Endangered Species Act: Pesticide Registration Consultation Cost Analysis
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Analysis of Cost Estimates and Additional Resources Required for Timely FIFRA/ESA Pesticide Registration Review
A report released on Nov. 4, 2013 by Summit Consulting, LLC and commissioned by CropLife America (CLA) estimates that the duplicative registration review process for crop protection products would cost taxpayers an additional $474 million over the next 10 years. The report, “Analysis of Cost Estimates and Additional Resources Required for Timely FIFRA/ESA Pesticide Registration Review,” includes a review of agency budgetary capacity and a determination of the breakdown of estimated costs.
As required by amendments to the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) in 1996 and 2007, the U.S. Environmental Protection Agency (EPA) must complete a 15-year cycle of pesticide registration review by 2022 to ensure that registered products meet current regulatory requirements. Pesticide products are already reviewed and regulated by EPA under FIFRA, and the NMFS and FWS are mandated to ensure that federal actions, including pesticide registrations, are compliant with ESA. In order to complete the currently scheduled review, the report concludes that NMFS and FWS would need to implement the following costly increases:
- Completion of these dockets would require a 13-fold increase in current budget and a 25-fold increase over current staffing levels at NMFS.
- Completion of these dockets would require a 17-fold increase over current budget and a 71-fold increase over current staffing levels at FWS.
Pesticides are already thoroughly reviewed and regulated by the U.S. Environmental Protection Agency (EPA) under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The report further emphasizes the need to fix a redundant regulatory process that burdens taxpayers while also offering no additional benefits for threatened and endangered wildlife species.
EPA has the expertise and resources to regulate crop protection products in a manner that protects endangered species without requiring duplicate efforts by other, already overloaded federal agencies. Under FIFRA, EPA conducts a rigorous assessment of environmental risk to all species, including those listed as threatened or endangered, in order to determine the potential impacts that every crop protection product may have on wildlife. Recent court rulings have required additional rounds of environmental review by NMFS and FWS – known collectively as “the Services.” In their review, the Services follow a separate set of regulations under the ESA, using different reasoning and interpretations of science. The end result: One set of regulators must consult with another set of regulators in order to continue regulating a product that is already regulated.
Improving the pesticide registration process will save more than just money. A logical, streamlined and thorough registration process for crop protection products, which is already being conducted by EPA staff, is crucial for American agriculture and all species, including those classified as threatened or endangered. In addition to the financial burdens on taxpayers and regulatory agencies, the bureaucratic quarreling surrounding ESA consultations threatens to disrupt nationwide agricultural productivity, our nation’s food supply and agricultural competitiveness with other countries.