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32 GOLF COURSE MANAGEMENT 01.17 (advocacy) Stuart Z. Cohen, Ph.D. firstname.lastname@example.org More pesticide restrictions possible under endangered species review Golf course superintendents may find themselves impacted by ongoing pesticide endangered species assessments. On April 11, 2016, the EPA's Office of Pesticide Pro - grams (OPP) published a notice of avail- ability of draft Biological Evaluations of chlorpyrifos, diazinon and malathion (EPA- HQ-OPP-2016-0167). This magnum opus of 70-plus documents per chemical that de - scribes determinations of potential impacts of three insecticides on approximately 1,800 listed species was just an interim step. As this article went to press, the next step in this court-mandated process was the scheduled publication of final Biological Evaluations in December regarding potential impacts on members of a listed species. Draft Biological Opinions on the likelihood that the pesticides will jeopardize the listed species populations will come in April 2017, with the final Biolog - ical Opinions scheduled for December 2017. ("Listed," in this context, means that the spe - cies are federally designated as endangered or threatened, or are proposed pursuant to the Endangered Species Act.) The EPA is also scheduled to assess glyphosate (Roundup), simazine, atrazine and propazine in the near future. This overall risk-assessment process was developed jointly by the National Marine Fisheries Service (NOAA), the Fish & Wild - life Service (DOI), and OPP (EPA). OPP determined that approximately 80 to 97 percent of the listed species are likely to be adversely affected, depending on the chemical. The Biological Evaluation (BE) process was intended to focus on problems that needed solving, but the process that has been devel - oped is instead analogous to casting a wide net with a fine mesh over a large population. As a result, enormous EPA resources are being con - sumed — and will continue to be consumed — until this broken process is fixed. How did we reach this point in the pro - cess? One answer, from the 30,000-foot per- spective, is the overall approach that links a series of low-probability assumptions. Prob - abilities are multiplicative, not additive; i.e., P 0.1 × P 0.1 × P 0.1 = P 0.001 . A series of worst-case assumptions will tend to yield overly conser - vative conclusions. A more specific answer is that the pro - cess to model pesticides in surface water from stormwater runoff and spray drift is overly conservative. To their credit, the scientists in OPP's Environmental Fate & Effects Division mostly recognize this. Overly conservative modeling of flowing streams. The BEs predict concentrations of chlorpyrifos that exceed its water solubility limit. More important, modeled concentra - tions significantly exceed monitored concen- trations. The biggest problem acknowledged by OPP scientists is that the modeled predictions for the freshwater flowing water scenarios ("bins") exceed the water solubility limit and the monitored concentrations for chlorpyrifos, for example, by several orders of magnitude. In fact, OPP states in the chlorpyrifos BE: "Taken together, there is little confidence in the estimates derived for bins 3 and 4 (fresh - water flowing water)." The reasons for these overpredictions are many. For example, all sites in a very large wa - tershed are assumed to be treated on the same day. All farm fields and urban/suburban treat - ment areas are assumed to be prone to runoff. Each modeled area is assumed to have all of a crop treated with the subject pesticide. All en - vironmental persistence parameters are input at the upper 90th percentile. Overly conservative modeling of estuarine and marine environments. This will be a much shorter analysis, because there is much less to analyze. The three aquatic bins (scenarios) in this category are intertidal nearshore, subtidal nearshore, and offshore marine. But OPP has not constructed modeling scenarios for these three environments. Instead, OPP scientists are using five of the other static and flowing water bins as surrogates. This leads to unrea - sonable overestimates as well. For example, bin 5 is used to model tidal pools. It is 0.1 meter deep × 1 meter wide × 1 meter long, and it contains no process for flushing due to over - land stormwater runoff or the twice-per-day flood (incoming) tide. OPP scientists have acknowledged this de - ficiency in estuarine/marine scenarios. As a result, several of us have developed a proposed approach to create such scenarios, which we presented at the August meeting of the Amer - ican Chemical Society. An incomplete record. The BE docket con - tains a letter written by the law firms Wiley Rein and Crowell & Moring on behalf of their clients, Dow AgroSciences and Makhteshim Agan of North America. In a 28-page attach - ment, they documented dozens of errors of omission and commission in the three pro - posed BEs. The purpose of their letter is to request that the comment period be extended until after the record is made correct and com - plete. But this request, as valid as it may be, may push the EPA and the Services past the court-ordered December 2017 deadline for the final Biological Opinions. T e way forward. This isn't clear. OPP scientists have been working hard to develop a new Spatial Aquatic Model (SAM), which should address many — but not all — of the problems with the current aquatic modeling assessment. The FIFRA Scientific Advisory Panel of external reviewers gave it a generally favorable review in fall 2015, but it will likely not be ready in time to partially rescue the process by the court-ordered deadlines. As a former deputy director of OPP said at a meeting in June 2016, the process is bro - ken, and so many internal resources will be consumed with findings such as these — that 80 to 97 percent of the roughly 1,800 species are likely to be adversely affected — that the EPA will not be able to perform many of its other statutory obligations. He concluded that strong Agency and Services leadership is needed to effect a change in culture. If the EPA and the Services stay on this path, I pre - dict superintendents will lose use of several pesticides in the next 10 years. Stay tuned. Stuart Z. Cohen, Ph.D., is president of Environmental & Turf Services Inc. (www.environmentalandturf.com), and is also an environmental chemist and risk assessor with the firm. He is a Certified Groundwater Professional, and worked at the EPA for 11 years.