In several respects, EPA criticized NMFS’ revised biological opinion on 2,4-D, triclopyr butoxyethl  ester, diuron, linuron,  captan and chlorothalonil. However, EPA also commended NMFS on several changes NMFS made in this BiOp.  One of these changes is NMFS’ enhanced use of special and temporal analysis in the BiOp.  EPA recommended that NMFS continue this enhanced use in future BiOps.  In EPA’s own words, from a letter to NMFS: 

“EPA believes that NMFS’ enhanced use of spatial and temporal analysis focused on specific use patterns represents an important improvement in NMFS’ methodology to determine whether specific ESUs/DPSs have the potential to be exposed to levels of concern for a given pesticide.  Though limited in this Second Draft BiOp, EPA believes that future assessments should incorporate an expanded use of this type of analysis for all use sites for individual pesticides.  EPA continues to believe that the spatial and temporal relevance of individual use patterns is vital to making spatially explicit risk decisions and limiting the impact of mitigation options on growers and other pesticide users, while still achieving protections for listed species, and the function of such water bodies in the life cycle of the species.  Also NMFS has used additional sources of monitoring data (i.e., data provided by the Oregon Department of agriculture) in the second Draft BiOp which EPA believes provides important information to help put modeling results in context.”

EPA’s letter to NMFS may be found here.