i 

# Pesticide Use in the Imported Fire Ant Program

Environmental Assessment March 2012 United States Department of Agriculture

Marketing and Regulatory Programs

Animal and Plant Health Inspection Serviceii 

# Pesticide Use in the Imported Fire Ant Program

Environmental Assessment March 2012

Agency Contact: Charles Brown Director, Emergency Management Emergency and Domestic Programs Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Rd. Unit 134 Riverdale, MD 20737

________________________________ _____________________ The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis o f race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, or marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alter native means for communicatio n of program information (Braille, large print, audiotape, etc.) should contact USDA’S TARGET Center at (202) 720

– 2600 (voice and TDD).

To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326

– W, Whitten Building, 1400 Independence Avenue, SW, Washington, DC 20250

– 9410 or call (202) 720

– 5964 (voice and TDD). USDA is an equal opportunity provider and employer.

________________________________ _____________________ Mention of companies or commercial products in this report does not imply recommendation or endorsement by t he U.S. Department of Agriculture over others not mentioned. USDA neither guarantees nor warrants the standard of any product mentioned. Product names are mentioned solely to report factually on available data and to provide specific information.

________________________________ _____________________ This publication reports research involving pesticides. All uses of pesticides must be registered by appropriate State and/or Federal agencies before they can be recommended.

________________________________ _____________________ CAUTION: Pesticides can be injurious to humans, domestic animals, desirable pla nts, and fish or other wildlife

— if they are not handled or applied properly. Use all pesticides selectively and carefully. Follow recommended practices for the disposal of surplus pesticides and pesticide containers.iii 

# Table of Contents

I. Introduction

................................ ................................ ....................... 1

A. Distribution and Biology of IFA

................................ ................. 1

B. APHIS Fire Ant Quarantine Program

................................ ....... 3

C. Purpose and Need for IFA Quarantine Program Changes

..... 5

D. Scope of Analysis

................................ ................................ ...... 7

II. Alternatives

................................ ................................ ...................... 8

A. No Action

................................ ................................ ................... 8

B. Preferred Alternative

................................ ................................ . 9

III. Affected Environment

................................ ................................ ... 12

A. Land Use and Ecological Resources within the Geographic

Area

................................ ................................ ............................... 12

B. Ai r Quality within the Geographic Area

................................ .. 14

C. Water Quality within the Geographic Area

............................ 14

IV. Environmental Effects

................................ ................................ .. 15

A. No Action

................................ ................................ ................. 16

B. Preferred Alternative

................................ ............................... 28 V. Cumulative Impacts

................................ ................................ ...... 41

VI. Other Environmental Considerations

................................ .......... 44

A. Executive Orders

................................ ................................ .... 44 B. Threatened and Endangered Species

................................ ... 45 VII. Listing of Agencies and Persons Consulted

............................... 46 VIII. Appendices

................................ ................................ ................. 47 Appendix I. Observed Damage to Wildlife by IFA

..................... 47 Appendix II. Land Resource Regions Overlapping with the Geographic Areas Covered in this Env ironmental Assessment 48 Appendix III. Major Uses of Land (2007) for States within the IFA Quarantine and the Expanded Geographic Area Covered in

this Environmental Assessment

................................ ................... 50 Appendix IV. Counties within the IFA Quarantine and the Expanded Geographic Area Covered in this Environmentaliv Assessment that are Designated as Nonattainment Areas for

One or More Common Air Pollutants Tracked by the Environmental Protection Agency (EPA)

................................ .... 51 Appendix V. Number of Watersheds and Watersheds Containing Waters Impaired with Chemicals Used in the IFA Program

................................ ................................ ........................ 53

IX. References

................................ ................................ ................... 551 

# I. Introduction

The invasive insect s , Solenopsis invicta Buren ( S

. invicta Buren)

, and S. richteri Forel ( S

. richteri Forel) and their hybrids, collectively known as imported fire ant 1 (IFA) (Hymenoptera: Formicidae) are a health hazard to humans, domestic animals, and wildlife ; a nuisance in public and agricultural lands; and can cause infrastructure damage. IFA has become established throughout the souther n United States, as well as Puerto Rico. In response to the introduction of IFA to the United States, the Federal government implemented a quarantine in 1958

, with periodic revisions

, to update expansion of IFA

, as well as identify new control measures

. An update to the approved list of pesticides for use in commercial plant nurseries and grass sod farms ( under the Federal IFA quarantine program )

, as well as an evaluation of the expansion of the quarantine area to determine whether control of IFA is neede d in new areas

, are needed to prevent further movement of IFA

.


### A. Distribution and Biology of IFA

Two species of IFA were introduced into the United States from South America at the port of Mobile, Alabama. The black imported fire ant, S

. richteri Forel, arrived sometime around 1918 and the red imported fire ant, S

. invicta Buren, in the late 1930s. Both species probably came to the port in soil used as ballast in cargo ships.

Solenopsis invicta is known to infest portions or all of Alabama, Arkansas, C alifornia, Florida, Georgia, Louisiana, Mississippi, New Mexico, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, Virginia

, and Puerto Rico. In the United States

, S. richteri is only reported from northeastern Mississippi, northwestern Alabama, and southern Tennessee. A hybrid of S. invicta and S. richteri has been found from the middle of both Mississippi and Alabama northward, in the southeastern corner of Tennessee, and the northwestern corner of Georgia ( Diffie et al. 1988 )

.

IFA disperses naturally through mating flights, colony movement (ants can relocate their colony), and sometimes through rafting 2

1 The common name for Solenop sis invicta is red imported fire ant; for S. richteri

, black imported fire ant. Synonyms for imported fire ant include red imported fire ant, fire ant, RIFA and IFA. during periodic floods. Natural spread occurs slowly and within a local area. However, the rapid spread of IFA throughout the sout hern portion of the United States since the 1950s was likely due to human activities

— fire ants can be transported in dirt clods attached to vehicles and machinery; can be moved in soil

- containing products

, including nursery stock and commercial sod; and ca n be associated with baled hay and woody ornamental plants used in

2 Rafting is the process by which IFA form a mass of intertwined ants and float on water d uring heavy rains or floods (http://www.insectscience.org/11.171/i1536

- 2442

- 11

- 171.pdf)2 landscaping. Soil used in construction projects, such as road construction, is also a likely avenue through which fire ants spread ( King et al. 2009 )

. The infestations in almond groves in Kern County, California likely originated from bee hives transported from i nfested S tates for the purpose of pollinating crops ( Wojcik et al. 2001 )

.
Similar to other ant species

, IFA form colonies in which ants have specific roles (also called a socially hierarchical colony) . A typical S. invicta

c olony (nest) has one or more queens

. With in the colony t here are two types of ant groups : worker groups ( classified as minims, minors, and majors based on size ) comprised of sterile females and sexual groups ( Lofgren et al. 1975 )

. The percentage of the colony comprised of these two castes varies depending on the time of year and the age of the colony ; sexuals are produced primarily in the spring. Th e female controls the sex of her offspring by fertilizing or not fertilizing an egg ( Tschinkel 2006 )

. Males arise from unfertilized eggs while females arise from fertilized eggs ( Tschinkel 2006 )

. The number of winged sexuals participating in a nuptial flight (males and females mate in the air) is around 600 to 700 per flight of which around 95 percent of the females will have mated ( Tschinkel 2006 )

. A mature colony , on average, participates in around eight to nine flights per year; not all se xuals are released for every flight.

After their nuptial flight, new queens start forming and usually complete their nest within 6 to 7 hours after mating ( Lofgren et al. 1975 )

. The first eggs are laid within 24 to 48 hou rs after completing their nest. The time f rom egg to first adult worker is between 18 to 30 days

— the first larvae hatch in about a week an d both the larval (4 instars total) and pupal stage s last about a week ( Lofgren et al. 1975

, Tschinkel 2006 )

. Queens may live for 6 or 7 years and can produce as many as 1,500 eggs per day using stored sperm from their one

- time mating. Males live for approximately 4 days. Workers (sterile females) live between 1 and 6 months ( Tsch inkel 2006 )

. Within 3 years (considered the colony’s maturation point), the colony’s population can reach 230,000 workers (which the authors consider to be a conservative estimate) ( Lofgren et al. 1975 )

. The colony size does fluctuate throughout the year, being at its highest population levels in late fall and at its lowest population levels in spring ( Tschinkel 2006 )

. Colonies die of old age in 5 to 8 years and are replaced by younger colonies ( Tschinkel 2006 )

. Temperature and soil moisture, as well as the physica l properties of the soil are important for colony foundation and survival ( Lofgren et al. 1975 )

. Fire ants are unable to effectively forage when soil temperatures at a 2

- centimeter ( cm ) depth are below 15 °C; they are unable to produce a brood (eggs, larvae

, and pupae) when soil temperatures are below 24 °C ( Tschinkel 2006 )

. In central and south Florida, brood production can occur year round; at its most northern range, brood production c eases in3 the wintertime. On average, the seasonal reproductive cycle begins in March and ends in October

.

A mature mound can extend 1 meter or more into the ground, reaching the water table in some areas. The size of the mound above ground varies depend ing on the soil type. There is evidence that large colonies can occupy several mounds. A mature mound may remain viable for several
years ( Lofgren et al. 1975 )

. The density of colonies in the United States averages around 500 mounds/ hectare ( ha ) ; densities of 1,400 mounds/ha have been recorded (cited in ( Allen et al. 2004 ) ).

Fire ants are generalist feeders, feeding on plants and domestic and wild animals. Preferred food sources include insects, spiders, myriapods (subphylum of arthrop ods containing millipedes, centipedes, and others), earthworms, and other small invertebrates ( Lofgren et al. 1975 )

.

States in which IFA s are present and likely to expand into additional non

infested counties include Arizona, California, New Mexico, North Carolina

, and Texas , as well as a northern expansion in Arkansas

, Oklahoma, and Tennessee ( Korzukhin et al. 2001 )

. IFA could potentially spread to and annually survive in portions of Delaware, Hawaii, Maryland, Nevada, Oregon, Utah, Virginia and Washington ( Korzukhin et al. 2001 )

. In more arid climates, IFA would likely be restr icted to areas along water courses and irrigated lands ( Korzukhin et al. 2001 )

. A map of IFA distribution and expansion in the United States

, based on Korzukhin et al

., (2001) is available on the U

. S

. D epartment of Agricultural Research Service (ARS) w ebsite: http://www.ars.usda.gov/Research/docs.htm?docid=9165

. Overlaying climate change scenarios on predictive spread models indicate that the range of IFA survival in Oklahoma will likely move northward (and westward) given the increase in air temperatu res and wetter climate ( Levia and Frost 2004 )

.


### B. APHIS Fire Ant Quarantine Program

USDA

– APHIS currently conducts regula tory actions to quarantine IFA under the Plant Protection Act (7 U

. S

. Code (U

. S

. C

. ) 7701, et seq.), and the implementing regulations are currently contained in 7 Code of Federal Regulations ( CFR ) 301 Subpart Imported Fire Ant (301.81

– 1

– 301.81

– 10). The pur pose of the Federal quarantine (7 CFR § 301.81) is to prevent the artificial spread of IFA into noninfested areas of the United States by regulating the following articles :

**•** I FA queens and reproducing colonies of IFA

**•** Soil, separate or with other articles

o F or example, containerized plants4 **•** Baled hay or straw stored in direct contact with the ground

**•** Plants and sod with roots and soil attached, except plants maintained indoors in a home or office environment and not for sale

o For example, balled and burlapped pl ants, field sod, field grown commodities

**•** Used soil

- moving equipment, unless removed of all noncompacted soil

The F ederal IFA quarantine “does not require control or eradication programs” ( USDA APHIS PPQ 2010 )

. However, before regulated articles are moved from a quarantine area to a nonquarantine area they must be free of infestation and must be treated according to approved procedures ( USDA APHIS 2007 ) , or must be grown or produced in a manner that woul d ensure freedom from infestation ( USDA APHIS PPQ 2010 )

. Regulated articles meeting these requirements must be accompanied with a certificate for interstate movement ( USDA APHIS PPQ 2010 )

. Facilities shipping regulated articles must be done either under a compliance agr eement or a limited permit ( USDA APHIS PPQ 2010 )

.
According to 7 § CFR 301.81 (revised January 1, 2011) and Memo DA

2009

– 54 (October 28, 2009, http://www.aphis.usda.gov/plant_health/plant_pest_info/fireants/download s/da

- 2009

- 54.pdf ), the following areas are under F ederal quarantine ( f

igure 1) :

**•** Entire S tate: Alabama, Florida, Georgia, Louisiana, Mississippi

, and South Carolina

**•** Part of the S tate: Arkansas, California ( one county and part of two others ), New Mexico (one county), North Carolina, Oklahoma, Tennessee , Texas

, and Virginia

**•** Territories: Puerto Rico (entire)

The current IFA program involves surveys and quarantine requirements on potentially infested commodities. The quarantine requirements involve the use of chemical treatments on commodities to insur e that shipments from nurseries, sod farms, and field

- growing nursery facilities are free of IFA.5 Figure 1. Imported fire ant (IFA) quarantine in the United States as of December, 2011.



### C. Purpose and Need for IFA Quarantine Program Changes

APH IS is responsible for taking actions to exclude, eradicate, and/or control plant pests under the Plant Protection Act (7 U

. S

. C

. 7701 et seq.). As such, it is important that APHIS take the steps necessary to prevent the artificial spread of IFA from the cu rrent infested counties to new areas. APHIS proposes to change its IFA Federal quarantine program regulations by revising the list of approved pesticides and the commodity type (plants grown in containers, balled and burlap p ed, or field or grass sod) to wh ich they are applied for use against IFA in commercial nursery and sod facilities, and to expand the areas in which quarantine activities may be conducted.

APHIS has determined that under the provisions of the National Environmental Policy Act (NEPA) (s ee 42 U.S.C. 4321 et seq.) and APHIS’ National Environmental Policy Act (NEPA) implementing procedures (see 7 CFR p art 372), an environmental assessment ( EA ) should be prepared for these proposed actions. The availability of this EA and a 30

- day comment p eriod will be announced by publishing a notice in the Federal Register

. APHIS’ decisionmaker for the actions described in this EA will take appropriate action after reviewing the EA, its associated analyses, public comments received, and other relevant re sponses and6 recommendations. If major changes to the proposed actions in this EA occur as a result of this process, or if APHIS’ decision is a finding of no significant impact (FONSI), APHIS will prepare a similar announcement to notify the pub lic of the decision being made. APHIS has prepared two other EAs that are relevant to this EA: Imported Fire Ant Regulatory P rogram, January 1999

, and Imported Fire Ant Regulatory P rogram, February 1992.

APHIS needs to change the approved list of pesticides becau se options for chemical control of IFA through the use of insect icides have evolved over time. Changes in availability of insecticides that are effective against IFA

, as well as e nsuring a range of pest management options requires APHIS to periodically ev aluate new treatment options. In addition, t he U.S. Environmental Protection Agency (EPA) regulates the registration, distribution, sale

, and use of pesticides under its Federal Insecticide, Fungicide and Rodenticide Act (FIFRA; 7 U.S.C. §136 et seq. (199 6)) regulations. As pesticide registrations change, the chemicals availab le for

use to control IFA also change. USDA

– APHIS needs to evaluate the current pesticide options for IFA control and determine their applicability

, and human health and environment al impacts resulting from use in the Federal quarantine program.

In addition

, IFA continues to pose a threat to human health, domestic animals, wildlife

, public and agricultural lands

, and property so there is a need to e nsure effective control methods ar e available.

From a human health perspective

, a n estimated 14 million people are stung annually ( Drees 2002 )

. “Approximately 30% of the people living in infested areas are stung each year; of these, approximately 1% may develop hypersensitivity to the ant’s venom” (Vinson

, 1997 cited in ( Wojcik et al. 2001 ) )

. In 1998, approximately 33,000 people sought medical treatment for IFA bites in South Carolina at an estimated cost of $2.4 millio n ( Caldwell et al. 2009 )

.
Adverse economic impacts caused by IFA are mo stly attributed to control
programs rather than from direct impact from IFA

. Sources of economic impact include the cost of treatment on agricultural lands to protect livestock and farm workers

, and on public lands to protect people and wildlife; cost of treatment on residential property; cost to regulatory agencies; infrastructure damage to highways, telephone and cable lines; cost of medical treatment for both humans and animals; reduction in economic profit to industries restricted from shipping materia ls that are under quarantine; and funding costs for research. Annual cost of $1.3 billion and $1.2 billion are estimated for the S tates of Florida and Texas, respectively ( Lard et al. 2006 )

. Establishment of IFA in California could cost the S tate between $387 million and $989 million per year ( Jetter et al. 2002 ) ; in Hawaii, $211 million per year ( Gutrich et al. 2007 )

.7 Lard et al. ( 2006 ) estimates IFA costs the United States , including Puerto Rico , ca. $6 billion annually. The range of fire ants is expected to expand and with it the economic impacts will likely increase as control programs are imple mented in new areas.

Numerous papers on the mortality to vertebrates and invertebrates caused directly or indirectly by IFA are published in scientific literature

. In addition

, IFA is harmful to species designated as threatened or endangered at the Feder al level, S tate level, or both ( a ppendix 1 lists a few examples)

. IFA is considered a culprit in the extinction in the wild of the Stock Island tree snail ( Orthalicus reses reses (Say)) ( Wojcik et al. 2001 )

. Diffie et al. ( 2010 ) estimate that o ver 246 reptilian species reside in area s in which fire ants inhabit

, all of which can be impacted by IFA. Research is underway

t o determine the impact of IFA on the Schaus swallowtail, Papilio aristodemus onceanus Schaus, a federally listed endangered species whose population has been in decline ( Wojcik et al. 2001 )

.
IFA can negatively impact native arthropod communities through predation and competition, resulting in loss of ecological communities ( including loss of species diversity and trophic simplification) ( Allen et al. 2001

, Epperson and Allen 2010 )

. Arthropods a re an integral part of ecosystem functions

, including nutrient cycling, seed dispersal, decomposition, and pollination (cited in ( Epperson and Allen 2010 ) ). Native ant species diversity and richness are greater in areas treated for IFA, indicating that arthropod communities are negatively impacted by IFA ( Allen et al. 2001

, Epperson and Allen 2010 )

.


### D. Scope of Analysis

This EA will analyze the human health and environmental impacts that can be reasonabl y expected to occur if the proposed action to update the Federal quarantine activities for IFA is implemented

. These activities will only take place in commercial plant nurseries that produce container

grown, balled and burlapped, field grown plants and /or sod within the IFA quarantine and wish to ship to areas outside of the quarantine.

Current IFA infestations and associated quarantine areas are documented in all or part of Alabama, Arkansas, California, Florida, Georgia, Louisiana, Mississippi, New Mexico, North Carolina, Oklahoma, South Carolina, Tennessee , Texas, Virginia

, and Puerto Rico. The areas requiring quarantine activities are likely to expand due to the effects of climate change

. M aps depicting the potential expansion of the pest are available on the USDA Agricultural Research Service (ARS) W ebs ite at www.ars.usda.gov/Research/docs.htm?docid=9165

.
This EA will analyze quarantine activities in the current quarantine area (figure 1) , as well as activities that may be carried out in expanded8 quarantine areas as the detection of IFA in new areas c ould occur

. The geographical region covered in this EA includes the current IFA quarantine area

, as well as the re mainder of the counties in the S tates of Arkansas, North Carolina, Oklahoma, Tennessee, Texas

, and Virginia. In California, five additional counties are included in the scope (San Bernardino, Ventura, Santa Barbara, San Diego, and Imperial) and the counties of Los Angeles and Riverside are included entire ly

. Published data on the potential expansion of IFA demonstrate a much larger area for

e xpansion than what is covered in the scope of this EA. The selection and addition of counties to the scope of analysis in this EA was based on a combination of factors

, such as the current areas of IFA infestation, where
recent expansion of IFA h as been observed

, and the published literature regarding potential areas of expansion

. 

# II. Alternatives

T his EA will analyze the potential environmental and human health effects anticipated from two alternatives in response to the need

— (1) no action

, and (2) the preferred alternative, changing certain IFA pesticides and use patterns

.


### A. No Action

Under the no action alternative, the chemicals which are currently authorized by APHIS for the treatment of sod, field grown plant s , container grown plants

, and balled and burlapped plants under the IFA quarantine (t able 1

– 1 ) would continue to be used within the area under quarantine as long as they are registered for use by EPA

. Two active ingredients , diazinon and tefluthrin, that have been part of the IFA
quar antine program are no longer registered for IFA use and therefore will not be analyzed in this EA.9 Table 1

– 1. Current I nsecticide s U se d for IFA Q uarantine

.

Active Ingredient Formulation Name Formulation Type + Commodity

Container Field

grown B&B 1 G rass sod

Bifenthrin Talstar ®

, Bifenthrin Pro ®

,

Onyx Pro ® G, F, EC X

Chlorpyrifos Dursban ®

, Chlorpyrifos EC, WP, G X X X X

Diazinon 2 Diazinon/D

- z

- n ® WP, EC X

Fenoxycarb Aw ard ® Bait X

Fipronil Chipco ® Choice TM

, Chipco ®

, Top Choice TM G X X 3 X

Hydramethylnon Amdro ® Pro

, Siege ® Pro Bait X

Methoprene Extinguish ® Bait X

Pyriproxyfen Distance ® Bait X

Tefluthrin 2 Fireban ® G X

1 B&B = Balled and b urlapped p lants 2 N o longer available for IFA quarant ine use. 3 A pproved by 24C in the S tate of Tennessee for field grown use

+ WP = wettable powder ; EC = emulsifiable concentrate ; G = g ranular ; and F = flowable



### B. Pr eferred Alternative

Under the preferred alternative, APHIS is proposing to add additional insecticides and use patterns to the list of chemicals already allowed in the IFA program and listed in the no action alternative (t able 1

– 2 )

. In addition, APHIS is removing the use of diazi non and tefluthrin from the list of treatments for use in the IF A program because these are no longer registered for use

. The additional insecticides are being added to provide a broader range of chemical treatment options and are not being proposed as additional treatments beyond what is currently required in the
qua rantine program

. All of the products have residential and/or commercial uses in nurseries to control other pests.10 Table 1

– 2. Pr eferred I nsecticides and U se P atterns for IFA Q uarantine.

Active Ingredient Formulation Name Formulation Type + Commodit y

Container Field

grown B&B 3 Grass sod

Bifenthrin Talstar ®

, Bifenthrin Pro ®

,

Onyx Pro® G, F, EC X X X X

Chlorpyrifos Dursban ®

, Chlorpyrifos EC, WP,G X X X X

Fenoxycarb Aw ard ® Bait X

Fipronil Chipco ® Choice TM

, Chipco ® Top

,

Choice TM G X X 1 X

Hydr amethylnon Amdro ® Pro, Siege ® Pro Bait X

Methoprene Extinguish ® Bait X

Pyriproxyfen Distance ® Bait X

Bifenthrin + Cypermethrin Talstar ® Xtra G X X X

Bifenthrin + Clothianidin Aloft ® SC X X

Bifenthrin + Imidacloprid Allectus ® G , SC X

Pe rmethrin 2 GardStar ® EC

Imidac loprid +

Cyfluthrin Discus TM G X X X

λ

- cyhalothrin Scimitar ® G , SC X X X X

1 A pproved by 24C in state of Tennessee for field grown use 2 U se on/around hay and bees as a soil drench treatment for ants 3 B&B = Balled and b urlapped p lants

+ WP = wettable powder, EC = emulsifiable co ncentrate, G = g ranular, F = flowable

, SC = suspension concentrate

In summary, the changes that would result if the preferred alternative is implemented are as follows :

**•** For b ifenthrin, the same three formulations (Talstar ® , Bifenthrin Pro ®

, and O nyx Pro ® ) and the same formulation types (granular, flowable

, and emulsifiable concentrate) would be used on container

- grown plants, field

- grown plants, balled and burlapped plants

, and grass sod instead of container

- grown plants only (four commodity t ypes) ;

**•** For c hlorpyrifos, the same two formulations (Dursban ® and

c hrlorpyrifos) and the sa me formulation types (emulsifiable concentrate, wettable powder

, and granular) would be used on all four11 commodity types, resulting in no change in the way this pest icide is used in the IFA program;

**•** For d iazinon, the option for use of any formulation would be removed from the IFA program because it is no longer registered for this use;

**•** For f enoxycarb

, the same bait formulation of Award ® would used on field

- grown pla nts, resulting in no change in the way this pesticide is used in the IFA program;

**•** For f ipronil, the same two granular formulations of Chipco ® ChoiceTM and Chipco ® Top ChoiceTM would be used on container

- grown plants, field

- grown plan t s , and grass sod , r esulting in no change in the way this pesticide is used in the IFA program;

**•** For h ydramethylnon, the same two bait formulations of Amdro ® Pro and Siege ® Pro would be used on field

- grown plan t s, resulting in no change in the way this pesticide is used in t he IFA program;

**•** For m ethoprene, the same bait formulation of Extinguish ® w ould be used on field

- grown plan t s, resulting in no change in the way this pesticide is used in the IFA program;

**•** For p yriprox y fen, the same bait formulation of Distance ® would be

u sed on field

- grown plan t s, resulting in no change in the way this pesticide is used in the IFA program;

**•** For the pesticide combination of bifenthrin and cypermethrin, a granular formulation of Talstar ® Xtra

, for use on cont a iner

- grown plants, field

- grown p lan t s, and grass sod would be added to the options available for IFA control;

**•** For the pesticide combination of bifenthrin and clothianidin, one suspension concentrate formulation of Aloft ® for use on field

- grown plants and grass sod would be added to the options available for IFA control;

**•** For the pesticide combination of bifenthrin and imidacloprid, granular and suspension concentrate formulations of Allectus ® for use on balled and burlapped plants would be added to the options available for IFA

c ontrol;

**•** For permethrin, one emulsifiable concentrate formulation of GardStar ®
for use on and around hay as a soil drench treatment for ants would be added to the options available for IFA control;12 **•** For the pesticide combination of imidacloprid and cyfluth rin, one granular formulation of DiscusTM for use on field

- grown plants, balled and burlapped plants, and grass sod would be added to the options available for IFA control;

**•** For the pesticide tefluthrin, the option for use of any formulation would be re moved from the IFA program because it is no longer registered for this use; and

**•** For the pesticide λ

- cyhalothrin, granular and suspension concentrate formulations of Scimitar ® for use on container

- grown plants, field

grown plants, balled and burlapped pla nts
, and grass sod would be added to the options available for IFA control.


# III

. Affected Environment

The area under the Federal IFA quarantine is broad (impacting 1 4 S tates and one territory) and has a diversity of soil types

, animals (vertebrates and invertebrates)

, plants , and climatic factors. Although the quarantine area is broad, IFA program activities, namely the application of pesticides at facilities that commercially produce or sell regulated articles for distribution outside of the quara ntine area, will not impact the entire quarantine area ; only those areas under or near treatment.

The nursery and grass sod industry in the United States, including those located in the region covered in this EA, implement pest management in their facil ities, and the use of pesticides may be one of the management options u tilized

. In conventional growing practices for nursery plants and grass sod, pesticides, including those belonging to the amidinohydrazone, carbamate, insect growth regulator, neonicot inoid, organophospate, phenylpyrazol, and pyrethroid pesticide classes may be used to control a range of insect pests, not just IFA. Pesticide formulations belonging to these classes are also used in conventional agricultural crop production to control in sect pests; used in animal production to control nuisance pests to livestock; and for residential use to control garden or infrastructure pests

, or even pests on pets.

The discussion below provides an overview of the affected environment

, including ecolo gical resources and air and water quality for areas under the current IFA quarantine

, and the expanded areas described in this EA.



### A. Land U se and E cological R esources w ithin the G eographic A rea

There are 11 land resource regions that overlap with the geogr aphic areas covered in this EA ( a ppendix 2 )

. Land resource regions are13 “geographically associated major land resource areas which approximate broad agricultural market regions” ( USDA NRCS 2006 )

. For a detailed description of the land resource regions, please see the Lan d Resource Regions and Major Land Resource Areas of the United States, the Caribbean, and the Pacific Basin available on the U.S. Natural Resources Conservation Service W ebsite ( ftp://ftp

fc.sc.egov.usda.gov/NSSC/Ag_Handbook_296/Handbook_296_high.pdf ).

Every 5 years , the USDA

– Economic Research Service compiles a report on the major uses of land in the United States; the latest report available is based on data from 20 07. Approximately 48 percent of land use in the region covered in this assessment is for cropland and grassland, which includes pasture and range. This is a slight overestimate because only eight counties in California and one county in New Mexico are in cluded in the geographic scope; removing these S tates from land use calculations brings the estimated total to 46 percent. Appendix 3 provides a summary of land use in the S tates covered in the scope of this assessment

.
National, S tate, county
, and city parks

, as well as National Wildlife Refuges are located within the geographic area described for this
assessment

. The estimates of acres dedicated to special

- use areas available in a ppendix 3 include these lands. Parks are considered mixed

use and are us ed for recreational purposes

, as well preservation of animal habitats and ecological resources. National Wildlife Refuges are managed by the U.S. Fish and Wildlife Service and are areas set aside to conserve fish, wildlife

, and plants. A wide diversity o f terrestrial and aquatic habitats occurs within the geographic boundary considered in this EA. These habitats support a wide diversity of fish and wildlife species

, with many rare and endangered species. Approximately 606 species list ed as threatened or endangered under the Endangered Species Act occur within the boundary defined in this EA. Natural habitats may have IFA infestations ; however

, the quarantine program is directed solely at treatments within commercial nurseries. These are highly disturbe d areas that may have some use by wildlife

, but would not be preferred habitats to support wildlife populations

. Similar to soils in agricultural production, nurseries and sod farms are disturbed creating preferred habitat for IFA ( Tschinkel 2006 )

.
There are approximately 9 dominant soil orders (of a total of 12 orders) and 4 4 domi nant soil suborders (of a total of 64 suborders) in the land resource regions that are encompassed within the geographic area of this EA ( a ppendix 2 ). Soil orders “are differentiated by the presence or absence of diagnostic horizons or features that refle ct soil forming
processes .” ( USDA NRCS 1999 )

. The criteria for differentiating suborders vary between soil orders. For example, a suborder under one soil order is differentiated based on its we tness, while a suborder under another soil order is differentiated based on its dominant temperature14 regime. The physical properties of soil influence water holding capacity and runoff

, as well as the bi n ding affinity of various pesticides

. Both the physical properties of soil as well as soil moisture are important for IFA colony formation and survival ( Lofgren et al. 1975 )

. Disturbed soils that would support IFA colony formation will have different physical chara cteristics compared to any surrounding undisturbed soils. Soils become disturbed through various agricultural practices

, including planting, harvesting, tilling, and application of organic and inorganic amendments.



### B. Air Q uality w ithin the G eographic A r ea

The re are 86 counties in the current quarantine area and expanded area described for this EA that are designated as nonattainment areas, meaning the air pollution levels persistently exceed the national ambient air quality standards set by EPA ( a ppendi x 4 )

. Counties may reach nonattainment for more than one air pollutant, as is the case for several counties in the IFA quarantine area. Forty

- nine counties are designated as nonattainment

areas due to th eir particulate matter levels (combining county lis tings for both the 1997 and 2006 standards)

. PM

- 2.5 is fine particles of both solid particles and liquid droplets

, and are believed to pose the largest health risks. Sources of fine particles include motor vehicles, power plants, wood burning and certain industrial processes ( EPA 2011c )

. Five counties

are designated as nonattainment areas due to their lead levels. Sources of lead emissions include ore and metals processing

, and certain aircraft operating on leaded gasoline ( EPA 2011c )

. Sixty

- one count ies are designated as nonattainment areas due to their ozone levels. The active ingredients , including byproducts, evaluated in this assessment are not classified as ozone producers or depleters

, and are not expected to contribute to ozone air pollutants. APHIS recognizes that the potential exists for some incremental increase in ozone production

, as well as some other types of air pollutants due to the use of combustion engines in the course of application of the pesticides under the preferred alternativ e

. However, any increase would be minimal when compared to the use of combustion engines as part of normal agricultural practices.



### C. Water Q uality w ithin the G eographic A rea

Several hundred watersheds are within the current quarantine area and expanded area described in this EA ( a ppendix 5 ). A watershed is an area that drains to a common waterway, such as a stream, wetland, aquifer,

ocean, and so on

. American Heritage Rivers, created by Executive Order 13061 (September, 11, 1997) with selection criteri a developed by the Council on Environmental Quality (CEQ) are designated by EPA

, and are rivers that represent natural, cultural

, and historic resources. Five rivers15 designated as American Heritage Rivers flow through areas evaluated in this EA ( a ppendix 5 )

. The Clean Water Act provides a structure for regulating the discharge of pollutants into waters and regulates quality standards for surface waters. Section 303(d) of the Clean Water Act requires S tates to develop lists of its impaired and threatened w aters (stream/river segments, lakes ) ( EPA 2011f )

. Causes for impairment are numerous and include categories such as pathogens, metals, salinity, sediments, pesticides, trash, and other organic and inorganic compo unds. Most of the watersheds for S tates and their respective counties that are considered in this EA h ave one or more impaired waters, meaning that the water is not meeting one or more of its designated uses ( b ased on 2010 w atershed data except for V irgin ia where data was from 2008; data for Mississippi was poor) ( EPA 2011f )

. Four chemicals currently used in the IFA Quarantine Program and three chemicals listed under the preferred alternative in this EA are found in one

or more of these impaired waters. Bifenthrin, chlorpyrifos, and diazinon are reported in impaired waters in California; chlorpyrifos and diazinon are reported in impaired waters in Oklahoma; and fipronil is reported in impaired waters in Louisiana

. Not all waters have been assessed in all watersheds.


# I V

. Environmental Effects

This section of the EA will evaluate the potential impacts of the no action and preferred alternative. Risks to human health and the environment of each insec ticide are summarized in the following sections. The proposed insecticides for the IFA quarantine are also used in nurseries to control insect pests other than IFA. The potential for impacts to human health are going to be greatest for workers and applicators in th e IFA program

. The use of insecticides in the IFA program are restricted to established nurseries and sod farms that want to ship commodities out of the current quarantine zone. There is the possibility for exposure to the public once the treated plant s are shipped out of the nursery and delivered for planting. Because some of the treated plants could be used in landscaping

, there is a potential for some exposure to the public by handling treated plant s during and after planting. Incidental dermal or di etary exposure could occur in these situations ; however

, the risk is reduced by weathering and degradation of insecticides during holding and transport

, as well as binding of program insecticides to soil particles. In addition

, treated commodities do not include any plants that would typically be eaten by humans; therefore

, risk to the general public through this route of exposure would be low

. However, the potential for d ietary risk from exposure to program insecticides through drinking water a re discuss ed for each pesticide

. Dermal and inhalation risks to the general population would be greatest during the time of application but would be very low because16 treatments would only occur in nurseries where the public would not be present during application. A review of t he labels for each insecticide offers a range of requirements for personal protective equipment

, based on the potential risk of each insecticide. All applications made in nurseries to comply with th e IFA quarantine will be done by qualified individuals and in compliance with all l abel recommendations to e nsure applicator and worker exposure and subsequent risk is minimized. In some cases

, use patterns for some formulations proposed in the preferred alternative are not currently registered fo r that particular use ; however

, APHIS is working with the registrants to expand labels for those formulations so that they can be incorporated into the quarantine program and nursery treatment program

. In the int erim

, only those pesticides labe led for a
p articular use pattern will be used in the IFA quarantine program.

From an environmental perspective

, all treatments are focused on making applications to soil whether that occurs in containerized plants or in more
open areas , such as sod. A majority of the insecticides used in the IFA program are nonsystemic 3 in nature ; therefore

, no insecticide plant residues would be anticipated for most of the treatments

, with the exception of treatments using imidacloprid and clothianidin which are systemic insectic ides. The potential for risk s to nontartget organisms consuming residues from plants and insec ts from a broadcast application 4 are discussed in the following summaries.



### A. No Action

a. Human Health

Bifenthrin is a synthetic pyrethroid insectici de that acts on the peripheral and central nervous system impacting axons

, and is effective as a contact or ingested compound

. Bifenthrin can be used in multiple formulations in the IFA program

, is incorporated into soil media for containerized plants

, an d is not used for any other use patterns

. Bifenthrin has moderate acute oral toxicity but low dermal toxicity . The reported median lethality value (LD 50 ) in mammals ranges from 53.8 to 70.1 mg/kg. Bifenthrin is not considered to be a dermal sensitizer o r an eye or skin irritant ( Wassell et al. 2008 )

. Acute effects of the currently used formulations appear to be similar or less than the technical active ingredient

, based on available data on the material safe ty data sheet for each formulation

. Bifenthrin is not considered to be a reproductive or developmental toxicant ; h owever, it is considered a potential carcinogen

, based on the formation of urinary bladder tumors when administered at high doses to mice

. R isk to g round

3 Nonsystemic means that the pesticide remains on the outside of the plant that is treated. By comparison, a pesticide that is systemic gets incorporated into the plan t that is treated. 4 Broadcast application means the uniform application of a pesticide in an area, typically accomplished using a spreader, sprayer, or other type of application technique. 1. Bifenthrin (Container Use Only)17 and surface drinking water resources are not expected to be significant for the proposed use pattern

, based on label restrictions regarding the protection of surface water and the environmental fate properties for bifenthrin which demonstrate low solubility and a high affinity for binding to soil

.

b. Ecological Resources

Bifenthrin has low to slight toxicity to birds

, and moderate acute toxicity to wild mammals. Significant exposure and risk to nontarget terrestrial vertebrates are not e xpected due to low toxicity and the fact that applications are restricted to soil media in containerized plants where nontarget organisms would not be expected to forage

. Impa cts to terrestrial invertebrate populations in the environment surrounding the

c ommercial nurseries from bifenthrin treatments are not anticipated a s treatments are made to soil with in the containers. Any incidental contact by terrestrial invertebrates in these containers could result in toxicity because pyrethroid insecticides are t oxic to most terrestrial invertebrates. Bifenthr in is considered highly toxic to honey bees by oral and contact
exposure.

Similar to other pyrethroid insecticides

, bifenthrin is considered highly toxic to fish and aquatic invertebrates. Toxicity val ues for both groups of organisms range from the low p arts per trillion (ppt) to the low parts per billion (ppb), depending on the test species and conditions ( Solomon et al. 2001

, Meléndez and Federoff 2010 )

. Offsite transport of bifenthrin to aquatic habitats is not expected to occur because tre atments are restricted to containerized media

. Any bifenthrin that could move through the containerized media would not be at concentrations that could move offsite and result in adverse impacts to aquatic resources. Bifenthrin binds tightly to soil and has very low solubility, reducing the potential for transport and exposure to aquatic organisms.

c. Environmental Quality

Bifenthrin impacts to soil are not anticipated under the current use pattern because it is applied only to containerized plants su bject to quarantine
treatment. Due to the method of application bifenthrin is also not expected to runoff or drift from the point of application in quantities that could impact aquatic resources because treatments occur only to containerized media. An y bifenthrin that could move offsite would not be expected to impact surface or groundwater. Bifenthrin has extremely low solubility and mobility in soil

, suggest ing that it would not be a threat to ground water ( Meléndez and Federoff 2010 )

. Bifenthrin does degrade slowly in soil and sediment

, based on field terrestria l and aquatic dissipation data ( Gan et al. 2008

, Meléndez and Federoff 2010 )

. Dissipation half

- lives range from approximately 80 days to greater than 118 year under different soil and sediment conditions. Impacts to air quality from volatilization a re not expected due to the low vapor pressure for bifenthrin. Some bifenthrin could occur in the atmosphere during application

, but will be restricted to the area of treatment because applications are made using ground sprayers with a large coarse droplet size that will minimize drift.

a. H uman Health

Chlorpyrifos is an organophosphate insecticide with a mode of action that occurs primarily through the inhibition of the cholinesterase enzyme

. Chlorpyrifos is used as an emulsifiable concentrate or wettable powder formulation for the treatment of containerized and balled and burlapped plants. It may also be used in treating field

- grown plants and grass sod prior to shipment. Acute oral toxicity is moderate based on median lethality values ranging f rom 60 to 1,000 mg/kg, depending on the test species. Dermal toxicity is considered low, and the formulations can cause moderate eye and moderate to severe skin irritation

, depending on the formulation being used. Chlorpyrifos is not considered mutagenic

, teratogenic, or carcinogenic in studies submitted to support registration ( USDA APHIS 2005 )

. Exposure to humans from the c ontamination of groundwater resources is not expected

, bas ed on the environmental fate of chlorpyrifos and label requirements

. Labeled ground a pplication buffers of 25 feet from surface water and spray drift mitigat ion language on chlorpyrifos labels for IFA will re duce the potential for contamination of surface drinking water. Spray drift mitigation measures include restrictions on droplet size, sprayer boom height, and wind speed restrictions.

b. Ecological Re sources

Chlorpyrifos is considered to be moderately to highly toxic to birds, depending on the test species ( USDA APHIS 2005

, EPA 2011a )

. Symptoms of nonfatal exposure to birds include cholinesterase depression (ChE), weight loss, reduced egg production, a nd reduced hatchling survival. Indire ct impacts to mammals and birds that depend on insects as part of their diet could occur for those species that forage exclusively in areas where chlorpyrifos may be broadcast applied

, such as field grown plants and sod fields. These types of areas are hi ghly disturbed areas , particular ly grass sod

, which is removed after treatment. Wild mammals and birds would forage outside of these disturbed areas , therefore, indirect impacts would be expected to be minimal. Impacts to terrestrial invertebrates, such as worker honey bees, are expected in areas where treatment would occur ; however

, impacts to pollinators is expected to be minor as applications are made using ground equipment and to plants that would not have flower s present where pollinator exposure wou ld be more likely to occur

. 2. Chlorpyrifos19 Chlorpyrifos is highly toxic to fish and aquatic invertebrates with acute median lethality values ranging from the low ppt to low ppb range, depending on the test species ( USDA APHIS 2005

, EPA 2011a )

. Exposure a nd risk to aquatic species will be reduced by adherenc e to label requirements to reduce drift, and by the application of 25

- foot buffers from aquatic resources.

c. Environmental Quality

Potential e ffects of chlorpyrifos on air, soil, or water quality would be restricted to areas near the site of applicatio n . Chlorpyrifos can persist in soil and water for several months under certain conditions ; however, the persistence is generally only for a month or less. This is dependent on the organic content of the soil. Chlorpyrifos degrades quickly in the presenc e of light, with a half

- life of approximately 3 hours. In water, it will bind readily with sediment with aqueous half

- lives ranging from 7 to 28 days. Labeled application buffers prohibiting treatment in proximity to water bodies and spray drift mitigati on restrictions will reduce the potential for contamination of surface water habitats. Chlorpyrifos can volatilize into the atmosphere; however, its persistence is expected to be short, with a half

- life of only a few hours because of its photolytic sensit ivity ( Racke 1993 ) . Chlorpyrifos can impact air quality through drift from broadcast ground applications. These impacts would be restricted to areas wi thin the nurseries with offsite transport reduced by adherence to label requirements regarding the minimization of drift.

a. Human Health

Fenoxycarb is a juvenile hormone agonist that is classified as an insect growth regulator. Juvenile hormone is pr oduced naturally by insects and is important in their development and reproduction. In this case

, fenoxycarb prevents the larval insects from maturing to an adult. Its use in the IFA program is as a bait formulation called Award ® that is used for making ground

- based field applications ; it is not used on container

- grown and balled and burlap p ed plants or in grass sod production . The current registration for fenoxycarb and all associated uses is scheduled to expire in December 2012

, at which point only res erves in commerce will be available for use ( EPA 2011b )

. The technical active ingredient is practically nontoxic to mammals in oral, dermal

, and inhalation exposures ( Sullivan 2000a ) . The formulated material is slightly more toxic than the technical material with an oral LD 50 value of 4

, 921 mg/kg

, and would be classified as slightly toxic. Formulation dermal and inhalation toxicity is considered practically nontoxic

, with median values greater than the highe st test concentration. The potential for eye and skin irritation is considered minimal to slight for the Award ® formulation

, and it is not considered a skin sensitizer. Fenoxycarb is not a developmental or 3. Fenoxycarb20 reproductive toxicant

, and has not been shown to be mutagenic. Fenoxycarb does show evidence of carcinogenicity

, based on liver and lung tumors in subchronic and chronic studies using mice ( NIH 2011 )

.

b. Ecological Resources

Toxicity to terrestrial vertebrates

, such as wild mammals and birds

, is expected to be low

, based on available data for fe noxycarb. Mammalian toxicity data used to evaluate the potential for human health impacts demonstrates low toxicity

, as well as the oral and dietary toxicity data for birds ( EPA 2011a ) . Data for the northern bobwhite and mallard duck show no lethal impacts occurring at concentrations greater than the highest test concentration in each study. Acute toxicity studies demonstrate low toxicity to poll inators

, such as adult or larval honey bees ( Aupinel et al. 2007

, EPA 2011a ) . Studies designed to evaluate sublethal impacts to h oney bees have shown impacts to honey bees ; however

, treatments were made using a liquid formulation under the assumption that applications would occur to flowering plants ( Thompson et al. 2005

, Aupinel et al. 2007

, Heylen et al. 2010 ) . Fenoxycarb applications in the IFA program are made using a ground bait fo rmulation where exposure to honey bees through foraging on treated flowering plants is not anticipated. There could be some impacts to other terrestrial invertebrates, in particular during development ; however

, these impacts would be restricted to the

ar ea of treatment within a nursery.

Fenoxycarb toxicity to fish is moderate to high with median lethality values ranging from the mid ppb to low part per million (ppm) range for

warm water and freshwater species ( EPA 2011a ) . Acute toxicity to aquatic invertebrates varies in the mid ppb to low ppm range based on available data for freshwater and marine invertebrates. Comparative chronic toxicity be tween fish and aquatic invertebrates is significantly greater with effect concentrations in the low ppt range for invertebrates compared to ppb for fish. Chronic studies using various freshwater cladocerans as test organisms have shown impacts to reproduc tion and increased male production ( Oda et al. 2005

, Tatarazako and Oda 2007

, Matsumoto et al. 2008 ) . Current label requirements regarding restrictions on applications near water and the method of application in the IFA
program reduce risks to aquatic species . Applications are made using a bait formulation

, which will minimize drift and any runoff of fenoxycarb from treated areas . Any fenoxycarb that would move offsite would be primarily as material bound to soil , reducing bioavailability and risk to
water

- column organisms.

c. Environmental Quality

Feno xycarb impacts to soil, water

, and air are expected to be minor and restricted to the area of treatment because of the formulation used in the21 IFA program and the environmental fate of the insecticide. Fenoxycarb degradation in soil appears to be bi

- phasi c with primary half

- lives of less than 10 days

, and secondary half

- lives greater than 80 days under aerobic conditions ( Sullivan 2010 ) . Fenoxycarb has moderate solubility in water but has a strong affinity to bind to soil and sediment

, with organic part itioning coefficient values ranging from 1

, 251 to 2

, 599

, depending on soil types ( Sullivan 2010 ) . The tendency to adsorb to soil and sediment reduces the risk to surface and groundwater resources with any fenoxycarb entering surface water primarily boun d to soil in runoff. The primary environmental metabolite of fenoxycarb

, however

, does have greater mobility in soil and could impact surface and groundwater resources. Any fenoxycarb that may enter surface water is susceptible to microbial degradation. The reported aquatic half

- life of fenoxycarb under aerobic conditions is 19 days

, while under anaerobic conditions it is greater than 1

, 000 days ( Sullivan 2010 ) . Volatilization into the atmosphere from water or soil is not expected to occur in quantiti es that could impact air quality. Fenoxycarb is applied as bait consisting of large particles that would not be susceptible to drift. The chemical characteristics that determine the potential for volatilization show that concentrations in the air would b e very low. Any material that would volatilize would degrade in less than 6 hours ( Sullivan 2010 )

.

a. Human Health

Fipronil is a phenyl pyrazole insecticide that acts by interfering with chloride ions passing through the chloride channel resulting i n overstimulation of the central nervous system. Fipronil is used in the IFA
program as a granular formulation ( i.e.

, Chipco ® ) for treatment of containers and grass sod. Applications to field grown plants are also allowed under a Special Local Need (FIFR A Section 24 ( c )) pesticide approval in Tennessee. It is not used on ball ed and burla p p ed plants. The technical grade material is moderately toxic to mammals in oral and inhalation acute toxicity studies with median lethality values of 92 and 354 mg/kg, r espectively ( Drew et al. 2009 ) . Fipronil is considered practically nontoxic in dermal exposures. The formulations proposed for use in the IFA program are considered practically nontoxic in oral, dermal

, and inhalation exposures , based on available data. Eye and skin irritation varies from slight to moderate. Fipronil is not mutagenic , however, it is a possible human carcinogen because of an increase in thyroid follicular cell tumors in the rat. Developmental and rep roductive toxicity studies report no observable effect levels (NOEL s ) ranging from less than 0.10 mg/kg/day to 20 mg/kg/day. Fipronil is neurotoxic to dogs and rats in acute and subchronic studies ( Drew et al. 2009 )

. Exposure to workers and applicators will be reduced by using a granular formulation. Threats to groundwater are not anticipated due to the environmental fate of fipronil which does not indicate mobility or leaching. There is the potential for surface wat er contamination ; however

, adherence to label 4. Fipronil22 restrictions, including application buffer zones, will minimize the potential for contamination of surface water used for drinking water.

b. Ecological Resources

The acute toxicity of fipronil to wild mammal s is moderate based on available data for studies used to support human health assessments. Fipronil toxicity to birds is highly variable. Acute oral toxicity is considered low to mallards with LD 50 values exceeding 2

, 000 mg/kg while the equivalent endpo int for the northern bobwhite is 11.3 mg/kg suggesting high toxicity to upland gamebirds. A similar trend is seen in subacute d ietary studies where the toxicity is much higher for the northern bobwhite compared to the mallard ( Tingle et al. 2003 ) . Toxicity to terrestrial invertebrates is also variable depending on the test species. Fipronil appears to have low toxicity to earthworms however i t has been shown to be toxic to some beneficial insects ( Tingle et al. 2003 )

.
Impacts to sensitive terrestrial invertebrates would be expec ted in commercial sod applications. These impacts would be restricted to the areas of application that are already highly disturbed because the sod is grown and then removed for shipment. Risks to wild mammals and birds that could forage in these areas w ould be greatest after treatment but prior to harvest. Indirect risks to wild mammals and birds that depend on terrestrial invertebrates would not be expected to occur because they would forage in areas other than the treated areas which are intensively

m

anaged for sod production and then harvested prior to shipment.

Fipronil and its degradates are highly toxic to aquatic species. Median lethality values for the parent material to fish range from approximately 42 to 248 ppb in acute exposures ( Tingle et al. 2003 )

. Sensitivity to aquatic invertebrates is more variable however fipronil is highly toxic to aquatic invertebrates with LC 50 valu es ranging from low ppt for midge larvae to the low ppb for the freshwater cladoceran ( Tingle et al. 2003 )

. Sediment toxicity is also high for the midge in exposures to fipronil and associated metabolites ( Maul et al. 2008 )

. Applications adjacent to water bodies could result in runoff that could impact aquatic resources. Risk to aquatic resources would be greatest for sod ap plications compared to treatments to containerized plants. Label restrictions regarding the protection of water bodies with application buffers ranging from 15 to 60 feet will reduce risk to aquatic resources. In the case of the protection of freshwater resources , the application buffer must contain groundcover that will also reduce the flow of fipronil

- contaminated water from areas of
treatment to aquatic areas

, as well as trap sediment bound fipronil particles.23 c. Environmental Quality

Reported val ues for field dissipation half

- lives are 33 to 75 days for bare soil and 12 to 15 days in turf. Under aerobic conditions, organisms present in the soil gradually breakdown fipronil. Aerobic soil metabolism studies reported the half

- life of fipronil in sa ndy loam to be 122 days with the amide and sulfone metabolites accounting for 27 to 38 percent
, and 14 to 24 percent of the total amount of pesticide applied , respectively ( Tingle et al., 2003 ). Fipronil binds tightly to soil so runoff from treated fields would contain most of the insecticide bound to soil particles. In water, the reported solubilities fo r fipronil are 2.0 to 2.4 ppm ( Tingle et al., 2003 ). The reported half

- life for fipronil under aerobic aquatic conditions was 14.5 days. The major meta bolite ( a sulfide degradate) typically represents 74 percent of the total residue after 30 days . Fipronil has a relatively low vapor pressure indicating it does not readily volatilize. Consequently, drift would be the only expected pathway for movement i nto the air which would be minor because all proposed formulations are granular and would not be anticipated to drift from areas of application.

a. Human Health

Hydramethylnon is an amidinohydrazone insecticide that binds to cytochrome in the electro n transport system of mitochondria

. Hydramethylnon works as a metabolic inhibitor by blocking the biological process in the insect that makes a denosine t riphosphate (ATP). ATP is a compound required by most biological processes to provide energy for life. Hydramethylnon is used in the IFA program on field

- grown plants ; it is not used on container

- grown and balled and burla p ped plants or in grass sod production

. It is selectively toxic to insects with chewing or sponging mouthparts

, and functions as a slo w acting stomach toxicant. It is relatively nontoxic to insects that use other modes of feeding and to insects where exposure is limited to cuticular contact. Toxicity of the technical active ingredient is considered moderate in oral exposures with media n lethality values ranging from 817 to 1

, 502 mg/kg. Acute toxicity from dermal and inhalation exposures are low with a reported inhalation median lethality value of 2.9 mg/L

, and a value of greater than 2

, 000 mg/kg for dermal exposure ( EPA 1998 )

. The formulation proposed in the IFA program is granular bait which is considered practically nontoxic in
acute
, oral, dermal

, and inhalation exposures. The formulation is also not considered to be an ey e/skin irritant or skin sensitizer. Hydramethylnon is not considered to be mutagenic, teratogenic

, or a developmental toxicant based on studies to support registration that were conducted using the technical ingredient.

Hydramethlynon is classified as a possible carcinogen based on an increased incidence in lung adenomas in long

- term exposure studies using mice. Similar results were not observed in studies using the rat ; however

, 5. Hydra

methylnon24 impacts to male rats included a decrease in size and atrophy of testes ( EPA 2003a )

.

b. Ecological Resources

Hydramethylnon has low toxicity to wild mammals

, based on mammalian data submitted to support human health assessments. Avian toxicity is low determined f rom available oral and dietary data. The northern bobwhite is more sensitive in acute and subacute exposures compared to the mallard ( EPA 1998 ) . No chronic toxicity data appears to be available for birds. Toxicity to terrestrial invertebrates

, such as pollinators

, is low based on contact studies ( EPA 2011a )

. Apperson et al. ( 1984 ) showed minimal impacts to native ant populations after treatment for IFA with the formulation proposed for use in the IFA program. Other field studies ha ve shown some impacts to native ant populations

, as well as ground

- dwelling pests
, such as cockroaches and crickets ( Plentovich et al. 2010 ) . Impacts to select terrestria l invertebrates are possible ; however

, these impacts will be minimized by the use of granular bait and would occur only in the area of treatment. These impacts are not expected to have indirect effects to other animals that depend on insects for prey. Th e selective nature of the bait formulation and the active ingredient will minimize population level impacts.

Available aquatic toxicity data for hydramethylnon demonstrates high toxicity to most species. Fish median lethality values range from 100 μ g/L f or channel catfish to 1.7 mg/L for the bluegill sunfish ( EPA 2011a ) . Acute toxicity to invertebrates ranges from the low ppb for the mysid shrimp to greater than 1 ppm for the freshwater cladoceran ( EPA 2011a )

. Chronic toxicity of the formulation and technical active ingredient is high to a quatic invertebrates (EPA, 2011). Hydramethylnon is also considered highly toxic to aquatic plants. Risk to aquatic resources could occur in cases where applications are made adjacent to shallow water bodies. The bait formulation is a granule which will reduce the offsite transport of drift . Also, there are label restrictions designed to protect aquatic nontarget organisms. This includes wind speed restrictions and avoiding conditions which could result in movement into sensitive

areas.

c. Environm ental Quality

The formulation proposed in the IFA program and the environmental fate of hydramethylnon suggest that any impacts to soil, water

, or air will be restricte d to the area of application. O n soil surfaces

, hydramethylnon degrades quickly due to its sensitivity to light. Half

- lives of less than 4 days have been reported for soil in biphasic reactions while the photolytic half

- life in water is less than one day

. In the absence of light

, microbial degradation is slow with reported half

- lives gre ater than 1 year25 ( EPA 1998 ) . Any material that does not degrade will bind tightly to soil from the available data suggesting that hydramethylnon is no t mobile and expected to impact water quality

. Impacts to air quality are not expected because the formulation is a granule applied by ground equipment which will reduce the potential for drift. Hydramethylnon is also not expected to volatilize into the atmosphere from soil or water

, based on avail able product chemistry data ( EPA 1998 )

.

a. Human Health

Methoprene is an insect growth regulator that mimics the insect juvenile hormone which is critical to insect development. Methoprene is used in the IFA program on field

- grown plants ; it is not used on container

- grown and balled and burla p ped plants or in grass sod production. Technical methoprene is considered practically nontoxic to mammals in acute oral, dermal

, and inhalation exposur es. Median acute lethality values range from 5,000 to 34,00 0 mg/kg

, and dermal and inhalation values are greater than 2

, 000 mg/kg and 20 mg/L, respectively ( EPA 1991 ) . The technical ingredient is also not considered an eye or skin irritant

, and is not a skin sensitizer.

Data for the formulation proposed in the IFA program does not appear to be available ; however

, based on data for the technical active ingredient and the granular formulation proposed in the IFA program

, the toxicity is not anticipated to be significantly greater than the technical material. Methoprene is not consid ered to be a mutagenic or carcinogenic compound

, and in chronic dosing studies no observable effect levels (NOELs) were observed at the upper dosing range in studies designed to evaluate reproductive and developmental impacts. Risks to workers are low bec ause the toxicity is low and the granular formulation will reduce
exposure.

Methoprene is not expected to impact water resources that could be used as drinking water. Methoprene is not mobile; therefore leaching into groundwater is not anticipated. Th reats to surface water are reduced by the formulation proposed for use which will minimize drift. Low solubility and selective partitioning to soil and sediment will reduce the likelihood of methoprene residues in surface water that could be used for drin king water.

b. Ecological Resources

Toxicity of methoprene to wild mammals is low

, based on data submitted for human health assessments. Methoprene is also considered practically nontoxic to birds in acute and subacute exposures with median lethality values greater than the highest test concentration ( EPA 2011a ) . Long

term avian reproductive studies show effects at 30 ppm for the mallard

, 6. Methoprene26 but not the northern bobwhite where no chronic reproductive effects were noted. Methoprene has selective toxicity to terrestrial invertebrates due to the mode of action and when an insect may be exposed. Impacts to some soil

- borne terrestrial invertebrates h ave been noted and may occur in this
program ; however

, based on the method of application and formulation used in the IFA program

, impacts would be restricted to areas where the bait is used for field grown plants ( Campiche et al. 2007 )

. Pollinator impacts are not anticipated due to the lack of a significant exposure pathway to insects

, such as honey bees

, because a pplications are made to the ground using a granular formulation. In addition

, available data shows that impacts to honey bees, including sublethal impacts, occur at doses that would not be expecte d to occur in the IFA program or through the method of application used in those studies ( Robinson 1985

, Deng and Waddington 1997 )

. Median lethality values for methoprene toxicity to fish range from the low
ppm for cold water species

, such as the trout

, to greater than 100 ppm for channel catfish suggesting t hat methoprene is slightly to practica lly nontoxic to fish ( EPA 2001

, 2011a )

. Methoprene varies in toxicity to aquatic invertebrates depending on the test species. Median lethality values range from the low ppb to low ppm which would be classifie d as slightly to highly toxic. Several studies have been published regardi ng the potential impacts of methoprene and its metabolites to amphibians from its

use as a mosquitocide. A summary of acute toxicity data for methoprene shows that toxicity to amphibians is low with values greater than the highest test concentration which ranged from 1.0 to 10 ppm with no other adverse effects noted ( EPA 2001 )

. Studies designed to assess the ef fects of methoprene and its metabolites on the development of amphibians have shown impacts occurring above the solubility for methoprene in water

, or at concentrations that could not occur from applications in the IFA
program ( Degitz et al. 2 003

, Henrick 2007 )

.

c. Environmental Quality

Methoprene degrades quickly in soil under aerobic and anaerobic conditions

, with half

- lives ranging from 10 to 14 days. Methoprene also binds tightly to soil and sediment and

, due to its low solubility

, will partition to sediment in cases where it moves offsite from drift or runoff to aquatic habitats. In water

, methoprene is resistant to hydrolysis but breaks down quickly in the presence of light

, with half

- lives less than 13 days ( EPA 1991 ) . Methoprene does exhibit properties that suggest a slight potential for volatilization into the atmosphere from soil and water ( Csondes 2004 ) . This effect is reduced by the preference of methoprene to bind to soil and water

, and any methoprene that will volatilize is susceptible to degradation by sunlight. Movement of methoprene from the27 site of application from drift will be minimal because it is applied as bait and not susceptible to drift when compared to a liquid formulation.

a. Human Health

Pyriproxyfen is part of a group of insecticides ( known as insect growth regulators ) that act as a juvenile hormone analog

. Juvenile hormone is critic al in the development, reproduction, and diapause of insects. It is used as an insecticide to prevent larval insects from maturing to adults. The product currently used in the IFA program is Distance ® which is a bait formulation used in field

- grown plant s ; it is not used on container

grown or ball ed and burlap p ed plants or in grass sod production

. Acute toxicity data for the pyriproxyfen active ingredient and the proposed formulation demonstrate very low toxicity from oral, dermal, or inhalation
exposure s. Median lethality values (LD/LC 50 ) for all three exposure pathways are greater than the highest test concentrations suggesting that the formulation is practically nontoxic in acute exposures. Handling the formulated product can result in minor eye irri tation

, but is not a skin irritant or skin sensitizer

. In longer term studies

, pyriproxyfen has been shown to have low toxicity with NOELs well above any exposures scenarios that could occur in the IFA program ( Hanson 2009 ) . Pyriproxyfen and its associated metabolites are not considered to be carcinogenic or mutagenic

, as demonstrated in available mammalian studies to support registration of the active ingredient ( Bayoumi et al. 2003

, Hanson 2009 ) . Available mammalian toxicity data that has been submitted for registration of pyriproxyfen does not i ndicate any effects related to endocrine disruption. The greatest risk of exposure will be to workers during application. Applications will only be made by certified personnel following all label recommendations regarding worker safety.

b. Ecological Resources

Proposed pyriproxyfen applications are not expected to have adverse impacts to fish or wildlife

, based on the method of application, the low toxicity of the insecticide to most organisms, and program mitigations to reduce exposure and risk. Py riproxyfen has low toxicity to wild mammals and birds suggesting little direct risk and

, based on the mode of action of pyriproxyfen and the small areas of treatment, would not be expected to have adverse impacts for those terrestrial organisms that depend on insects as prey items. Pyriproxyfen will have some impacts to nontarget terrestrial invertebrates ; however, these impacts will be restricted to the area of treatment and will only impact some invertebrates because of the selective nature of the insect icide. Available acute contact toxicity data for pollinators shows that pyriproxyfen is practically nontoxi c to adult honey bees ( EPA 2011a )

. Al so, no toxicity has bee n observed in adult 7. Pyriproxyfen28 bumblebees or to male production and brood production. However, pyriproxyfen may impact larval bumblebee mortality at concentrations higher than the application rates used in this program ( Mommaerts et al. 2006 )

.

P yriproxyfen toxicity to aquatic organisms is variable with acute toxicity above water solubility (0.367 m g/L ) for most fis h species, suggesting low
acute risk to a quatic vertebrates ( EPA 2011a ) . Sublethal impacts in acute and chronic exposures can occur at concentrations in the low ppb range for fish

, and in the ppt range for a quatic invertebrates ( Sihuincha et al. 2005

, Matsumoto et al. 2008

, EPA 2011a ) . Median lethal acute effects to aquatic inverte brates vary from the middle to upper ppb range, depending on the test species ( EPA 2011a ) . Direct or indirect risk to aquatic organisms through l oss of food items is expected to be low because of the application method previously described that will reduce the likelihood of offsite drift and runoff.

c. Environmental Quality

Impacts to soil quality from pyriproxyfen applications are not expect ed, because of the location of the treatments and the fate of pyriproxyfen in soil

. Any contact with soil will be localized and not expected to persist, based on field dissipation half

- lives ranging from 3.5 to 16.5 days

, and aerobic soil metabolism half

- lives of less than 2 weeks ( Sullivan 2000b )

. Pyriproxyfen is not anticipated to have impacts to air quality due to the proposed method of application and environmental fate for the insecticide. Pyriproxyfen has a low vapor pressure suggesting that volatilization into the atmosphere from plants and soil will be minimal

. Because it is applied as bait

, movement out of the area of treatment due to drift is not anticipated. Impacts to surface or groundwater are also not anticipated due to the low solubility of pyriproxyfen in water

, as well as its preference to bind to soil and sediment. This will also reduce the potential for volatilization from water into the atmosphere

, which is considered moderate for pyriproxyfen

, based on available fate data ( Sullivan 2000b )

.


### B. Preferred Alternative

Expansion of bifenthrin use includes applications to field

- grown plants

, as well as balled and burlapped plants and sod that could require treatment in the IFA quar antine zone. In addition to it s use as a stand

- alone active ingredient in various formulations

, bifenthrin applications may also occur in combination with other active ingredients

, such as cypermethrin, clothianidin

, and imidacloprid ( which are discussed below ). 1. Bifenthrin (In

- field Commodities, Balled and Burlapped Plants, Grass Sod)29 a. Human Health

Expansion of bifenthrin use in the IFA program is not anticipated to have significant additional human health risk beyond that discussed in the no action alternative

. Although incre ased usage could result in increased potential exposure to workers and applicators, the personal protective equipment and pesticide label restrictions required for the proposed granular formulations reduce exposure and risk as compared to the concentrate f ormulation. Broadcast applications like those proposed for field plants and grass sod could increase the potential for drinking water contamination compared to container

- only applications

, as described in the no action alternative. However, an increase i n risk to ground drinking
water resources is not expected because of the low solubility and extremely low mobility of bifenthrin

, suggesting that it would not leach into groundwater. Offsite transport into surface water would be very low for the granular formulations due to lack of drift

. A dherence to label restrictions including

, in some cases

, application buffers will minimize transport of bifenthrin and any other active ingredients to surface drinking
water resources from drift or runoff

. b. Ecologic al Resources

Expanded use of bifenthrin in the IFA program could result in an increase in risk to nontarget organisms from bifenthrin exposure , in particular to aquatic resources. Expanded treatments to balled and burlapped plants will not result in incr eased risk to nontarget organisms beyond that previously discussed for containerized media in the no action alternative. However, treatments to field grown plants and grass sod would have a greater potential risk to nontarget organisms because these appli cations are broadcast applied to fields where exposure would be greater to terrestrial and aquatic resources

. Impacts to terrestrial invertebrates that may occur in the area of broadcast applications would be restricted primarily to the treatment area bec ause of the ground

- based applications of bifenthrin and formulations proposed for use. Increased risk to aquatic resources would also be expected ; however

, label restrictions, including buffers for some formulations, will reduce the potential for adverse impacts to aquatic resources immediately adjacent to nursery facilities.

c. Environmental Quality

Any impacts described for bifenthrin under the no action alternative would be anticipated to be more widespread under the preferred alternative because bi fenthrin use would expand.30 a. Human Health

Cypermethrin is a pyrethroid insecticide that effects the axon of the nerve resulting in paralysis ( EPA 2005b ) . Cypermethrin has several agricultural and nonagricultural uses to control a variety of insect pests. For the IFA
program , its proposed use is to treat containers, field

- grown plants

, and grass sod in a formulati on that also contains bifenthrin

. The technical active ingredient, cypermethrin, and the proposed formulation

, Talstar ® Xtra, is moderately toxic in oral exposures , but is considered practically nontoxic in dermal and inhalation exposures . The formulated material is severely irritating to the eye and moderately irritating to the skin . It is also considered a mild skin sensitizer.

C ypermethrin is not considered mutagenic or teratogenic ; however, it is considered a possible carcinogen because of results from a chronic mouse study where benign lung tumors were observed at the highest dose level. These levels are well above those expected in this program. Similar effects were not observed in other test species in chronic studies ( McNeilly and Wang 2007 )

. There is data that demonstrate endocrine

related impacts in vertebrates, but at residues that would not be expected to occur in this program. Jin et al. ( 2011 ) observed a decrease in testosterone levels in male mice dosed at 20 mg/kg of body weight. Wang
et al. ( 2011 ) also observed effects to mice after maternal exposure during lactation to male offspring. Doses of 25 mg/kg resulted in reduced serum and testicular testosterone levels in male mic e that returned to normal as they reached maturity; however, a reduction in testicular weights and tissue effects remained unchanged. These values are in the effect range for studies that have been submitted to support the registration of cypermethrin

. R isk to human health, and in particular workers and applicators

, will be low due to the toxicity of cypermethrin and the granular formulation proposed for use. Exposure to cypermethrin in drinking water is not anticipated.

The proposed formulation is a granule which will minimize the potential for offsite drift. Cypermethrin has very low water solubility and preferentially binds to soil and sediment

, suggesting that it would not be susceptible to leaching into groundwater and would not be present in any runoff to surface water bound to soil particles

.

b. Ecological Resources

C ypermethrin has low acute and chronic avian toxicity with reported acute median lethal doses and chronic no observable effect concentrations (NOECs) greater than the highest test concentration ( EPA 2005b )

. Toxicity is high to most terrestrial invertebrates, including honey bees ; however, the gran ular formulation proposed for use in the IFA program will reduce potential offsite impacts due to the low drift potential

. 2. Cypermethrin31 Broadcast applications would be expected to have impacts to some terrestrial invertebrates ; however

, these impacts would be restrict ed to the area of application and

, in the case of soil

- borne invertebrates , would be minimized by the affinity for the insecticide to bind to soil, reducing bioavailability over time ( Hartnik and Styrishave 2008 ) . The impacts th at could occur to some terrestrial invertebrates from IFA treatment with cypermethrin is not expected to pose an indirect risk to terrestrial vertebrates that depend on invertebrates for prey , in particular for container treatments

. In the case of field a pplications

, vertebrates would be expected to forage over areas greater than the area of treatment.

C ypermethrin is considered highly toxic to aquatic invertebrates and vertebrates with reported median lethality values in the low ppt to low ppb
range , d epending on the test species

, although fish were slightly less sensitive when compared to aquatic invertebrates ( Solomon et al. 2001

, EPA 2005b )

. Acute and chronic risk to aquatic habitats is low because of the granular formulation proposed for use which reduces the potential for drift. Runoff will also be low because cypermethrin has low water sol ubility and will bind to soil and sediment reducing bioavailability to aquatic organisms. In addition

, label language regarding the protection of aquatic habitats will reduce the risk to aquatic biota.

c. Environmental Quality

Cypermethrin is not expec ted to cause adverse impacts to soil, water, or air quality due to the method of application and the environmental fate of the insecticide

. Cypermethrin breaks down in soil under aerobic and anaerobic conditions

, with half

- lives of less than 65 days ( EPA 2005b )

. As discussed previously

, there is the potential for impacts to soil

- borne invertebrates ; however

, this will be restricted to the area of treatment because of the granular formulation proposed for use. Cypermerthrin has very low water solubility and a high binding affinity to soil and sediment that would result in a very low probability of surface or groundwater

co ntamination. Cypermethrin that would move offsite as drift and enter surface water would dissipate quickly from the water column due to its low water solubility and affinity for sediment particles . The rapid partitioning of pyrethroid insecticides from w ater to sediments has been observed in field applications

, as well as laboratory data ( Crossland 1982 )

. In the field

, half

- lives are less than a day under a variety of conditions ( Roessink et al. 2005

, He et al. 2008 )

. Physical and chemical characteristics of cypermethrin preclude significant volatilization into the atmosphere. Cypermethrin would also not be present in the atmosphere as drift because the proposed form ulation is a granule and would not be expected to remain in the atmosphere after application

.32 a. Human Health

Clothianidin is a systemic pesticide that belongs to the neonic o tinoid insecticide class which acts on the nicotinic acetylcholine receptor af

fecting the central nervous system in insects. Clothianidin is proposed for use in this program using the formulation, Aloft ® SC, which also contains the insecticide bifenthrin. It will be used to treat field plants and sod, but not container

- grown or ba lled and burlapped plants. Clothianidin has low acute oral toxicity to rat s but is moderately toxic to mice

, with a reported median le thality value of 425 mg/kg ( EPA 2003b )

. Acute dermal and inhalation toxicity of the active ingredient and the proposed formulation is low with median lethality values exceeding the highest concentration tested. Clothianidin is not considered to be teratogenic, mutagenic

, or carci nogenic

, based on available mammalian studies. The formulation proposed for use in this program is a slight to moderate eye irritant and slight skin irritant and is considered a skin sensitizer

, based on data available on the material safety data sheet.

Clothianidin does exhibit chemical fate properties that suggest mobility in soil and could contaminate drinking water. Conservative estimates of exposure from surface and groundwater contamination do not present any risk to the general population. Risk to groundwater is further reduced by avoiding applications in areas with a high water table and/or permeable soils

. R isk to surface water will be reduced by following label restrictions regarding application buffers from surface water resources.

b. Eco logical Resources

Clothianidin has low to moderat e toxicity to wild mammals and is considered practically nontoxic to birds

, based on oral and dietary
exposures ( EPA 2003 b

, 2011a )

. Conservative assumptions regarding the ingestion of contaminated prey items

, such as insects

, demonstrate very low risk to wild mammals and birds that may forage on treated field

grown plants in nurseries. Indirect risk to vertebrate populations from the loss of prey items is not anticipated from the treatment of fields because they are not typically large areas

, they are already dist urbed due to other activities

, and not exclusive habitats fo r foraging

. Clothianidin is toxic to honey bees and

, because of its systemic action

, may impact pollinators due
to residues in pollen and nectar. Studies designed to assess these types of impacts in bumblebees have shown that maximum clothianidin residue s measured in the field had no observed effects on foraging ability or colony health ( Franklin et al. 2004 )

. Clothianidin was linked to a 2008 bee death incident in Germany. The combination of conditions that occurred in that incident ( i.e.

, application method, weather, use pattern) are not expected in this program ; therefore

, that type of exposure and risk to honey bees and pollinators are not likely to occur. Label restrictions also reduce bee

e xposure by restricting applications on blooming, pollen

, shedding

, and 3. Clothianidin33 nec tar

- producing parts of the plant if bees are anticipated to forage in the area within a 5

- day window after treatment.

Acute toxicity to fish is low with median lethality values greater than the highest test concentration. Acute toxicity to aquatic inve rtebrates is more variable with median lethality values ranging in the low ppb range for some freshwater and marine invertebrates

, such as mysid shrimp and chironomids ( i.e. midges ) to greater than 100 ppm for standard test species

, such as the freshwater cladoceran ( EPA 2003b

, 2011a )

. Adherence to label precautions

, including a 25

- foot buffer, will reduce the risk to aqu atic biota

.

c. Environmental Quality

Clothianidin applications to field

- grown plants and grass sod are not expected to have adverse impacts to soil, water

, or air quality beyond the area of treatment. Clothianidin degradation in soil is slow with laboratory and field studies documenting half

- lives of approximately 148 days to greater than two years. Clothianidin used in combination with bifenthrin as proposed in this program would result in impacts to soil invertebrates ; however

, these impacts wou ld be restricted primarily to the areas of application which are managed nurseries. Clothianidin is considered to be highly mobile in soil and could contaminate water in areas where applications are made in clos e proximity to surface water or to permeable soils with a high groundwater table. The label for the formulation proposed in this program requires a 25

- foot application buffer from various water bodies. Avoiding applications to soils that are permeable will also reduce the likelihood of groundwater contamination. Any clothianidin that would reach water would be susceptible to degradation by light with a reported half

- life of less than 1 day. Degradation of clothianidin from hydr olysis or biological factors is slower because clothianidin is resista nt to hydrolysis and has an aquatic metabolism half

life value of approximately 1 month ( EPA 2003b )

. Impacts to air quality are not anticipated due to the low v apor pressure of clothianidin and method of application which includes the use of ground equipment.

a. Human Health

Permethrin is a pyrethroid insecticide that has a varied toxicology profile. Proposed use in the IFA program is on and around hay and beehi ves, but not for treatment of container

- grown, field

- grown, or balled and burlap p ed plants and grass sod. Acute mammalian toxicity of permethrin is variable for the active ingredient with oral LD 50 values ranging from approximately 40 mg/kg to greater tha n 3,580 mg/kg. Dermal toxicity is considered low with LD 50 values of greater than 2,000 mg/kg for the rabbit and rat ( Kinard et al. 2005 ) . Acute inhalation is also low (LC 50 >23.5 mg/L), as is the potential for acute eye and dermal irritation ( Kinard et al. 2005 )

. The 4. Permethrin34 formulation proposed for use, Gardstar ® , has moderate acute oral toxicity to mammals with a median lethality value of 1

, 490 mg/kg. Similar to the technical active ingredient

, dermal and inhalation toxicity is very low with values reported as greater than the highest concentration tested in those studies . The form ulation is considered slightly irritating to the skin but is not a skin sensitizer ; however

, it is corrosive to the eye according to data on the material safety data sheet. Chronic toxicity studies of permethrin have demonstrated low toxicity in prenatal developmental and reproductive studies. Based on the review of studies submitted to EPA for reregistration, the no observable adverse effect level (NOAEL) in these types of studies ranged from 50 mg/kg/day to 600 mg/kg/day ( Kinard et al. 2005 )

. L ong

- term toxicity studies that assessed carcin ogenicity using the dog, rat, and mouse reported NOAEL values ranged from 36.9 to 316.1 mg/kg/day, depending on species and endpoint. Permethrin has been established as a possible human carcinogen by EPA; however, the
exposure levels where those types of effects occurred were high, and the effect was only seen in mice

, not rat or dog studies.

b. Ecological Resources

Nontarget terrestrial vertebrates, such as birds, do not appear to be sensitive to permethrin exposure

, based on the low LD 50 toxicity va lues for several bird species that range from greater than 2,000 to greater than 23,000 mg/kg ( Rexrode and Meléndez 2005 ) . Chronic toxicity to birds is also low with NOEC values ranging from 25 to 500 ppm, which were the highest test concentrations used in each study. Permethrin is toxic to honey bees, as well as other beneficial insects ; however

, the risk will be localized because proposed applications will occur as a soil drench around hay bales and adjacent to bee hives

.
Aquatic organisms are m ore sensitive to permethrin than other test organisms, based on the range of toxicity values to marine and freshwater fish and invertebrates ( EPA 20 11a ) . A large number of freshwater and marine aquatic toxicity studies have been conducted using permethrin with a result of high acute and chronic toxicity to aquatic fauna. Generally, fish are less sensitive than invertebrates with fish LC 50 values r anging from the high ppt to mid ppb range, depending on the species and respective life stage, study duration, and test conditions. The marine and freshwater aquatic invertebrate toxicity range is lower with reported LC 50 /EC 50 values ranging from the low ppt to low ppb range ( Solo mon et al. 2001

, Rexrode and Meléndez 2005 ) . Permethrin chronic toxicity to fish and aquatic invertebrates is also high

, with NOEC values ranging from the low ppt to low ppb range for fish and aquati c invertebrates, respectively. The proposed use of permethrin in this program as a soil drench to small localized areas around hay bales and in proximity to bee colonies will reduce the potential amount of permethrin that could runoff or drift into aquati c areas. As a soil drench

, large droplets can be used that will35 mitigate drift concerns. Runoff to aquatic areas will be minimized due to the preferential binding affinity of permethrin to soil and sediment

, and label restrictions regarding surface water protection.

c. Environmental Quality

The potential for impacts to soil, water

, and air quality beyond the site of application are not anticipated for the proposed use of permethrin in the IFA program . There would be potential impacts to soil

- borne te rrestrial invertebrates in the area where the soil drench would occur ; however

, because these would not be broadcast applications the impacts would be localized at the point of treatment. Degradation half

- lives in soil under aerobic conditions are typical ly less than 40 days ; however

, under anaerobic conditions m ay exceed 204 days ( Rexrode and Meléndez 2005 )

. In water

, similar differences in half

- lives occur between aerobic and anaerobic conditions. Permethrin has low water solubility and a strong affinity for binding to soil and sediment. Risk to groundwater is not anticipated

, b ased on the fate of permethrin in water and the proposed application methods for the IFA program. Permethrin may impact surface water from drift ; however

, the use of larg e droplets and localized treatments will minimize the potential for drift. Permethrin that may enter surface water from runoff will be bound to soil particles or

, once in the
water
, will rapidly bind to sediment. This is reflected in the aquatic field di

ssipation data for permethrin with reported half

- lives of approximately 3 days or less in studies conducted using pond water. Impacts to air quality are not anticipated because applications will be made using large droplets that would not be expected to r emain in the atmosphere. In addition

, the chemical fate information for permethrin, in particular the vapor pressure value, indicates that permethrin would not be expected to volatilize into the atmosphere in quantities that could result in negative impac ts to air quality ( Rexrode and Meléndez 2005 )

.

a. Human Health

Imidacloprid bel ongs to a class of insecticides called neonicotinoids which act by binding directly to the acetylcholine binding receptor

. Technical and formulated imidacloprid has low t o moderate acute oral mammalian toxicity with median toxicity values ranging from 400 to greater than 2

, 000 mg/kg. The technical material, as well as several formulations, are considered practically nontoxic from dermal or inhalation exposure ( Anatra

- Cordone and Durkin 2005 ) . Acute lethal median toxicity values are typically greater than 2

, 000 mg/kg and 2.5 mg/L for dermal and inhalation exposures, respectively. Its proposed use in the IFA program is in two different formulati ons that are premixed with other active ingredients

. T he first formulation, Allectus ®

, is proposed for use in balled and burlapped plants with bifenthrin

, and in the second formulation, DiscusTM, it is premixed with cyfluthrin and would be use d in field

- grown 5. Imidacloprid36 plants

, balled and burlapped plants

, and grass sod ; neither formulation would be used in container

- grown plants

. The toxicity and risk of bifenthrin and cyfluthrin are discussed indiv idually elsewhere in this section. Available acute toxicity data for formulations similar to those proposed in the IFA program but with higher percentages of each active ingredient suggest low acute oral, dermal

, and inhalation toxicity. Both formulatio n s are not considered to be a skin sensitizer, and have low risk as a skin and eye irritant. Available data for imidacloprid and associated metabolites suggest a lack of mutagenic , carcin ogenic

, or genotoxic effects at relevant doses. Developmental

- , immun e

- , and endocrine

related effects have been observed in some mammal studies. In all cases

, the noted effects were observed at doses above maternal effects in the case of developmental studies, and at concentrations and durations not expected in the IFA pr ogram ( Anatra

- Cordone and Durkin 2005 )

.

Potential risks to human health are restricted

, primarily

, to applicators. As proposed in this program, t he use of granular formulations will minimize oral, dermal

, and inhalation exp osure during application. Adherence to label language regarding personal protective equipment and the low oral, dermal

, and inhalation toxicity of these two formulations will minimize risk to workers who would be making applications with either formulatio n. Imidacloprid does have chemical properties that suggest it could be a threat to groundwater. Avoiding applications in areas where a high water table is present and soils that are highly permeable will reduce the potential for groundwater contamination

.

b. Ecological Resources

Imidacloprid is considered to have moderate toxicity to wild mammals and is considered toxic to birds, with acute oral median lethal toxicity values ranging from 41 to 152 mg/kg. Concerns have been raised about potential le thal and sublethal effects to honey bees and other pollinators. Median lethal toxicity values of imidacloprid have been based upon oral or contact exposure. Laboratory and field studies of honey bees indicate a lack of adverse effects at test concentrati ons comparable to realistic exposure scenarios, and adverse health impacts to hives only with greater exposures ( USDA APHIS 2008 )

. However

, recent laboratory studies assessing sublethal impacts of imidacloprid have demonstrated impacts to honey bees when exposed to lower levels of imidacloprid and the insect pat hogen, Nosemia spp. ( Pettis et al. 2012 ) . Broadcast applications of DiscusTM would pose the greatest risk to pollinators and other sensitive terrestrial invertebrates due to the method of applications and presence of the broad spectrum insecticide, cyfluthrin. Labeled restrictions regarding the protection of honey bees during application will help reduce exposure and risk. Exposure is further reduced in sod treatments a s honey bees would not be expected to be attracted to these areas due to a lack of flowering plants.37 Exposure to wild mammals and birds from applications of imidacloprid and associated residues is not expected to occur at levels that could result in significant risk

. The terrestrial insects that feed upon vegetation of those host plants that have been treated with these applicat ions are likely to be impacted, but the effects would be restricted to the areas of
treatment. Indirect impacts to vertebrate populations that depend on insect prey are not anticipated

. All treatments take place i n commercial nurseries. A reas of sod that could be treated with the DiscusTM formulation would be expected to have some impacts to nontarget terrestrial invertebrates ; however, the impacts would be restricted primarily to areas of treatment where sod would be removed for shipment. Vertebrates tha t might forage in these areas would also forage outside of the treatment area since their foraging range would not be restricted to highly disturbed areas within the nurseries

. Imidacloprid has low toxicity to aquatic organisms including fish, amphibian s , and some aquatic invertebrates. Acute toxicity to fish and amphibians is low with acute median lethal concentrations typically exceeding 100 mg/L ( Anatra

- Cordone and Durkin 2005

, EPA 2011a )

. Chronic toxicity to fish is in the low ppm range , depending on the test species and endpoint. Aquatic invertebrates are more sensitive to imidacloprid when compared to fish

, with acute median toxicity values in the low ppb range to greater than 100 mg/L

, depending on the test species ( Anatra

- Cordone and Durkin 2005

, EPA 2011a )

. Aquatic vertebrates and invertebrates can be exposed through runoff or drift from the site of application. Drift is not considered a significant route of exposure because the formulations proposed for use are granules

. Runoff could occur and would be greatest for the DiscusTM formulation because it is proposed for field use. Conservative esti mates of potential residues that could runoff from the proposed applications are not expected to have any direct impacts to aquatic vertebrate populations. Indirect risk through the loss of aquatic prey items is also not anticipated

, based on the potentia l range of concentrations and toxicity data for aquatic invertebrates.

c. Environmental Quality

Imidacloprid persistence in soil can range from 27 to 229 days

, based on field dissipation studies ( Anatra

- Cordone and Durkin 2005

, Fossen 2006 )

. Imidacloprid does not adsorb strongly to soil particles. Imidacloprid is soluble in water and has a half

- life under natural light of less than 5 hours in water

, but is stable to hydrolysis

. Based on the che mical properties of imidacloprid, there is the potential for leaching into groundwater resources. Adherence to label requirements, as well as the avoidance of applications to permeable soils and/or areas where the water table is high will ensure the prote ction of groundwater. Imidacloprid is not expected to impact air quality because the method of application will not result in38 significant drift. Volatilization to the atmosphere is also not anticipated, based on the chemical properties of imidacloprid.

a. Human Health

Cyfluthrin is a synthetic pyrethroid insecticide with broad spectrum activity. The mode of toxic action occurs by causing the sodium channels to stimulate nerves to produce repetitive discharges. Muscle contractions are sustained until a block of the contractions occurs. Nerve paralysis can occur at high levels of exposure

. T he DiscusTM formulation , which is a mixture of imidacloprid and cyfluthrin

, will be used on field

- grown plant s, balled and burlapped plan t s , and grass sod, but not in container

- grown plan t s, as discussed in the previous section of this document on imidacloprid. The acute oral median lethal toxicity of cyfluthrin is

co nsidered to be low to moderate in mammals. Inhalation and acute dermal toxicity are considered to be low. The formulation of cyfluthrin to be used in the program is of comparable or lower acu te toxicity than the active ingredient. The program applications pose no evident dermal irritation or sensitization, but may result in mild eye irritation . An acute neurotoxicity study using the rat resulted in a decrease in motor activity at 10 mg/kg/da y , with a resulting NOEL of 2 mg/kg/day ( EPA 2005a )

.
Reproductive and developmental toxicity studies in rats found a maternal NOEL of 3 mg/kg/day, and a developmental NOEL of 10 mg/kg/day. Cyfluthrin is not considered to pose mutagenic or carcinogenic risks ( EPA 1997 )

. Cyfluthrin risk to surface or groundwater will be reduced due to the formulation proposed for use and the environmental fate of pyreth roids. Drift is not anticipated because the formulation is a granule

, and movement into groundwater is unlikely due to the very low mobility and solubility of cyfluthrin. The DiscusTM formulation proposed for use in the IFA program contains the active ing redient imidacloprid which does have chemical properties that suggest mobility in soils and possible leaching into groundwater. Avoiding applications to permeable soils or in areas where a high water table is present will reduce the risk to groundwater th at could be used as drinking water.

b. Ecological Resources

The acute oral median lethal toxicity of cyfluthrin is considered to be low to moderate for mammals. Inhalation and acute dermal toxicity are considered to be low. The formulation of cyfluthr in to be used in the program is of comparable or lower toxicity than the active ingredient. Cyfluthrin is considered to be practically nontoxic to birds

, with acute oral median lethal toxicity values greater than 2,000 mg/kg (EPA, 201 1 ). Chronic toxicity to birds is also low

, based on reproductive studies conducted with the mallard and northern bobwhite

, with no effect

c oncentrations greater than 250 ppm ( EPA 2011a )

. 6. Cyfluthrin39 The broad

- spectrum activity of cyfluthrin results in high toxicity to most insects, including pollinators. The 48

- hour contact median lethal dose for honey bees is 0.037 μg/bee ( EPA 2011a )

. Pollinators

, such as honey bees

, should not be impacted ; however

, because applications are made using a granular formulation

, no applications to flowering parts of plants are anticipated

, and the insecticide is not systemic in plants

. Impacts to soil

borne terrestrial invertebrates are not expected for applications to balled and burlapped plants , although impacts to field grown plants and grass sod would be anticipated where applications o ccur. Commercial nurseries are intensively managed and their environment is not likely to be favorable to native, terrestrial invertebrates.

Cyfluthrin is highly toxic to fish and very highly toxic to most aquatic invertebrates ( EPA 2011a ) . The greatest risk to aquatic resources is through drift from cyfluthrin applications. Cyfluthrin runoff is not expected to be significant to aquatic resource s because this type of insecticide binds tightly to soil and has very low solubility

, thereby reducing the potential for transport and exposure to most aquatic organisms. There is the potential for risk to sediment

- dwelling invertebrates ; however

, adheren ce to label recommendations and the lack of drift will reduce the potential for aquatic residues that could result in i mpacts to aquatic invertebrate populations.

c. Environmental Quality

Cyfluthrin impacts to soil, water, and air quality are expected to be minimal

, based on the environmental fate and label requirements for application. Cyfluthrin half

- lives in soil are variable depending on pH and organic matter. Laboratory and field dissipation half

- lives range from approximately 30 to 94 days. Onc e cyfluthrin reaches the soil, it binds very tightly to soil particles

, and is not considered to be water soluble. Its high affinity for soil and low solubility suggest that any cyfluthrin that reaches an aquatic resource will be soil bound or will partit ion very rapidly to the sediment. The lack of mobility suggests that ground water contamination will not be a concern. Surface water quality could be impacted from drift during applications; however, several mitigation

measures are stated on the label to protect surface water quality. Cyfluthrin will only occur in the atmosphere during application

, but will dissipate rapidly and is not expected to volatilize back into the atmosphere based on its chemical properties.

a. Human Health

Lambda cyhalothr in is a pyrethroid insecticide with a mode of action similar to those previously described in this EA. The proposed use in the IFA program would be to containers, balled and burlapped plants , field

7. Lambda cyhalothrin40 grown plants

, and sod using the formulation Scimitar ® GC

, which is a liquid concentrate. The technical active ingredient has moderate acute oral toxicity with LD 50 values of 56 to 79 mg/kg ( Durkin 2010 ) . Dermal and inhalation toxicity is also moderate with values of 623 mg/kg and 0.065 mg/L, respectively. Similar data for the formulation proposed in the IFA pro gram shows much lower toxicity with oral, dermal

, and inhalation values greater than the highest concentration tested and would be considered practically nontoxic. The formulation proposed for use is not considered to be an eye irritant

, but is a slight s kin irritant. Exposure of the concentrated material to the skin can cause parasthesia which is a slight tingling or numbness sensation. Lambda cyhalothrin is not a developmental or reproductive toxicant at relevant exposure levels

, and is not considered mutagenic or carcinogenic. Adherence to label directions and program requirements will minimize the potential exposure and risk to applicators and workers who would be at risk in the proposed applications to various commodities in commercial nurseries und er quarantine

.

b

. Ecological Resources

Lambda cyhalothrin is considered practically nontoxic to birds

, based on available data for the bobwhite quail and mallard duck ( EPA 2011a )

. Chronic toxicity is also low with NOEC values greater than the highest test concentration in long

- term reproductive studies. Lambda cyhalothrin is considered highly toxic to honey bees and other pollinators and

, due to its broad spectrum activity

, would be expected to impact terrestrial invertebrates in areas of treatment.

Lambda cyhalothrin is very highly toxic to aquatic vertebrates and invertebrates in acute and chronic exposures. Acute and chronic toxicity

to freshwater and marine fish are from the low ppt to low ppb range ( EPA 2011a )

. Aquatic invertebrates are more variable in their sensitivity to la mbda cyhalothrin

, b ased on available data. Ac u t e median lethality values range from 1 ppt for mosquito larvae and freshwater amphipods to 2.4 ppb for midge larvae. Current labeling for the proposed formulation require a 25

- foot application buffer from wa ter bodies for all uses and additional drift mitigation measures , such as droplet size requirements, vegetative filter strips

, temperature inversion

, and wind speed restrictions for sod uses which will reduce the exposure and risk to aquatic fauna.

c

. Environmental Quality

Impacts to soil, water

, and air quality are not anticipated for the proposed use of lambda cyhalothrin beyond the areas of application within commercial nurseries. The half

- life of lambda cyhalothrin in soil is less than 50 days und er aerobic conditions

, and the insecticide will bind strongly to soil based on available data regarding partitioning between soil and water. In water

, lambda cyhalothrin has very low water solubility41 and

, due to its preferential binding to soil and sedime nt
, will not occur in solution

. Under aerobic conditions in water the half

- life is approximately 21 days. Due to the low solubility and high affinity for soil

, lambda cyhalothrin is not expected to contaminate groundwater. Surface water contamination is also minimized due to the environmental fate of lambda cyhalothrin and label restrictions that require buffer zones

, as well as other measures, depending on the use pattern, that will reduce offsite drift and runoff . The reported vapor pressure for lambd a cyhalothrin indicates that it will not volatilize into the atmosphere and impact air quality

, and will only occur in the atmosphere near the ground in areas where applications occur in the nurseries.


# V

. Cumulative Impacts

Cumulative impacts are those impacts on the environment which result from the i n cremental impact of a proposed action when added to other past, present, and reaso n ably foreseeable future actions regardless of what agency (Federal or non

- Federal) or person undertakes such other actions

. Cumulative impacts can result from individua l ly minor but collectively significant actions taking place over a period of time.

The insecticides proposed to be added to the list of available insecticides for the IFA quarantine p rogram are also used in a wide variety of residential and/or commercial applications throughout the area covered in the affected environment of this EA

, based on information collected from pesticide labels ( available in the EPA Pesticide Product Label System ( EPA 2011d ) )

. Land use summaries for each S tate discussed in the affected environment of this EA and the broad spectrum activity for a majority of the IFA insecticides suggests that urban and agricultural use of these products also occurs. These products are used to treat multiple pests

, in cluding IFA

, at a greater frequency of use than that used in the IFA quarantine program. In addition

, s everal of the proposed insecticides are also part of pest management and eradication programs supported by APHIS, some of which overlap in counties wher e IFA treatments could

occur. ( Information for APHIS plant pest programs is available on the APHIS w ebsite : http://www.aphis.usda.gov/plant_health/plant_pest_info/index.shtm l

. )

For example

, cypermethrin is listed as a chemical option in the Asian citrus psyllid (ACP), and the boll weevil and pink bollworm moth eradication programs. In addition

, the ACP program has several chemical treatment options with some of those ove rlapping with insecticides being proposed, or currently used, in the IFA program (clothianidin, imidacloprid, chlorpyrifos, bifenthrin , zeta

- cypermethrin, cyfluthrin and permethrin). Additional pesticide active ingredients available in the boll weevil pro gram that are part of the IFA program include permethrin,42 chlorpyrifos, bifenthrin, cyfluthrin, lambda

- cyhalothrin and zeta

cypermethrin. In the pink bollworm program , chlorpyrifos and permethrin are additional pesticide active ingredients that are either part of the current IFA program or being proposed for use. Chlorpyrifos use is also listed as a treatment option for the European gypsy moth and light brown apple moth programs. While several APHIS programs have pesticide

- active ingredients that are par t of the current and proposed new list for IFA, cumulative impacts from this program relative to other APHIS programs would be expected to be minimal. In the case of the boll weevil and pink bollworm programs , applications are confined to cotton fields ; i nsecticides are only used in rare cases where other treatments

, such as trapping, sterile insect technique

, and mating disruption will not result in eradication within a particular field. Recent insecticide treatments in both of these programs have been m inimal or have not occurred in some years due to the success of other control measures. In addition

, programs like the light brown apple moth are restricted to California , thus the potential for cumulative impacts would be restricted to those areas where there is overlap without impact on the remaining S tates that are part of the IFA quarantine. The pink bollworm program is only active in select counties within California, New Mexico, Arizona

, and Texas

, and no chemical treatments occurred in 2011 . There is the possibility that some nurseries treating for ACP may also treat for IFA ; however

, there is uncertainty in which treatments would be used in each program

, and when treatment s would occur in relation to each other. Both programs offer multiple chemi cal options from which to select in meeting the requirements of the quarantine.

In the case of the IFA quarantine

, all program insecticide treatments will only occur in commercial nurseries where ground disturbance and other activities ( e .g., pesti cide use and fertilizer application ) are routine activities unrelated to IFA. Cumulative impacts to human health and terrestrial resources ( e.g., soil and nontarget fauna from the proposed pesticides ) are expected to be minor within the current quarantine a s applications for IFA already take place. The newer active ingredients appear to have equal or less risk to human health

, and will be confined primarily to applicators that treat plants prior to shipment. Some of the proposed new insecticides (e.g., i midacloprid and clothianidin ) do have a greater risk of mobility and could impact drinking water ; however

, label language will reduce the risk of these insecticides to aquatic resources. Geographic areas where the IFA quarantine does not currently exist, but covered in this EA, would expect to see increased insecticide use due to the IFA quarantine once the county becomes part of the IFA quarantine. Increased pesticide loading would be anticipated within the nurseries ; however, adherence to label language will reduce the potential for significant cumulative impacts beyond those already occurring with other activities in the nursery. There is the potential for cumulative impacts to aquatic resources that are adjacent to nursery operations. Offsite transpo rt43 of pesticide runoff into receiving streams from applications to containerized plants, as well as broadcast applications in nurseries, have been noted in several studies ( Stearman and Wells 1997

, Briggs et al. 1998

, Gan and Lee 2005

, Gan 2006 ) . Two products prop osed for new or expanded use in this EA, permethrin and bifenthrin, have been shown to occur in runoff from nurseries ( Gan 2006 ) . Bifenthrin

, in particular

, is linked to impaired water bodies in counties in California that are part of the IFA quaranti ne. Treatments using bifenthrin in proximity to these impaired water bodies could have cumulative impacts in addition to the residues that already occur. Due to temporal and spatial uncertainty in bifenthrin use patterns

, it is difficult to quantify the potential for additional pesticide loading and impacts . The same is true for chlorpyrifos and fipronil which are listed as causes for impairment for one or more water bodies within the current quarantine. In other cases where impairment is due to reasons other than the proposed pesticides

, there is the concern for mixture toxicity which could result in cumulative impacts to water quality and aquatic resources. Water bodies that are impaired for reasons other than pyrethroid and organ o phosphate insecticid e toxicity may also be impacted with increased pesticide use because impacts could be a result of mixture effects. Water quality data from areas within the current IFA quarantine, as well as outside the quarantine, show pesticide mixtures to be a common o c currence in surface water with varying impacts to aquatic organisms ( Gilliom et al. 2007 ) . M ixtures , including pesticides currently used and proposed for use in the IFA program

, can have additive or greater than additive toxicity to aqu a tic and terrestrial organisms ( Deneer 2000

, Lydy and Austin 2004

, Key et al. 2007

, Trimble et al. 2009

, Svendsen et al. 2010 )

. In the case of pyrethroids

, such as permethrin and cyfluthrin, they may also have slightly an t agonistic toxicity to aquatic biota , therefore there is uncertainty in the ability to quantify the potential cumulative impacts of these mixtures ( Brander et al. 2009 )

. Many of the proposed new formulations have buffer zone restrictions

, as well as other protective label language regarding aquatic resources that will minimize the potential for any cumulative impacts to aquatic resources.

Incremental cumulative impacts to human health and the environment are expected to be minor within the nurseries to be treated and

, in particular

, to those already under the IFA quarantine. The additional pesticides that can be used do not appear to result in additional risk to human health beyond those curr ently used in the program. Cumulative impacts from offsite transport through runoff and drift are more difficult to quantify due to the geographic area considered in the EA

, and the uncertainty regarding spatial and temporal use patterns of pesticides and other contaminants in aquatic resources. In cases where the nurseries are not adjacent to aquatic

resources , no cumulative impacts would be expected. In cases where aquatic resources are in proximity to treatment areas

, the method of application, the fo rmulations proposed, label restrictions

, and the fate of44 most insecticides proposed for use will reduce the potential for cumulative impacts to any aquatic resources.


# V I

. Other Environmental Considerations

A. Executive Orders

Consistent with Executive Order (EO) 12898, “Federal Actions to Address Environmental Justice in Minority Populations and Low

- I ncome Populations,” APHIS considered the potential for the proposed action to have any disproportionately high adverse human health or environmental effec ts on any minority populations and low

- income populations. IFA quarantine treatments will only take place in nurseries that occur within the current quarantine area

, and have regulated articles that require treatment prior to shipment to areas that are no t part of the quarantine. These nurseries are established commercial facilities where applications will only be made in the nurseries and not in locations where the public ( including minority and low

- income populations ) would be present. The potential fo r the offsite movement of pesticide is reduced by the proposed use patterns of each formulation

, and adherence to all label language designed to protect the public

, as well as workers and applicators

, within the nurseries. Because chemical treatments are being applied only in nurseries

, APHIS has determined that the human health and environmental effects from the proposed applications are minimal and are not expected to have disproportionate adverse effects to any minority or low

- income populations

.

Con sistent with EO 13045, “Protection of Children from Environmental Health Risks and Safety Risks,” APHIS considered the potential for disproportionately adverse environmental health and safety risks to children resulting from the proposed action. All propo sed treatments will occur within production nursery facilities where the public, including children, would not be present. Drift to areas adjacent to production nurseries where children could be present is not expected because the method s of application a nd formulations used have a low potential to move offsite through the atmosphere. The lack of exposure to this portion of the population would suggest that risks to children from the proposed application of insecticides would not be expected to result in adverse impacts. Items shipped out of the quarantine area after treatment and then moved to areas where children may occur is another potential route of
exposure.

Exposure of IFA treatments to children is greatest in soil which is where IFA resides and is the focus of treatment s in the quarantine program

. Exposure to children would be low in these situations because the soil associated with the roots of the plant that may have residues would be45 localized relative to the amount of untreated soil in the area if plants are transplanted. Two of the proposed formulations contain active ingredients, imidacloprid and clothianidin, that are considered systemic

. Therefore, plants treated with these pesticides w ould contain some residues. Use of both insecticid es in the IFA program would not be to plants grown for food

, thus reducing the potential for dietary exposure that could result in adverse effects to children and the general population. In addition

, treated plants with any IFA insecticide may be held aft er treatment at the nursery prior to shipping where degradation and weathering would occur

, further reducing exposure. Based on the available data regarding the toxicity of each insecticide and their proposed use pattern
, APHIS determined that no dispropo rtionate effects to children are anticipated as a consequence of implementing the p referred alternative


### B. Threatened and Endangered Species

Section 7 of the Endangered Species Act and its implementing regulations require Federal agencies to ensure that their actions are not likely to jeopardize the continued existence of endangered or threatened species or result in the destruction or adverse modification of critical habitat. APHIS is preparing a b iolog i cal a ssessment (BA) that evaluates the potential for impacts to listed species u nder the jurisdiction of the Fish and Wildlife Service ( FWS )

. The potential for affecting endangered and threatened species exists primarily within the nurseries where pesticide treatments would occur

. The FWS BA addresses the potential for impacts to approximately 606 listed species that have been identified to occur within the current quarantine area and the expanded areas described in this EA

. Effects determinations and mitigation mea s ures have been proposed for those sp ecies where co

- occurrence between trea t ments and habitat may

occur. Any conservation measures decided upon w ill be incorporated into the compliance agreements required by the nurseries. Concurren ce with FWS on the BA will e nsure that adequate protecti ve measures are in place for the protection of listed sp e cies that may co

- occur with program activities.46 

# V I I . Listing of Agencies and Persons Consulted

U.S. Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quar antine CPHST Gulfport Lab 3505 25 th Ave. Gulfport, MS 39501

U.S. Department of Agriculture Animal and Plant Health Inspection Service Policy and Program Development Environmental and Risk Analysis Services 4700 River Road

, Unit 149 Riverdale, MD 20737

U.S. Department of Agriculture Animal and Plant Health Inspection Service P lant Protection and Quarantine E mergency and Domestic Programs Environmental Compliance 4700 River Road

, Unit 150 Riverdale, MD 2073747 

# VI I I. Appendices

Appendix I

. Observed D amage to W ildlife by IFA

Animal ( T ype) Noted E ffects Reference
Gopher tortoise Direct predation on hatchlings ( Allen et al. 2004 )
Alligator mississippiensis Infested nests received less maintenance by females resulting in hatchlings w ith low er birth rate ( Allen et al. 2004 )

Bu r mese python Eggs susceptible to IFA in laboratory studies ( Diffie et al. 2010 )
Loggerhead sea turtle (federally listed endangered species) Eggs susceptible to IFA in laboratory studies ( Diffie et al. 2010 )

Diamondback terrapin (IUCN Red List 1 as low er risk or near threatened) Eggs susceptible to IFA in laboratory studies ( Diffie et al. 2010 )

Yellow belly slider Eggs susceptible to IFA in laboratory studies ( Diffie et al. 2010 )
Eastern painted turtle Eggs susceptible to IFA in laboratory studies ( Diffi e et al. 2010 )

Yellow rat snake Eggs susceptible to IFA in laboratory studies ( Diffie et al. 2010 )

Vireo griseus (black capped vireo is federally endangered; w hite

eyed vireo) Protection of nests from IFA predation increased nest survival by 10% ( Campomizzi et al. 2009 )

Orthalicus reses reses (Say) (Stock Island tree snail) Federall y listed as threatened; Florida S tate listed as endangered; extinct from the w ild; IFA thought to be a major factor in its extinction ( Wojcik et al. 2001 )

Cottontail rabbit ( Sylvilagus floridanus (Allen)) Mortality (33 to 75%) of new born rabbits when exposed to fire a nts Hill, E.P.

, 1970. Observations of imported fire ant predation on nestling cottontails. Proc. Southeast. Assoc. Game Fish Comm. 23: 171

– 181 (cited in ( Wojcik et al. 2001 ) )
Box turtle ( Terrapene c arolina triunguis (Agssiz)) Mortality of adult turtles due to IFA stin gs Montgomery, W.B.

, 1996. Predation by the fire ant, Solenopsis invicta , on the three

- toed box turtle, Terrapene carolina triunguis

. Bull. Chicago Herpetol. Soc. 31: 105

– 106. (cited in ( Wojcik et al. 2001 ) )
Toad ( Bufo houstonensis (Sanders)) IFA stings caused mortal ity of young toads; federally listed as endangered Freed, P.S. and K. Neitman

, 1988. Notes on predation on the endangered Houston toad, Bufo houstonensis

. Tex. J. Sci. 40: 454

– 456. (cited in ( Wojcik et al. 2001 ) )

1 IUCN = International Union for Conservation of Natu re and Natural Resources. The IUCN Red List provides information on the conservation status of plant and animal species (http://www.iucnredlist.org/)

.48 

### Appendix I I

. Land R esource R egions Overlapping w ith the G eographic A reas C overed in this E nvironmental A ssessment

Land R esource R egion (LRR) O verlapping w ith F ederal Q uarantine 1 States or P arts T hereof U nder F ederal Q uarantine and F all w ithin the LRR States or P arts T hereof

w ithin the LRR N ot U nder F ederal Q uarantine Soil O rders and S uborders F ound in the LRR

C

— California subtropical fruit, truck, and specialty crop region California (one county under quarantine and parts of 2 other counties) There are four dominant soil orders: Alfisols, Entisols, Mollisols, and Vertisols. There are six dominant soil s uborders: Xeralfs, Xererts, and Xerolls; Fluvents, Orthents, and Ochrepts are found in the flood plains and alluvial fans and are soils important for agricultural purposes.

D

— Western range and irrigated region California

– one county; New Mexico

- one c ounty There are three dominant soil orders: Aridisols, Entisols, and Mollisols. There are five dominant soil suborders: Argids, Calcids, Orthents, Ustolls

, and Xerolls.

G

— Western Great Plains Range and Irrigated Region Texas (small portion of the nort hw est corner) , Oklahoma (very small portion) Colorado, Kansas, Montana, Nebraska, New Mexico, North Dakota, South Dakota, Wyoming There are tw o dominant soil orders: Entisols, Mollisols

. There are four dominant soil suborders: Ustorhents, Torriorhents, H aplustolls, and Argiustolls

.

H

— Central Great Plains w inter w heat and range region Oklahoma, Texas Colorado, Kansas, Nebraska, New Mexico The dominant soil order is Mollisols, but significant acreages of Alfisols, Entisols, and Inceptisols are also prese nt. The dominant soil suborder is Argiustolls. Other suborders include Haplustolls, Ustipsamments, Calciustolls, Paleustolls, and Paleustalfs.

I

— Southw est plateaus and plains range and cotton region Texas There are five dominant soil orders: Alfisols, Aridisols, Inceptisols, Mollisols, and Vertisols. There are five dominant soil suborders: Calcids, Ustalfs, Ustolls, Usterts, and Ustepts.

J

— Southw estern prairies cotton and forage region Oklahoma, Texas Kansas There are four dominant soil orders: Mo llisols, Entisols, Alfisols, and Vertisols. There are four major soil suborders: Paleustalfs, Haplustolls, Haplusterts, and Argiustolls.

N

— East and central farming and forest region Alabama, Arkansas, Georgia, North Carolina, Oklahoma, South Carolina, Tennessee, Virginia Illinois, Indiana, Kentucky, Missouri, Ohio, Pennsylvania, West Virginia; very small areas in Kansas, Maryland, New York There are four domi n ant soil orders: Alfisols, Entisols, Inceptisols, or Ultisols. There are four major soil sub orders: Dystrudepts, Hapludalfs, Hapludults, and Paleudults.

O

— Mississippi delta cotton and feed grains region Arkansas, Louisiana, Mississippi, Tennessee Missouri, very small areas in Kentucky and Illinois There are four dominant soil orders: Alfisol s, Vertisols, Inceptisols, or Entisols.49 There are five major suborders: Aqualfs, Aquerts, Epiaqualfs, Epiaquerts, and Udifluvents.

P

— South Atlantic and gulf slope cash crops, forest, and livestock region Alabama, Arkansas, Florida, Georgia, Louisiana, Mi ssissippi, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, Virginia Illinois, Kentucky, Missouri There are five major soil orders: Alfisols, Entisols, Inceptisols, Ultisols, or Vertisols. There are 14 major soil suborders: Dystruderts, Dystr udepts, Fragiudalfs, Eutrudepts, Fluvaquents, Fraglossudalfs, Hapludalfs, Hapluderts, Hapludults, Kandiudults, Kanhapludults, Paleudalfs, Paleudults, and Quartzipsamments.

T

— Atlantic and Gulf Coast low land forest and crop region Alabama, Florida, Georgia

, Louisiana, Mississippi, North Carolina, South Carolina, Texas, Virginia Delaw are, Maryland, New Jersey There are five dominant soil orders: Alfisols, Entisols, Histosols, Spodosols, and Ultisols. There are five dominant soil suborders: Aqualfs, Aquents, Aquults, Psamments, and Udults.

U

— Florida subtropical fruit, truck crop, and range region Florida The dominant soil order is Entisols, and significant areas of Alfisols and Histosols. There are three dominant suborders: Aqualfs, Aquents, and Psamments.

1 Land resource regions ( LRR s) are geographically associated major land resource areas ( MLRA s) which approximate broad agricultural market regions (USDA

– NRCS). LRRs are categorized by capital letters. Major land resource areas ( MLRA s) are geographically associated land resource units ( LRU s). MLRAs are described in the Agriculture Handbook 206, and include brief descriptions of total area of the MLRA in a particular S tate; list of major cities, highways, and culturally significant Federal

- and S tate

- owned lands within each MLRA; and information on physiography, geology, climate, w ater, soils, biological resources, and land use in the MLRA.

(Source: ( USDA NRCS 2006 )50 

### Appendix III

. Major U ses of L and (2007) for S tates w ithin the IFA Q uarantine and t he E xpanded G eograph ic A rea C overed in t his E nvironmental A ssessment

State Cropland Grassland P asture and R ange Forest

use L and Special

use A reas Urban A reas Miscellaneous O ther L and Total L and A rea 1

------------------------------------- 1,000 acres

----------------------- --------------
Alabama 3,104 2,642 22,587 1,535 1,140 1,468 32,476

Arkansas 8,240 3,293 18,596 1,568 589 1,039 33,324

California 2 9,550 27,524 26,983 25,377 5,166 5,213 99,814

Florida 2,760 5,558 15,649 5,008 4,052 1,486 34,513
Georgia 4,619 1,292 24,267 2,073 2,465 2,344 37,060

Louisiana 4,435 1,860 14,142 1,975 1,088 4,380 27,880
Mississippi 5,556 2,055 19,579 958 607 1,265 30,020

New Mexico 2 2,367 52,122 14,977 6,477 493 1,232 77,668

North Carolina 4,843 1,231 18,037 2,858 2,357 1,849 31,175

Oklahoma 12,840 18,707 7,620 1,731 736 2,312 43,947

South Carolina 2,001 795 12,646 1,081 1,230 1,517 19,270

Tennes see 6,019 2,093 13,913 2,072 1,594 688 26,379

Texas 34,115 101,735 17,159 6,220 4,646 3,676 167,550
Virginia 3,251 2,463 15,350 1,662 1,555 1,059 25,340

1 Miscellaneous areas

, such as marshes, open swamps, bare r ock areas, deserts, rural residential areas, and other uses not inventoried.

2 Values for California and New Mexico are for the entire S tate; however, only eight counties in California and one county in New Mexico are part of the geographic scope of this as sessment.

Source: ( USDA ERS 2007

, Nickerson et al. 2011 )

.51 

### Appendix IV. Counties w ithin the IFA Q uarantine and the E xpanded G eographic A rea C overed in t his E nvironmental A ssessment t hat a re D esignated a s N onattainment A reas for O ne or M ore C ommon A ir P ollutants T ra cked by the Environmental Protection Agency (EPA)

State or P art T hereof U nder IFA Q uarantine and the States and C ounties C onsidered in the EA 1 Number of C ounties with N onattainment S tatus 1 County with N onattainment S tatus Pollutant 2

Alabama (all 67 coun ties are under IFA quarantine) 5 Jackson, Jefferson, Shelby, Walker PM

- 2.5 1997
Jefferson, Shelby, Walker PM

- 2.5 2006

Pike Lead 2008
Arkansas (part or all of 33 counties are under IFA quarantine; This EA considers all 75 counties) 0 No counties list ed

California (part or all of 3 counties are under IFA quarantine; This EA considers 8 counties out of 57) 7 Los Angeles Lead 2008
Los Angeles, Orange, Riverside, San Bernardino PM

- 2.5 1997

Imperial, Los Angeles, Orange, Riverside, San Bernardino P M

- 2.5 2006

Imperial, Los Angeles, Orange, Riverside, San Bernardino PM

- 10

Imperial, Los Angeles, Orange, Riverside, San Bernardino, San Diego, Ventura 8

- Hr Ozone

Florida (all 66 counties are under IFA quarantine) 1 Hillsborough Lead 2008

Georgia (a ll 156 counties are under IFA quarantine) 27 Barrow , Bartow , Bibb, Carroll, Catoosa, Cherokee, Clayton, Cobb, Cow eta, De Kalb, Douglas, Fayette, Floyd, Forsyth, Fulton, Gw innett, Hall, Heard, Henry, Monroe, New ton, Paulding, Putnam, Rockdale, Spalding, Wal ker, Walton PM

- 2.5 1997

Barrow , Bartow , Carroll, Cherokee, Clayton, Cobb, Cow eta, De Kalb, Douglas, Fayette, Forsyth, Fulton, Gw innett, Hall, Henry, New ton, Paulding, Rockdale, Spalding, Walton 8

- Hr Ozone

Louisiana (all 60 counties are under IFA quara ntine) 5 Ascension, East Baton Rouge, Iberville, Livingston, West Baton Rouge 8

- Hr Ozone

Mississippi (all 82 counties are under IFA quarantine) 0 No counties listed

New Mexico (1 county out of 33 is under IFA quarantine) 1 Dona Ana PM

- 10

North Carolina (60 counties

– all or 10 Cataw ba, Davidson, Guilford PM

- 2.5 199752 part thereof

– are under IFA quarantine; this EA considers all 100 counties) Cabarrus, Gaston, Iredell, Lincoln, Mecklenburg, Row an, Union 8

- Hr Ozone

Oklahoma (8 counties fall w ithin the IFA quarantine; this EA considers all 77 counties) 0 No counties listed

South Carolina (all 46 counties are under IFA quarantine) 1 York 8

- Hr Ozone

Tennessee (55 counties are w ithin the IFA quarantine; this EA considers all 93 counties) 7 Anderson, Blo unt, Hamilton, Knox, Loudon, Roane PM

- 2.5 1997

Anderson, Blount, Knox, Loudon, Roane PM

- 2.5 2006

Sullivan Lead 2008

Texas (188 counties fall w ithin the IFA quarantine; this EA considers all 254 counties) 18 Collin Lead 2008, 2009

El Paso PM

- 10
Brazoria, Chambers, Collin, Dallas, Denton, Ellis, Fort Bend, Galveston, Harris, Johnson, Kauf man, Liberty, Montgomery, Parker, Rockw all, Tarrant, Waller 8

- Hr Ozone

Virginia (2 counties fall w ithin the IFA quarantine; this EA considers all 95 counties) 4 Arlington, Fairfax, Loudoun, Prince William PM

- 2.5 1997 ; 8

- Hr Ozone

1 The IFA quarantine area includes S tates of: Alabama, Florida, Georgia, Louisiana, Mississippi

, South Carolina

, and parts of Arkansas, California (part of Los Angeles and Riversi de County and the entire county of Orange ), New Mexico (one county), North Carolina, Oklahoma, Tennessee, Texas

, and Virginia. The geographic range of this EA includes the current quarantine area

, as well as areas into which IFA is likely to expand, based on research done by Korzukhin et al. ( 2001 )

. The expanded regio n includes the entire S tate of Arkansas, North Carolina, Oklahoma, Tennessee, Texas, and Virginia. It also includes several additional counties in California (San Bernardino, Ventura, Santa Barbara, San Diego, and Imperial) and the entire county of Los An geles

, and Riverside in California

. 2 PM

- 10 = Particulate matter 10 micrometers in diameter or less; PM

- 2.5 = Particulate matter 2.5 micrometers in diameter or less; the year follow ing a pollutant is the version of the standard used at the time of the meas urement; 8

- Hr Ozone is measured by taking “ the 3

- year average of the fourth

- highest daily maximum 8

- hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm”.

Source: ( EPA 2011c )53 

### Appendix V. Number of W atersheds and W atersheds C ontaining W aters I mpaired w ith C hemicals U sed in t he IFA Program

State or P art T hereof

w ithin the C urrent Federal Q uarantine Number of W atersheds w ithin the C urrent Q uarantine A rea 1 and w ithin the E xpanded G eograph ical R egion C overed in t his EA 3 Chemicals U sed or P roposed F or U se in T he IFA Program F ound in I mpaired W aters

Alabama (entire S tate) 52 Chlorpyrifos
Arkansas (part of S tate) 22 (est.) 1
59 total 3 None listed

California (part of S tate) 4 (est.) 1
40 to tal Calleguas Watershed (Ventura Co.): Chlorpyrifos, Diazinon, Bifenthrin; Los Angeles Watershed (Los Angeles and Ventura Co.): Diazinon; Newport Bay Watershed (Orange Co.): Chlorpyrifos, Diazinon; Salton Sea Watershed (Imperial, Riverside, San Bernardi no, San Diego Co.): Chlorpyrifos, Diazinon; San Diego Watershed (San Diego Co.): Diazinon; San Gabriel Watershed (Los Angeles, Orange, and San Bernardino Co.): Diazinon; Santa Clara Watershed (Los Angeles, Santa Barbara, and Ventura Co.): Chlorpyrifos, D iazinon; Santa Maria Watershed (Santa Barbara Co.): Chlorpyrifos
Florida (entire S tate) 54 3 None listed
Georgia (entire S tate) 52 3 None listed
Louisiana (entire S tate) 60 3 Fipronil
Mississippi (entire S tate) 59 3 None listed
New Mexico (Dona Ana County) 4 None listed

North Carolina (part of S tate) 28 (est.) 1
58 total 3 None listed

Oklahoma (part of S tate) 20 (est.) 1
67 total 3 Lower Canadian

- Walnut Watershed, Deep Fork Watershed, Lower Cimarron

- Skeleton Watershed : Chlorpyrifos

Lower Verdigr is Watershed, Polecat

- snake Watershed : Diazinon
Puerto Rico (entire territory) 11 3 Pesticides listed but type not specified
South Carolina (entire S tate) 38 3 None listed
Tennessee (part of S tate) 23 (est.) 1
60 total 3 None listed

Texas (part of S tat e) 112 (est.) 1 None listed54 210 total 3

Virginia (part of S tate) 4 (est.) 1
53 total 3 None listed

1 The (est.) indicates the number is an estimate; w e are unable to precisely overlay the S tates or counties under partial IFA quarantine with watershed and national w ildlife refuge areas using the maps and resources consulted. The estimates provide enough information for the purposes of this document.

2 The number of f ederally listed threatened or endangered species is unique for each National Wildlife Refu ge but is not unique across refuges; a species may be found in multiple refuges.
3 The total number of watersheds per S tate was obtained from EPA’s Surf your watershed (http://cfpub.epa.gov/surf/locate/index.cfm ).

Sources: ( EPA 2011e

, FWS 2 011a

, b )55 

# IX

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