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The Environmental Protection Agency (EPA) recently released its Draft Revised Method for National Level Endangered Species Risk Assessment Process for Biological Evaluations of Pesticides. This proposal updates the to pesticide consultations under section 7 of the Endangered Species Act (ESA) that have been in place since 2015. While we appreciate the need to provide additional guidance and clarity, we find numerous problems with the EPA’s proposal. As written, this guidance is woefully inadequate to ensure the protection of federally listed threatened and endangered species. Our goal in these comments is to help EPA identify these problems and then provide recommendations on how to resolve them. We organize our comments in the order of the major analytical steps, but first note problems common to the whole document.
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