(Beyond Pesticides, January 11, 2022) Neonicotinoid insecticides can have detrimental effects on liver health, according to research published in the Journal of Hazardous Materials. While this is the first study to investigate how these chemicals harm the liver, there is increasing evidence that neonicotinoids, otherwise notorious for their effects on pollinators and aquatic life, can cause direct harm to human health. As the U.S. Environmental Protection Agency (EPA) continues to protect the pesticide industry from any measure of meaningful regulation around these hazardous products, the job falls to advocates to place pressure on elected officials to make the changes necessary to safeguard long-term health and well-being. Scientists postulated that neonicotinoids are neither metabolized by the liver nor excreted by urine. To test that hypothesis, 201 individuals from a hospital in China were enrolled into a study. Of the enrolled,  81 were cancer patients, and 120 were not. These individuals underwent a procedure called endoscopic retrograde cholangiopancreatography whereby samples of their bile, a fluid produced in the liver, were retrieved and analyzed. Researchers also performed a series of blood tests, measuring a range of biomarkers, including cholesterol, bilirubin, bile acids, white blood cells, platelets, and others. Lastly, scientists determined the amount […]

(Beyond Pesticides, January 10, 2023) Pollinator losses are responsible for reducing the global production of nuts, fruits, and vegetables by 3-5%, and this loss of healthy, nutrient-dense food is resulting in over 425,000 excess deaths each year, according to research published late last year in Environmental Health Perspectives. While the connection between pollination, food production and health is intuitive, the study’s ability to trace how these impacts are directly harming the well-being of people living right now is shocking, and is a clear sign that pollinator losses must be taken seriously and addressed through meaningful action. To those who consider the decline of pollinators to be some vague, amorphous future threat, let this study end that myth. According to researchers, “Today’s estimated health impacts of insufficient pollination would be comparable to other major global risk factors: those attributable to substance use disorders, interpersonal violence, or prostate cancer. Per a United Nations report, 75 percent of the world’s food crops depend at least in part on pollination, with pollinators contributing an estimated $235 to $577 billion to global crop production annually. Pollinator declines are already adversely impacting food production. A 2016 paper by many of the scientists in the current study […]

(Beyond Pesticides, January 4, 2022) A study published in Environmental Science and Technology finds neonicotinoids (neonics) and their breakdown products (metabolites), like other chemical pesticide compounds, can readily transfer from mother to fetus. The National Health and Nutrition Examination Survey (NHANES) finds U.S. pregnant women experience frequent exposure to environmental pollutants that pose serious health risks to both mother and newborn. Many known pollutants (i.e., heavy metals, polychlorinated biphenyl, and pesticides) are chemicals that can move from the mother to the developing fetus at higher exposure rates. Hence, prenatal exposure to these chemicals may increase the prevalence of birth-related health consequences like natal abnormalities and learning/developmental disabilities. Children are particularly vulnerable to the impacts of pesticide exposure as their developing bodies cannot adequately combat exposure effects. Moreover, a mother’s pesticide exposure can have a stronger association with health disorders than childhood exposure, and a newborn can still encounter pesticides. Therefore, it is essential to understand how pesticides impact the health and well-being of individuals during critical developmental periods. Beyond Pesticides has covered a variety of pregnancy risks from pesticides and other toxic chemicals, including these in just the last three years: pesticides and children’s sleep disorders; prenatal exposures to a multitude of chemicals; insecticides and childhood leukemia; insecticides and Attention Deficit/Hyperactivity Disorder. The study […]

(Beyond Pesticides, November 23, 2022) A new study throws into question the value of the pest management concept of setting action levels around pest infestations. In the course of watermelon production over a span of two years, pollination, not pest levels, was the key determining factor for yield. “These data advocate for a reprioritization of management, to conserve and protect wild bee pollination, which could be more critical than avoiding pest damage for ensuring high yields,” the study, published in Proceedings of the Royal Society B, indicates. Action levels are considered an important aspect of an integrated pest management (IPM) approach in agriculture, whereby a pest infestation reaches levels considered economically unacceptable, leading to a decision to engage in pest control. The concept of IPM however has been influenced by the chemical industry over the decades since its original definition and recent data indicates that it has failed to stop toxic pesticide use. The original intent of IPM was the adoption of preventive practices and utilization of nonchemical tools, placing pesticide use as a last resort when pest control is warranted. However, farms that self-identify as IPM operations use pesticides, sometimes as the first line of defense, while attempting to […]

(Beyond Pesticides, November 15, 2022) Spraying a flowering plant with synthetic fertilizers makes it less attractive to bumblebees, according to research published this month in PNAS Nexus.  “A big issue is thus—agrochemical application can distort floral cues and modify behaviour in pollinators like bees,” said study author Ellard Hunting, PhD, of the University of Bristol, UK. The findings underscore the limited understanding that proponents of chemical agriculture have for the complex processes that food production relies upon and reinforce calls for a broad scale transition to regenerative, organic farming practices. Scientists began with the knowledge that spray applications of various agrichemicals affect the visitation patterns of bumblebees and other pollinators through a range of different processes. Past research finds that notorious bee-killing neonicotinoid insecticides not only kill bees outright, but also result in a range of complex damage, including their ability to impede bees’ olfactory senses and adversely affect their vision and flying ability. Other chemicals like glyphosate weaken bees’ ability to distinguish between colors.   A growing area of research is investigating the ways in which pollinators use static electric fields surrounding flowers to find food sources. A 2013 study found that bumblebees use floral electrical fields to discriminate […]

(Beyond Pesticides, October 27, 2022) A study published in Environment International adds to the growing body of research evaluating the association between neonicotinoid insecticides (neonics/NIs) and breast cancer. Past studies suggest neonics act as endocrine disruptors, affecting the development and regulation of estrogen hormones that promote breast cancer. However, this study is one of the few to evaluate the toxicological and molecular mechanisms involved in initiating breast cancer events. According to the Centers for Disease Control and Prevention (CDC), breast cancer is a disease that causes breast cells to grow out of control, with the type of breast cancer depending on the cells themselves. Most common forms of breast cancer have receptors on the cell surface that can increase cancer growth when activated by estrogen, progesterone, or too much of the protein called HER2. One in ten women will receive a breast cancer diagnosis, and genetics can only account for five to ten percent of cases. When a cancer cell lacks receptors for these molecules, G protein-coupled estrogen receptors (GPERs) are an essential biological target of estrogen and plays a role in hormone-dependent cancer development. GPERs regulate estrogen through non-genetic cellular pathways, forgoing attachment to standard molecular receptors, leading to triple-negative breast cancer (TNBC). Although past […]

(Beyond Pesticides, October 6, 2022) A new study finds alarmingly high levels of PFAS (Per- and Polyfluoroalkyl Substances) “forever chemicals” in commonly used pesticides, calling into question assurances from the U.S. Environmental Protection Agency (EPA) that contamination is limited to storage containers. For some pesticides, PFAS levels are nearly one billion times higher than the EPA’s recently updated Health Advisory for the PFAS chemical PFOS. “If the intent was to spread PFAS contamination across the globe there would be few more effective methods than lacing pesticides with PFAS,” said Kyla Bennett, PhD, of the nonprofit Public Employees for Environmental Responsibility. “These findings point to an appalling regulatory breakdown by EPA.” A team of researchers based in Texas, including scientists from Texas Tech and the U.S. Department of Agriculture’s (USDA) Cropping Systems Research Laboratory, participated in the study published in the Journal of Hazardous Materials Letters. Ten different formulated pesticide products were tested for 24 different PFAS substances. The pesticide products selected were determined based on unexpected PFAS contamination at USDA’s research facility. During the course of conducting a separate study on plant uptake of PFAS, detectable levels of PFAS were found in plants intended to be used as unexposed controls. […]

(Beyond Pesticides, September 27, 2022) Exposure to widely used neonicotinoid insecticides harms amphibians at multiple life stages, adversely affecting their ability to survive in the wild, according to research published in the Journal of Zoology. As long-lived, systemic insecticides, neonicotinoids are consistently found in U.S. waterways,  often above federal safety limits, making these findings particularly dangerous for frogs and other amphibians throughout the country. As troubling data piles up on this class of dangerous insecticides, which are damaging pollinators, birds, deer, aquatic wildlife, and human health, it is left to the public to place pressure on federal regulators and members of Congress to act. To understand the impact of neonicotinoids on amphibian life stages, researchers conducted a range of  experiments. These were designed to investigate how exposure to the neonicotinoid imidacloprid affected larval survival, sexual development, locomotor skills, and avoidance behavior of the wood frog (Rana sylvatica). Larval survival was examined by exposing tadpoles to 10 parts per billion (ppb) of imidacloprid, a rate lower than the lethal concentration expected to kill half of other frogs species in acute toxicity tests. Four treatment protocols were established, adding the variable of natural pond drying to half of the tested frogs to […]

(Beyond Pesticides, September 21, 2022) Strawberry plants pollinated by wild bees exposed to neonicotinoid insecticides produce smaller berries than those pollinated by unexposed bees, finds research published in the journal PLOS One. The findings are yet another piece of evidence pointing to the need for major reforms in the way pesticides are evaluated and pollinators are protected in the United States. As decades of evidence have piled up on the dangers posed by long-lived, systemic, neonicotinoid insecticides, the U.S. Environmental Protection Agency (EPA) has done little to address the damage to pollinator populations, while needed legislation, the Saving America’s Pollinators Act, has languished in Congress without a hearing or a vote, despite having over 75 cosponsors. This new study describes a novel consideration for how neonicotinoids may harm pollinators and impact the food supply. “Previous studies have shown that clothianidin affects wild bees negatively in terms of foraging speed, development and reproduction. Our results indicate that it can also impair the bees’ ability to pollinate strawberry flowers,” says study coauthor Lina Herbertsson, PhD. Scientists established 12 outdoor cages each with 10 strawberry plants and 11 canola plants. For half of the cages, the canola plants were grown with seeds coated […]

(Beyond Pesticides, September 7, 2022) Neonicotinoid (neonic) insecticides are causing widespread contamination within deer populations in Minnesota, with recent data showing significant increases over sampling that took place just two years earlier. The Minnesota Department of Natural Resources (MDNR) began sampling the spleens of deer in the state after research conducted in South Dakota found widespread contamination, but also links to harmful effects as a result of the exposure. The latest findings will result in further testing, yet the sum of research on the dangers of neonicotinoids – not only to deer, but pollinators, birds, aquatic wildlife, and even human health – demands, according to advocates, a precautionary approach and meaningful restrictions on these potent systemic pesticides. Officials at MDNR have no explanation for the increase in contamination over the last sample period. “We’re not exactly sure why we saw that increase,” said Department of Natural Resources Ungulate Research Scientist Eric Michel, PhD, to mprnews.org. “But regardless, the two years of data are showing us that neonics are being detected pretty much across the state. When we look for them we find them in deer spleens. So that’s kind of the big takeaway from what we’re seeing right now.” Results […]

(Beyond Pesticides, August 25, 2022) A study published in World Journal of Pediatrics finds an association between antibiotic and neonicotinoid (neonic) exposure and onset of pediatric (childhood) type 1 diabetes (T1D) through effects on the gut microbiome. Individuals with type 1 diabetes are at higher risk of other autoimmune disorders, including thyroid and celiac disease. Ample evidence demonstrates environmental contaminants like pesticides and antibiotics negatively affect human mouth and gut microbes. Through the gut biome, pesticide exposure can enhance or exacerbate the adverse effects of additional environmental toxicants on the body. Moreover, studies find low levels of pesticide exposure during pregnancy or childhood cause adverse health effects from metabolic/immune disorders to mental and physical disabilities. Children are particularly vulnerable to the impacts of pesticide exposure as their developing bodies cannot adequately combat exposure effects. Although studies show how chemical exposures affect overall human health, more research is now questioning how these toxic chemicals influence gut health and subsequent occurrence of diseases. In children, gut microbiome disruption, or gut dysbiosis, has significant associations with type 1 diabetes development, and disruption of gut microbiota plays a role in type 2 diabetes development. Over 11 percent (>37 million) of individuals in the U.S. have diabetes, and cases are growing by millions annually. With increasing rates of type 1 and […]

(Beyond Pesticides, August 2, 2022) Members of the United States Senate are calling on the U.S. Fish and Wildlife Service (FWS) to phase out the use of toxic pesticides in National Wildlife Refuges in order to protect declining wildlife species and the country’s unique natural resources. Led by Senator Cory Booker (D-NJ), the senators sent a letter to FWS Director Martha Williams urging FWS to “expeditiously begin a rulemaking process to phase out the use of agricultural pesticides on National Wildlife Refuges.” The move comes at a time when native wildlife and the ecosystems humans rely upon are under greater threats than ever before from climate change, habitat destruction, and the indiscriminate use of toxic pesticides. “The Refuge System was established to provide sanctuary for listed threatened and endangered species, migratory birds, and other wildlife,” wrote the senators in a letter to U.S. Fish & Wildlife Director Martha Williams. “The Refuges’ migratory sanctuary and breeding grounds are especially critical for North American birds, as they have faced precipitous population declines; there are 3 billion fewer breeding birds in North America than there were in 1970. Unfortunately these birds and other threatened species are being put at risk by pesticide use […]

(Beyond Pesticides, June 2, 2022) A California judge ordered state-run pesticide spraying to cease on public, agricultural, wild lands, and private properties. The judge states that government officials fail to consider and minimize the potential health and environmental risk associated with pesticide use. Moreover, officials failed to notify the public on the risks of pesticide spraying. The suit was brought by the Environmental Working Group (EWG), the City of Berkeley and ten other public health, conservation and food safety organizations, including Beyond Pesticides. Board member of the California Environmental Health Initiative Nan Wishner states, “The court made the right decision to throw out CDFA’s plan to cement into place for the indefinite future the agency’s ‘spray now, ask questions later approach to pest management, which would have perpetuated the existing situation, in which Californians learn their yards or neighborhoods are to be sprayed only when the treatments are about to happen and have little or no recourse to stop the use of pesticides.”  On May 19, 2022, the Superior Court of California – County of Sacramento ruled to remove an environmental impact report allowing California’s Department of Food and Agriculture (CDFA) to spray pesticides at any time and any place. Removal […]

(Beyond Pesticides, May 31, 2022) Fifty years after the banning of DDT, the notorious insecticide is still harming iconic birds of prey along the California coastline. According to research published in Environmental Science and Technology, California condors and marine mammals along California’s coast are contaminated with several dozen different halogenated organic compounds (hazardous, often-chlorinated chemicals) related to DDT, chlordane, and other now-banned legacy chemicals. The findings highlight the incredible importance of addressing these original “forever chemicals,” and making certain that we do not continue to repeat the mistakes of the past with new and different, yet equally dangerous, chemistries. Between 1947 and 1971, the Montrose Chemical Corporation of California, the largest historical producer of DDT, released over 1,700 tons of DDT into the LA sewer system, which eventually made its way into the Pacific Ocean. During this time, several other companies discharged PCBs, leading to further chemical contamination of land and sediment. As recent as April 2021, scientists discovered 25,000 barrels likely containing DDT near Catalina Island along the southern California coast. These releases have resulted in serious environmental and health problems throughout the coastal food chain. Yet, as the present study shows, scientists are only beginning to understand the […]

(Beyond Pesticides, April 4, 2022) Recent actions by the U.S. Environmental Protection Agency (EPA) highlight the urgent need to prevent pesticides from further endangering crucial pollinators, including birds, bees, and bats. Tell EPA To Ban Neonics and Protect Against Other Threats to Pollinators. Tell Congress To Insist that EPA Does Its Job. Despite EPA’s own findings of evidence of serious threats posed by neonicotinoid (neonic) pesticides to pollinators, aquatic invertebrates, and other wildlife, it issued interim decisions on these neonics in January 2020 that disregard the science on the pesticides’ impacts and it appears that the agency is prepared to finalize these registrations late in 2022. This would, barring further action, extend the use of these harmful compounds for 15 years. Now is the time to let EPA know that continued use of neonicotinoids is unacceptable. Furthermore, building on a history of unenforceable and impractical pesticide label restrictions resulting in EPA findings of ludicrously small or no risk, the agency spun its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” As the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases, EPA actions continue to protect pesticide […]

(Beyond Pesticides, March 25, 2022) Recent coverage by The Guardian of the U.S. Environmental Protection Agency’s (EPA’s) plan — to extend the registration of several demonstrably harmful neonicotinoid insecticides — compels Beyond Pesticides to identify, once again, the agency’s failures to enact its core mission. That mission is “to protect human health and the environment,” and to ensure that “national efforts to reduce environmental risks are based on the best available scientific information.” EPA has undertaken a review of the registration of several members of the neonicotinoid (neonic) family of pesticides and, despite the agency’s own findings of evidence of serious threats to pollinators, aquatic invertebrates, and other wildlife, it issued interim decisions on these neonics in January 2020 that disregard the science on the pesticides’ impacts. EPA appears to be prepared to finalize these registrations late in 2022; this would, barring further action, extend the use of these harmful compounds for 15 years. Neonics are used widely in the U.S., both on crops to kill sucking insects, and as seed treatments with the same goal for the developing plant. These insecticides are systemic compounds, meaning that once applied, they travel to all parts of a plant through the vascular […]

(Beyond Pesticides, March 1, 2022) A report by the Independent finds chemical-intensive farming of crops for animal feed puts thousands of endangered species at risk. U.S. farmlands use more than 235 million pounds of pesticide (i.e., herbicides and insecticides) solely for animal feed production, many of which are highly hazardous pesticides (HHPs). Several HHP hazard categories include acutely toxic, chronic health hazards, and environmental hazards. Therefore, animal feed production intensifies global pollution, increases pesticide exposure, and degrades human, animal, and ecological health.  Although the report demonstrates a need to eliminate toxic pesticide use for the sake of human, animal, and ecosystem health, it will take more than eliminating the worst chemicals to address the impending biodiversity collapse and the climate crisis. Experts highlight the need for an urgent shift to organic land and agricultural management practices. The study notes, “These pesticides are taking a toll on our environment and biodiversity. Endangered species like the highly imperiled whooping crane, monarch butterflies, all species of salmon, the rusty-patched bumble bee, the San Joaquin kit fox, and the northern long-eared bat, as examples, all face significant threats from industrial agricultural operations and the chemicals applied. In order to conserve biodiversity and better protect vulnerable species and their habitats, […]

(Beyond Pesticides, January 26, 2022) Officials in New Jersey and New York are taking action to protect their states’ declining pollinator populations by restricting  outdoor uses of neonicotinoid (neonic) insecticides. In New York, the state Department of Environmental Conservation announced it would make these pesticides “restricted use,” and only available to state certified applicators. In New Jersey, A2070/S1016, sponsored by state Senator Bob Smith and Assemblyman Clinton Calabrese, was signed by Governor Phil Murphy last week after years of advocacy from national, state, and local pollinator and environmental groups. “The law relies on the most up-to-date science to ban the largest uses of neonics in the state,” said Lucas Roads, staff attorney at the Natural Resources Defense Council. “This is great news for not just pollinators that are poisoned by neonics, but for all the farmers who depend on insect pollination and for all New Jerseyans that value thriving ecosystems.” A2070/S1016 provides for a targeted phase-out of outdoor uses of bee-toxic neonicotinoids, chemicals implicated not only in the decline of pollinators, but also the collapse of entire ecosystems. Beginning 12 months after passage, the bill requires state agencies classify neonicotinoids as “restricted use.” Under this designation, only certified pesticide applicators […]

(Beyond Pesticides, January 6, 2022) Seeds treated with neonicotinoid insecticides contaminate honeydew, often the biggest source of food for pest predators, according to recent research published in the journal Environmental Pollution. Concerned advocates for pollinators and pesticide reform are likely familiar with fact that neonicotinoids are systemic, and once applied to a seed or sprayed on a plant are taken up by the plant and distributed throughout the pollen, nectar and dew drops that a plant produces. But there is another systemic effect that is not included in that picture, and in monoculture crops, it could be the biggest source of carbohydrates for beneficial pest predators – honeydew. Honeydew is produced from phloem-feeding (sap sucking) pests like aphids, whiteflies, leafhoppers, and other hemipteran insects. The waste that these insects produce is liquid, and full of sugars. “This rich carbohydrate source is a common food for many beneficial insects, including pollinators, such as bees and flies, and some natural enemies of pests, such as ants, wasps and beetles,” said John Tooker, PhD, coauthor of a recent literature review published in Biological Reviews. “Honeydew often is more abundant than nectar in agroecosystems.” In 2019, a study published in the Proceedings of the […]

(Beyond Pesticides, December 10, 2021) In a win for pollinators, a California Superior Court has issued a ruling that sulfoxaflor, a systemic pesticide that is “field legal” but “bee lethal,” can no longer be used in the state. The suit was brought by the Pollinator Stewardship Council and the American Beekeeping Federation. The ruling of the Superior Court of the State of California for Alameda County finds that the argument of the petitioners — that sulfoxaflor approval decisions by the California Department of Pesticide Regulation (DPR) violated the California Environmental Quality Act (CEQA) — is valid. Eliminating this highly bee-toxic pesticide from use in the state is expected to protect not only native bees and other pollinators (including Monarch butterflies in early Spring), but also, the many millions of managed-colony bees that are transported to California for pollination of almond and other crops. The suit was filed against DPR, Corteva inc., Dow Agrosciences LLC, the Siskiyou County Department of Agriculture, and James E. Smith as Siskiyou County Agricultural Commissioner. Having found for the petitioners’ request for a Writ of Mandate (a court order requiring a lower court or public authority to perform its statutory duty), the court instructed the petitioners to […]

(Beyond Pesticides, December 7, 2021) One exposure. That’s all it takes for wild bees to experience declines in reproduction and population growth from neonicotinoid insecticides, according to research recently published in the Proceedings of the National Academy of Sciences (PNAS). This incredible sensitivity is exactly the sort of process that could rapidly drive pollinator species into extinction. It is the sort of finding that one would expect government agencies tasked with protecting the environment to discern. Yet, regulators at the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs have consistently failed to listen and meaningfully respond to the latest science. As this is done, the agency is fully aware that ever more pollinators are slated for endangered status, jeopardizing our agricultural economy, ecosystem stability, and the joy we all gain from watching our favorite pollinators flit about the landscape. Over the course of two years, researchers established a crossed experiment with ground-nesting blue orchard bees (Osmia lignaria). These pollinators, native to North America, overwinter and nest in narrow holes or tubes, making them particularly sensitive to ground-based pesticide applications. Researchers conducted their study during the first year by exposing a group of larval bees to the neonicotinoid imidacloprid through […]

(Beyond Pesticides, November 10, 2021) The diversity and abundance of freshwater aquatic insects plunges when commonly used neonicotinoid (neonic) insecticides leach into waterways, finds research published in the Proceedings of the National Academy of Sciences this month. While this is the latest study exploring the effects of neonicotinoids in the field at real-world exposure levels, it is far from the first to show unacceptable hazards to wildlife and ecological health. As research on neonics piles up, advocates are watching in dismay as regulators at the Environmental Protection Agency (EPA) fail to respond to the science and allow indiscriminate poisoning to continue. To determine how neonicotinoids affect critical aquatic species near the bottom of the food chain, researchers created a series of 36 experimental ditches, split into four groups of nine. One group acted as a control and received no pesticide, and each other group received, 0.1, 1.0, or 10 parts per billion (ppb) of the thiacloprid, a neonic insecticide often cited by industry and regulators as having lower toxicity concerns than other neonicotinoids. Mimicking a pulse that may come from a nearby insecticide application, each group of ditches was dosed every two weeks for a period of three months. Scientists […]

(Beyond Pesticides, October 25, 2021) The Environmental Protection Agency (EPA) is requesting public comments on its draft Biological Evaluations (BEs) for neonicotinoid insecticides imidacloprid, clothianidin, and thiamethoxam by 11:59 pm (EDT) on Monday, October 25, 2021. The BEs will factor into EPA’s registration review decisions on the three bee-toxic insecticides. Written comments must be submitted through Regulations.gov. Please feel free to cut and paste parts of  Beyond Pesticides’ comments (linked here) or cut and paste into Regulations.gov the suggested comment language at the very bottom of this alert.  Tell EPA to protect endangered species from pesticides. EPA’s Biological Evaluations for these highly toxic chemicals make no agency conclusion or recommendation that would trigger a request to initiate formal Endangered Species Act (ESA) §7(a)(2) consultations with the U.S. Fish and Wildlife Service (USFWS) to determine a possible jeopardy finding for the listed species and requisite mandatory use restrictions of the relevant pesticide. This, despite the fact that for imidacloprid the agency’s draft Biological Evaluation made a May Affect determination for 89% of the 1821 species considered and 90% of the 791 critical habitats considered. Strikingly, a May Affect determination was made for 100% of amphibian and avian listed species and their […]