Bridging Data Gaps in Risk Assessments of Threatened and Endangered Plants: The Role of Reproductive Strategies and Pollinator Traits

Project Objectives:

Literature review for listed plants with unknown reproductive strategies

Characterizing listed plant pollinators

This goal is to provide sufficient information for EPA and FWS to categorize Group 7 and 11 plants (from the “Malathion BiOp”: unknown other aspects of reproduction strategy) into either Groups 5 and 9 (required outcrossing for optimum reproduction) or Groups 6 and 10 (capable of sustaining the population using self-pollination or asexual methods).

This goal is to further refine how endangered plant insect pollinators are characterized to assess risk to various terrestrial invertebrate taxa (e.g., insect order) and assist in determining risk rankings by EPA and FWS for insecticides where terrestrial invertebrates are expected to be impacted (e.g., mortality or sublethal effects).

Background:

Under the Endangered Species Act (ESA), the Environmental Protection Agency (EPA) is required to ensure that pesticide registrations do not jeopardize the continued existence of federally threated or endangered (listed) species or adversely modify their designated critical habitats through consultation with the Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS; collectively “the Services”) as outlined in Section 7 of the ESA. The conclusion of this formal consultation process results in a Biological Opinion (BiOp) were the Services reviews EPA’s endangered species assessment (referred to as a “Biological Evaluation” or BE) and, for each species where the EPA determines that the pesticide is likely to adversely affect an individual of that species, concludes if the proposed action is likely to cause jeopardy to the species population or adverse modification of critical habitat. While comprehensive, this entire process for an individual pesticide active ingredient currently takes 4 to 12 years and there are only a few examples of final BiOps (from both Services) available which underscores the challenge for EPA and Services to meet their obligations under ESA given that there are thousands of pesticide products and over 1,700 listed species in the U.S. EPA is currently developing plans to streamline this process including the option of predicting jeopardy determinations (referred to a J/AM determinations) in their BEs. This project is focused on addressing the uncertainty associated with determining “indirect” effects of pesticides on listed plant species, primarily through direct effects on pollinator species which may impact their ability to provide pollination services to endangered plants.