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Biological Opinion Doesn't Help Environment by Jay Vroom, Guest Comment Capital Press, August 22, 2008

Recently, the National Marine Fisheries Services released a draft biological opinion under the terms of a settlement agreement that required them to respond to the Environmental Protection Agency on the three insecticides chloripyrifos, diazinon and malathion with respect to their potential effects on threatened and endangered salmon.

This opinion claimed "overwhelming evidence" supported their opinion that the use of these agricultural pesticides interferes with fishes' ability to find food, reproduce and even swim.

Though the report's intent is to provide useful information toward safeguarding marine species and habitats, it greatly overstates the predicted risk of the use of highly regulated, registered and essential crop protection products, circumvents the intent of interagency consultation and unnecessarily alarms the public.

In fact, hydrological manipulation, habitat destruction and hatchery operations continue to be indentified as top influences adversely affecting ESA-listed salmon and their environment.

All pesticides, whatever their use, must undergo a rigorous and lengthy testing process by the EPA to ensure they cause no unreasonable adverse effects on the environment and human health. Hundreds of scientists at EPA's Office of Pesticide Programs daily evaluate data based on best available science and stringent regulations that require numerous studies on every pesticide active ingredient registered.

However, the NMFS draft biological opinion ignores the peer-reviewed findings of EPA scientists and introduces unfounded assumptions about these products and their potential to affect salmon.

Rather than respecting the enormous scientific input by pesticide registrants and stringent review and collection of data by EPA to develop its opinion, NMFS set aside EPA's assessment and instead used incorrect data and obsolete labels to evaluate cancelled uses and application practices that are no longer employed.

EPA's ongoing re-evaluation process has already specified lower application rates, fewer use sites and other restrictions for these products, minimizing any potential risk of well-established crop protection products indispensible to the creation of sustainable American agriculture.

NMFS' release of this draft biological opinion prior to receiving additional input from knowledgeable parties - such as EPA and product registrants - regrettably wastes both the Service's and Agency's limited resources.

Its use of an unvalidated, unpublished, non-peer reviewed population model to generate predicted population effects in or near the habitat occupied by salmon in the Pacific Northwest misleads the public and does not reflect good science.

As production demands on farmers increase to meet the renewable fuel, fiber and food needs of a growing global population, crop protection products play a vital role in increasing agricultural productivity and improving the quality of life for all Americans.

Such products also allow sustainable increases in food production without a reduction in wildlife habitat.

Our industry continues to be a partner in positively impacting agriculture while being responsible stewards of the environment. To achieve these goals we must work together with government agencies to ensure the safety and effectiveness of our products.

NMFS' inadequate evaluation of data results in an incorrect overstatement of exaggerated risk as "fact." This misleads the public and undermines the credibility of all agencies involved, and does little to advance the goal of protection of species or the environment.

Moving forward, it is imperative NMFS use the best available sound science and work in cooperation with the EPA and registrants to certify the most accurate data is used before finalizing their opinion based on review of EPA's risk assessment; this ensures all agencies involved, as well as the public, have a clear and correct understanding of their impact.