and climate change—when they instead intersect at a nexus from which each element affects all the others. The problem is essentially that all the elements are part of the same crisis, yet actions to address issues within each—and, importantly, to resist addressing them—are dealt with in isolation. A proper perspective, gleaned from the report, is to view each element from the center where all parts meet, thus addressing the issues in coordination. According to the IPBES report, “[F]ragmented governance of biodiversity, water, food, health and climate change with different institutions and actors often working on disconnected and siloed policy agendas, resulting in conflicting objectives and duplication of efforts.” The IPBES is an independent body analogous to the Intergovernmental Panel on Climate Change (IPCC) but structured similarly and in close contact with the United Nations (UN). The new report comes at the behest of IPBES’s 147 member countries—75 percent of the UN’s membership—to address the interconnections among the five global crises. The report strongly demonstrates that a holistic, globe-spanning frame […]

(Beyond Pesticides, January 3, 2025) Pesticides that are sprayed and become airborne significantly disrupt ecological balances and affect nontarget species that are crucial for maintaining biodiversity, according to an article in Environmental Pollution. In this review of studies throughout countries in North and South America, Europe, and Asia, among others, researchers from Germany, Norway, the United Kingdom, and Poland reinforce the science about pesticides’ direct effect on species and the cascading effects of pesticide drift through various trophic levels within food webs that lead to overall devasting population effects. This study “addresses the interconnectedness of these impacts and illustrates the complex threats that pesticide drift poses to biodiversity across multiple ecosystems,” the researchers state. They continue: “Impacts include reduced reproductive rates, changes in growth, development, and/or behavior, modification of diversity or community organization, disruption of food webs, and declines of important species. Pesticides disrupt the delicate balance between species that define a functioning ecosystem. Impacts can be local, transnational, or even continental.” Pesticide drift threatens beneficial species and subsequently the entire agricultural system. The process of pesticide drift, “in which up to 25% of applied pesticides are carried by air currents, can transport chemicals over hundreds or even thousands of […]

(Beyond Pesticides, January 2, 2025) Adding to the body of scientific literature on the fast escalating antibiotic resistance crisis is a study published by Chinese scientists in Environmental Science & Technology, which shows that antibiotic resistance genes (ARGs) in soils move up through trophic levels via predation. Gut microbiomes of soil fauna have been found to be reservoirs of ARGs. How this process operates in soils is vital, because what happens in soil microbes does not stay there. If bacteria altered in soils move up trophic levels, ARGs may strengthen the multicellular agricultural pests the industry is trying to kill—insects, fungi, plants—not to mention bringing their libraries of resistant genes into the microbiomes of vertebrates, including humans. Antibiotic resistance is a natural phenomenon, but human activity has greatly increased its presence in ecosystems the world over, including in one of the ecological niches of greatest concern to the future of food and human health: soils. Soils are complexes of mineral and organic substrates populated by billions of microorganisms and tiny animals. They are rapidly being degraded by conventional agriculture, forestry, and land management practices generally—more than a third of the world’s agricultural land has already been severely damaged by pesticides, […]

(Beyond Pesticides, December 24, 2024 – January 1, 2025) We wish you a healthy and happy holiday season! The health and environmental challenges that we face as families and communities across the nation and worldwide require us to stay engaged. The stark reality of the challenges ahead energizes us at Beyond Pesticides to strengthen our program—now, more than ever!   And, we trust that you, like us, want to push forward for a livable future. In this context, please see our annual report and summary on the important work that we are doing, and please consider a contribution to Beyond Pesticides during this holiday season.  While the threats of health, biodiversity, and climate crises grow exponentially, the solutions we have advocated for decades are now within reach. We know how to produce food and manage land without petrochemical pesticides and fertilizers, as organic food is widely available. Beautiful parks, playing fields, and schoolyards do not require toxic chemical use. At the same time, the regulatory system underperforms, as existential health and environmental problems escalate.   And, we know that individual steps that we take to stay healthy, as important as they are, cannot protect us and the natural world, on which […]

(Beyond Pesticides, December 23, 2024) As the U.S. Fish and Wildlife Services (FWS) proposes to list the Monarch butterfly as a threatened species under the Endangered Species Act, a look at the factors contributing to the butterfly’s catastrophic decline includes a stunning failure of the U.S. Environmental Protection Agency’s (EPA) regulation of pesticides to protect biodiversity and the ecosystems necessary to its survival. While there are many factors affecting the survival of Monarchs, EPA’s Office of Pesticide Programs (OPP) has allowed pesticide use to continue unabated, with only rhetorical attention to the problem. Meanwhile, the science shows a range of pesticide effects associated with insecticides and herbicides. A study published in PLOS One in June identifies insecticides as the primary driver in butterfly’s decline, as EPA points, almost exclusively to herbicide use and the destruction of Monarchs’ food source, milkweed habitat. While two or several factors can be true at the same time, EPA has failed to consider the confluence of factors, including the impacts of climate, as rising temperatures are exacerbated by the production and use of petrochemical pesticides. FWS is stepping in at a critical time with looming biodiversity collapse and in the absence of EPA taking the reins […]

Image: Art Page submission from Carol Moyer, “Monarch Butterfly Sideways with Closed Wings.“ (Beyond Pesticides, December 20, 2024) On December 12, the U.S. Fish and Wildlife Service (FWS) opened a public comment period on its proposal to list the monarch butterfly (Danaus plexippus) as a threatened species and to designate critical habitats for the species under the Endangered Species Act of 1973. Under the proposal, the designated habitats would span approximately 4,395 acres throughout overwintering sites in coastal California. The public comment period will be open until March 12, 2025. These suggested protections call attention to the role of chemical-intensive agriculture in affecting populations of pollinators and other beneficial organisms. George Kimbrell, legal director at the Center for Food Safety, shares in a press release that the “monarch listing decision is a landmark victory 10 years in the making. It is also a damning precedent, revealing the driving role of pesticides and industrial agriculture in the ongoing extinction crisis… But the job isn’t done: Monarchs still face an onslaught of pesticides. The Service must do what science and the law require and promptly finalize protection for monarchs.” In the docket, FWS states, “Under the Act, a species warrants listing if […]