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Regarding: 1018-AI95, Counterpart Regulations
I am writing today to voice my opposition to your agency's proposed “counterpart regulations,” backed by the Bush administration, which weaken protections for fish and wildlife from the hazards of toxic pesticides.
The proposed rule, issued on January 30, 2004, will undermine the basic protections set forth in the Endangered Species Act by shutting out of the pesticide risk assessment process the expert agencies whose involvement adds much needed expertise on wildlife and their habitat.
The EPA is supposed to consult with the federal fish and wildlife agencies to assess the effect of new pesticide use on endangered wildlife prior to approving the use. Although this mandated consultation process has not always occurred, I do not agree that getting rid of the requirement is the way to solve the problem. We should be finding better ways to facilitate more communication between the expert agencies and the EPA, not less. The proposed rules are touted by industry as making the EPA consultation requirements more “efficient and timely,” but removing expert consultations is not the way to accomplish this.
Endangered species need greater, not weaker, protections from toxic pesticides. Pesticides kill millions of fish and other species each year. Salmon in the Pacific Northwest, piping plovers in Florida, and San Joaquin kit foxes and golden eagles in California are just a few of the species that have suffered due to pesticide applications in recent years. The U.S. Fish and Wildlife Service and NOAA Fisheries must contribute their expertise and use their authority to ensure sufficient protections are put in place.
I strongly oppose the proposed counterpart regulations and do not want the EPA to be the sole agency in charge of protecting endangered species from pesticides. I urge you to withdraw the proposed rule change.
Thank you for your consideration.
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