(Beyond Pesticides, February 13, 2015) With the U.S. Environmental Protection Agency’s (EPA)  nod to the pesticide industry on expanded uses of the herbicides 2,4-D and glyphosate, environmental groups are charging that the agency violated the Endangered Species Act (ESA).  Repeating a pattern of putting the environment in harm’s way through violations of  federal endangered species  law, a lawsuit filed Friday  documents   EPA’s  failure to consult with the U.S. Fish and Wildlife Service (FWS) regarding the impact of the herbicide on two endangered species —the whooping crane and the Indiana bat— with the recent approval of Dow AgroSciences’ herbicide, Enlist Duo, for use on genetically engineered (GE) crops in six midwestern states. Enlist Duo is an herbicide that incorporates a mix of  glyphosate  and a new formulation of  2,4-D, intended for use on GE Enlist Duo-tolerant corn and soybean crops. Approved for use on GE corn and soybeans that are engineered to withstand repeated applications of the herbicide, the creation of 2,4-D-tolerant crops and EPA’s approval of Enlist Duo is the result of an overuse of glyphosate, an ingredient in Monsanto’s Roundup. The misuse resulted in an infestation of glyphosate-resistant super weeds which can now be legally combatted with the […]

(February 9, 2015, Beyond Pesticides) A report, Monarchs in Peril: Herbicide-Resistant Crops and the Decline of Monarch Butterflies in North America, released by Center for Food Safety (CFS) last week, reveals the devastating  impact of Monsanto’s and the nation’s biggest selling herbicide, Roundup (glyphosate), on the survival  of monarch butterflies. The herbicide is  used to treat  millions of acres of herbicide-tolerant  genetically engineered (GE) crops, eliminating the monarchs’ sole source  of food, milkweed, and approaching  a collapse of their population, which has plummeted over the past 20  years. The report cites findings that  glyphosate use on Roundup Ready  (glyphosate-tolerant) crops has nearly eradicated milkweed around farmland in the monarchs’ vital midwest breeding ground. At the urging of scientists and public interest groups, the U.S. Fish and Wildlife Service (FWS) is currently considering listing the monarch as a threatened species under the Endangered Species Act (ESA). “This report is a wake-up call. This iconic species is on the verge of extinction because of Monsanto’s Roundup Ready crop system,” said Andrew Kimbrell, executive director at Center for Food Safety. “To let the monarch butterfly die out in order to allow Monsanto to sell its signature herbicide for a few more years is […]

(Beyond Pesticides, January 6, 2015) At the close of 2014, the U.S. Fish and Wildlife Service (FWS) announced plans to conduct a year-long status review of the monarch butterfly to determine whether the species is eligible for protection under the Endangered Species Act (ESA). FWS is taking this action as result of an August 2014 legal petition filed by health and environmental groups that presented substantial information indicating that listing under the ESA may be warranted. In November 2014, Beyond Pesticides joined over 200 environmental groups and businesses in a letter asking for federal protection for monarch butterflies in the wake of shocking declines. The North American monarch butterfly population fell by 90 percent in the past 20 years, dropping from a high of approximately  one billion in the mid-1990s to fewer than 35 million butterflies in the winter of 2013-2014— the lowest number ever recorded. Each year monarch butterflies travel over 2,000 miles between Canada, the U.S., and Mexico, across multiple generations, to reach their winter hibernation grounds in late October. As FWS indicates, this journey has become “more perilous for many monarchs” due to threats along their migratory paths. Scientists believe the butterfly’s decline is being driven in […]

(Beyond Pesticides, November 14, 2014) In the face of staggering declines of monarch butterflies, more than 40 leading scientists and 200 organizations and businesses this week urged the Secretary of the Department of the Interior, Sally Jewell, to protect these butterflies under the Endangered Species Act (ESA). These groups and scientists are supporting the formal petition to the U.S. Fish and Wildlife Service (FWS) submitted this summer, which seeks federal protection for monarch butterflies. Forty scientists from around the U.S. and Mexico signed on to a letter requesting protected status for the butterflies and for FWS to recognize the importance of continued research by scientists and citizen scientists in understanding and conserving the monarch butterfly and its habitat. The scientists also request FWS to streamline the permitting process, so that scientific and conservation research and citizen science activities are encouraged rather than deterred by a listing. In a separate letter, over 200 environmental groups and businesses called on FWS to take swift and effective action by granting the monarch butterfly protection as a threatened species under the ESA. Both letters come in support of a formal petition to FWS seeking federal protection for monarchs. The petition was filed in August […]

(Beyond Pesticides, October 23, 2014) Lawsuit filed against Environmental Protection Agency for approval of 2,4-D use on genetically engineered corn, soy crops in six Midwest states.A coalition of farmers and environmental groups filed a lawsuit to sue the U.S. Environmental Protection Agency (EPA) today on behalf of six Midwest states where a toxic herbicide cocktail called Dow’s Enlist Duo, a blend of glyphosate and 2,4-D, was approved on October 15 for use on genetically engineered (GE) crops. Approved for use on GE corn and soybeans that are engineered to withstand repeated applications of the herbicide, the creation of 2,4-D-resistant crops and EPA’s approval of Enlist Duo is the result of an overuse of glyphosate, an ingredient in Monsanto’s Roundup. The misuse resulted in an infestation of glyphosate-resistant super weeds which can now be legally combatted with the more potent 2,4-D. Dow Chemical has presented 2,4-D resistant crops as a quick fix to the problem, but independent scientists, as well as USDA analysis, predict that the Enlist crop system will only foster more weed resistance. “The toxic treadmill has to stop,” said Jay Feldman, executive director of Beyond Pesticides. “EPA and USDA cannot continue to ignore the history, science, and public […]

(Beyond Pesticides, October 21, 2014) Due in large part to the use of rodenticides in the cultivation of illegal marijuana grow operations, earlier this month the U.S. Fish and Wildlife Service (FWS) announced a proposal to list fishers, medium sized carnivores of the weasel family, as threatened under the Endangered Species Act. Fishers are the second species in the West that have been recognized by regulators as adversely affected  by illegal marijuana grow operations. Coho salmon have also been affected as a result of pesticide and fertilizer use, water withdrawals, and clear-cut logging that have silted, dried up, and polluted streams where the salmon run. Fishers, which are found throughout North America and have been part of the forests in Pacific states for thousands of years, have all but virtually disappeared in much of Washington, Oregon and California, according to FWS. Illegal marijuana grow operations have been a troubling source of wildlife deaths as growers often use “industrial-sized quantities of poison in forests to fend off rodents,” says Humboldt County District Supervisor Rex Bohn. A study published in PLOS One in 2012 found that 79% of fishers surrounding an illegal marijuana grow operation had been exposed to anticoagulant rodenticides. Fishers […]

(Beyond Pesticides, August 29, 2014) Environmentalists issued a legal petition to the U.S. Fish and Wildlife Service on Tuesday calling for the protection of the monarch butterfly as a threatened species under the  Endangered Species Act (ESA). Monarch butterflies, a striking and familiar symbol of beauty and nature in the U.S., have had their population decline by a staggering 90 percent in the past two decades alone, most likely due to a significant loss of habitat of more than 165 million acres – an area about the size of Texas -as well as nearly a third of their summer breeding grounds. Part of the decline of monarch butterflies  stems from the loss of milkweed, a native plant where the butterflies lay their eggs and is their main food source. Although little use to farmers, milkweed is an important plant to butterflies, wasps, and bees. A recent study attributed the disappearance of milkweed plants primarily to the use of genetically-engineered (GE) corn and soybean crops. The widespread adoption of GE agriculture and the ever-growing use of herbicides are contributing extensively to the loss of milkweed areas. Scientists also point to the prolific use of herbicides in the Midwest eliminating these plants, […]

(Beyond Pesticides, July 17, 2014) The U.S. Fish and Wildlife Service (FWS) issued an internal memorandum last week that  signals a significant shift in its pesticide-application policies for Pacific Region wildlife refuges: no more neonicotinoids. The memorandum, dated July 9, 2014, states, “The Pacific Region will begin a phased approach to eliminate the use of neonicotinoid insecticides (by any method) to grow agricultural crops for wildlife on National Wildlife Refuge System lands, effectively immediately. By January 2016, Region 1 will no longer use neonicotinoid pesticides in any agricultural activity.” In February 2014, environmental groups, including Beyond Pesticides, filed a legal petition to ban the use of neonicotinoids on wildlife refuges. The new guidelines go on to explain that the change in policy will also affect the transition period through 2016. During that time, refuge managers must exhaust all remedies before application or use of neonicotinoids, including the use of neonicotinoid-treated seeds. Additionally, starting in 2015 all refuge managers must prepare and submit a Pesticide Use Proposal (PUP) in order to apply any neonicotinoids during the transition to the ban. While not a direct response to the petition filed earlier this year calling for a ban of genetically-engineered crops and neonicotinoids […]

(Beyond Pesticides, June 6, 2014) On June 4,  after a two year dispute between the Environmental Protection Agency (EPA) and a coalition of conservation organizations and fishing groups, an agreement  was finally reached to set reasonable no-spray buffer zones to protect salmon from five harmful insecticides: diazinon, chlorpyrifos, malathion, carbaryl, and methomyl. These buffer zones protect salmon habitat by stopping aerial spraying of pesticides within 300 feet, and ground based spraying within 60 feet of salmon supporting waters. According to the agreement, it also provides detailed notifications to state regulators, pesticide applicators, farmers and the public about the mandatory no-spray buffer zones. These stipulations will remain in place until the National Marine Fisheries Service has completed their analysis of the impacts of those five pesticides.  Then, once the analysis is completed, EPA will execute permanent protections based on their findings. EPA is required by law under the Endangered Species Act to protect what little salmon are left on the Pacific Coast. Salmon are a  critical indicator of how well we are maintaining both marine and terrestrial ecosystems, because their habitats are in streams, lakes, rivers, estuaries and the ocean. The fish  are extremely sensitive to changes in water quality, and […]

(Beyond Pesticides, March 26, 2014) Conservation and food-safety groups filed a formal notice of intent to sue the U.S. Environmental Protection Agency (EPA) on Monday for failing to protect hundreds of endangered fish, butterflies and other species from a new, toxic pesticide, cyantraniliprole. The suit claims EPA violated the Endangered Species Act (ESA) by approving the widespread agricultural and residential use of the new pesticide in January without input from the U.S. Fish and Wildlife Service and National Marine Fisheries Service, the two federal agencies in charge of protecting endangered species. The Notice of Intent to Sue is being filed by the Center for Biological Diversity,  Center for Food Safety, and Defenders of Wildlife. Cyantraniliprole, a new, systemic insecticide, was formally registered by the EPA earlier this year. Despite evidence that cyantraniliprole is toxic to honey bees, EPA’s registration document for cyantraniliprole finds that, “There is a reasonable certainty that no harm will result from aggregate exposure to the pesticide residue.” According  to EPA’s assessment the pesticide is also slightly to very highly toxic to aquatic organisms. Comments from beekeepers and concerned groups, including Beyond Pesticides, urged EPA not the grant registration, given the toxic nature of the pesticide and […]

(Beyond Pesticides, March 12, 2014) As many as 700 birds have been found dead in a wildlife reserve in New South Wales, Australia. Preliminary tests reveal that the pesticide, fenthion, was the cause of death for many little correlas, galahs and sulphur-crested cockatoos found over the past two weeks. Certain uses of fenthion for home gardens and a range of agricultural uses were scheduled for suspension by the Australian Government, but a few months ago fenthion use, long associated with bird kills, was extended for another year. For the past two weeks, dead birds have been found all along a mile of Troy Reserve on the Talbragar River, in New South Wales, Australia. Testing of samples from the dead birds indicated fenthion, an organophosphate insecticide highly toxic to birds, as the most likely cause of the deaths. Volunteers helped gather the carcasses to prevent raptors, such as whistling kites and tawny frogmouths, from feeding on the poisoned carrion. About 30 sick birds, including two kites, have been so far been rescued. Locals found the first deaths on February 27 but were initially prevented from collecting the carcasses out of concern about possible bird flu. About 200 dead birds were found […]

(Beyond Pesticides, February 27, 2014) Beyond Pesticides joined Center for Food Safety (CFS), Public Employees for Environmental Responsibility (PEER), and Center for Biological Diversityearlier this week in filing a formal petition for rulemaking with the U.S. Department of the Interior (DOI). The petition demands that the U.S. Fish and Wildlife Service (FWS), the DOI bureau tasked with managing and regulating the system of National Wildlife Refuges (NWRs) across this country, establish better protections for wildlife and their habitat by prohibiting the use of genetically engineered (GE) crops and neonicotinoid pesticides in NWRs as well as other necessary policy changes. The petition asserts that the allowed cultivation of GE crops and use of neonicotinoid pesticides on lands designated as NWRs violates not only the purpose and protective standards of the National Wildlife Refuge Act (NWRA), which seeks to conserve, manage and restore fish wildlife, and plant resources and their habitats for the present and future generations, but also threatens endangered species by resulting in destruction of critical habitat protected under the Endangered Species Act (ESA). Specifically, pollen from GE crops drift and contaminate related wild plants and natural crops. There is also the problem that GE crops are overwhelmingly engineered for […]

(Beyond Pesticides, January 13, 2013) As medical and recreational production of marijuana in the U.S. increases, new and complicated questions have risen over how to limit consumers’ exposure to pesticides through marijuana consumption. Many growers are facing limited institutional knowledge and economic forces that could lead to the unnecessary use of pesticides. States are also still wrestling with the adequate  regulation of production and testing practices. Exposure to pesticides from marijuana consumption may also be more harmful than exposure through food consumption when consumed through inhalation. As marijuana consumption becomes more widely legalized, many are calling for  stronger safety standards for marijuana production. Alan Schreiber, Ph.D., President of the Agriculture Development Group, believes that the legalization of recreational marijuana use in Colorado and Washington will lead to immense demand for pest prevention research. Currently, growers of marijuana lack institutional assistance from federal agencies or state agricultural extension services, which have limited understanding of marijuana production. There is a concern that the lack of  field research and increased demand may lead to heavy pesticide use. In Washington, the state will allow the equivalent of 46 acres to be grown for recreational use, a factor that Dr.. Schreiber says will drive most […]

(Beyond Pesticides, November 19, 2013) Last week, the Environmental Protection Agency (EPA), the U .S. Department of Agriculture (USDA), Fish and Wildlife Service (FWS), and National Marine Fisheries Service (NMFS) released a white paper identifying how they plan to reconfigure the pesticide review process to meet the pesticide approval requirements for the Endangered Species Act (ESA). The new approach outlined in the white paper incorporates suggestions from the National Academy of Sciences’ Research Council (NRC) report released last May. The white paper is a step towards overhauling a deeply flawed process, though there will be several challenges to implementing this new approach for the agencies moving forward. Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), before a pesticide can be sold, distributed, or used in the U.S., EPA is required to determine that the pesticide does not cause unreasonable adverse effects on the environment. However, in the case of species listed as endangered or threatened under the ESA, all federal agencies, including EPA, are required to ensure that their actions will not jeopardize the continued existence of a listed species by diminishing the species’ numbers and reproduction. To do this, in its pesticide registration process, EPA is required to […]

(Beyond Pesticides, November 6, 2013) A federal district court approved a settlement Monday requiring the U.S. Fish and Wildlife Service to better protect California red-legged frogs from seven common pesticides known to be highly toxic to amphibians. The settlement gives the agency two years to prepare “biological opinions” under the Endangered Species Act (ESA) to analyze pesticide use in and near the frog’s aquatic and upland habitats.   A 2006 legal settlement secured by the Center for Biological Diversity (CBD) required the U.S. Environmental Protection Agency (EPA) to assess pesticide impacts on red-legged frogs and to then formally consult with the Fish and Wildlife Service (FWS) under the ESA. The EPA’s assessments found that widespread use of pesticides is likely harming red-legged frogs and the court ordered temporary pesticide use restrictions that remain in effect today. EPA determined that 64 other pesticides are “likely to adversely affect” or “may affect” red-legged frogs. Despite the EPA’s findings, however, FWS and EPA failed to complete the required consultation, resulting in the litigation by CBD that culminated in Monday’s settlement. The court order gives FWS two years to complete biological opinions for seven pesticides: glyphosate, malathion, simazine, pendimethalin, permethrin, methomyl and myclobutanil. This […]

(Beyond Pesticides, July 9, 2013) A recent pesticide contamination incident in Great Britain’s Kennet River has decimated aquatic invertebrate populations on a ten mile stretch of river between the towns of  Marlborough and Hungerford. The contamination occurred after a spill of the toxic pesticide chlorpyrifos entered a Marlborough sewage system. The lack of aquatic invertebrates could lead to a dramatic decline of the river’s chalk trout population. A similar incident occurred in Great Britain on the Wey River in 2003, and in Sussex Ouse in 2001. This recent calamity helps to underscore the importance for the U.S. Environmental Protection Agency (EPA), across the Atlantic, to fully implement pesticide restrictions that U.S. conservation groups are seeking to enforce through court action. The damage to the U.K. river may have been caused by, according to an Express article, only two tablespoons of the neurotoxic insecticide chlorpyifos. Members of the public have been advised by Britain’s Environment Agency to avoid skin contact with the water and not to eat fish caught from the river.  The contamination has occurred at the height of fly-fishing season. Environmental organizations are afraid that a decline in the number of aquatic invertebrates could lead chalk trout and other […]

(Beyond Pesticides, July 3, 2013) In light of recent action in Europe to suspend to use of certain neonicotinoid pesticides, Beyond Pesticides joined 12 other environmental and advocacy organizations in urging the Obama administration to direct the U.S. Environmental Protection Agency (EPA) to follow the European Union’s (EU) lead in recognizing that risks posed by these pesticides are unacceptably high, and suspend the use of these chemicals in the U.S. to protect pollinators and the nation’s agricultural economy. The letter urges the Obama administration to not only direct EPA to follow Europe’s lead in suspending certain neonicotinoid pesticides uses, but requests even more protective measures, including a minimum two-year suspension for all outdoor uses of neonicotinoid insecticides pending resolution of their hazards to bees and beneficial organisms. Highlighting the negative environmental and economic impacts of outdoor uses of the EPA-approved neonicotinoid insecticides: imidacloprid, clothianidin  , thiamethoxam, dinetofuran and acetamiprid, as well as a recognition that the initial risk assessments for these chemicals fail to adequately consider key risks to bee health, the letter to President Obama notes that it, “would not be responsible to continue to allow these threatening compounds to be used so broadly.” On average, U.S. beekeepers lost […]

(Beyond Pesticides, May 2, 2013) A committee of the National Academy of Sciences’ Research Council (NRC) issued a new report that outlines steps to improve regulatory problems associated with pesticides that harm endangered and threatened species. The report, Evaluating Risks That Pesticides Pose to Endangered, Threatened Species — New Report  suggests the need to overhaul  EPA’s deeply flawed pesticide approval process. Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), before a pesticide can be sold, distributed, or used in the United States, the U.S. Environmental Protection Agency (EPA) is required to determine  that the pesticide does not cause unreasonable adverse effects on the environment. However,  in the case of species  listed as endangered or threatened under  the U.S. Endangered Species Act (ESA), all federal agencies, including  EPA,  are required to ensure that their actions will not jeopardize the continued existence of a listed species by diminishing the species’ numbers and  reproduction. To do this, in its pesticide registration process,  EPA is required to consult with the Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) when a federal action may adversely  affect a listed species or its habitat. Over the last decade, questions have been raised regarding […]

(Beyond Pesticides, February 27, 2013) Last week a U.S. Court of Appeals found that pesticide restrictions to protect endangered salmon and steelhead proposed by the National Marine Fisheries Service (NMFS) in its Biological Opinion (BiOp) were “arbitrary and capricious,” supporting Dow AgroSciences LLC and other pesticide makers’ claims that the restrictions were based on “unsupported assumptions and conclusions.” The BiOp concluded that the pesticides chlorpyrifos, malathion and diazinon, three of the most highly toxic pesticides still in use, pose risks to salmon, steelhead and their habitat. In collaboration with NMFS, the U.S. Environmental Protection Agency (EPA) is tasked with implementation of any recommended pesticide restrictions to satisfy the mandate under Section 7 of the Endangered Species Act (ESA). However, to date, EPA has not taken any actions to implement any of the proposed measures to protect endangered salmon and steelhead, in part due to challenges from industry. Dow AgroScience LLC, Makhteshim Agan of North America, Inc., and Cheminova, Inc. USA first filed a suit in 2009 (Dow Agrosciences v. National Marine Fisheries ), challenging the NMFS’ 2008 BiOp to restrict  chlorpyrifos, malathion and diazinon as being based on numerous unsupported assumptions and conclusions, and faulty analyses. The U.S. District Court […]

(Beyond Pesticides, November 1, 2012) Conservation groups and fisherman have filed lawsuits against U.S. Environmental Protection Agency (EPA) demanding that pesticide restrictions be implemented around salmon streams. Regulatory buffers surrounding streams and watersheds have not been fully implemented by EPA, though it is required to by law. The National Marine Fisheries Service (NMFS), which promotes sustainable fisheries, recovery of protected species, and the health of coastal marine habitats, commented that common pesticides should not be sprayed within 500 to 1000 feet of waterways. Its comments focused on the impacts of chlorpyrifos, diazinon and malathion, which jeopardize the health of federally protected salmon species. Despite this and other evidence that supports the need for buffer zones, EPA has withheld action until the 4th U.S. Circuit Court of Appeals resolves the case. EPA is mandated by law to protect dwindling species like salmon under the Endangered Species Act. Salmon, in particular, are a good indicator of how well we are taking care of both the marine and terrestrial ecosystems, because they live in streams, lakes, rivers, estuaries, and open ocean. They are also extremely sensitive to changes in water quality and upstream changes to the river flow, turbidity, and temperature. It goes […]

(Beyond Pesticides, September 18, 2012) Take Action! On September 25, EPA will close its public comment period for the petition requesting the agency to suspend the bee-killing pesticide clothianidin. The U.S Environmental Protection Agency (EPA) has failed to recognize that pollinators face unique hazards from clothianidin, a neonicotinoid pesticide which is linked to disruptions in bee mobility, navigation, and feeding behavior. So far thousands of concerned beekeepers, gardeners, hobbyists and folks like you have told EPA to suspend clothianidin and protect pollinators now! Without your support, clothianidin’s effects on honey bees will continue to put beekeepers, rural economies, and our food system at risk. With one in three bites of food reliant on honey bee pollination, it’s imperative that we act now! Tell EPA to suspend the use of the bee-killer clothianidin and protect pollinators. See sample comments here. If you are having trouble submitting to the docket, click here. Background Colony Collapse Disorder (CCD) is the name given to the mysterious decline of honey bee populations around the world beginning in 2006. On average, the U.S. Department of Agriculture (USDA) reports that beekeepers have been losing over 30% of their honey bee colonies each year—but some are losing many […]

(Beyond Pesticides, September 7, 2012) Yesterday, Beyond Pesticides joined with the Center for Food Safety and the Sierra Club, along with beekeepers from around the country, to file a 60-Day Notice letter with the Environmental Protection Agency (EPA) announcing the intent to jointly sue the agency for Endangered Species Act (ESA) violations. The potential lawsuit highlights EPA’s continuing failure to ensure, through consultation with the U.S. Fish and Wildlife Service, that its numerous product approvals for the neonicotinoid insecticides clothianidin and thiamethoxam are not likely to jeopardize any federally-listed threatened or endangered species. “EPA has failed to uphold the clear standards of the Endangered Species Act,” said Peter Jenkins, attorney at the Center for Food Safety. “By continuing to ignore the growing number of reports and studies demonstrating the risks of neonicotinoids to honey bees and a large number of already threatened and endangered species, the EPA is exposing these already compromised populations to potentially irreversible harm.” The Notice of Intent to Sue follows a legal petition previously filed by several environmental organizations and more than two dozen beekeepers requesting that EPA immediately suspend use of the chemical clothianidin that poses fatal harm to pollinators. While refusing to issue an […]

(Beyond Pesticides, August 30, 2012) The U.S. Environmental Protection Agency (EPA) announced on August 17 that it is seeking comments on a proposal developed jointly with the U.S. Department of Agriculture (USDA), the National Marine Fisheries Service (NMFS), and the U.S. Fish and Wildlife Service (FWS) to enhance opportunities for stakeholder input during pesticide registration reviews and endangered species consultations. The proposal specifically emphasizes coordination across federal agencies and expanding USDA’s role, as well as pesticide users to provide current pesticide use information to EPA’s ecological risk assessments. The proposal describes EPA’s plan to reach out to potentially affected pesticide users to discuss the technical and economic feasibility of draft Reasonable and Prudent Alternatives (RPAs) intended to avoid jeopardy to threatened and/or endangered species. It also describes the process by which public comments received on RPAs will be summarized and organized by EPA and provided to the Services, which will prepare a document to be included in the administrative record of the consultation explaining how comments were considered, and if appropriate, how the final biological opinion was modified to address the comments. The Services will provide the document to EPA, and both the Services and EPA will make the document […]