Industry Misinformation Exposed
When the National Marine Fisheries Service (NMFS) recently concluded that several common pesticides were harmful to endangered fish, Dow Agrosciences and other pesticide manufacturers responded with a lawsuit arguing that the science was faulty. Last week, NCAP and allies submitted detailed testimony which systematically refutes their false claims.
The major arguments are outlined in the brief as follows:
NMFS properly reported and considered a range of data on harmful pesticide concentrations.
- NMFS examined all lethal concentration values in the best available
data, but did not let a single value drive its initial assessment. - NMFS considered the best available science on salmonid exposures.
NMFS rationally considered the best available water monitoring data to help assess exposure.
- NMFS properly considered the best available data from the exposure.
- NMFS did not rely on the lowest-end effects concentrations in its population models.
NMFS explained the rationale for the reasonable and prudent alternatives to protect fish.
NMFS adequately considered, and where appropriate, responded to comments.
Click here to read them in full detail.
