Comments on the Draft - Washington State-Initiated Plan
BACKGROUND & COMMENT SUMMARY
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.
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 DirectorAmy 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