AMCA's L&R Committee worked with industry partners, registrants to submit a substantial comment on the EPA's Vulnerable Species Pilot Program https://storymaps.arcgis.com/collections/896d140363174c9d8ee78e4c471bd7fd?item=1
. For the EPA’s Vulnerable Species Pilot, the Agency identified an initial set of “pilot” listed species and is proposing pesticide mitigation measures designed to reduce their exposures to conventional pesticides from non-residential outdoor uses of those pesticides (e.g., agricultural, rights of way, mosquito adulticide). The pilot species were deemed particularly vulnerable to the potential effects of pesticides due to a combination of factors including a limited geographic range, small population size, and general susceptibility to environmental stressors where effects to even a small number of individuals may be highly impactful to populations or the entire species. EPA proposed that the mitigations would apply to the majority of conventional outdoor-use pesticides.
AMCA submitted a detailed comment to provide examples of why this Pilot Project would be detrimental to our profession. Our position is that mosquito control applications should be considered as a separate use type when developing ESA interim mitigation measures and not included in the Pilot Project. The Agency has recently completed a Malathion consultation pertaining to adult mosquito control. During that process, the Agency, the Services, the registrant, and the stakeholders all reached a cooperative agreement on ESA mitigations. Those mitigations represent a scientifically supported compromise between protecting public health and protecting endangered species. AMCA urged EPA to utilize the results of the recent Malathion consultation for all wide area, ULV applications to manage adult mosquitoes. Furthermore, due to their vastly different mode of action and targeted nature, mosquito larvicide applications should be considered as their own use type.
EPA will review all comments and finalize their plan at the end of this year. We'll stay on top of this and all regulatory issues facing our industry.