Jun 27, 2022
EPA publishes final biological evaluations for imidacloprid, clothianidin and thiamethoxam

On June 16, the U.S. Environmental Protection Agency (EPA) released the final Biological Evaluations (BE) for the neonicotinoid insecticides clothianidin, imidacloprid and thiamethoxam as part of an Endangered Species Act (ESA) evaluation that identifies potential impacts on endangered and threatened species and their critical habitats. The BE reflects a “likely to adversely affect” (LAA) determination for 67%, 79% and 77% of the listed species, respectively.

According to EPA, the LAA threshold for a BE is very conservative as the likely “take” of even one individual of a species triggers LAA (even if that species is almost recovered). This often results in a high number of “may affect” determinations in a BE. An LAA determination in the BE, however, should not be interpreted to mean that EPA has concluded that imidacloprid is putting a species in jeopardy. Those determinations are made by the National Marine Fisheries Service and the Fish and Wildlife Service.

During the comment period for clothianidin and imidacloprid, National Potato Council (NPC) and the state potato organizations submitted comments with examples of product utilization and challenges of alternative products across the nation. Bob Mattive, vice president of NPC’s Environmental Affairs Committee, stated, “It is disappointing that refinements and usage data, which were provided in comments on the draft BE, were not incorporated.”

The next stage is formal consultation with Fish and Wildlife Service and National Marine Fisheries Service. It is hoped that the Services can refine their analysis to present a realistic assessment of the impacts of these products on listed species populations.

EPA will revise the proposed interim decisions (originally published Jan. 2020) to include mitigations based on the respective BEs and publish it for public comment in early 2023. NPC will continue to monitor the process and submit comments if necessary related to the proposed interim decision.

– National Potato Council


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