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When EPA registers a pesticide or reevaluates it in registration review, the Agency has a responsibility under the Endangered Species Act (ESA) to ensure that the pesticide registrations do not jeopardize the continued existence of federally threatened or endangered (listed) species or adversely modify their designated critical habitats. Where EPA determines that a pesticide in the registration or registration review process “may affect” a listed species, EPA must consult with the U.S. Fish and Wildlife Service and/or the National Marine Fisheries Service (the Services), as applicable. During consultation, the Services provide EPA with measures, where needed, to avoid jeopardy and minimize take to listed species and adverse modification of critical habitats from a pesticide. If the Environmental Protection Agency (EPA) identifies a need for geographically specific mitigations to protect a federally listed endangered and threatened (“listed”) species and/or designated critical habitat from the use of pesticides, EPA may communicate those mitigations and where they apply using a web-based system called BulletinsLive! Two (BLT).The locations where those mitigations apply are called Pesticide Use Limitations Areas (PULAs). Thus, the purpose of a PULA is to identify areas where pesticide mitigation measures must be implemented to conserve a listed species and its critical habitat (if designated). These areas are where pesticide exposures are likely to impact the continued existence of listed species, resulting in a reduction in survival or recovery of the species. PULAs focus mitigation to where they are most needed to protect populations and include one or more species that share the same mitigation measures for a pesticide or group of pesticides. Using PULAs ensures species protection while minimizing impacts to pesticide users.
EPA and Fish and Wildlife Service (FWS) have developed a number of PULAs for pesticide registration activities. EPA anticipates developing many more PULAs as it implements protections for more listed species under its ESA strategies, as described in EPA's Endangered Species Act (ESA) workplan, and through registration or registration review activities under FIFRA. Due to the need to develop a large number of PULAs in a clear and transparent manner, EPA developed a standardized approach described here that it plans to use to develop species maps that serve as the basis for developing PULAs.
Under the standardized approach described here, the development of a species map is first informed by the geographic areas that need to be conserved for listed species and/or critical habitats. EPA refers to this area as the species core map. A core map can be considered the building block of a PULA. A species core map is drawn using the best available information for a species. Such information typically obtained from FWS can include species designated critical habitat, its range, or biological information (such as occurrence data, habitat information, or other biological information that can be mapped. A PULA combines the species-specific core maps then adds adjacent areas to account for pesticide-specific transport (via spray drift and runoff/erosion) and/or exposure to taxa the species depends on such as pollinators or prey, as applicable. PULAs are ultimately the mapped areas where mitigations measures must be implemented to minimize impacts to specific listed species.
A core map that has been developed and reviewed is an ‘interim’ core map that EPA will begin to use to develop a PULA for a species. Once Fish and Wildlife Service species experts have reviewed the core map, then the core map will be considered a ‘final’ map. The species core maps found in this layer have gone through QA/QC and are considered interim or final. EPA will develop PULAs from these core maps. To develop a PULA from a core map, EPA will add adjacent areas to the core map to create a potential pesticide exposure zone known as a ‘buffer’ that accounts for pesticide movement (e.g. via spray drift or run-off) into areas identified in the core map. When applicable, these exposure areas may also account for areas important for a species diet or pollination, if applicable.