Comments on the
Draft Washington State-Initiated Plan

• Background & Comment Summary
• Comments

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BACKGROUND & COMMENT SUMMARY

WSDA requested and received comments on the draft version of the Washington state-initiated plan, "Washington State Endangered Species Protection Plan for Pesticide Use."

The majority of stakeholder who reviewed the state-initiated plan agreed it was necessary to generate accurate data that reflects the current pesticide use and exposure conditions in Washington state's salmonid habitat.

One objective of the state-initiated plan is to provide state-specific data to EPA for ESA pesticide effects determinations. Some reviewers supported this objective and want WSDA to ensure that ESA pesticide effects decisions are made using actual pesticide use data and not by using maximum allowed uses on the product label.

Other reviewer criticized WSDA for proposing the use of actual pesticide use data and want ESA pesticide effects determinations to be made using only the maximum allowed uses on the pesticide label.

Several reviewers noted the state-initiated plan does not clearly define the role of WSDA. While some reviewers think the role of the program is to protect pesticide users from unnecessary restrictions, other reviewers believe the program's goal should be the protection of salmonids.

COMMENTS

WSDA is providing all comments received from the review of the draft version of the Washington state-initiated plan.

• CropLife America
  Ray S. McAllister, Ph.D., Regulatory Science and Policy Leader
• Hop Growers of Washington
  Steven. E. George, Governmental Affairs
• Northwest Coalition for Alternative to Pesticides
  Norma Grier, Executive Director
  Amy Lodholz, Intern
• PCC Natural Markets
  Randy Lee, Chief Financial Officer
• Washington Farm Bureau
  John Stuhlmiller, Asst. Director of Government Relations
• Washington Friends of Farms and Forests
  Heather Hansen, Executive Director
• Washington State Department of Ecology - Water Quality Program
  David C. Peeler, Water Quality Program Manager
• Washington State Potato Commission
  Pat Boss, Executive Director
• Washington State University - Washington State Pest Management Resource Service
  Catherine Daniels, Pesticide Coordinator
• Washington State University - Department of Entomology
  Carol Ramsey, Pesticide Education Specialist
• Washington Toxics Coalition
  Erika Schreder, Staff Scientist