Strategy to Protect Endangered Species from Insecticides
Similar to the EPA’s Herbicide Strategy, the Insecticide Strategy is designed to identify early mitigations before the agency completes effects determinations to reduce potential impacts to federally endangered and threatened (listed) species and their designated critical habitat from the agricultural use of conventional insecticides while helping to ensure the continued availability of these important pesticide tools. As part of this strategy, EPA is developing a framework to assess potential impacts of specific insecticides to listed aquatic and terrestrial invertebrates as well as impacts to those listed species that rely on aquatic and terrestrial invertebrates as prey or for pollination services and identify any needed mitigations. The Insecticide Strategy itself would not impose any requirements on pesticide users and it is not a rulemaking action. The Insecticide Strategy represents a framework that EPA expects would inform the existing mechanisms EPA uses to register and re-register pesticides. In addition, EPA expects that the Strategy would increase the efficiency of future ESA consultations on insecticides with the U.S. Fish and Wildlife Service (FWS), which has authority over most listed species that could benefit from the Strategy.
The Draft Insecticide Strategy
This draft identifies protections that EPA will consider when it registers a new insecticide or reevaluates an existing one. The draft Insecticide Strategy includes:
- an introduction including the scope of the strategy;
- the draft framework that EPA expects to use to identify potential population-level impacts, identify mitigation measures to address these impacts, and determine the geographic extent of the mitigation measures;
- case studies to illustrate how the framework could be applied to representative insecticides; and
- how EPA expects to implement the strategy in its registration and registration review actions.
This draft strategy incorporates lessons learned from EPA’s draft herbicide strategy, which the agency released last year to minimize the impacts of agricultural herbicides on hundreds of listed species. For example, based on feedback received on the draft herbicide strategy, EPA designed the mitigations in the draft insecticide strategy to maximize the number of options for farmers and other pesticide users when implementing the mitigation. These mitigation options also consider farmers who are already implementing measures to reduce pesticide runoff and those who are located in areas less prone to pesticide runoff, such as flat lands and regions with less rain to carry pesticides off fields. These measures also include the U.S. Department of Agriculture’s Natural Resources Conservation Service practices and state or private stewardship measures that are effective at reducing pesticide runoff.
Similar to the herbicide strategy, the draft insecticide strategy uses the most updated information and processes to determine whether an insecticide will impact over 900 listed species and identify protections to address any impacts. To determine impacts, the draft strategy considers where a species lives, what it needs to reproduce (e.g., for food or pollinators), where the pesticide will end up in the environment, and what kind of impacts the pesticide might have if it reaches the species. These refinements greatly reduce the need for pesticide restrictions in situations that do not benefit species.
The draft Insecticide Strategy and accompanying support documents are available in docket EPA-HQ-OPP-2024-0299 for public comment for 60 days.