April 3, 2013
Timothy D. Male, Defenders of Wildlife, 1130 17th Street, NW, Washington, DC 20036.
To improve pesticide consultations under the ESA, at least three key questions should be answered. First, under the ESA, what level of risk to ESA-listed species is acceptable from the registration of a pesticide under the Federal Insecticide, Fungicide, and Rodenticide Act? Second, how will the federal agencies that implement and comply with the ESA receive enough funding to meet their current and future pesticide consultation workload? Third, how can these agencies improve the process of consultation, so that it is more effective, efficient, transparent, and predictable? This presentation explains the importance of each question and provides a starting point for answers.