Get the Facts on Endangered Salmon
NCAP and allies at Earthjustice and Pacific Coast Federation of Fishermen’s Associations have put together a factsheet summarizing the case for new pesticide buffer zones protecting endangered salmon.
In 2008 and 2009, the National Marine Fisheries Service (NMFS) released two “biological opinions” that set forth requirements for protecting Pacific salmon and steelhead from six toxic organophosphate and carbamate pesticides. These pesticides are the first among 37 pesticides that NMFS and EPA must assess to determine their impacts on endangered salmon and steelhead under a court order issued in 2002.
The six organophosphate and carbamate pesticides at issue are broad-spectrum neurotoxic chemicals used in both agricultural and/or urban insect control. These pesticides were found multiple times in every single water basin tested along the west coast. In some watersheds, many of these pesticides were found at levels above government standards set to protect aquatic life -sometimes at concentrations 1000 times higher than accepted levels.
In the biological opinions, federal wildlife scientists comprehensively reviewed the science regarding the impacts of pesticides on salmon and ultimately concluded that current uses of these insecticides jeopardize the existence of these imperiled fish. NMFS reached its conclusions after publishing drafts of its findings and considering comments from – and after meeting extensively with – pesticide manufacturers. The agency requested and analyzed the most current information that manufacturers, state agencies, and users were willing to provide – including voluntary measures and growers’ best practices. Because use patterns and practices change and because high levels of these pesticides are routinely found in water samples, NMFS also properly focused on the legal uses allowed by the current pesticide labels.
NMFS found that these chemicals can directly kill salmon and steelhead and also cause a number of sub-lethal and indirect effects to fish. They interfere with salmon’s ability to find their way back to their home waters to spawn, kill aquatic insects and other prey for young salmon, and make fish more susceptible to infection, parasites, disease, predation, and other secondary causes of mortality. Based on all of this evidence, NMFS found that these pesticides were likely reducing the number of salmon returning to spawn (OP BiOp at 292, Carbamate BiOp at 482-83).
In addition to jeopardizing salmon, these pesticides pose serious risks to public heath – especially the health of young children. A number of recent studies have linked prenatal exposure to organophosphate insecticides with behavioral problems, including attention deficit/hyperactivity disorder. A 2006 study published in Pediatrics, compared the risks of chlorpyrifos to prenatal cocaine exposure. Diazinon exposure has been associated with an increased risk of brain cancer in children and the cancer non- Hodgkin’s lymphoma in farmers.
We must take steps to protect salmon and the fishing communities that depend on them
The biological opinions prescribe measures necessary to keep these pesticides out of water and to protect endangered salmon and steelhead populations in Washington, Oregon, California, and Idaho. The mitigation measures include: a prohibition on aerial spraying of the pesticides within 600 - 1,000 feet of salmon waters and between 50 - 600 feet for ground sprays; and a prohibition on sprays when wind speeds exceed 10 mph. The organophosphate biological opinion also requires a 20-foot non-crop vegetative buffer around salmon waters. The measures were to be implemented within one year.
While attempting to implement these requirements, EPA has proposed changes to the protections NMFS prescribed, based on a misinterpretation of the data in the biological opinions. EPA, for example, proposed smaller buffers than NMFS a based on these incorrect assumptions. But when EPA proposed that industry implement even its more permissive buffers, the pesticide industry refused to make any changes. EPA notified the industry on April 29, 2010 that it “will pursue administrative procedures” to compel them to implement buffers. To date EPA has not put a single one of these protections in place.
Unfortunately, the chemical manufactures Dow AgroSciences, Makhteshim-Agan North America and Cheminova have balked at implementing any measures and told EPA on May 7, 2010 that they are “not now prepared to make any of the registration revisions,” needed to protect salmon because in the manufacturer’s opinion, use of these pesticides “is not taking or jeopardizing any protected species and not adversely affecting any critical habitat.” This stance flies in the face of the expert fisheries agency’s conclusion that these pesticides are jeopardizing the continued existence of salmon and steelhead. Despite the extensive public and industry involvement in the development of these biological opinions, and an over two-year delay in putting these vital protections in place, the pesticide industry and others are also seeking regulatory changes to slow this process even more and to give the pesticide industry special rights in the process, including the ability to veto protective measures.
Numerous alternatives to these pesticides already exist. Many farmers avoid the use of these heavy-handed broad-spectrum chemicals because they kill beneficial insects and can lead to greater pest problems over time. In addition, many growers already set back crops from streams – land enrolled in the USDA Conservation Reserve Program utilizes setbacks from waterbodies.
While the federal agencies may disagree over the precise details of the program, we agree with NMFS and EPA that immediate action to implement these measures is critical to the future existence of endangered salmon on the West Coast. Please tell industry and EPA to enforce the salmon buffer rules.
Susan Holmes, Earthjustice, 202-667-4500
Glen Spain, Pacific Coast Federation of Fishermen’s Associations, 541-
Aimee Code, NW Center for Alternatives to Pesticides, 541-344-5044, ext. 27