(Beyond Pesticides, May 30, 2024) The House Agriculture Committee voted 33-21 on May 23 to move the Farm, Food, and National Security Act out of committee after a contentious markup and onslaught of amendments that undermine water health, soil health, and local democratic authority to protect people and the environment from toxic pesticide exposure. One of nearly sixty amendments introduced in the markup last week included the continuation of a decade-long attack on National Pollutant Discharge Elimination System (NPDES) permit via Clean Water Act (CWA) for pesticide discharge. What was most illuminating however was not the passage of the bill itself, but Big Agriculture’s raucous approval. Advocates see pesticide industry and its allies’ support for what it is—the reliance on petrochemical-based pesticides leading to economic instability, ecosystem collapse, and the degradation of democratic institutions. With support for entrenched dependency on petrochemical pesticides and fertilizers, the committee’s bill requires taxpayers to pay through the government’s crop insurance program for escalating losses caused by chemical-intensive farming practices, contributing to yield losses that the U.S. Department of Agriculture (USDA) says are “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease. . .” However, the frequency of these […]

(Beyond Pesticides, April 24, 2024) On April 16, 2024, the U.S. Environmental Protection Agency (EPA) posted an “update” to the Draft Herbicide Strategy Framework (Draft Herbicide Strategy Framework to Reduce Exposure of Federally Listed Endangered and Threatened Species and Designated Critical Habitats from the Use of Conventional Agricultural Herbicides) that was released last summer, weakening aspects of the agency’s efforts to “protect” endangered species from herbicide use. The update outlines three types of modifications to the Draft Strategy, including “simplifying” its approach, increasing growers’ “flexibility” when applying mitigation measures, and reducing the mitigation measures required in certain situations. By reducing the stringency of the Strategy, advocates are again questioning EPA’s commitment to fulfilling legal requirements under the Endangered Species Act (ESA) or protecting endangered species and their habitats in the midst of an unprecedented rate of global extinction. ESA is celebrated as one of the most far-reaching conservation laws globally, credited with preventing the extinction of 99 percent of those species the government targets for protection, according to the U.S. Fish and Wildlife Service (USFWS). ESA establishes a framework to categorize species as “endangered” or “threatened,” granting them specific protections. Under ESA, EPA is required to consult with relevant agencies […]

(Beyond Pesticides, September 11, 2023) As environmental groups pursue a legal strategy to challenge the U.S. Fish and Wildlife Service (USFWS) for its failure to protect a wildlife refuge from industrial aquaculture, they are also urging the public to hold Refuge officials accountable to the Refuge Improvement Act with a write-in campaign. (See Take Action campaign below.) Earlier this year, USFWS allowed the establishment of a commercial aquaculture operation that cultivates 34 acres of non-native Pacific oysters within a 50-acre tideland parcel leased  from the Washington State Department of Natural Resources within the Dungeness National Wildlife Refuge. The failure to fully evaluate the compatibility of this use with the purposes of the refuge raises concerns of compliance with the law governing National Wildlife Refuges throughout the country. Beyond Pesticides has said, “USFWS is willing to allow, for private profit, the industrialization of refuge lands for shellfish operations.”  Refuges are critical habitat throughout the U.S. that protect critical ecosystems. According to the lawsuit, the Dungeness National Wildlife Refuge shelters a bay rich in marine life. Eelgrass beds attract brant, shorebirds feed on the tideflats, and ducks find sanctuary in the calm waters. The Refuge is a preserve and breeding ground for more than […]

(Beyond Pesticides, August 18, 2023) Yesterday, three environmental organizations filed a lawsuit against the U.S. Department of Interior for failing to protect the Dungeness National Wildlife Refuge from industrial aquaculture. The groups, including Protect the Peninsula’s Future, Coalition to Protect Puget Sound Habitat, and Beyond Pesticides, filed their complaint in the U.S. Western District Court of Washington State. The complaint states that the U.S. Fish and Wildlife Service (USFWS), U.S. Department of Interior, must “take action that is required by the Refuge Improvement Act and conduct a compatibility determination and require a special use permit for a proposed industrial aquaculture use” that will abut and impact the Refuge. The plaintiffs are represented by the Seattle, WA law firm of Bricklin and Newman LLP. The shellfish operation leases 50 acres of Washington State bottomlands; 34 acres to be covered with up to 80,000 plastic bags of non-native shellfish and staked into the bottomlands, potentially killing all benthic life underneath and snaring wildlife in the netting. This operation would shift the natural year-round-sediment movement, directing the sediment into the eelgrass beds – beds protected for rearing salmon for whales and nourishing particular migratory ducks. Additionally, the plastic bags will cover primary feeding […]

(Beyond Pesticides, July 3, 2023) Mosquito season is upon us, and to many that means spraying pesticides to kill them. But not only is spraying flying mosquitoes the most ineffective way to prevent mosquito problems, it is also counterproductive because it eliminates some of our most attractive and helpful allies—birds. Tell EPA to eliminate pesticides that threaten birds or their insect food supply. Tell the U.S. Fish and Wildlife Service and Department of Interior to protect birds by eliminating the use of pesticides that threaten them. Tell Congress that EPA and other agencies need to do their job and protect birds and other mosquito predators. While the appetite of purple martins for mosquitoes is well known, most songbirds eat insects at some stage of their life. Many birds who eat seeds or nectar feed insects to their young, including flying insects that may be bothersome–like mosquitoes or flies. Altogether, birds consume as many as 20 quadrillion individual insects, totaling 400-500 million metric tons, per year. Mosquito-eating birds include many well-known residents of our communities. They include, for example, wood ducks, phoebes and other flycatchers, bluebirds, cardinals, downy woodpeckers, swallows, swifts, robins, orioles, wrens, great tits, warblers, nuthatches, hummingbirds, red-winged blackbirds, […]

(Beyond Pesticides, June 5, 2023) Butterflies—the most attractive of our insect fauna—are disappearing at an appalling rate, largely due to pesticide use. Recent studies have documented declines of almost 50% from 1990 to 2011 in Europe (with trends continuing), of 58 percent between 2000 and 2009 in the U.K., and of 33% from 1996–2016 in the state of Ohio in the U.S. Even steeper declines have been documented for Monarch butterflies, with an 80 percent decline of Eastern monarchs and 99 percent decline of Western monarchs. Tell EPA to eliminate pesticides that threaten butterflies. Tell the U.S. Fish and Wildlife Service and Department of Interior to help bring back butterflies by eliminating the use of pesticides that threaten them. Tell Congress that EPA and other agencies need to do their job and protect our most charismatic insects. Last year, EPA admitted that three neonicotinoid pesticides are “likely to adversely affect from two-thirds to over three-fourths of America’s endangered species—1,225 to 1,445 species in all,” including many butterfly species. On May 5 of this year, EPA released new analyses of these neonics’ effects on endangered species. EPA’s analyses focus on the species most at risk of extinction, and the results represent […]

(Beyond Pesticides, May 16, 2023) U.S. Fish and Wildlife Service (USFWS) is set to be sued for its failure to implement strong protections for imperiled manatee populations. Earlier this month, the Harvard Animal Law and Policy Clinic, Center for Biological Diversity, Miami Waterkeeper, and engineer Frank González Garcia sent USFWS a notice of intent to sue after USFWS failed to respond to a petition sent by the groups last fall. “It has been months of agony and unjustified time lost for manatees in Puerto Rico,” said Mr. Garcia, an engineer who is concerned with the loss of natural resources. “Recent fatal accidents and unprecedented toxic water discharges aggravate the already precarious living and survival conditions of this beloved species,” Mr. Garcia said. Recent reporting has captured a dismal situation for manatee populations. The species is under threat from a range of anthropogenic impacts, from boat strikes to harmful herbicide contamination, pollution-driven red tides, and algae blooms that have destroyed seagrass beds the species rely upon. Starvation resulting from the loss of seagrass beds was the cause of death for more than 1,000 manatees in 2021, prompting wildlife officials to feed them cabbage and lettuce as a last resort to keep […]

(Beyond Pesticides, April 14, 2023) In March, scientists at the National Marine Fisheries Service (NMFS) issued a draft Biological Opinion (BiOp) stating that carbaryl and methomyl — two commonly used carbamate insecticides — cause significant harm to dozens of already-endangered fish species in the Pacific Northwest’s Columbia, Willamette, and Snake rivers. The BiOp indicates that these toxic compounds, in wide use on orchards and field vegetables throughout the Willamette Valley, the Columbia River Gorge, and southeastern Washington, will likely threaten scores of species on the Endangered Species list: 37 species at risk from carbaryl and 30 from methomyl. In addition, the BiOp says, “both are likely to harm or destroy many areas designated as critical habitat for endangered species.” The mitigation measures proposed by NMFS and the U.S. Environmental Protection Agency (EPA), in light of this BiOp, are likely to be inadequate to the problem, given that both compounds can drift through air and/or migrate into groundwater and generate toxic runoff. These two neurotoxic insecticides, carbaryl and methomyl, are very toxic to bees, birds, fish, and other aquatic organisms. In addition, carbaryl is a likely human carcinogen and an endocrine disruptor, and has harmful impacts on multiple bodily systems. Methomyl is […]

(Beyond Pesticides, November, 30, 2022) A petition filed last week with the U.S. Fish and Wildlife Service (USFWS) urges increased protections for the West Indian manatee after dramatic declines in its population over the last several years. In 2017, the USFWS downgraded protections for the manatee, a move that was widely criticized by conservation groups as premature. That sentiment has become a reality, with nearly 2,000 manatees dying over the last two years from a range of preventable factors. West Indian manatees, a species of manatee that includes the Florida and Antillean Manatee subspecies, were first listed under the Endangered Species Act (ESA) in 1973, at a time when there were less than 1,000 individual animals in the United States. By 2017, the number of manatees had increased to over 6,000, leading then-Interior Secretary Ryan Zinke to downlist (downgrade) the animals from endangered to threatened under ESA. ESA works to protect species by listing them as either threatened or endangered. A species classified as endangered is in danger of extinction throughout all or a significant a portion of its range and a threatened classification means the species is likely to be endangered within the foreseeable future.  Endangered species are given […]

(Beyond Pesticides, September 13, 2022) Every store-bought milkweed sample tested in a recent study contains multiple toxic pesticides, placing monarchs reliant on these plants in harm’s way at a time the species can ill afford any further loss to its population. Pollinator declines have influenced many residents throughout the U.S. to take action into their own hands and transform their home yards or businesses into an oasis for bees, birds, and butterflies. Yet the recent study published in Biological Conservation finds that many retailers are dousing their ‘wildlife-friendly’ plants with pesticides that put this vulnerable species in further danger. “That was the most shocking part,” said lead author Christopher Halsch, a doctoral study at University of Nevada, Reno. “The fact that plants labeled as potentially beneficial or at least friendly to wildlife are not better and in some cases might be worse than other plants available for purchase. This research sheds light on how pesticides may impact western monarchs, but many other butterflies are facing even steeper population declines, and pesticides are likely one driver.” Testing was conducted by purchasing milkweed plants at 33 different stores spanning 15 different states. A sample of each plant was cut after purchase, and […]

(Beyond Pesticides, September 9, 2022) One kind of solution to the biodiversity crisis that is likely not on most folk’s bingo cards comes from a Nevada cattle rancher, who has shifted his relationship with . . . wait for it . . . beavers. As climate change impacts ramp up their toll in the U.S. via intensified droughts, floods, and wildfires, solutions are widely and eagerly sought, if deployed at insufficient pace. In this Nevada case, Agee Smith — unlike his rancher father, who reportedly “waged war against the animals, frequently with dynamite” — welcomes beavers and their industry on his ranch land. Doing so has yielded multiple benefits for his operation, the environment, and biodiversity. As reported by The New York Times, “Mr. Smith has become one of a growing number of ranchers, scientists and other “beaver believers” who see the creatures not only as helpers, but as furry weapons of climate resilience.” Many landowners, of all stripes, consider beavers to be destructive “nuisance” animals that wantonly fell trees, and in so doing sometimes flood farm fields, back yards, roads, forests, or grazing acreage. Public complaints about such behaviors resulted in the federal government’s killing of more than 25,000 beavers […]

(Beyond Pesticides, August 15, 2022) Senator Cory Booker (D-NJ) and seven other 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. 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. Join eight U.S. Senators in calling for a phase out of the use of toxic pesticides in National Wildlife Refuges. “The Refuge System was established to provide sanctuary for listed threatened and endangered species, migratory birds, and other wildlife,” wrote the senators in their letter. “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 […]

(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, July 26, 2022) As monarch butterfly numbers continue to drop throughout the United States, an international conservation group is listing the migratory monarch butterfly as endangered. The move by the International Union for the Conservation of Nature (IUCN) places pressure on the U.S. Fish and Wildlife Service (FWS) to prioritize protections for this rapidly dwindling iconic species. “Today’s Red List update highlights the fragility of nature’s wonders, such as the unique spectacle of monarch butterflies migrating across thousands of kilometres,” said Bruno Oberle, PhD, IUCN Director General. “To preserve the rich diversity of nature we need effective, fairly governed protected and conserved areas, alongside decisive action to tackle climate change and restore ecosystems. In turn, conserving biodiversity supports communities by providing essential services such as food, water and sustainable jobs.” Migratory monarch butterflies are under threat from a range of factors harming both their western and eastern populations. Logging and deforestation have destroyed much of their overwintering grounds in Mexico and California. Climate change has subjected the butterflies to temperature anomalies and extremes, severe weather, and wildfires. Herbicide use has eliminated millions of acres of breeding habitat by killing off milkweed plants that monarchs require to rear their […]

(Beyond Pesticides, June 13, 2022) Birds are beautiful. They fill our world with color, song, and acrobatics. Most songbirds eat insects during the nesting season, thus contributing to management of insects in crops and gardens. It is no wonder that Rachel Carson chose their absence as an indicator of ecosystem collapse in Silent Spring. Tell your U.S. Senators to cosponsor S. 4187, the Neotropical Migratory Bird Conservation Enhancements Act. Tell your U.S. Senators and Representative to ensure that EPA does not allow pesticides that threaten birds or their insect food supply.  It’s not always easy to be a bird. About half of the world’s bird species migrate up to tens of thousands of miles each year. Whether at home or on the way to warmer climates for the winter, birds face harsh weather conditions, barriers like windows and radio towers, and the problem of storing enough energy for the flight in a tiny body. About 72 million birds are killed by pesticides and other toxic chemicals every year. In addition, pesticide use has contributed to the collapse of insect populations—the source of protein and fat that birds need to raise their young. Congress has passed laws to help prevent a […]

(Beyond Pesticides, April 29, 2022) The U.S. Fish and Wildlife Service’s (FWS’s) plan to list a rare milkweed species, and the areas in which it grows in south Texas, as critical and endangered has garnered political pushback from Texas Attorney General Ken Paxton. In February, FWS announced its intention to list 691 acres of prostrate milkweed habitat in order to protect it, given its critical role in supporting monarch butterfly populations. But Attorney General (AG) Paxton sent a letter to FWS saying that the critical and endangered determination “would further destabilize Texas’s border, hindering the construction of the border wall,” and that it would risk security on the border with Mexico. FWS countered with a press release stating that, “This listing and critical habitat proposal is based on the best available science, including a species status assessment that included input and review from academia and state agencies.” The 1973 Endangered Species Act (ESA) mandates that federal agencies, in consultation with FWS and/or the U.S. National Oceanic and Atmospheric Administration (NOAA) Fisheries Service, ensure that any actions in which they engage (whether authorizing, implementing, or funding) are unlikely to jeopardize the existence of a listed species, or have negative impacts on […]

The organic solutions to problems highlighted in the latest issue of Pesticides and You—based on the importance of healthy ecosystems and public health protection—are within reach, and the data creates an imperative for action now that phases out pesticides within a decade, while ensuring food productivity, resilient land management, and safe food, air, and water. (Beyond Pesticides, April 15, 2022) The current issue of Pesticides and You, RETROSPECTIVE 2021: A Call to Urgent Action, is a look at a year of science, policy, and advocacy that informs both the existential problems that the U.S. and the world are facing due to toxic pesticide dependency, and solutions that can be adopted now. The information in this issue captures the body of science that empowers action at the local, state, and federal level, and provides a framework for challenging toxic pesticide use and putting alternatives in place. The issue finds that 2021 was a pivotal year in both defining the problem and advancing the solution. This year in review is divided into nine sections that provide an accounting of scientific findings documenting serious pesticide-induced health and environmental effects, disproportionate risk to people of color and those with preexisting conditions, regulatory failures, at the same time […]

(Beyond Pesticides, March 30, 2022) An article by the Audubon Society covers ongoing advocacy to end pesticide spraying in wildlife refuges. Wildlife refuges act as a sanctuary, providing habitat and protection essential for the survival and recovery of species nationwide. However, portions of the wildlife sanctuary can have agricultural uses, allowing farmers to cultivate crops on various acres, subsequently applying pesticides. Pesticide spraying in or around wildlife refuges threatens the survivability and recovery of species that inhabit the area. Moreover, many of these pesticides are highly toxic to human and animal health. Analyses like these are significant, especially since the globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk. With the increasing rate of biodiversity loss, advocates say it is essential for government agencies to enforce policies that eliminate pesticide use in wildlife refuges. Ending pesticide applications in sanctuaries can protect the well-being of animals, humans, and the ecosystem. Hannah Connor, senior attorney at the Center for Biological Diversity (CBD), notes, “It’s not a huge economic driver of the refuge system, and it is truly problematic in terms of fulfilling its mission and goals[…]. That just means it should be […]

(Beyond Pesticides, March 21, 2022) With a history of unenforceable and impractical pesticide label restrictions resulting in U.S. Environmental Protection Agency (EPA) findings of ludicrously small or no risk, the agency is at it again with its latest announcement that spins its approval of the continued use of the deadly organophosphate insecticide malathion as “protecting threatened and endangered species.” This just the latest example of an irresponsible federal agency falling far short, as the nation and world sit on the brink of biodiversity collapse and deadly pesticide-induced diseases. Tell EPA to protect endangered species. Tell Congress to make sure the Biden administration protects endangered species.  The announcement follows the release of a final biological opinion by U.S. Fish and Wildlife Service (FWS), which, according to the Center for Biological Diversity (CBD), “relies on scientifically unfounded assessment methods imposed during the Trump administration [and] stands in sharp contrast to the agency’s 2017 conclusion that 1,284 species would likely be jeopardized by malathion.” Meanwhile, the National Marine Fisheries Service, a sister agency to the U.S. Fish and Wildlife Service, released an updated biological opinion that determined malathion and two other toxic organophosphate pesticides are causing jeopardy to virtually every endangered U.S. salmon, sturgeon, […]

(Beyond Pesticides, January 31, 2022) Public concern is now heightened as Florida manatees are facing extremely severe threats—so severe that wildlife officials have resorted to feeding them cabbage and lettuce in an attempt to keep their rapidly dwindling populations alive. Protecting manatees will require a multi-faceted approach, including upgrading their status to endangered and protecting their watery habitat from toxic threats. Tell the U.S. Fish and Wildlife Service to upgrade the Florida manatee to endangered and require protection from chemical pollution. Tell your Congressional Representative and Senators to support H.R. 4946. Tell Florida’s Governor DeSantis to protect manatees. Florida manatees, a subspecies of the West Indian manatee (Trichechus manatus), can live as long as 60 years old, weigh up to 1,200 lbs, and have no natural predators. The biggest threat to these peaceful marine mammals is human activity. Humans harm manatees directly through boat strikes and encounters with fishing equipment, canal locks, and other flood control structures, but the largest threat comes from chemical pollutants. In 2017, the U.S. Fish and Wildlife Service downgraded Florida manatees from fully endangered to threatened status under the Endangered Species Act. However, with recent reports indicating that over 1,000 manatees died in just the […]

(Beyond Pesticides, January 27, 2022) Wildlife officials in Florida have resorted to supplementing starving manatees with cabbage and lettuce in an attempt to keep their rapidly dwindling populations alive. Massive Red Tides exacerbated by runoff from urban and agricultural pollution have directly killed off dozens of manatees over the last several years, but the indirect effects of these harmful algae blooms have been most catastrophic, resulting in significant loss of the seagrass beds upon which manatees rely. While Florida Governor Ron DeSantis has announced plans to spend $481 million on water quality improvement projects, conservationists note that the funds are primarily directed toward point source wastewater treatment, and more is needed to address nonpoint source herbicide and fertilizer runoff from agricultural, and urban and suburban yards. Florida manatees, a subspecies of the West Indian manatee, can live as long as 60 years old, weigh up to 1,200 lbs, and have no natural predators within their range. The biggest threat to these peaceful marine mammals is human activity and environmental stressors. Unfortunately, the former is well-known to exacerbate the latter. Humans harm manatees primarily through boat strikes, but the animals can also die from eating or becoming entangled in fishing equipment, […]

(Beyond Pesticides, November 29, 2021) The U.S. Fish and Wildlife Service (FWS) is reviving its proposal to aerially apply (by helicopter) the toxic rodenticide brodifacoum to kill house mice on the Farallon Islands National Wildlife Refuge off the Northern California coast. Globally significant wildlife populations inhabit the Farallones, including hundreds of thousands of seabirds and thousands of seals and sea lions. According to FWS, these include: thirteen species seabird species that nest on the islands including Leach’s Storm-petrel, Ashy Storm-petrel, Fork-tailed Storm-petrel, Double-crested Cormorant, Brandt’s Cormorant, Pelagic Cormorant, Black Oystercatcher, Western Gull, Common Murre, Pigeon Guillemot, Cassin’s Auklet, Rhinocerous Auklet, and Tufted Puffin; pinnipeds including Northern fur seals, Steller sea lions, California sea lions, harbor seals, and northern elephant seals that breed or haul-out onto Farallon Refuge; and endemic species including white sharks, hoary bats, and arboreal salamanders. Tell the California Coastal Commission to deny the proposed aerial dispersal of the highly toxic rodenticide brodifacoum on the Farallon Islands. Brodifacoum is a “second generation anticoagulant rodenticide” (SGAR) that is highly toxic to birds, mammals, and fish. It also poses a secondary poisoning risk to predators. The California Department of Pesticide Regulation quotes the FWS: “Secondary exposure to SGARs is particularly […]

(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 […]