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Final Environmental Assessment Rangeland Grasshopper 

and Mormon Cricket Suppression Program

Carbon, Emery, Grand & San Juan Counties, Utah

EA Number: UT-20-1

Prepared by:

Animal and Plant Health Inspection Service

65 South 100 East

Richfield, UT 84701

June 26, 2020
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Table of Contents

I. Need for Proposed Action...................................................................................................... 5

A. Purpose and Need Statement .............................................................................................. 5

B. Background Discussion ...................................................................................................... 5

C. About This Process............................................................................................................. 8

II. Alternatives............................................................................................................................ 9

A. No Action Alternative......................................................................................................... 9

B. Insecticide Applications at Conventional Rates or Reduced Agent Area Treatments with 

Adaptive Management Strategy (Preferred Alternative)........................................................ 10

C. Experimental Treatments Alternative ............................................................................... 11

III. Affected Environment.......................................................................................................... 11

A. Description of Affected Environment............................................................................... 11

B. Site-Specific Considerations............................................................................................. 13

1. Human Health ................................................................................................................ 13

2. Non-target Species......................................................................................................... 14

3. Socioeconomic Issues.................................................................................................... 14

4. Cultural Resources and Events ...................................................................................... 16

5. Special Considerations for Certain Populations ............................................................ 18

IV. Environmental Consequences.............................................................................................. 19

A. Environmental Consequences of the Alternatives............................................................ 20

1. No Action Alternative.................................................................................................... 20

2. Insecticide Applications at Conventional Rates or Reduced Agent Area Treatments 

with Adaptive Management Strategy.................................................................................... 21

3. Experimental Treatments Alternative ............................................................................ 30

B. Other Environmental Considerations................................................................................ 30

1. Cumulative Impacts....................................................................................................... 30

2. Tribal Consultation ........................................................................................................ 32

3. Executive Order 13186, Responsibilities of Federal Agencies to Protect Migratory 

Birds...................................................................................................................................... 32

4. Endangered Species Act ................................................................................................ 33

5. Bald and Golden Eagle Protection Act .......................................................................... 33

6. Additional Species of Concern ...................................................................................... 34

7. Fires and Human Health Hazards.................................................................................. 34

8. Cultural and Historical Resources ................................................................................. 35

V. Literature Cited .................................................................................................................... 35

VI. Listing of Agencies and Persons Consulted......................................................................... 42

A. Bureau of Land Management ...................................................................................... 42

B. Utah Department of Agriculture and Food................................................................ 42

D. USDA, Forest Service................................................................................................. 43

E. USDA, Fish and Wildlife Service............................................................................... 43

F. Utah Division of Wildlife Resources .......................................................................... 43

G. Utah State University Extension Service .................................................................... 43
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General Guidelines for Grasshopper / Mormon Cricket Treatments ................................... 45

Operational Procedures.............................................................................................................. 46

GENERAL PROCEDURES FOR ALL AERIAL AND GROUND APPLICATIONS....... 46

SPECIFIC PROCEDURES FOR AERIAL APPLICATIONS............................................ 47
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Appendices

Appendix 1: FY 2020 Guidelines for Treatment of Rangeland for the 

Suppression of Grasshoppers and Mormon Crickets, USDA APHIS PPQ 

Western Region ...............................................................................................45

Appendix 2: Map of Affected Environment........................................................49

Appendix 3: FWS/NMFS Correspondence .........................................................50

Appendix 4: Responses to Comments to EA’s .......................................63

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pesticide containers
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Final Site-Specific Environmental Assessment 

Rangeland Grasshopper and Mormon Cricket Suppression Program

Carbon, Emery, Grand & San Juan Counties, Utah

I. Need for Proposed Action

A. Purpose and Need Statement

An infestation of grasshoppers or Mormon crickets may occur in Carbon, Emery, Grand 

&/or San Juan Counties, Utah. The Animal and Plant Health Inspection Service (APHIS) 

and any cooperating agency, based on location of infestation may, upon request by land 

managers or State departments of agriculture, conduct treatments to suppress grasshopper 

infestations as part of the Rangeland Grasshopper and Mormon Cricket Suppression 

Program (program). The term “grasshopper” used in this environmental assessment (EA)

refers to both grasshoppers and Mormon crickets, unless differentiation is necessary.

Populations of grasshoppers that trigger the need for a suppression program are normally 

considered on a case-by-case basis. Participation is based on potential damage such as 

wildlife and livestock forage destruction and benefits of treatments including crop 

protection or protection of sensitive species from grasshopper depredation. The goal of 

the proposed suppression program analyzed in this EA is to reduce grasshopper 

populations to economically acceptable levels in order to protect rangeland ecosystems or 

cropland adjacent to rangeland.

This EA analyzes potential effects of the proposed action and its alternatives. This EA 

applies to a proposed suppression program that would take place from May 1st to 

September 30th in Carbon, Emery, Grand &/or San Juan Counties, Utah. 

This EA is prepared in accordance with the requirements under the National 

Environmental Policy Act of 1969 (NEPA) (42 United States Code § 4321 et. seq.) and 

the NEPA procedural requirements promulgated by the Council on Environmental 

Quality, United States Department of Agriculture (USDA), and APHIS. A decision will 

be made by APHIS based on the analysis presented in this EA, the results of public 

involvement, and consultation with other agencies and individuals. A selection of one of 

the program alternatives will be made by APHIS for the 2020 Control Program for 

Carbon, Emery, Grand & San Juan Counties, Utah.

B. Background Discussion

Rangelands provide many goods and services, including food, fiber, recreational 

opportunities, and grazing land for cattle (Havstad et al., 2007; Follett and Reed, 2010). 

Grasshoppers and Mormon crickets are part of rangeland ecosystems, serving as food for 

wildlife and playing an important role in nutrient cycling. However, grasshoppers and 

Mormon crickets have the potential to occur at high population levels (Belovsky et al., 
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1996), that result in competition with livestock and other herbivores for rangeland forage 

and can result in damage to rangeland plant species.

In rangeland ecosystem areas of the United States, grasshopper populations can build up 

to economic infestation levels1 despite even the best land management and other efforts 

to prevent outbreaks. At such a time, a rapid and effective response may be requested and 

needed to reduce the destruction of rangeland vegetation. In some cases, a response is 

needed to prevent grasshopper migration to cropland adjacent to rangeland. 

APHIS surveys grasshopper populations on rangeland in the Western United States, 

provides technical assistance on grasshopper management to land owners and managers, 

and may cooperatively suppress grasshoppers when direct intervention is requested by a 

Federal land management agency or a State agriculture department (on behalf of a State 

or local government, or a private group or individual). APHIS’ enabling legislation 

provides, in relevant part, that ‘on request of the administering agency or the agriculture 

department of an affected State, the Secretary, to protect rangeland, shall immediately 

treat Federal, State, or private lands that are infested with grasshoppers or Mormon 

crickets’... (7 U.S.C. § 7717(c)(1)). The need for rapid and effective response when an 

outbreak occurs limits the options available to APHIS. The application of an insecticide 

within all or part of the outbreak area is the response available to APHIS to rapidly 

suppress or reduce grasshopper populations and effectively protect rangeland. 

In June 2002, APHIS completed an Environmental Impact Statement (EIS) document 

concerning suppression of grasshopper populations in 17 Western States (Rangeland 

Grasshopper and Mormon Cricket Suppression Program, Environmental Impact 

Statement, June 21, 2002). The EIS described the actions available to APHIS to reduce 

the damage caused by grasshopper populations in Arizona, California, Colorado, Idaho, 

Kansas, Montana, Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Oregon, 

South Dakota, Texas, Utah, Washington, and Wyoming. During November 2019, APHIS 

published an updated EIS to incorporate the available data and analyze the environmental 

risk of new program tools. 

APHIS’ authority for cooperation in this suppression program is based on Section 417 of 

the Protection Act otL.000 (7 U.S.C. § 7717).

The Utah Agricultural Code, Section 4-35, provides for certain actions authorized by this 

“Insect Infestation Emergency Control Act.” It authorizes the Utah Commissioner of 

 1 The “economic infestation level” is a measurement of the economic losses caused by a particular population level 

of grasshoppers to the infested rangeland. This value is determined on a case-by-case basis with knowledge of many 

factors including, but not limited to, the following: economic use of available forage or crops; grasshopper species, 

age, and density present; rangeland productivity and composition; accessibility and cost of alternative forage; and 

weather patterns. In decision making, the level of economic infestation is balanced against the cost of treating to 

determine an “economic threshold” below which there would not be an overall benefit for the treatment. Short-term 

economic benefits accrue during the years of treatments, but additional long-term benefit may accrue and be 

considered in deciding the total value gained by treatment. Additional losses to rangeland habitat and cultural and 

personal values (e.g., aesthetics and cultural resources), although a part of decision making, are not part of the 

economic values in determining the necessity of treatment.
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Agriculture to appoint members to a Decision and Action Committee who are directly 

affected and involved in the current insect infestation emergency. The committee 

establishes a system of priorities for any insect infestation emergency, and members of 

USDA, APHIS, PPQ in Utah have served on the committee and have been asked to help 

address the grasshopper/Mormon cricket problem which this document analyzes. The 

Commissioner of Agriculture, with the consent of the governor, has declared that this 

infestation jeopardizes property and recourses and has designated, with the help of 

APHIS surveys, the areas affected. He has initiated operations to control the problem in 

those designated areas and has request APHIS to enter into a cooperative agreement with 

the Utah Department of Agriculture and Food (UDAF) in order to cooperatively attack 

the infestations and mitigate consequences related thereto.

In October 2015, APHIS and the Bureau of Land Management (BLM) signed a 

Memorandum of Understanding (MOU) detailing cooperative efforts between the two 

groups on suppression of grasshoppers and Mormon crickets on BLM lands (Document 

#15-8100-0870-MU, October 15, 2015). This MOU clarifies that APHIS will prepare and 

issue to the public site-specific environmental documents that evaluate potential impacts 

associated with proposed measures to suppress economically damaging grasshopper and 

Mormon cricket populations. The MOU also states that these documents will be prepared 

under the APHIS NEPA implementing procedures with cooperation and input from the 

BLM. 

The MOU further states that the responsible BLM official will request in writing the 

inclusion of appropriate lands in the APHIS suppression project when treatment on BLM 

land is necessary. The BLM must also prepare a Pesticide Use Proposal (Form FS-2100-

2) for APHIS to treat infestations. According to the provisions of the MOU, APHIS can 

begin treatments after APHIS issues an appropriate decision document and BLM 

prepares and approves the Pesticide Use Proposal.

In November 2019, APHIS and the Forest Service (FS) signed an MOU detailing 

cooperative efforts between the two groups on the suppression of grasshoppers on FS 

system lands (Document # 19-8100-0573-MU, November 06, 2019). This MOU clarifies 

that APHIS would prepare and issue to the public site-specific environmental 

documentations that evaluate potential impacts associated with the proposed measures to 

suppress economically damaging grasshopper populations. The MOU also states that 

these documents would be prepared under the APHIS NEPA implementation procedures 

with cooperation and input from the FS.

The MOU further states that the responsible FS official would request in writing the 

inclusion of appropriate lands in the APHIS suppression project when treatment on FS 

land is necessary The FS must also prepare a Pesticide Use Proposal (Form: FS-2100-2) 

for APHIS to treat infestations. According to the provisions of the MOU, APHIS can 

begin treatments after APHIS issues an appropriate decision document and FS prepares 

and approves the Pesticide Use Proposal.
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In September 2016, APHIS and the Bureau of Indian Affairs (BIA) signed an MOU 

detailing cooperative efforts to suppress grasshoppers on Tribal lands. This MOU 

clarifies that APHIS would prepare and issue to the public site-specific environmental 

documents that evaluate potential impacts associated with the proposed measures to 

suppress economically-damaging grasshopper populations. The MOU also states that 

these documents would be prepared under the APHIS NEPA implementing procedures 

with cooperation and input from the BIA.

The MOU further states that the responsible BIA official would request in writing the 

inclusion of appropriate lands in the APHIS suppression project when treatment on BIA 

land is necessary. The BIA must also approve a pesticide use proposal for APHIS to treat 

infestations of grasshoppers or Mormon crickets. According to the provisions of the 

MOU, APHIS can begin treatments after APHIS issues an appropriate decision document 

and the BIA approves the pesticide use proposal.

C. About This Process

The EA process for grasshopper management is complicated by the fact that there is very 

little time between requests for treatment and the need for APHIS to take action with 

respect to those requests. Surveys help to determine general areas, among the scores of 

millions of acres that potentially could be affected, where grasshopper infestations may 

occur in the spring of the following year. Survey data provides the best estimate of future 

grasshopper populations, yet environmental factors lead to certain forecasts where the

specific treatment areas will be. Therefore examining specific treatment areas for 

environmental risk analysis under NEPA is typically not possible. At the same time, the 

program strives to alert the public in a timely manner to its more concrete treatment plans 

and avoid or minimize harm to the environment in implementing those plans.

The current EIS provides a solid analytical foundation; however, it may not be enough to 

satisfy NEPA completely for actual treatment proposals. The program typically prepares

a Draft EA tiered to the current EIS for each of the 17 Western States, or portion(s) of a 

state, that may receive a request for treatment. The Draft EA analyzes aspects of 

environmental quality that could be affected by treatments in the area where grasshopper 

outbreaks are anticipated. The Draft EA will be made available to the public for a 30-day 

comment period. When the program receives a treatment request and determines that 

treatment is necessary, the specific site within the state will be evaluated to determine if 

environmental factors were thoroughly evaluated in the Draft EA. If all environmental 

issues were accounted for in the Draft EA, the program will prepare a Final EA and 

Finding of No Significant Impact (FONSI). Once the FONSI has been finalized copies of 

those documents will be sent to any parties that submitted comments on the Draft EA,

and to other appropriate stakeholders. To allow the program to respond to comments in a 

timely manner, the Final EA and FONSI will be posted to the APHIS website. The 

program will also publish a notice of availability in the same manner used to advertise the 

availability of the Draft EA.

This draft EA was published for a 30-day comment period that began on March 15, 2020. 

A notice of availability was published announcing the beginning of the 30-day comment 
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period in the Deseret News and the Salt Lake Tribune newspapers. The Draft EA was 

sent to various stakeholders and was also published at the APHIS website. APHIS 

received comments from 2 entities during the 30-day comment period. APHIS provided 

a comment to responses in Appendix 4 and updated the Final EA where appropriate.

II. Alternatives

To engage in comprehensive NEPA risk analysis APHIS must frame potential agency 

decisions into distinct alternative actions. These program alternatives are then evaluated 

to determine the significance of environmental effects. The 2002 EIS presented three 

alternatives: (A) No Action; (B) Insecticide Applications at Conventional Rates and 

Complete Area Coverage; and (C) Reduced Agent Area Treatments (RAATs), and their 

potential impacts were described and analyzed in detail. The 2019 EIS was tiered to, and 

updated the 2002 EIS. Therefore the 2019 EIS considered the environmental background 

or ‘No Action’ alternative of maintaining the program that was described in the 2002 EIS 

and Record of Decision. The 2019 EIS also considered an alternative where APHIS 

would not fund or participate in grasshopper suppression programs. The preferred 

alternative of the 2019 EIS allowed APHIS to update the program with new information 

and technologies that not were analyzed in the 2002 EIS. Copies of the complete 2002 

and 2019 EIS documents are available for review at 65 South 100 East, Richfield, UT 

84701. These documents are also available at the Rangeland Grasshopper and Mormon 

Cricket Program web site, http://www.aphis.usda.gov/plant-health/grasshopper. 

All insecticides used by APHIS for grasshopper suppression are used in accordance with 

applicable product label instructions and restrictions. Representative product specimen 

labels can be accessed at the Crop Data Management Systems, Inc. web site at 

www.cdms.net/manuf/manuf.asp. Labels for actual products used in suppression 

programs will vary, depending on supply issues. All insecticide treatments conducted by 

APHIS will be implemented in accordance with APHIS’ treatment guidelines and 

operational procedures, included as Appendix 1 to this Final EA. 

This Final EA analyzes the significance of environmental effects that could result from 

the alternatives described below. These alternatives differ from those described in the 

2019 EIS because grasshopper treatments are not likely to occur in most of Carbon,

Emery, Grand or San Juan Counties, and therefore the environmental baseline should 

describe a no treatment scenario. 

A. No Action Alternative

Under Alternative A, the No Action alternative, APHIS would not conduct a program to 

suppress grasshopper infestations within Carbon, Emery, Grand or San Juan Counties, 

Utah. Under this alternative, APHIS may opt to provide limited technical assistance, but 

any suppression program would be implemented by a Federal land management agency, 

a State agriculture department, a local government, or a private group or individual.
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B. Insecticide Applications at Conventional Rates or Reduced Agent 

Area Treatments with Adaptive Management Strategy (Preferred 

Alternative)

Under Alternative B, the Preferred Alternative, APHIS would manage a grasshopper 

treatment program using techniques and tools discussed hereafter to suppress outbreaks. 

The insecticides available for use by APHIS include the U.S. Environmental Protection 

Agency (USEPA) registered chemicals carbaryl, diflubenzuron, and malathion. These 

chemicals have varied modes of action: carbaryl and malathion work by inhibiting 

acetylcholinesterase (enzymes involved in nerve impulses); and diflubenzuron is a chitin 

inhibitor. 

APHIS would make a single application per year to a treatment area, and could apply 

insecticide at an APHIS rate conventionally used for grasshopper suppression treatments, 

or more typically as reduced agent area treatments (RAATs). APHIS selects which 

insecticides and rates are appropriate for suppression of a grasshopper outbreak based on 

several biological, logistical, environmental, and economical criteria. The identification 

of grasshopper species and their life stage largely determines the choice of insecticides 

used among those available to the program. RAATs are the most common application 

method for all program insecticides, and only rarely do rangeland pest conditions warrant 

full coverage and higher rates.

The RAATs strategy is effective for grasshopper suppression because the insecticide 

controls grasshoppers within treated swaths while conserving grasshopper predators and 

parasites in swaths not directly treated. RAATs can decrease the rate of insecticide 

applied by either using lower insecticide concentrations or decreasing the deposition of 

insecticide applied by alternating one or more treatment swaths. Both options are most 

often incorporated simultaneously into RAATs. Either carbaryl, diflubenzuron or 

malathion would be considered under this alternative at the following application rates:

• 8.0 – 16.0 fluid ounces (0.25 - 0.50 lb a.i.) of carbaryl ULV spray per acre;

• 10.0 pounds of 2 or 5 percent (0.20 lb a.i. or 0.50 lb a.i.) carbaryl bait per acre;

• 0.75 or 1.0 fluid ounce (0.012 or 0.016 lb a.i.) of diflubenzuron per acre; or

• 4.0 – 8.0 fluid ounces (0.31 – 0.62 lb a.i.) of malathion per acre.

The width of the area not directly treated (the untreated swath) under the RAATs 

approach is not standardized. The proportion of land treated in a RAATs approach is a 

complex function of the rate of grasshopper movement, which is a function of 

developmental stage, population density, and weather (Narisu et al., 1999, 2000), as well 

as the properties of the insecticide (insecticides with longer residuals allow wider spacing 

between treated swaths). Foster et al. (2000) left 20 to 50% of their study plots untreated, 

while Lockwood et al. (2000) left 20 to 67% of their treatment areas untreated. Currently 

the grasshopper program typically leaves 50% of a spray block untreated for ground 

applications where the swath width is between 20 and 45 feet. For aerial applications, the 

skipped swath width is typically no more than 20 feet for malathion, 100 feet for carbaryl 

and 200 feet for diflubenzuron. The selection of insecticide and the use of an associated 
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swath widths is site dependent. Rather than suppress grasshopper populations to the 

greatest extent possible, the goal of this alternative is to suppress grasshopper populations 

to a desired level.

The typical suppression treatment design will be 1.0 ounce of diflubenzuron per 

acre applied at 50% coverage.

Insecticide applications at conventional rates and complete area coverage, is an approach 

that APHIS has used in the past but is currently uncommon. Under this alternative, 

carbaryl, diflubenzuron or malathion would cover all treatable sites within the designated 

treatment block per label directions. The application rates under this alternative are as 

follows:

• 16.0 fluid ounces (0.50 pound active ingredient (lb a.i.)) of carbaryl spray per 

acre;

• 10.0 pounds (0.50 lb a.i.) of 5 percent carbaryl bait per acre;

• 1.0 fluid ounce (0.016 lb a.i.) of diflubenzuron per acre; or

• 8.0 fluid ounces (0.62 lb a.i.) of malathion per acre.

The potential generalized environmental effects of the application of carbaryl, 

diflubenzuron, and malathion, under this alternative are discussed in detail in the 2019 

EIS. A description of anticipated site-specific impacts from this alternative may be found 

in Part IV of this document.

C. Experimental Treatments Alternative

There are none planned.

III. Affected Environment

A. Description of Affected Environment

The proposed suppression program area included in the EA encompasses

10,745,192 acres (16,789 sq. miles) within southeastern Utah. This represents

21.3% of the land in Utah. Approximately 79.7% of the land within the fourcounty area is classified as federal, 9.7% of the acreage is state and the remaining 

10.6% of the land is private.

Carbon and Emery Counties lie within the Green River drainage which consists of

semi-arid lowlands, the Tavaputs Plateau and Roan Cliffs in the northeast, and the

high elevation (10,000 ft.) Wasatch Plateau on the west. The green

River forms the eastern boundary of both counties and is approximately 4 , 100 ft. in

elevation. The general area of concern is 5,500 ft. in elevation, primarily level to

gently sloping to the east. The area has diverse topography of Mancos shale lowlands 

and open count1y with low-lying rolling hills and the Wasatch Plateau escarpment t o

the west.
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Grand and San Juan Counties are located in the upper Colorado River Region and

have diverse topography ranging from Mancos shale lowlands to fertile valleys

dominated by high plateaus and mesa tops with deep gorges and gullies and include

unique rock formations.

Within Carbon and Emery Counties, the area is semi-arid with an average rainfall of 6

to 11 inches per year in the lowlands and averages of up to 30 inches at mountain 

elevations. In Grand and San Juan Counties, the average rainfall is 5 to 10 inches 

per year in the lowlands and 12-16 inches in the higher elevations.

Within the four-county area, the length of the growing season is related to elevation,

ranging from 20-160 days. The climate is characterized by low relatively humidity, 

rapid evaporation, generally clear skies, and daily and annual fluctuations in

temperatures (i.e. cold winters, hot summers).

The soils in Carbon and Emery Counties are of sedimentary origin and are in

climatic soil groups including desert, semi desert, Upland Mountain and High 

Mountain, with some riparian groups and some badlands, rock out croppings

and irrigated soils. Some have been identified as saline,usually associated with the

Mancos formation or some older marine sediments around the San Rafael Swell.

Grand and San Juan Counties are generally characterized within the Colorado 

Plateau. The soils are mainly arid soils and are relatively fertile; they support

forested areas. Soils derived from the Mancos Shale formation (portions of the

Cisco desert) are susceptible to erosion, have saline-alkali characteristics and low

site productivity. Once the soils are disturbed, the impact is generally longlasting.

Within Carbon, Emery, Grand and San Juan Counties, native vegetation is

primarily desert saltbrush including greasewood, blackbrush, saltbrushes and shad

scale, with some sagebrush steppe vegetation mixed with pinyon-juniper and

mountain browse as the elevation increases. A small portion of higher elevation

mountain slopes contain stands of aspen, mountain shrubs and Douglas fir.

Agricultural areas include native and improved rangeland, irrigated pastures and

cropland and some orchards.

Surface water resources in Grand and San Juan counties generally consist of the

upper Colorado River basin with other portions located in the Delores and

Green River Basins. Typically the headwaters in the Book cliffs meet State Class

C water quality standards. The lower reaches often exceed one or more

parameters. Parameters typically exceeded are total dissolved solids and

sodium. Flash flooding often follows the intense summer and fall thunderstorms

that occur in the area. Sediments and salts are transported to the Colorado River 

during these periods of high runoff and intermittent flows. Most of the
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Perennial streams are found in Bookcliffs and La Sal Mountain drainages.

Within Carbon and Emery Counties, surface water resources consist of the Green,

Muddy, Price and San Rafael Rivers, some intermittent live streams, ponds, reservoirs,

stock tanks and troughs, seeps and springs. The Green River provides excellent

recreational opportunities. Many of the rivers and streams support fisheries. The

water resources provide adequate water for wildlife and domestic livestock use as well

as habitat for wildlife.

B. Site-Specific Considerations

1. Human Health

The major population centers within Carbon, Emery, Grand and San Juan Counties are

sparse. The total population of the four counties is approximately 55,600 (less than

three percent of the entire population of Utah).

The 2002 EIS and 2019 EIS contains detailed hazard, exposure, and risk analyses for the 

chemicals available to APHIS. Impacts to workers and the general public were analyzed 

for all possible routes of exposure (dermal, oral, inhalation) under a range of conditions 

designed to overestimate risk. The operational procedures and spraying conditions 

examined in those analyses conform to those expected for operations. The following 

discussion summarizes the hazards, potential exposure, and risk to workers and the 

general public for operations in Utah. Operational procedures identified in Appendix 1 

would be required in all cases and further mitigation measures are identified in this 

section, as appropriate.

No treatment will occur over congested areas, recreation areas, or schools and if 

appropriate, a buffer zone will be enacted and enforced.

Groundwater wells are a major source of domestic water supplies. Groundwater and 

surface water are the major rural and livestock water source. No impact is anticipated. 

Strict adherence to label requirements and USDA treatment guidelines (Appendix 1) will 

be followed regarding treatments bordering open surface waters.

Malathion and carbaryl are cholinesterase inhibitors. Cholinesterases (including AChE) 

are enzymes that function at the nerve synapse. The nerve synapse is the point where 

information in the form of electrical impulses is relayed or transmitted by chemical 

messengers (called transmitters) from one nerve cell to another. Cholinesterase then 

inactivates or destroys the transmitter chemical (like acetylcholine) after it completes its 

job, otherwise the transmitter would continue indefinitely and precise control of the 

enervated tissue (muscle or organ) would be lost. Refer to the 2015 guidelines 

(Appendix 1) for further information on mitigating exposure to cholinesterase inhibitors. 

No human health effects are likely from exposure to diflubenzuron if it is used according 

to label instructions. A human exposure assessment was done in detail for diflubenzuron 
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and can be found in APHIS’s “Chemical Risk Assessment for Diflubenzuron Use in 

Grasshopper Cooperative Control Program”.

2. Non-target Species

Wildlife in Carbon, Emery, Grand and San Juan Counties is of special concern (see

Table 3 for mitigation measures pertaining to wildlife). The Cisco Desert/Delores

Triangle treatment area along the Utah/Colorado border and the Dry Valley/Lisbon

Valley treatment area north of Monticello, lie within Biogeographic area F. This

biogeographic area could be inhabited by 421 species of wildlife (31 fishes, 10

amphibians, 28 reptiles, 262 birds, and 90 mammals). Many of these species of 

wildlife inhabiting the biogeographic area are considered to be of high interest to the

State of Utah.

The Utah Division of Wildlife Resources (DWR) January 1992 (revised) list of native

Utah Species of Special Concern is attached (see Table 2). Some of the species listed

in that attachment are listed by the U.S. fish and Wildlife Service as threatened,

endangered or proposed threatened or endangered species. These species are found in

various locations throughout the state, but no distribution map is available. The list is

provided to inform the reader that there are species of concern throughout the state (see

table 2). It also emphasizes the necessity for strict adherence to proper application

procedures and associated mitigation measures to avoid unacceptable impacts to

wildlife.

Upland game birds (sage grouse, ruffed grouse, blue grouse, and chukar partridge) and

.game fish (trout and catfish) are known to inhabit the general area. Mule deer, elk,

pronghorn antelope, Rocky Mountain bighorn sheep and an introduced moose population all

occur within the combined four-county area. In addition, pronghorn antelope inhabit the

Cisco Desert, while mule deer and elk inhabit the Delores Triangle area. Deer are

present the entire year; however, their population increases during the winter.

Candidate species for federal listing, state-listed species, and/or other sensitive species

identified by state or federal agencies within the area include: white- faced ibis, longbilled curlew, western snowy plover, Williamson's sapsucker, Lewis' woodpecker, 

Grace's warbler, Mexican vole, , burrowing owl, ferrnginous hawk, Swainson's hawk,

western bluebird and the purple martin.

3. Socioeconomic Issues

Recreation use is moderate over most of the affected area. There are several

dispersed camping sites. Hunting seasons increase recreation use in the form of

dispersed camping and general hunting activity. Hunting season occurs later in the

year during a time when grasshopper and cricket populations have begun to

dwindle such that fewer insects are present. Hunters probably will not be affected.

ATV use is fairly prevalent throughout.
15 | Page

The presence of high densities of grasshoppers or Mormon crickets will result in

fewer people engaging in recreational activities during the spring and summer within

the affected areas. High insect densities in a campsite detract considerably from the

quality of the recreational experience. Crickets tend to get into unsecured tents and

food.

The quality of the recreational experience forATV users and horseback riders also

will be indirectly impaired by high densities of grasshoppers and/or crickets. Such

numbers crossing roads and trails are killed by vehicle traffic, leaving wind rows of

dead insects in the travel way as well as providing a vehicular safety hazard by

leaving slick residues on local roads.

People who normally recreate in areas that are heavily infested will likely relocate to

areas that are not infested. Displacement of users will be more of an inconvenience

to the public than an actual effect on the recreational values of the area.

Displacement will also increase pressure on other public lands as people move to

new locations to camp and to engage in other recreational activities. Social capacity

tolerances will be impacted. The potential for user conflict will increase, in

particular as motorized recreationists displace to other already heavily used areas.

Such locations will experience more pressure and may experience site degradation.

Areas currently not impacted or used by dispersed campers may become subjected

to use and development as people look for areas for recreation which are not infested

with insects.

Small towns near the affected areas receive limited business from recreationists who

visit public lands. Many local gas stations/public stores rely fairly heavily on

summer business to support their operations.

Livestock grazing is one of the main uses of most of the affected area, which provides

summer range for ranching operations. Permittees may run cattle, sheep and/or

horses for a season that runs generally from the first of June to the end of September,

weather and vegetation conditions permitting.

A substantial threat to the animal productivity of these rangeland areas is the

proliferation of grasshopper/Mormon cricket populations. These insects have been

serious pests in the Western States since early settlement. Weather conditions

favoring the hatching and survival of large numbers of insects can cause outbreak

populations, resulting in damage to vegetation. The consequences may reduce

grazing for livestock and result in loss of food and habitat for wildlife.

Livestock grazing on public lands contributes important cultural and social values to

the area. Intertwined with the economic aspects of livestock operations are the

lifestyles and culture that have co-evolved with Western ranching. Rural social
16 | Page

values and lifestyles, in conjunction with the long heritage of ranching and farming

continue to this day, dating back to the earliest pioneers in Utah, who shaped the

communities and enterprises that make up much of the state. The rural Western

lifestyle also contributes to tourism in the area, presenting to travelers a flavor of the

West through tourist-oriented goods and services, photography of sheep bands or

cattle in pastoral settings and scheduled events. .

Ranchers displaced from public lands due to early loss of forage from insect damage

will be forced to search for other rangeland, to sell their livestock prematurely or to

purchase feed hay. This will affect other ranchers (non- permittees) by increasing

demand, and consequently, cost for hay and/or pasture in the area. This will have a

beneficial effect on those providing the hay or range, and a negative impact on other

ranchers who use these same resources throughout the area. In addition, grazing on

private lands resulting from this impact will compound the effects to vegetation of

recent drought conditions over the last six years (e.g., continual heavy utilization by

grasshoppers/crickets, wildlife and wildfire),resulting in longer-term impacts (e.g.,

decline or loss of some preferred forage species) on grazing forage production on

these lands.

The lack of treatment would result in the eventual magnification of

grasshopper/Mormon cricket problems resulting in increased suppression efforts,

increased suppression costs and the expansion of suppression needs onto lands where

such options are limited. For example, control needs on crop lands where chemical

options are restricted because of pesticide label restrictions.

Under the no action alternative, farmers would experience economic losses. The

suppression of grasshoppers and/Mormon crickets in the affected area would have

beneficial economic impacts to local landowner, farmers and beekeepers. Crops near

infested lands would be protected from devastating migrating hordes, resulting in higher

crop production; hence, increased monetary returns.

4. Cultural Resources and Events

Federal and state public lands that are part of the region's visual and cultural

resources include the arches National Park, Canyonlands National Park, Glen

Canyon National Recreation Area, Fishlake National Park, and the Manti-La Sal

National Forest. Also in the area are the Hovenweep, Natural Bridges, and

Rainbow Bridge National Monuments and the Grand Gulch and Dark Canyon

Primitive Areas. State parks within the area include: Scofield State Park, Price

Canyon Recreation Area, Huntington State Park, Millsite State Park, Goblin Valley 

Park, Dead Horse Point State Park, Green River State Park, Newspaper Rock State

Park, Goosenecks State Park and Edge of the Cedars State Park.

The Uintah and Ouray and Navajo Indian Reservations occupy a portion of Grand

and San Juan Counties.
17 | Page

A variety of activities have occurred throughout the area of concern that affect

cultural resources. These activities and any cumulative impacts associated with

them will occur regardless of whether or not grasshoppers/Mormon crickets are

treated.

Use of motorized equipment off existing roads could impact surface artifacts by

damaging them or displacing them in their overall juxtaposition with other artifacts. 

Maintaining the integrity of a historical site is important to understanding the

significance of the site and the artifacts found therein. Non-treatment of infested land

will likely later result in more intensive and extensive treatment of that infested land. 

Most of the non-public lands that will be affected have already been heavily disturbed 

and any artifacts on them likely impacted. Consequently, it is unlikely that additional 

treatments will result in additional impacts on cultural properties.

With no treatment of grasshoppers or crickets on public lands, aerial application of

insecticides off public lands will likely increase. Though this should not disturb or

displace cultural artifacts, carrying agents in the spray could damage artifacts 

(USDA, APHIS EIS, 2002, p. 71). However, most if not all of the areas likely to be

treated have been heavily disturbed in the past, and any artifacts on them likely

impacted. Consequently, it is unlikely that these aerial treatments will result in

additional impacts on cultural properties.

Motorized vehicles (pick-up trucks and/or ATV's) may be used to treat portions of

the affected areas. This will create a risk of impacting cultural properties.

The risk is small given that the off-road use of vehicles will create only minor soil

disturbance, and the areas involved are not likely to contain significant sites of

which public officials are not already aware. Known sites will be avoided to

mitigate impacts. Any sites located during treatment activities will be reported,

then avoided during continuing operations. Past similar grasshopper/cricket 

treatments throughout the state have not resulted in any known impacts to cultural

properties.

In addition to the treatments proposed under this alternative, a broad variety and 

number of activities throughout the project area could affect, or have affected,

cultural resources. These activities and any cumulative impacts associated with

them will occur, regardless of whether or not grasshoppers/crickets are treated. No

direct, indirect or change in cumulative impacts on cultural resources in the area

will occur due to implementation of the treatment alternative.

To ensure that historical or cultural sites, monuments, buildings or artifacts of

special concern are not adversely affected by program treatments, APHIS will

confer with BLM, Forest Service or other appropriate land management agency on

a local level to protect these areas of special concern. APHIS also will confer with

the appropriate tribal authority and with the BIA office at a local level to ensure

that the timing and location of planned program treatments do not coincide or

conflict with cultural events or observances, such as sun dances, on tribal lands.
18 | Page

5. Special Considerations for Certain Populations

a) Executive Order No. 12898, Federal Actions to Address Environmental

Justice in Minority Populations and Low-Income Populations

Executive Order (E.O.) 12898, Federal Actions To Address Environmental Justice in 

Minority Populations and Low-Income Populations, was signed by President Clinton on 

February 11, 1994 (59 Federal Register (FR) 7269). This E.O. requires each Federal 

agency to make achieving environmental justice part of its mission by identifying and 

addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of its programs, policies, and activities on minority populations and 

low-income populations. Consistent with this E.O., APHIS will consider the potential for 

disproportionately high and adverse human health or environmental effects on minority 

populations and low-income populations for any of its actions related to grasshopper 

suppression programs. 

The human population around grasshopper programs is diverse and lacks any special

characteristics that implicate greater risks of adverse effects for any minority or lowincome populations. A demographic review in the APHIS EIS 2002 revealed certain

areas with large populations, Spanish-speaking populations and some with large

American Indian tribal populations. Low-income farmers and ranchers would

comprise, by far, the largest group affected by APHIS program efforts in this area of 

concern.

When planning a site-specific action related to grasshopper/Mormon cricket

infestations, APHIS considers the potential for disproportionately high and adverse

human health or environmental impacts of its actions on minority and low-income

populations before any proposed action. In doing so, APHIS program managers

will work closely with representatives of these populations in the locale of planned

actions through public meetings.

APHIS intervention to locally suppress damaging insect infestations will stand to

greatly benefit,rather than harm, low-income farmers and ranchers by helping them to

control insect threats to their livelihood. Suppressing grasshopper or Mormon cricket

infestations on adjacent public or private rangelands will increase inexpensive

available forage for their livestock and will significantly decrease economic losses to

their crop lands by invading insects. Such would obviate the need to perform

additional expensive crop pesticide treatments or to provide supplemental feed to their

livestock which would further impact low-income individuals.

In past grasshopper programs, the U.S. Department of the Interior's (USDI) Bureau

of Land Management or Bureau of Indian Affairs (BIA) have notified the appropriate

APHIS State Plant Health Director when any new or potentially threatening

grasshopper infestation is discovered on BLM lands or tribal lands held in trust and

administered by BIA. Thus, APHIS has cooperated with BIA when grasshopper

programs occur on Indian tribal lands. For local Indian populations, APHIS program

managers will work with BIA and local tribal councils to communicate information to
19 | Page

tribal organizations and representatives when programs have the potential to impact the

environment of their communities, lands or cultural resources.

b) Executive Order No. 13045, Protection of Children from Environmental 

Health Risks and Safety Risks

The increased scientific knowledge about the environmental health risks and safety risks

associated with hazardous substance exposures to children and recognition of these issues 

in Congress and Federal agencies brought about legislation and other requirements to 

protect the health and safety of children. On April 21, 1997, President Clinton signed 

E.O. 13045, Protection of Children from Environmental Health Risks and Safety Risks 

(62 FR 19885). This E.O. requires each Federal agency, consistent with its mission, to 

identify and assess environmental health risks and safety risks that may 

disproportionately affect children and to ensure that its policies, programs, activities, and 

standards address those risks. APHIS has developed agency guidance for its programs to 

follow to ensure the protection of children (USDA, APHIS, 1999). 

Treatments used for grasshopper programs are primarily conducted on open rangelands

where children would not be expected to be present during treatment or enter during

the restricted entry period after treatment. Based on review of the insecticides and their

use in programs, the risk assessment concludes that the likelihood of children being

exposed to insecticides from a grasshopper or Mormon cricket program is very slight

and that no disproportionate adverse effects to children are anticipated over the

negligible effects to the general population.

APHIS also institutes program measures (i.e., 500 foot buffers around homes, schools, 

and occupied buildings and campgrounds) and notification of residents that mitigates the 

potential for exposure of program insecticides to children.

IV. Environmental Consequences

Each alternative described in this EA potentially has adverse environmental effects. The 

general environmental impacts of each alternative are discussed in detail in the 2002 and 

2019 EIS. The specific impacts of the alternatives are highly dependent upon the 

particular action and location of infestation. The principal concerns associated with the 

alternatives are: (1) the potential effects of insecticides on human health (including 

subpopulations that might be at increased risk); and (2) impacts of insecticides on nontarget organisms (including threatened and endangered species). 

APHIS has written human health and ecological risk assessments (HHERAs) to assess 

the insecticides and use patterns that are specific to the program. The risk assessments 

provide an in-depth technical analysis of the potential impacts of each insecticide to 

human health; and non-target fish and wildlife along with its environmental fate in soil, 

air, and water. The assessments rely on data required by the USEPA for pesticide product 

registrations, as well as peer-reviewed and other published literature. The HHERAs are 

heavily referenced in this Final EA. These Environmental Documents can be found at the 

following website: http://www.aphis.usda.gov/plant-health/grasshopper . 
20 | Page

A. Environmental Consequences of the Alternatives

Site-specific environmental consequences of the alternatives are discussed in this section.

1. No Action Alternative

Under this alternative, APHIS would not conduct a program to suppress grasshoppers. If 

APHIS does not participate in any grasshopper suppression program, Federal land 

management agencies, State agriculture departments, local governments, private groups 

or individuals, may not effectively combat outbreaks in a coordinated effort. Without the 

technical assistance and coordination that APHIS provides during grasshopper outbreaks, 

the uncoordinated programs could use insecticides that APHIS considers too 

environmentally harsh. Multiple treatments and excessive amount of insecticide could be 

applied in efforts to suppress or even locally eradicate grasshopper populations. There are 

approximately 100 pesticide products registered by USEPA for use on rangelands and 

against grasshoppers (Purdue University, 2018). It is not possible to accurately predict the 

environmental consequences of the No Action alternative because the type and amount of 

insecticides that could be used in this scenario are unknown. However, the environmental 

impacts could be much greater than under the APHIS led suppression program alternative 

due to lack of treatment knowledge or coordination among the groups.

The potential environmental impacts from the No Action alternative, where other 

agencies and land managers do not control outbreaks, stem primarily from grasshoppers 

consuming vast amounts of vegetation in rangelands and surrounding areas. 

Grasshoppers are general feeders, eating grasses and forbs first and often moving to 

cultivated crops. High grasshopper density of one or several species and the resulting 

defoliation may reach an economic threshold where the damage caused by grasshoppers 

exceeds the cost of controlling the grasshoppers. Researchers determined that during 

typical grasshopper infestation years, approximately 20% of forage rangeland is removed, 

valued at a dollar adjusted amount of $900 million. This value represents 32 to 63% of 

the total value of rangeland across the western states (Rashford et al., 2012). Other 

market and non-market values such as carbon sequestration, general ecosystem services, 

and recreational use may also be impacted by pest outbreaks in rangeland.

Vegetation damage during serious grasshopper outbreaks may be so severe that all 

grasses and forbs are destroyed; thus, plant growth is impaired for several years. Rare 

plants may be consumed during critical times of development such as seed production, 

and loss of important plant species, or seed production may lead to reduced diversity of 

rangeland habitats, potentially creating opportunities for the expansion of invasive and 

exotic weeds (Lockwood and Latchininsky, 2000). When grasshoppers consume plant 

cover, soil is more susceptible to the drying effects of the sun, making plant roots less 

capable of holding soil in place. Soil damage results in erosion and disruption of nutrient 

cycling, water infiltration, seed germination, and other ecological processes which are 

important components of rangeland ecosystems (Latchininsky et al., 2011).

When the density of grasshoppers reaches significantly high levels, grasshoppers begin to 

compete with livestock for food by reducing available forage (Wakeland and Shull, 1936; 

Belovsky, 2000; Pfadt, 2002; Branson et al., 2006; Bradshaw et al., 2018). Ranchers 
21 | Page

could offset some of the costs by leasing rangeland in another area and relocating their 

livestock, finding other means to feed their animals by purchasing hay or grain, or selling 

their livestock. Ranchers could also incur economic losses from personal attempts to 

control grasshopper damage. Local communities could see adverse economic impacts to 

the entire area. Grasshoppers that infest rangeland could move to surrounding croplands. 

Farmers could incur economic losses from attempts to chemically control grasshopper 

populations or due to the loss of their crops. The general public could see an increase in 

the cost of meat, crops, and their byproducts.

2. Insecticide Applications at Conventional Rates or Reduced Agent Area 

Treatments with Adaptive Management Strategy

Under Alternative 2, APHIS would participate in grasshopper programs with the option 

of using one of the insecticides carbaryl, diflubenzuron, or malathion, depending upon 

the various factors related to the grasshopper outbreak and the site-specific 

characteristics. The use of an insecticide would typically occur at half the conventional 

application rates following the RAATs strategy. APHIS would apply a single treatment to

affected rangeland areas in an attempt to suppress grasshopper outbreak populations by a 

range of 35 to 98 percent, depending upon the insecticide used. 

a) Carbaryl

Carbaryl is a member of the N-methyl carbamate class of insecticides, which affect the 

nervous system via cholinesterase inhibition. Inhibiting the enzyme acetylcholinesterase

(AChE) causes nervous system signals to persist longer than normal. While these effects 

are desired in controlling insects, they can have undesirable impacts to non-target 

organisms that are exposed. The APHIS HHERA assessed available laboratory studies 

regarding the toxicity of carbaryl on fish and wildlife. In summary, the document 

indicates the chemical is highly toxic to insects, including native bees, honeybees, and 

aquatic insects; slightly to highly toxic to fish; highly to very highly toxic to most aquatic 

crustaceans, moderately toxic to mammals, minimally toxic to birds; moderately to 

highly toxic to several terrestrial arthropod predators; and slightly to highly toxic to larval 

amphibians (USDA APHIS, 2018a). 

The offsite movement and deposition of carbaryl after treatments is unlikely because it

does not significantly vaporize from the soil, water, or treated surfaces (Dobroski et al., 

1985). Temperature, pH, light, oxygen, and the presence of microorganisms and organic 

material are factors that contribute to how quickly carbaryl will degrade in water.

Hydrolysis, the breaking of a chemical bond with water, is the primary degradation 

pathway for carbaryl at pH 7 and above. In natural water, carbaryl is expected to degrade 

faster than in laboratory settings due to the presence of microorganisms. The half-lives of 

carbaryl in natural waters varied between 0.3 to 4.7 days (Stanley and Trial, 1980; 

Bonderenko et al., 2004). Degradation in the latter study was temperature dependent with 

shorter half-lives at higher temperatures. Aerobic aquatic metabolism of carbaryl reported 

half-life ranged of 4.9 to 8.3 days compared to anaerobic (without oxygen) aquatic 

metabolism range of 15.3 to 72 days (Thomson and Strachan, 1981; USEPA, 2003).

Carbaryl is not persistent in soil due to multiple degradation pathways including 

hydrolysis, photolysis, and microbial metabolism. Little transport of carbaryl through 
22 | Page

runoff or leaching to groundwater is expected due to the low water solubility, moderate 

sorption, and rapid degradation in soils. There are no reports of carbaryl detection in 

groundwater, and less than 1% of granule carbaryl applied to a sloping plot was detected 

in runoff (Caro et al., 1974).

Acute and chronic risks to mammals are expected to be low to moderate based on the 

available toxicity data and conservative assumptions that were used to evaluate risk. 

There is the potential for impacts to small mammal populations that rely on terrestrial 

invertebrates for food. However, based on the toxicity data for terrestrial plants, minimal 

risks of indirect effects are expected to mammals that rely on plant material for food. 

Carbaryl has a reported half-life on vegetation of three to ten days, suggesting mammal 

exposure would be short-term. Direct risks to mammals from carbaryl bait applications is 

expected to be minimal based on oral, dermal, and inhalation studies (USDA APHIS, 

2018a).

A number of studies have reported no effects on bird populations in areas treated with 

carbaryl (Buckner et al., 1973; Richmond et al., 1979; McEwen et al., 1996). Some 

applications of formulated carbaryl were found to cause depressed AChE levels (Zinkl et 

al., 1977; Gramlich, 1979); however, the doses were twice those proposed for the full 

coverage application in the grasshopper program.

While sublethal effects have been noted in fish with depressed AChE, as well as some 

impacts to amphibians (i.e. days to metamorphosis) and aquatic invertebrates in the field 

due to carbaryl, the application rates and measured aquatic residues observed in these 

studies are well above values that would be expected from current program operations. 

Indirect risks to amphibian and fish species can occur through the loss of habitat or 

reduction in prey, yet data suggests that carbaryl risk to aquatic plants that may serve as 

habitat, or food, for fish and aquatic invertebrates is very low.

Product use restrictions appear on the USEPA-approved label and attempt to keep 

carbaryl out of waterways. Carbaryl must not be applied directly to water, or to areas 

where surface water is present (USEPA, 2012c). The USEPA-approved use rates and 

patterns and the additional mitigations imposed by the grasshopper program, such as 

using RAATs and application buffers, where applicable, further minimize aquatic 

exposure and risk.

The majority of rangeland plants require insect-mediated pollination. Native, solitary bee 

species are important pollinators on western rangeland (Tepedino, 1979). Potential 

negative effects of insecticides on pollinators are of concern because a decrease in their 

numbers has been associated with a decline in fruit and seed production of plants. 

Laboratory studies have indicated that bees are sensitive to carbaryl applications but the 

studies were at rates above those proposed in the program. The reduced rates of carbaryl 

used in the program and the implementation of application buffers should significantly 

reduce exposure of carbaryl applications to pollinators. In areas of direct application 

where impacts may occur, alternating swaths and reduced rates (i.e., RAATs) would 

reduce risk. Potential negative effects of grasshopper program insecticides on bee 

populations may also be mitigated by the more common use of carbaryl baits than the 
23 | Page

ULV spray formulation. Studies with carbaryl bran bait have found no sublethal effects 

on adults or larvae bees (Peach et al., 1994, 1995).

Carbaryl can cause cholinesterase inhibition (i.e., overstimulate the nervous system) in 

humans resulting in nausea, headaches, dizziness, anxiety, and mental confusion, as well 

as convulsions, coma, and respiratory depression at high levels of exposure (NIH, 2009a;

Beauvais, 2014). USEPA classifies carbaryl as “likely to be carcinogenic to humans” 

based on vascular tumors in mice (USEPA, 2007, 2015a, 2017a).

USEPA regulates the amount of pesticide residues that can remain in or on food or feed 

commodities as the result of a pesticide application. The agency does this by setting a 

tolerance, which is the maximum residue level of a pesticide, usually measured in parts 

per million (ppm), that can legally be present in food or feed. USEPA-registered carbaryl 

products used by the grasshopper program are labeled with rates and treatment intervals 

that are meant to protect livestock and keep chemical residues in cattle at acceptable 

levels (thereby protecting human health). While livestock and horses may graze on 

rangeland the same day that the land is sprayed, in order to keep tolerances to acceptable 

levels, carbaryl spray applications on rangeland are limited to half a pound active 

ingredient per acre per year (USEPA, 2012c). The grasshopper program would treat at or 

below use rates that appear on the label, as well as follow all appropriate label 

mitigations, which would ensure residues are below the tolerance levels.

Adverse human health effects from the proposed program ULV applications of the 

carbaryl spray (Sevin® XLR Plus) and bait applications of the carbaryl 5% and 2% baits 

formulations to control grasshoppers are not expected based on low potential for human 

exposure to carbaryl and the favorable environmental fate and effects data. Technical 

grade (approximately 100% of the insecticide product is composed of the active 

ingredient) carbaryl exhibits moderate acute oral toxicity in rats, low acute dermal 

toxicity in rabbits, and very low acute inhalation toxicity in rats. Technical carbaryl is not 

a primary eye or skin irritant in rabbits and is not a dermal sensitization in guinea pig 

(USEPA, 2007). This data can be extrapolated and applied to humans revealing low 

health risks associated with carbaryl.

The Sevin® XLR Plus formulation, which contains a lower percent of the active 

ingredient than the technical grade formulation, is less toxic via the oral route, but is a 

mild irritant to eyes and skin. The proposed use of carbaryl as a ULV spray or a bait, use 

of RAATs, and adherence to label requirements, substantially reduces the potential for 

exposure to humans. Program workers are the most likely human population to be 

exposed. APHIS does not expect adverse health risks to workers based on low potential 

for exposure to carbaryl when applied according to label directions and use of personal 

protective equipment (PPE) (e.g., long-sleeved shirt and long pants, shoes plus socks, 

chemical-resistant gloves, and chemical-resistant apron) (USEPA, 2012c) during loading 

and applications. APHIS quantified the potential health risks associated with accidental 

worker exposure to carbaryl during mixing, loading, and applications. The quantitative 

risk evaluation results indicate no concerns for adverse health risk for program workers 

(http://www.aphis.usda.gov/plant-health/grasshopper).
24 | Page

Adherence to label requirements and additional program measures designed to reduce 

exposure to workers and the public (e.g., mitigations to protect water sources, mitigations 

to limit spray drift, and restricted-entry intervals) result in low health risk to all human 

population segments.

b) Diflubenzuron

Diflubenzuron is a restricted use pesticide (only certified applicators or persons under 

their direct supervision may make applications) registered with USEPA as an insect 

growth regulator. It specifically interferes with chitin synthesis, the formation of the 

insect’s exoskeleton. Larvae of affected insects are unable to molt properly. While this 

effect is desirable in controlling certain insects, it can have undesirable impacts to nontarget organisms that are exposed.

USEPA considers diflubenzuron relatively non-persistent and immobile under normal use 

conditions and stable to hydrolysis and photolysis. The chemical is considered unlikely to 

contaminate ground water or surface water (USEPA, 1997). The vapor pressure of 

diflubenzuron is relatively low, as is the Henry’s Law Constant value, suggesting the 

chemical will not volatilize readily into the atmosphere from soil, plants or water. 

Therefore, exposure from volatilization is expected to be minimal. Due to its low 

solubility (0.2 mg/L) and preferential binding to organic matter, diflubenzuron seldom 

persists more than a few days in water (Schaefer and Dupras, 1977; Schaefer et al., 

1980). Mobility and leachability of diflubenzuron in soils is low, and residues are usually 

not detectable after seven days (Eisler, 2000). Aerobic aquatic half-life data in water and 

sediment was reported as 26.0 days (USEPA, 1997). Diflubenzuron applied to foliage 

remains adsorbed to leaf surfaces for several weeks with little or no absorption or 

translocation from plant surfaces (Eisler, 1992, 2000). Diflubenzuron treatments are 

expected to have minimal effects on terrestrial plants. Both laboratory and field studies 

demonstrate no effects using diflubenzuron over a range of application rates, and the 

direct risk to terrestrial plants is expected to be minimal (USDA APHIS, 2018c).

Dimilin® 2L is labeled with rates and treatment intervals that are meant to protect 

livestock and keep residues in cattle at acceptable levels (thereby, protecting human 

health). Tolerances are set for the amount of diflubenzuron that is allowed in cattle fat 

(0.05 ppm) and meat (0.05 ppm) (40 CFR Parts 180.377). The grasshopper program 

would treat at application rates indicated on product labels or lower, which should ensure 

approved residues levels. 

APHIS’ literature review found that on an acute basis, diflubenzuron is considered toxic 

to some aquatic invertebrates and practically non-toxic to adult honeybees. However, 

diflubenzuron is toxic to larval honeybees (USEPA, 2018). It is slightly nontoxic to 

practically nontoxic to fish and birds and has very slight acute oral toxicity to mammals, 

with the most sensitive endpoint from exposure being the occurrence of 

methemoglobinemia (a condition that impairs the ability of the blood to carry oxygen). 

Minimal direct risk to amphibians and reptiles is expected, although there is some 

uncertainty due to lack of information (USDA APHIS, 2018c; USEPA, 2018).
25 | Page

Risk is low for most non-target species based on laboratory toxicity data, USEPA 

approved use rates and patterns, and additional mitigations such as the use of lower rates 

and RAATs that further reduces risk. Risk is greatest for sensitive terrestrial and aquatic 

invertebrates that may be exposed to diflubenzuron residues.

In a review of mammalian field studies, Dimilin® applications at a rate of 60 to 280 g 

a.i./ha had no effects on the abundance and reproduction in voles, field mice, and shrews 

(USDA FS, 2004). These rates are approximately three to 16 times greater than the 

highest application rate proposed in the program. Potential indirect impacts from 

application of diflubenzuron on small mammals includes loss of habitat or food items. 

Mice on treated plots consumed fewer lepidopteran (order of insects that includes 

butterflies and moths) larvae compared to controls; however, the total amount of food 

consumed did not differ between treated and untreated plots. Body measurements, 

weight, and fat content in mice collected from treated and non-treated areas did not differ. 

Poisoning of insectivorous birds by diflubenzuron after spraying in orchards at labeled 

rates is unlikely due to low toxicity (Muzzarelli, 1986). The primary concern for bird 

species is related to an indirect effect on insectivorous species from a decrease in insect 

prey. At the proposed application rates, grasshoppers have the highest risk of being 

impacted while other taxa have a much reduced risk because the lack of effects seen in 

multiple field studies on other taxa of invertebrates at use rates much higher than those 

proposed for the program. Shifting diets in insectivorous birds in response to prey 

densities is not uncommon in undisturbed areas (Rosenberg et al., 1982; Cooper et al., 

1990; Sample et al., 1993).

Indirect risk to fish species can be defined as a loss of habitat or prey base that provides 

food and shelter for fish populations, however these impacts are not expected based on 

the available fish and invertebrate toxicity data (USDA APHIS, 2018c). A review of 

several aquatic field studies demonstrated that when effects were observed it was at 

diflubenzuron levels not expected from program activities (Fischer and Hall, 1992;

USEPA, 1997; Eisler, 2000; USDA FS, 2004). 

Diflubenzuron applications have the potential to affect chitin production in various other 

beneficial terrestrial invertebrates. Multiple field studies in a variety of application 

settings, including grasshopper control, have been conducted regarding the impacts of 

diflubenzuron to terrestrial invertebrates. Based on the available data, sensitivity of 

terrestrial invertebrates to diflubenzuron is highly variable depending on which group of 

insects and which life stages are being exposed. Immature grasshoppers, beetle larvae, 

lepidopteran larvae, and chewing herbivorous insects appear to be more susceptible to 

diflubenzuron than other invertebrates. Within this group, however, grasshoppers appear 

to be more sensitive to the proposed use rates for the program. Honeybees, parasitic 

wasps, predatory insects, and sucking insects show greater tolerance to diflubenzuron 

exposure (Murphy et al., 1994; Eisler, 2000; USDA FS, 2004). 

Diflubenzuron is moderately toxic to spiders and mites (USDA APHIS, 2018c). Deakle 

and Bradley (1982) measured the effects of four diflubenzuron applications on predators 

of Heliothis spp. at a rate of 0.06 lb a.i./ac and found no effects on several predator 
26 | Page

groups. This supported earlier studies by Keever et al. (1977) that demonstrated no 

effects on the arthropod predator community after multiple applications of diflubenzuron 

in cotton fields. Grasshopper integrated pest management (IPM) field studies have shown 

diflubenzuron to have a minimal impact on ants, spiders, predatory beetles, and 

scavenger beetles. There was no significant reduction in populations of these species 

from seven to 76 days after treatment. Although ant populations exhibited declines of up 

to 50 percent, these reductions were temporary, and population recovery was described as 

immediate (Catangui et al., 1996).

Insecticide applications to rangelands have the potential to impact pollinators, and in turn, 

vegetation and various rangeland species that depend on pollinated vegetation. Based on 

the review of laboratory and field toxicity data for terrestrial invertebrates, applications of 

diflubenzuron are expected to have minimal risk to pollinators of terrestrial plants. The 

use of RAATs provide additional benefits by using reduced rates and creating untreated 

swaths within the spray block that will further reduce the potential risk to pollinators.

Adverse human health effects from ground or aerial ULV applications of diflubenzuron 

to control grasshoppers are not expected based on the low acute toxicity of diflubenzuron 

and low potential for human exposure. The adverse health effects of diflubenzuron to 

mammals and humans involves damage to hemoglobin in blood and the transport of 

oxygen. Diflubenzuron causes the formation of methemoglobin. Methemoglobin is a 

form of hemoglobin that is not able to transport oxygen (USDA FS, 2004). USEPA 

classifies diflubenzuron as non-carcinogenic to humans (USEPA, 2015b). 

Program workers adverse health risks are not likely when diflubenzuron is applied 

according to label directions that reduce or eliminate exposures. Adverse health risk to 

the general public in treatment areas is not expected due to the low potential for exposure 

resulting from low population density in the treatment areas, adherence to label 

requirements, program measures designed to reduce exposure to the public, and low 

toxicity to mammals.

c) Malathion

Malathion is a broad-spectrum organophosphate insecticide widely used in agriculture on 

various food and feed crops, homeowner yards, ornamental nursery stock, building 

perimeters, pastures and rangeland, and regional pest eradication programs. The 

chemical’s mode of action is through AChE inhibition, which disrupts nervous system 

function. While these effects are desired in controlling insects, they can have undesirable 

impacts to non-target organisms that are exposed to malathion. The grasshopper program 

currently uses the malathion end-use product Fyfanon® ULV AG, applied as a spray by 

ground or air.

Volatility is not expected to be a major pathway of exposure based on the low vapor 

pressure and Henry’s Law constant that have been reported for malathion. The 

atmospheric vapor phase half-life of malathion is five hours (NIH, 2009b). Malathion’s 

half-life in pond, lake, river, and other natural waters varied from 0.5 days to ten days, 

depending on pH (Guerrant et al., 1970), persisting longer in acidic aquatic environments. 

The reported half-life in water and sediment for the anaerobic aquatic metabolism study 
27 | Page

was 2.5 days at a range of pH values from 7.8 to 8.7 (USEPA, 2006). The persistence of 

malathion in soils depends primarily on microorganism activity, pH, and organic matter 

content. The persistence of malathion is decreased with microbial activity, moisture, and 

high pH (USEPA, 2016a) and the half-life of malathion in natural soil varies from two 

hours (Miles and Takashima, 1991) to 11 days (Neary, 1985; USEPA, 2006). 

Malathion and associated degradates, in general, are soluble and do not adsorb strongly to 

soils (USEPA, 2000a). Inorganic degradation of malathion may be more important in 

soils that are relatively dry, alkaline, and low in organic content, such as those that 

predominate in the western program areas. Adsorption to organic matter and rapid 

degradation make it unlikely that detectable quantities of malathion would leach to 

groundwater (LaFleur, 1979). Malathion degradation products also have short half-lives. 

Malaoxon, the major malathion degradation product of toxicological concern, has halflives less than one day in a variety of soil types (USEPA, 2016a). The half-life of 

malathion on foliage has been shown to range from one to six days (El-Refai and 

Hopkins, 1972; Nigg, 1986; Matsumara, 1985; USDA FS, 2008).

While livestock and horses may graze on rangeland the same day that the land is treated 

with malathion, the products used by the grasshopper program are labeled with rates and 

treatment intervals that are meant to protect livestock. Tolerances are set for the amount

of malathion that is allowed in cattle fat (4 ppm), meat (4 ppm), and meat byproducts (4 

ppm) (40 CFR Parts 180.111). The grasshopper program would treat at application rates 

indicated on product labels or lower, which would ensure approved residues levels. In 

addition, the program would make only one application a year.

USEPA found malathion moderately toxic to birds on a chronic basis, slightly toxic to 

mammals through dietary exposure, and acutely toxic to aquatic species (including 

freshwater as well as estuarine and marine species) (USEPA, 2000b, 2016b). Toxicity to 

aquatic vertebrates such as fish and larval amphibians, and aquatic invertebrates is 

variable based on test species and conditions. The data available on impacts to fish from 

malathion suggest effects could occur at levels above those expected from program 

applications. Consumption of contaminated prey is not expected to be a significant 

pathway of exposure for aquatic species based on expected residues and malathion’s BCF 

(USEPA, 2016a; USDA APHIS, 2018d). Indirect effects to fish from impacts of 

malathion applications to aquatic plants are not expected (USDA APHIS, 2018d).

USEPA considers malathion highly toxic to bees if exposed to direct treatment on 

blooming crops or weeds. The Fyfanon® ULV AG label indicates not to apply product or 

allow it to drift to blooming crops or weeds while bees are actively visiting the treatment 

area (USEPA, 2012a). Toxicity to other terrestrial invertebrates is variable based on the 

test organism and test conditions however malathion is considered toxic to most 

terrestrial invertebrates (USEPA, 2016b).

Indirect risks to mammals resulting from the loss of plants that serve as a food source 

would also be low due to the low phytotoxicity of malathion. The other possible indirect 

effect that should be considered is loss of invertebrate prey for those mammals that 

depend on insects and other invertebrates as a food source. Insects have a wide variety of 
28 | Page

sensitivities to malathion and a complete loss of invertebrates from a treated area is not 

expected because of low program rates and application techniques. In addition, the aerial 

and ground application buffers and untreated swaths provide refuge for invertebrates that 

serve as prey for insectivorous mammals and would expedite repopulation of areas that 

may have been treated.

APHIS expects that direct avian acute and chronic effects would be minimal for most 

species (USDA APHIS, 2018d). The preferred use of RAATs during application reduces 

these risks by reducing residues on treated food items and reducing the probability that 

they will only feed on contaminated food items. In addition, malathion degrades quickly 

in the environment and residues on food items are not expected to persist. Indirect effects 

on birds from the loss of habitat and food items are not expected because of malathion’s 

low toxicity to plants and the implementation of RAATs that would reduce the potential 

impacts to invertebrates that serve as prey for avian species. Several field studies did not 

find significant indirect effects of malathion applications on avian fecundity (Dinkins et 

al., 2002; George et al., 1995; Howe, 1993; Howe et al., 1996; Norelius and Lockwood, 

1999; Pascual, 1994).

Available toxicity data demonstrates that amphibians are less sensitive to malathion than 

fish. Program malathion residues are more than 560 times below the most sensitive acute 

toxicity value for amphibians. Sublethal effects, such as developmental delays, reduced 

food consumption and body weight, and teratogenesis (developmental defects that occur 

during embryonic or fetal growth), have been observed at levels well above those 

assessed from the program’s use of malathion (USDA APHIS, 2018d). Program 

protection measures for aquatic water bodies and the available toxicity data for fish, 

aquatic invertebrates, and plants suggest low indirect risks related to reductions in habitat 

or aquatic prey items from malathion treatments.

Available data on malathion reptile toxicity suggest that, with the use of program 

measures, no lethal or sublethal impacts would be anticipated (USDA APHIS, 2015). 

Indirect risk to reptiles from the loss of food items is expected to be low due to the low 

application rates and implementation of preferred program measures such as RAATs 

(USDA APHIS, 2018d).

The risk to aquatic vertebrates and invertebrates is low for most species; however, some 

sensitive species that occur in shallow water habitats may be at risk. Program measures 

such application buffer zones, drift mitigation measures and the use of RAATs will 

reduce these risks.

Risks to terrestrial invertebrate populations are anticipated based on the available toxicity 

data for invertebrates and the broad spectrum activity of malathion (Swain, 1986; Quinn 

et al., 1991). The risk to terrestrial invertebrates can be reduced by the implementation of 

application buffers and the use of RAATs, which would reduce exposure and create 

refuge areas where malathion impacts would be reduced or eliminated. Smith et al. 

(2006) conducted field studies to evaluate the impacts of grasshopper treatments to nontarget terrestrial invertebrates and found minimal impacts when making reduced rate 

applications with a reduced coverage area (i.e. RAATs) for a ULV end-use product of 
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malathion. Impacts to pollinators have the potential to be significant, based on available 

toxicity data for honeybees that demonstrate high contact toxicity from malathion 

exposures (USDA APHIS, 2018d). However, risk to pollinators is reduced because of the 

short residual toxicity of malathion. In addition, the incorporation of other mitigation 

measures in the program, such as the use of RAATs and wind speed and direction 

mitigations that are designed to minimize exposure, reduce the potential for populationlevel impacts to terrestrial invertebrates.

Adverse human health effects from ULV applications of malathion to control 

grasshopper are not expected based on the low mammalian acute toxicity of malathion 

and low potential for human exposure. Malathion inhibits AChE in the central and 

peripheral nervous system with clinical signs of neurotoxicity that include tremors, 

salivation, urogenital staining, and decreased motor activity. USEPA indicates that 

malathion has “suggestive evidence of carcinogenicity but not sufficient to assess human 

carcinogenic potential” (USEPA, 2016c). 

Adverse health risks to program workers and the general public from malathion exposure 

are also not expected due to low potential for exposure. APHIS treatments are conducted 

in rangeland areas consisting of widely scattered, single, rural dwellings in ranching 

communities, where agriculture is a primary industry. Label requirements to reduce 

exposure include minimizing spray drift, avoidance of water bodies and restricted entry 

interval. Program measures such as applying malathion once per season, lower 

application rates, application buffers and other measures further reduce the potential for 

exposure to the public.

d) Reduced Area Agent Treatments (RAATs) 

The use of RAATS is the most common application method for all program insecticides 

and would continue to be so accept in rare pest conditions that warrant full coverage and 

higher rates. The goal of the RAATs strategy is to suppress grasshopper populations to a 

desired level, rather than to reduce those populations to the greatest possible extent. This 

strategy has both economic and environmental benefits. APHIS would apply a single 

application of insecticide per year, typically using a RAATs strategy that decreases the 

rate of insecticide applied by either using lower insecticide concentrations, or by 

alternating one or more treatment swaths. Usually RAATs applications use both options. 

The RAATs strategy suppresses grasshoppers within treated swaths, while conserving 

grasshopper predators and parasites in swaths that are not treated. 

The concept of reducing the treatment area of insecticides while also applying less 

insecticide per treated acre was developed in 1995, with the first field tests of RAATs in 

Wyoming (Lockwood and Schell, 1997). Applications can be made either aerially or with 

ground-based equipment (Deneke and Keyser, 2011). Studies using the RAATs strategy 

have shown good control (up to 85% of that achieved with a traditional blanket 

insecticide application) at a significantly lower cost and less insecticide, and with a 

markedly higher abundance of non-target organisms following application (Lockwood et 

al., 2000; Deneke and Keyser, 2011). Levels of control may also depend on variables 

such as body size of targeted grasshoppers, growth rate of forage, and the amount of 

coverage obtained by the spray applications (Deneke and Keyser, 2011). Control rates 
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may also be augmented by the necrophilic and necrophagic behavior of grasshoppers, in 

which grasshoppers are attracted to volatile fatty acids emanating from cadavers of dead 

grasshoppers and move into treated swaths to cannibalize cadavers (Lockwood et al., 

2002; Smith and Lockwood, 2003). Under optimal conditions, RAATs decrease control 

costs, as well as host plant losses and environmental effects (Lockwood et al., 2000; 

Lockwood et al., 2002). 

The efficacy of a RAATs strategy in reducing grasshoppers is, therefore, less than 

conventional treatments and more variable. Foster et al. (2000) reported that grasshopper 

mortality using RAATs was reduced 2 to 15% from conventional treatments, depending 

on the insecticide, while Lockwood et al. (2000) reported 0 to 26% difference in 

mortality between conventional and RAATs methods. APHIS will consider the effects of 

not suppressing grasshoppers to the greatest extent possible as part of the treatment 

planning process. 

RAATs reduces treatment costs and conserves non-target biological resources in 

untreated areas. The potential economic advantages of RAATs was proposed by Larsen 

and Foster (1996), and empirically demonstrated by Lockwood and Schell (1997). 

Widespread efforts to communicate the advantages of RAATs across the Western States 

were undertaken in 1998, and have continued on an annual basis. The viability of RAATs 

at an operational scale was initially demonstrated by Lockwood et al. (2000), and 

subsequently confirmed by Foster et al. (2000). The first government agencies to adopt 

RAATs in their grasshopper suppression programs were the Platte and Goshen County 

Weed and Pest Districts in Wyoming; they also funded research at the University of 

Wyoming to support the initial studies in 1995. This method is now commonly used by 

government agencies and private landowners in States where grasshopper control is 

required.

Reduced rates should prove beneficial for the environment. All APHIS grasshopper 

treatments using carbaryl, chlorantraniliprole, diflubenzuron, or malathion are conducted 

in adherence with USEPA-approved label directions. Labeled application rates for 

grasshopper control tend to be lower than rates used against other pests. In addition, use 

rates proposed for grasshopper control by APHIS are lower than rates used by private 

landowners.

3. Experimental Treatments Alternative

None are planned.

B. Other Environmental Considerations

1. Cumulative Impacts

Cumulative impact, as defined in the Council on Environmental Quality (CEQ) NEPA 

implementing regulations (40 CFR § 1508.7) “is the impact on the environment which 

results from the incremental impact of the action when added to the past, present, and 

reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) 
31 | Page

or person undertakes such actions. Cumulative impacts can result from individually 

minor but collectively significant actions taking place over a period of time.”

Potential cumulative impacts associated with the No Action alternative where APHIS 

would not take part in any grasshopper suppression program include the continued 

increase in grasshopper populations and potential expansion of populations into 

neighboring range and cropland. In addition, State and private land managers could apply 

insecticides to manage grasshopper populations however, land managers may opt not to 

use RAATs, which would increase insecticides applied to the environment. Increased

insecticide use from the lack of coordination and RAAT applications where suitable 

could increase the exposure risk to non-target species and the environment. In addition, 

land managers may not employ the extra program measures designed to reduce exposure 

to the public and the environment. 

Potential cumulative impacts associated with the Preferred Alternative are not expected 

to be significant because the program applies an insecticide application once during a 

treatment. The program may treat an area with different insecticides, but does not overlap 

the treatments. The program does not mix or combine insecticides. Based on historical 

outbreaks in the United States, the probability of an outbreak occurring in the same area 

where treatment occurred in the previous year is unlikely; however, given time, 

populations eventually will reach economically damaging thresholds and require 

treatment. The insecticide application reduces the insect population down to levels that 

cause an acceptable level of economic damage. The duration of treatment activity, which 

is relatively short since it is a one-time application, and the lack of repeated treatments in 

the same area in the same year reduce the possibility of significant cumulative impacts.

Potential cumulative impacts resulting from the use of insecticides include insect pest 

resistance, synergistic chemical effects, chemical persistence and bioaccumulation in the 

environment. The program use of reduced insecticide application rates (i.e. ULV and 

RAATs) are expected to mitigate the development of insect resistance to the insecticides.

Grasshopper outbreaks in the United States occur cyclically so applications do not occur 

to the same population over time further eliminating the selection pressure increasing the 

chances of insecticide resistance.

The insecticides proposed for use in the program have a variety of agricultural and nonagricultural uses. There may be an increased use of these insecticides in an area under 

suppression when private, State, or Federal entities make applications to control other

pests. However, the vast majority of the land where program treatments occur is 

uncultivated rangeland and additional treatments by land owners or managers are very 

uncommon making possible cumulative or synergistic chemical effects extremely 

unlikely. 

The insecticides proposed for use in the grasshopper program are not anticipated to 

persist in the environment or bioaccumulate. Therefore, a grasshopper outbreak that 

occurs in an area previously treated for grasshoppers is unlikely to cause an accumulation 

of insecticides from previous program treatments.
32 | Page

APHIS does not anticipate that any federal or non-federal pest control actions to coincide 

with any grasshopper or Mormon cricket treatments which might occur within the project 

areas. Such would preclude any negative issues that would arise due to cumulative 

pesticide application impacts.

2. Tribal Consultation

Executive Order 13175 "Consultation and Coordination with Indian Tribal 

Governments," calls for agency communication and collaboration with tribal officials 

when proposed Federal actions have potential tribal implications. The Archaeological 

Resources Protection Act of 1979 (16 U.S.C. §§ 470aa-mm), secures the protection of 

archaeological resources and sites on public and tribal lands.

Prior to the treatment season, program personnel notify Tribal land managers of the 

potential for grasshopper and Mormon cricket outbreaks on their lands. Consultation with 

local Tribal representatives takes place prior to treatment programs to inform fully the 

Tribes of possible actions APHIS may take on Tribal lands. Treatments typically do not 

occur at cultural sites, and drift from a program treatment at such locations is not 

expected to adversely affect natural surfaces, such as rock formations and carvings. 

APHIS would also confer with the appropriate Tribal authority to ensure that the timing 

and location of a planned program treatment does not coincide or conflict with cultural 

events or observances on Tribal lands.

3. Executive Order 13186, Responsibilities of Federal Agencies to Protect 

Migratory Birds

The Migratory Bird Treaty Act (MBTA) of 1918 (16 U.S.C. 703–712) established a 

Federal prohibition, unless permitted by regulations, to pursue, hunt, take, capture, kill, 

attempt to take, capture or kill, possess, offer for sale, sell, offer to purchase, purchase, 

deliver for shipment, ship, cause to be shipped, deliver for transportation, transport, cause 

to be transported, carry, or cause to be carried by any means whatever, receive for 

shipment, transportation or carriage, or export, at any time, or in any manner, any 

migratory bird or any part, nest, or egg of any such bird.

Executive Order 13186 directs Federal agencies taking actions with a measurable 

negative effect on migratory bird populations to develop and implement a Memorandum 

of Understanding with the USFWS that promotes the conservation of migratory bird 

populations. On August 2, 2012, a Memorandum of Understanding between APHIS and 

the USFWS was signed to facilitate the implementation of this Executive Order.

In accordance with Executive Order 13186, MBTA, APHIS will support the conservation 

intent of the migratory bird conventions by integrating bird conservation principles, 

measures, and practices into agency activities and by avoiding or minimizing, to the 

extent practicable, adverse impacts on migratory bird resources when conducting agency 

actions. Impacts are minimized as a result of buffers to water, habitat, nesting areas, 

riparian areas, and the use of RAATs. For any given treatment, only a portion of the 

environment will be treated, therefore minimizing potential impacts to migratory bird 

populations. 
33 | Page

4. Endangered Species Act

Section 7 of the Endangered Species Act (ESA) and its implementing regulations require 

Federal agencies to ensure their actions are not likely to jeopardize the continued 

existence of listed threatened or endangered (listed) species, or result in the destruction or 

adverse modification of critical habitat. Numerous federally-listed species and areas of 

designated critical habitat occur within the 17-State program area, although not all occur 

within or near potential grasshopper suppression areas or within the area under 

consideration by through this EA. 

APHIS considers whether listed species, species proposed for listing, experimental 

populations, or critical habitat are present in the proposed suppression area. Before 

treatments are conducted, APHIS contacts the U.S Fish and Wildlife Service (USFWS to 

determine if listed species are present in the suppression area, and whether mitigations or 

protection measures must be implemented to protect listed species or critical habitat. 

APHIS submitted a programmatic biological assessment and requested consultation with 

USFWS on March 9, 2015 for use of carbaryl, malathion, and diflubenzuron for 

grasshopper suppression in the 17-state program area. With the incorporation and use of 

application buffers and other operational procedures APHIS anticipates that any impacts 

associated with the use and fate of program insecticides will be insignificant and 

discountable to listed species and their habitats. Based on an assessment of the potential 

exposure, response, and subsequent risk characterization of program operations, APHIS 

concludes the proposed action is not likely to adversely affect listed species or critical 

habitat in the program area. APHIS has requested concurrence from the USFWS on these 

determinations. Until this programmatic Section 7 consultation with USFWS is 

completed, APHIS will conduct consultations with USFWS field offices at the local 

level.

APHIS completed informal consultation with the FWS regarding the Program at the State 

level years ago after having developed agreed-upon mitigation measures for all T&E and 

Proposed T&E species relative to GH/MC suppression projects in Utah. The USFWS has 

concurred with APHIS’s assessment that the Utah GH/MC suppression program is not 

likely to adversely affect species of concern. That consultation/concurrence has 

continued throughout the years as the T&E list has evolved.

5. Bald and Golden Eagle Protection Act

The Bald and Golden Eagle Protection Act (16 U.S.C. 668–668c) prohibits anyone, 

without a permit issued by the Secretary of the Interior, from “taking” bald eagles, 

including their parts, nests, or eggs. During the breeding season, bald eagles are sensitive 

to a variety of human activities. Grasshopper management activities could cause 

disturbance of nesting eagles, depending on the duration, noise levels, extent of the area 

affected by the activity, prior experiences that eagles have with humans, and tolerance of 

the individual nesting pair. Also, disruptive activities in or near eagle foraging areas can 

interfere with bald eagle feeding, reducing chances of survival. USFWS has provided 

recommendations for avoiding disturbance at foraging areas and communal roost sites 

that are applicable to grasshopper management programs (USFWS, 2007).
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No toxic effects are anticipated on eagles as a direct consequence of insecticide 

treatments. Toxic effects on the principle food source, fish, are not expected because 

insecticide treatments will not be conducted over rivers or lakes. Buffers protective of 

aquatic biota are applied to their habitats to ensure that there are no indirect effects from 

loss of prey.

6. Additional Species of Concern

There may be species that are of special concern to land management agencies, the 

public, or other groups and individuals in proposed treatment areas. For example, the 

sage grouse populations have declined throughout most of their entire range, with habitat 

loss being a major factor in their decline.

Grasshopper suppression programs reduce grasshoppers and at least some other insects in 

the treatment area that can be a food item for sage grouse chicks. As indicated in previous 

sections on impacts to birds, there is low potential that the program insecticides would be 

toxic to sage grouse, either by direct exposure to the insecticides or indirectly through 

immature sage grouse eating moribund grasshoppers. 

Because grasshopper numbers are so high in an outbreak year, treatments would not 

likely reduce the number of grasshoppers below levels present in a normal year. Should 

grasshoppers be unavailable in small, localized areas, sage grouse chicks may consume 

other insects, which sage grouse chicks likely do in years when grasshopper numbers are 

naturally low. By suppressing grasshoppers, rangeland vegetation is available for use by 

other species, including sage grouse, and rangeland areas are less susceptible to invasive 

plants that may be undesirable for sage grouse habitat.

APHIS will work with BLM, the state of Utah and any other appropriate agencies when 

grasshopper treatments are proposed in areas where sage grouse are present, or any other 

species that is known to be of special interest or concern to federal or state agencies or 

the public.

7. Fires and Human Health Hazards

Various compounds are released in smoke during wildland fires, including carbon 

monoxide (CO), carbon dioxide, nitrous oxides, sulfur dioxide, hydrogen chloride, 

aerosols, polynuclear aromatic hydrocarbons contained within fine particulate matter (a 

byproduct of the combustion of organic matter such as wood), aldehydes, and most 

notably formaldehyde produced from the incomplete combustion of burning biomass 

(Reisen and Brown, 2009; Burling et al., 2010; Broyles, 2013). Particulate matter, CO, 

benzene, acrolein, and formaldehyde have been identified as compounds of particular 

concern in wildland fire smoke (Reinhardt and Ottmar, 2004). 

Many of the naturally occurring products associated with combustion from wildfires may 

also be present as a result of combustion of program insecticides that are applied to 

rangeland. These combustion byproducts will be at lower quantities due to the short halflives of most of the program insecticides and their low use rates. Other minor combustion 

products specific to each insecticide may also be present as a result of combustion from a 
35 | Page

rangeland fire but these are typically less toxic based on available human health data 

(http://www.aphis.usda.gov/plant-health/grasshopper).

The safety data sheet (SDS) for each insecticide identifies these combustion products for 

each insecticide as well as recommendations for PPE. The PPE is similar to what 

typically is used in fighting wildfires. Material applied in the field will be at a much 

lower concentration than what would occur in a fire involving a concentrated 

formulation. Therefore the PPE worn by rangeland firefighters would also be protective 

of any additional exposure resulting from the burning of residual insecticides. 

8. Cultural and Historical Resources

Federal actions must seek to avoid, minimize, and mitigate potential negative impacts to 

cultural and historic resources as part of compliance with the National Historic 

Preservation Act (NHPA), the Archaeological Resources Protection Act of 1979, and 

NEPA. Section 106 of the NHPA requires Federal agencies to provide the Advisory 

Council on Historic Preservation with an opportunity to comment on their findings.

APHIS, prior to any treatment project, will consult with the appropriate landowner, the 

State Historic Preservation Office, any affected National Trail’s administrative office or 

other appropriate agencies, to ensure minimal impacts to cultural and historical resources.

V. Literature Cited

Beauvais, S. 2014. Human exposure assessment document for carbaryl. Page 136. 

California Environmental Protection Agency, Department of Pesticide 

Regulation.

Belovsky, G. E., A. Joern, and J. Lockwood. 1996. VII.16 Grasshoppers—Plus and 

Minus: The Grasshopper Problem on a Regional Basis and a Look at Beneficial 

Effects of Grasshoppers. Pages 1-5 in G. L. Cunningham and M. W. Sampson, 

editors. Grasshopper Integrated Pest Management User Handbook, Technical 

Bulletin No. 1809. U.S. Department of Agriculture, Animal and Plant Health 

Inspection Service, Washington, DC.

Belovsky, G. E. 2000. Part 1. Grasshoppers as integral elements of grasslands. 1. Do 

grasshoppers diminish grassland productivity? A new perspective for control 

based on conservation. Pages 7-29 in J. A. Lockwood et al, editor. Grasshoppers 

and Grassland Health. Kluwer Academic Publishers, Netherlands.

Bonderenko, S., J. Gan, D. L. Haver, and J. N. Kabashima. 2004. Persistence of selected 

organophophate and carbamate insecticides in waters from coastal watershed. 

Env. Toxicol. Chem. 23:2649-2654.

Bradshaw, J. D., K. H. Jenkins, and S. D. Whipple. 2018. Impact of grasshopper control 

on forage quality and availability in western Nebraska. Rangelands 40:71-76.

Branson, D., A. Joern, and G. Sword. 2006. Sustainable management of insect herbivores 

in grassland ecosystems: new perspectives in grasshopper control. BioScience 

56:743-755.

Broyles, G. 2013. Wildland firefighter smoke exposure. Page 26. U.S. Department of 

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VI. Listing of Agencies and Persons Consulted 

A. Bureau of Land Management

Nebeker, Glenn, Field Manager, Fillmore, UT Field Office

Riding, Trevor, Range Specialist, Fillmore, UT Field Office

Robbins, Josh, State Weed Coordinator, State Office

B. Utah Department of Agriculture and Food

Hougaard, Robert, Director of Plant Industry

Watson, Kristopher, State Entomologist, Plant Industry

C. USDA, APHIS, PPQ

Caraher, Kai, Biological Scientist – Staff Officer

Sullivan, Melinda, GH/MC National Operations Manager

Warren, Jim, Environmental Protection Specialist/Environmental Toxicologist
43 | Page

Wild, Alana, Utah/Nevada State Plant Health Director

D. USDA, Forest Service

E. USDA, Fish and Wildlife Service

Novak, Kate, T&E Specialist, Utah

Romin, Laura, Acting Field Supervisor, Utah

F. Utah Division of Wildlife Resources

Mumford, Vance, Southern Region Biologist

G. Utah State University Extension Service

 Nelson, Mark, Beaver

Cooper, Troy, Duchesne

Gale, Jody, Sevier County Agriculture Agent

Greenhalgh, Linden, Tooele

Kitchen, Boyd, Uintah

Wilde, Trent, Piute & Wayne

H. Utah County Commissioners

Brown, Ralph, Sevier County

Draper, Dean, Millard

I. Utah State Legislators
44 | Page

J. Federal Legislators
45 | Page

APPENDIX 1:

APHIS Rangeland Grasshopper and Mormon Cricket Suppression Program

FY-2020 Treatment Guidelines

Version 06/04/2020

The objectives of the APHIS Rangeland Grasshopper and Mormon Cricket Suppression Program 

are to 1) conduct surveys in the Western States; 2) provide technical assistance to land managers 

and private landowners; and 3) when funds permit, suppress economically damaging grasshopper 

and Mormon cricket outbreaks on Federal, Tribal, State, and/or private rangeland. The Plant 

Protection Act of 2000 provides APHIS the authority to take these actions.

General Guidelines for Grasshopper / Mormon Cricket Treatments

1) All treatments must be in accordance with:

a) the Plant Protection Act of 2000;

b) applicable environmental laws and policies such as: the National Environmental 

Policy Act, the Endangered Species Act, the Federal Insecticide, Fungicide, and 

Rodenticide Act, and the Clean Water Act (including National Pollutant Discharge 

Elimination System requirements – if applicable);

c) applicable state laws;

d) APHIS Directives pertaining to the proposed action;

e) Memoranda of Understanding with other Federal agencies.

2) Subject to the availability of funds, upon request of the administering agency, the 

agriculture department of an affected State, or private landowners, APHIS, to protect 

rangeland, shall immediately treat Federal, Tribal, State, or private lands that are infested 

with grasshoppers or Mormon crickets at levels of economic infestation, unless APHIS 

determines that delaying treatment will not cause greater economic damage to adjacent 

owners of rangeland. In carrying out this section, APHIS shall work in conjunction with 

other Federal, State, Tribal, and private prevention, control, or suppression efforts to 

protect rangeland.

3) Prior to the treatment season, conduct meetings or provide guidance that allows for public 

participation in the decision making process. In addition, notify Federal, State and Tribal 

land managers and private landowners of the potential for grasshopper and Mormon 

cricket outbreaks on their lands. Request that the land manager / land owner advise APHIS 

of any sensitive sites that may exist in the proposed treatment areas.

4) Consultation with local Tribal representatives will take place prior to treatment programs 

to fully inform the Tribes of possible actions APHIS may take on Tribal lands.

5) On APHIS run suppression programs, the Federal government will bear the cost of 

treatment up to 100 percent on Federal and Tribal Trust land, 50 percent of the cost on 

State land, and 33 percent of cost on private land. There is an additional 16.15% charge, 

however, on any funds received by APHIS for federal involvement with suppression 

treatments.
46 | Page

6) Land managers are responsible for the overall management of rangeland under their 

control to prevent or reduce the severity of grasshopper and Mormon cricket outbreaks. 

Land managers are encouraged to have implemented Integrated Pest Management

Systems prior to requesting a treatment. In the absence of available funding or in the 

place of APHIS funding, the Federal land management agency, Tribal authority or other 

party/ies may opt to reimburse APHIS for suppression treatments. Interagency 

agreements or reimbursement agreements must be completed prior to the start of 

treatments which will be charged thereto.

7) There are situations where APHIS may be requested to treat rangeland that also includes 

small areas where crops are being grown (typically less than 10 percent of the treatment 

area). In those situations, the crop owner pays the entire treatment costs on the croplands.

NOTE: The insecticide being considered must be labeled for the included crop as well as 

rangeland and current Worker Protection Standards must be followed by the applicator 

and private landowner.

8) In some cases, rangeland treatments may be conducted by other federal agencies (e.g., 

Forest Service, Bureau of Land Management, or Bureau of Indian Affairs) or by nonfederal entities (e.g., Grazing Association or County Pest District). APHIS may choose to 

assist these groups in a variety of ways, such as:

a) loaning equipment (an agreement may be required):

b) contributing in-kind services such as surveys to determine insect species, instars, and 

infestation levels;

c) monitoring for effectiveness of the treatment;

d) providing technical guidance.

9) In areas considered for treatment, State-registered beekeepers and organic producers

shall be notified in advance of proposed treatments. If necessary, non-treated buffer 

zones can be established.

Operational Procedures

GENERAL PROCEDURES FOR ALL AERIAL AND GROUND APPLICATIONS

1) Follow all applicable Federal, Tribal, State and local laws and regulations in 

conducting grasshopper and Mormon cricket suppression treatments.

2) Notify residents within treatment areas, or their designated representatives, prior to

proposed operations. Advise them of the control method to be used, proposed method of 

application, and precautions to be taken.

3) One of the following insecticides that are labeled for rangeland use can be used 

for a suppression treatment of grasshoppers and Mormon crickets:

a) Carbaryl

i) solid bait

ii) ultra-low volume (ULV) spray

b) Diflubenzuron ULV spray

c) Malathion ULV spray
47 | Page

4) Do not apply insecticides directly to water bodies (defined herein as reservoirs, lakes,

ponds, pools left by seasonal streams, springs, wetlands, and perennial streams and

rivers).

Furthermore, provide the following buffers for water bodies:

• 500-foot buffer with aerial liquid insecticide.

• 200 foot buffer with ground liquid insecticide.

• 200-foot buffer with aerial bait.

• 50-foot buffer with ground bait.

5) Instruct program personnel in the safe use of equipment, materials and procedures; 

supervise to ensure safety procedures are properly followed.

6) Conduct mixing, loading, and unloading in an approved area where an accidental spill 

would not contaminate a water body.

7) Each aerial suppression program will have a Contracting Officer’s Representative (COR)

OR a Treatment Manager on site. Each State will have at least one COR available to assist 

the Contracting Officer (CO) in GH/MC aerial suppression programs.

NOTE: A Treatment Manager is an individual that the COR has delegated authority 

to oversee the actual suppression treatment; someone who is on the treatment site 

and overseeing / coordinating the treatment and communicating with the COR. No 

specific training is required, but knowledge of the Aerial Application Manual and 

treatment experience is critical; attendance to the Aerial Applicators Workshop is 

very beneficial.

8) Each suppression program will conduct environmental monitoring as outlined in the

current year’s Environmental Monitoring Plan.

APHIS will assess and monitor rangeland treatments for the efficacy of the treatment, 

to verify that a suppression treatment program has properly been implemented, and to 

assure that any environmentally sensitive sites are protected.

9) APHIS reporting requirements associated with grasshopper / Mormon cricket 

suppression treatments can be found in the APHIS Grasshopper Program Guidebook:

http://www.aphis.usda.gov/import_export/plants/manuals/domestic/downloads/grasshopper.pd

f

SPECIFIC PROCEDURES FOR AERIAL APPLICATIONS

1) APHIS Aerial treatment contracts will adhere to the current year’s Statement of 

Work (SOW).
48

2) Minimize the potential for drift and volatilization by not using ULV sprays 

when the following conditions exist in the spray area:

a) Wind velocity exceeds 10 miles per hour (unless state law requires lower 

wind speed);

b) Rain is falling or is imminent;

c) Dew is present over large areas within the treatment block;

d) There is air turbulence that could affect the spray deposition;

e) Temperature inversions (ground temperature higher than air temperature) develop

and deposition onto the ground is affected.

3) Weather conditions will be monitored and documented during application and 

treatment will be suspended when conditions could jeopardize the correct spray 

placement or pilotsafety.

4) Application aircraft will fly at a median altitude of 1 to 1.5 times the wingspan of the

aircraft whenever possible or as specified by the COR or the Treatment Manager.

5) Whenever possible, plan aerial ferrying and turnaround routes to avoid flights over

congested areas, water bodies, and other sensitive areas that are not to be treated.
49 | Page

APPENDIX 2: Map of the Affected Environment
50 | Page

APPENDIX 3: FWS Correspondence 

THREATENED & ENDANGERED SPECIES DETERMINATIONS FOR UTAH 

APHIS 2020 GRASSHOPPER/MORMON CRICKET SUPPRESSION PROJECTS

1. Canada lynx (Lynx canadensis) (Threatened): The preferred habitat of the Canada lynx is 

montane coniferous forest. The proposed APHIS suppression program will have no 

effect on or cause no jeopardy to any population of Canada lynx since projects will avoid 

known or historic species habitat areas.

2. Black-footed ferret (Mustela nigripes) (Threatened): Possibly found in Carbon, Daggett, 

Duchesne, Emery, Grand, Rich, San Juan, Summit and Uintah Counties. Black-footed 

ferrets live in underground prairie dog burrows and eat prairie dogs as their primary food 

source. The black-footed ferret is, therefore, closely associated with prairie dog towns. 

For this reason, the major threat to the species is the decimation of prairie dog colonies 

through plague, poisoning and habitat loss. The only known population occurs in Coyote 

Basin, Uintah County. Direct toxic effects from carbary bait are low since plant-based 

baits are not sought-after food items for ferrets. Indirect effects by consumption of 

contaminated insects or prairie dogs might occur. Though prairie dogs may ingest 

carbaryl bait, and therefore, transfer that consumed carbaryl to a predator like the ferret, 

the potential for adverse effects remains low due to the unlikelihood of encountering 

significant quantities. Ten pounds of 2 percent active ingredient per acre maximum 

application rates preclude ingestion of sufficient toxin by insects or prairie dogs, 

themselves, to cause undesirable effects to ferrets. Direct toxic effects from Dimilin are 

low since diflubenzuron is slightly to very slightly toxic to mammals (Maas et al., (1981). 

There would be few if any indirect effects from the use of Dimilin. The proposed APHIS 

suppression program is not likely to adversely affect this species. PROTECTIVE 

MEASURES: No aerial application of Dimilin within 1 mile and no ground applications 

within 0.25 mile of the edge of identified habitat.

3. Utah prairie dog (Cynomys parvidens) (Threatened): Found in Beaver, Garfield, Iron, 

Kane, Millard, Piute, Sanpete, Sevier and Wayne Counties. Direct toxic effects from 

carbaryl bait are moderate since prairie dogs may ingest it. However, 10 pounds per acre 

maximum application rates preclude ingestion of sufficient toxin to create behavioral 

anomalies, let alone mortality, due to the unlikelihood of encountering significant 

quantities. Since prairie dogs may consume insects, indirect effects from carbaryl bait 

are possible, but large quantities of contaminated insects would have to be consumed for 

such to occur. Rapid decomposition rates of dead insects, quickly making them 

unpalatable as food items, coupled with low application rates, minimize the risk of 

adverse effects on prairie dogs from carbaryl bait treatments. Direct toxic effects from 

Dimilin are low since diflubenzuron is slightly to very slightly toxic to mammals (Maas 

et al., (1981). There would be no indirect effects from the use of Dimilin. The proposed 

APHIS suppression program would not likely adversely affect this species. 

PROTECTIVE MEASURES: Avoid using any pesticide within 1 mile of occupied 

habitat.
51

4. California condor (Gymnogyps californianus) (Endangered): California condors were 

released as part of Recovery Program efforts in northern Arizona beginning in the late 

1990’s. Sightings of the birds that were released have since been made almost statewide. 

Condors prefer mountainous country at low and moderate elevations, especially rocky 

and brushy areas near cliffs. California condors eat carrion, usually feeding on large 

items such as dead sheep, cattle and deer. Due to their foraging habits and preferences, 

the proposed APHIS grasshopper/Mormon cricket suppression program is unlikely to 

affect California condors. In addition, condors to date are occasional and temporary 

visitors to the state and are unlikely to contact suppression activities. 

5. Gunnison Sage-Grouse (Centrocercus minimus) (Threatened): Found in Grand and San 

Juan Counties. Male Gunnison sage-grouse conduct an elaborate display when trying to 

attract females on breeding grounds, or leks in the spring. Nesting begins in mid-April 

and continues into July. Gunnison sage-grouse require a variety of habitats such as large 

expanses of sagebrush with a diversity of grasses and forbs and healthy wetland and 

riparian ecosystems. It requires sagebrush for cover and fall and winter food. Direct 

toxic effects from carbaryl bait are low (Peach et al., 1994), but there may be minimal 

indirect effects since the young of this species depend upon arthropod groups for food. 

The use of carbaryl baits temporarily may lower the insect food base in the immediate 

area, though certainly not sufficiently to create adverse consequences to immature sagegrouse. Direct toxic effects from Dimilin are low since diflubenzuron is slightly to very 

slightly toxic to birds, but there may be minimal indirect effects such as a slight reduction 

in available prey items. The proposed APHIS suppression program will not likely 

adversely affect this species. PROTECTIVE MEASURES: No ground/aerial application 

will occur within 1 mile of known leks between March and July. Otherwise, no 

ground/aerial applications within 100/500 ft. of the edge of occupied habitat.

6. Mexican spotted owl (Strix occidentalis lucida) (Threatened): Possibly found in Carbon, 

Emery, Grand, Garfield, Iron, Kane, San Juan, Washington and Wayne Counties. In Utah 

spotted owls occupy and nest in rocky canyon habitats. Nests are located on cliffs and in 

caves. Mexican spotted owls feed mainly on small rodents, but also consume rabbits and 

other small vertebrates, including birds, reptiles and insects. Direct toxic effects from 

carbaryl bait are low since owls do not directly ingest it and since they do not depend on 

arthropod groups for food or seed dispersal. (George et al., 1992). Indirect toxic effects 

from carbaryl bait are low due to low application rates (10 pounds per acre or less) and 

small bait particle sizes, which preclude birds and small mammals from encountering 

sufficient quantities of toxin to cause adverse consequences to them or to owls which 

might consume them. APHIS only applies baits to areas of high grasshopper or Mormon 

cricket densities (8 or more per square yard), so any bait treatment is quickly and nearly 

totally consumed by the insects. Any remaining bait rapidly degrades from exposure to 

the elements (dew and higher soil pH’s). Birds and rodents may prey upon debilitated 

insects, but rapid decomposition rates quickly make dead insects unpalatable. That, 

coupled with low application rates, makes it unlikely that spotted owls would be 

adversely affected by eating birds or small mammals that may prey upon insects 

debilitated by carbaryl bait treatments. APHIS ground baiting protocol excludes 
52

treatment near the canyon habitats that spotted owls use for nesting. Direct and indirect 

toxic effects from Dimilin are also low since diflubenzuron is slightly to very slightly 

toxic to birds (Wilcox and Coffey, 1978). The proposed APHIS suppression program 

will not likely adversely affect this species. PROTECTIVE MEASURES: No aerial 

application will occur within 1 mile of suitable nesting habitat, and ground applications 

will be no closer than 0.25 mile to nesting habitat.

7. Southwestern willow flycatcher (Empidonax traillii extimus) (Endangered): Possibly 

found in Kane, San Juan and Washington Counties. The southwestern willow flycatcher 

utilizes dense riparian habitats. Forage items include insects, seeds and berries. Direct 

toxic effects from carbaryl bait are low (Peach et al., 1994), but there may be minimal 

indirect effects since this species depends on arthropod groups for food. The use of 

carbaryl baits may temporarily lower the insect food base in the immediate area, though 

certainly not sufficiently to create adverse consequences to flycatchers. Direct toxic 

effects from Dimilin are low since diflubenzuron is slightly to very slightly toxic to birds, 

but there may be minimal indirect effects such as a slight reduction in available prey 

items. The proposed APHIS suppression program will not likely adversely affect this 

species. PROTECTIVE MEASURES: No aerial application will occur within 1 mile of 

suitable nesting habitat, and ground applications will be no closer than 0.25 mile to 

nesting habitat.

8. Yellow-billed Cuckoo (Coccyzus americanus) (Threatened): Found throughout Utah. 

The yellow-billed cuckoo uses wooded habitat with dense cover and water nearby. Its 

nests in the West are often placed in willows along streams and rivers, with nearby 

cottonwoods serving as foraging sites. They sometimes lay their eggs in other birds’ 

nests. Cuckoos feed on insects (especially caterpillars), spiders, frogs, lizards, fruits and 

seeds. Direct toxic effects from carbaryl bait are low (Peach et al., 1994), but there may 

be minimal indirect effects since this species depends upon arthropod groups for food. 

The use of carbaryl baits may temporarily lower the insect food base in the immediate 

area, though certainly not sufficiently to create adverse consequences to cuckoos. Direct 

toxic effects from Dimilin are low since diflubenzuron is slightly to very slightly toxic to 

birds, but there may be minimal indirect effects such as a slight reduction in available 

prey items. The proposed APHIS suppression program will not likely adversely affect 

this species. PROTECTIVE MEASURES: No aerial application will occur within 1000 

ft. and no ground application will occur within 500 ft. of the edge of known locations of 

yellow-billed cuckoos or their critical habitat.

9. Bonytail (Gila elegans) (Endangered): Found in Carbon, Emery, Garfield, Grand, Kane, 

San Juan, Tooele, Uintah, Wayne and possibly Duchesne and formerly Daggett Counties. 

Bonytail are opportunistic feeders, eating insects, zooplankton, algae and higher plant 

matter. Although bonytail spawning in the wild is now rare, spawning occurs in the 

spring and summer over gravel substrate. Most bonytail are now produced in hatcheries 

and released into the wild as adults. Direct toxic effects from carbaryl bait are low since 

APHIS ground applicators remain at least 50 feet from water which precludes any bait 

from entering a water body, even during and after heavy rains. Carbaryl rapidly 

decomposes in the presence of water and soils with higher pH’s. Indirect effects from 
53

carbaryl bait are also low. Insects that ingest the bait are incapacitated by it within a 

matter of a minute or so; therefore, few could hop or fly into water bodies after bait 

consumption (APHIS personal experience). The use of bait near streams would not likely 

create an unnatural influx of contaminated grasshoppers or crickets into the water, so that 

fish might prey on them. Direct toxic effects from diflubenzuron are also low since it is 

only slightly toxic to fish (Willcox and Coffey, 1978; Julin and Sanders, 1978). Indirect 

effects from either carbaryl bait or Dimilin are minimal due to APHIS’s standard practice 

of maintaining 50 foot buffers with ground applications of bait and 500 foot buffers with 

aerial sprays around water. The proposed APHIS suppression program will not likely 

adversely affect this species. PROTECTIVE MEASURES: No aerial applications within 

1 mile of habitat or no ground treatments within 500 feet of habitat.

10. Colorado pikeminnow (Ptychocheilus lucius) (Endangered): Found in Carbon, Daggett, 

Emery, Garfield, Grand, San Juan, Uintah, Wayne and possibly Duchesne and formerly 

Kane Counties. Colorado pikeminnows are primarily piscivorous (they eat fish), but 

smaller individuals also eat insects and other invertebrates. The species spawns during 

the spring and summer over riffle areas with gravel or cobble substrate. Eggs are 

randomly broadcast onto the bottom, and usually hatch in less than one week. The 

proposed APHIS suppression program will not likely adversely affect this species. Direct 

and indirect toxic effects and PROTECTIVE MEASURES same as # 10.

11. Greenback cutthroat trout (Oncorhynchus clarki stomias) (Threatened): Found in San 

Juan County. The greenback cutthroat trout is a member of the Salmonidae family and is 

a subspecies of O. clarki. The subspecies feeds on aquatic insects as well as terrestrial 

invertebrates. It spawns in the spring in riffle areas when water temperatures reach 5-8 

degrees C. It requires clear, swift-flowing mountain streams with cover such as low, 

overhanging banks and vegetation. The proposed APHIS suppression program will not 

likely adversely affect this species. Direct and indirect toxic effects and PROTECTIVE 

MEASURES same as # 10. 

12. Humpback chub (Gila cypha) (Endangered): Found in Carbon, Daggett, Emery, 

Garfield, Grand, San Juan, Uintah, Wayne and possibly Duchesne and formerly Kane 

Counties. Humpback chub primarily eat insects and other invertebrates, but algae and 

fishes are occasionally consumed. The species spawns during the spring and summer in 

shallow, backwater areas with cobble substrate. Young humpback chub remain in these 

slow, shallow, turbid habitats until they are large enough to move into white-water areas. 

The proposed APHIS suppression program will not likely adversely affect this species. 

Direct and indirect toxic effects and PROTECTIVE MEASURES same as # 10.

13. Lahontan cutthroat trout (Oncorhynchus clarkii henshawi) (Threatened): The Lahontan 

cutthroat trout is a race of the cutthroat trout native to the Lahontan Basin of Oregon, 

California, and western Nevada. It has been introduced and become established in the 

Pilot Peak Range of western Box Elder County, Utah. Like other cutthroat races, the 

Lahontan cutthroat is an opportunistic feeder, with the diet of small individuals 

dominated by invertebrates, and the diet larger individuals composed primarily of fish. 

The proposed APHIS suppression program will not likely adversely affect this species. 

Direct and indirect toxic effects and PROTECTIVE MEASURES same as # 10.
54

14. June sucker (Chasmistes liorus) (Endangered): Found in Box Elder, Salt Lake, Utah and 

Weber Counties. June suckers are members of the sucker family, but they are not bottom 

feeders. The jaw structure of the June sucker allows the species to feed on zooplankton in 

the middle of the water column. June sucker adults leave Utah Lake and swim up the 

Provo River to spawn in June of each year. Spawning occurs in shallow riffles over 

gravel or rock substrate. Fertilized eggs sink to the stream bottom, where they hatch in 

about four days. The proposed APHIS suppression program will not likely adversely 

affect this species. Direct and indirect toxic effects and PROTECTIVE MEASURES 

same as # 10.

15. Razorback sucker (Xyrauchen texanus) (Endangered): Found in Carbon, Daggett, 

Emery, Garfield, Grand, San Juan, Uintah, Wayne and possibly Duchesne and formerly 

Kane Counties. The razorback sucker eats mainly algae, zooplankton and other aquatic 

invertebrates. The species spawns from February to June, and each female may deposit 

over 100,000 eggs during spawning. The proposed APHIS suppression program will not 

likely adversely affect this species. Direct and indirect toxic effects and PROTECTIVE 

MEASURES same as # 10.

16. Virgin chub (Gila seminuda) (Endangered): Found in Washington County. Virgin chub 

are opportunistic feeders, consuming zooplankton, aquatic insect larvae, other 

invertebrates, debris and algae. Interestingly, the diet of many adults is composed 

primarily of algae, whereas the diets of younger fish contain more animal matter. The 

species spawns during late spring and early summer over gravel or rock substrate. The 

proposed APHIS suppression program will not likely adversely affect this species. Direct 

and indirect toxic effects and PROTECTIVE MEASURES same as # 10.

17. Woundfin (Plagopterus argentissimus) Endangered): Found in Washington County, the 

species is now restricted to the Virgin River system. Woundfin diets are quite varied, 

consisting of insects, insect larvae, other invertebrates, algae, and detritus. The species 

spawns during the spring in swift shallow water over gravel substrate. The proposed 

APHIS suppression program will not likely adversely affect this species. Direct and 

indirect toxic effects and PROTECTIVE MEASURES same as # 10.

18. Desert tortoise ( Gopherus agassizii) (Threatened): Found in Washington County. 

Within its range, the desert tortoise can be found near water in deserts, semi-arid 

grasslands, canyon bottoms and rocky hillsides. Desert tortoises often construct burrows 

in compacted sandy or gravelly soil. Females nest under a large shrub or at the mouth of a 

burrow and lay one to three clutches of two to fourteen eggs from May to July; eggs 

hatch in late summer or fall. Burrows, which may contain many tortoises at once, are 

used for hibernation during cold winter months. The typical diet of the desert tortoise 

consists of perennial grasses, cacti, shrubs and other plant material. Historically APHIS 

has never received a request to treat in areas inhabited by desert tortoises, but if asked to 

do so, there would exist the threat of direct take by running over small tortoises with 

ground equipment. Direct toxic effects from the use of carbaryl bait are unknown, but 
55

the tortoises would not likely consume the bait at low application rates (10 pounds per 

acre) and given the small size and consistency of bait particles. Indirect effects are low 

since they do not depend on insects for food. No information was located about 

diflubenzuron’s toxicity to reptiles, but it is likely that it is low, based on the selective 

nature of its toxic mode of action (i.e., it interferes with the synthesis of chitin in those 

organisms that produce exoskeletons). The relative toxicity of diflubenzuron to reptiles 

is expected to be similar to that of mammals and birds (APHIS EIS, 2002). Indirect 

effects are also expected to be low since desert tortoises do not depend on insects for 

food. It is unlikely that grasshoppers or Mormon cricket populations would ever reach 

outbreak levels and require APHIS treatments in desert tortoise habitat. The proposed 

APHIS suppression program will not likely adversely affect this species. PROTECTIVE 

MEASURES: No aerial or ground applications will occur in the Beaver Dam Slope, the 

Tortoise Preserve or other occupied habitats of Washington County. If APHIS does 

receive a request to treat using ground equipment, then APHIS would re-consult with the 

USFWS.

19. Kanab ambersnail (Oxyloma kanabense) (Endangered): Found in Kane County. Pilsbry 

(1948), in the type description of this taxon, noted that it was found "on a wet ledge 

among rocks and cypripediums." Clarke (1991) reported the habitat of the Three Lakes 

population as a marsh dominated by Typha in its wettest portion. Grasses, Carex, violets, 

plantains and alders were also present. The densest snail aggregations were found under

fallen Typha stalks, at the edges of thick Typha stands. The snails were also frequently 

observed just within the mouths of vole burrows. The presence of standing water 

appeared to be important to their local distribution. Clarke (1991) found that the habitat 

of the small population that existed along Kanab Creek also included Mimulus guttatus, 

Dodocatheon pauciflorum, Aquilegia micrantha, a tall grass species and Juncus. Direct 

toxic effects of carbaryl bait are high, but mitigation measures would insure that this 

species would not come in contact with the toxin. Indirect effects are low since the 

susceptible insects are not likely food items. Direct toxic effects from Dimilin are none 

to slight - the median lethal concentration of diflubenzuron in water to the snail is greater 

than 125 mg/L (Willcox and Coffey, 1978) - especially given the low application rates 

and the self-imposed water/spring buffers of APHIS programs. Indirect effects are also 

expected to be low since susceptible insects are not likely food items. The proposed 

APHIS suppression program will not likely adversely affect this species. PROTECTIVE 

MEASURES: No aerial applications within 1 mile of occupied habitat, and no ground 

treatments within 500 feet of occupied habitat.

20. Autumn buttercup (Ranunculus aestivalis) (Endangered): Found in Garfield County. 

Autumn buttercup produces abundant yellow flowers that can be seen from late-July to 

early October. It is found in low, herbaceous, wet meadow communities on islands of 

drier peaty hummocks, and sometimes in open areas, at elevations ranging from 1940 to 

1965 meters. There are no direct toxic effects from carbaryl bait to this species. Indirect 

effects to plant pollinators from the use of carbaryl bait are low since insects must 

consume the bait in order to succumb to it. Target insects are unlikely pollinators of this 

species. There are no direct toxic effects from Dimilin, and the indirect effects to 

pollinators from the use of diflubenzuron are low since it is not toxic to adult insects. 
56

APHIS’s low application rate of one ounce per acre, coupled with the practice of treating 

not more than every other swath, preclude significant adverse impacts to larval insects as 

well. Only insect nymphs that undergo incomplete metamorphosis (i.e., 

grasshoppers/crickets) manifest significant adverse effects at the low doses of APHIS 

projects. The proposed APHIS program will not likely adversely affect this species. 

PROTECTIVE MEASURES: No aerial applications within 3 miles of occupied habitat,

and no ground treatments within 300 feet of occupied habitat.

21. Barneby reed-mustard (Schoenocrambe barnebyi) (Endangered): Found in Emery and 

Wayne Counties. Specimens have a branched woody base that gives rise to purple 

veined, white, or lilac flowers from late April to early June. Barneby reed-mustard grows 

in xeric, fine textured soils on steep eroding slopes of the Moenkopi and Chinle 

formations. It grows in sparsely-vegetated sites in mixed desert shrub and pinyon-juniper 

communities, at elevations ranging from 1460 to 1985 meters. The proposed APHIS 

program will not likely adversely affect this species. Direct and indirect toxic effects and 

PROTECTIVE MEASURES same as # 20.

22. Barneby ridge-cress (Lepidium barnebyanum) (Endangered): Found in Duchesne

County. This species grows in cushion-shaped tufts, has a thickened, branched woody 

base and produces abundant white to cream colored flowers that bloom in May and June. 

It grows along semi-barren ridges in pinyon-juniper woodlands, at elevations ranging 

from 1860 to 1965 meters. The proposed APHIS program will not likely adversely affect 

this species. Direct and indirect toxic effects and PROTECTIVE MEASURES same as # 

20.

23. Clay phacelia (Phacelia argillacea) (Endangered): Found in Utah County. It is a narrow 

endemic to Spanish Fork Canyon, Utah County, Utah. A member of the waterleaf family, 

it has a scorpion tale-like inflorescence that continues, as it unrolls, to produce blue to 

violet flowers from June to August. This species is a winter annual and is found in fine 

textured soil and fragmented shale derived from the Green River Formation. It grows on 

barren, precipitous hillsides in sparse pinyon-juniper and mountain brush communities, at 

elevations ranging from 1840 to 1881 meters. The proposed APHIS program will not 

likely adversely affect this species. Direct and indirect toxic effects and PROTECTIVE 

MEASURES same as # 20.

24. Clay reed-mustard (Schoenocrambe argillacea) (Threatened): Found in Uintah County. 

It is a plant that occurs in the Uinta Basin, Uintah County, Utah. A member of the 

mustard family, this species is a hairless perennial with a stout, woody base. It produces 

lilac to white, purple-veined flowers that bloom from mid-April through mid-May. 

Shrubby reed-mustard grows on the Evacuation Creek Member of the Green River 

Formation, where it is on substrates consisting of at-the-surface bedrock, scree, and finetextured soils. It occurs on precipitous slopes in mixed desert shrub communities, at 

elevations ranging from 1439 to 1765 meters. The proposed APHIS program will not 

likely adversely affect this species. Direct and indirect effects and PROTECTIVE 

MEASURES same as # 20.
57

25. Deseret milkvetch (Astragalus desereticus) (Threatened): Found in Utah County. This 

plant occurs at a single site in Utah County, Utah. A member of the bean family, this 

species is a perennial herb with gray-silvery leaves four to five cm long and white to 

pinkish petals with evident lilac-colored keel-tips. It blooms from late April to early June. 

Deseret milkvetch grows exclusively on sandy-gravelly soils weathered from 

conglomerate outcrops of the Moroni Formation. It likes steep south and west (rarely 

north) facing slopes and does well on larger, west-facing road-cuts. It is grows in an open 

pinyon-juniper-sagebrush community, at elevations ranging from 1645 to 1740 meters. 

The proposed APHIS program will not likely adversely affect this species. Direct and 

indirect effects and PROTECTIVE MEASURES same as # 20.

26. Dwarf bear-poppy (Arctomecon humilis) (Endangered): Found in Washington County. 

This plant is a narrow endemic to (occurs only in) Washington County, Utah. A member 

of the poppy family, this species is a perennial herb that produces abundant white 

flowers. The flowers bloom from mid-April through May, and are quite showy next to the 

red soils in which the plant grows. Dwarf bearclaw-poppy is found on gypsiferous clay 

soils derived from the Moenkopi Formation. It occurs on rolling low hills and ridge tops, 

often on barren, open sites in warm desert shrub communities, at elevations ranging from 

700 to 1402 meters. The proposed APHIS program will not likely adversely affect this 

species. Direct and indirect effects and PROTECTIVE MEASURES same as # 20.

27. Gierisch mallow (Sphaeralcea gierischii) (Endangered): Found in Washington County. 

A member of the mallow family, this species is a flowering perennial which is only found 

on gypsum outcrops associated with the Harrisburg Member of the Kaibab Formation in 

northern Mojave County, AZ and Washington County, UT. It has a woody base and dies 

back to the ground during the winter and re-sprouts from the base during late winter and 

spring depending on daytime temperatures and rainfall. How its flowers are pollinated, 

seed-dispersal mechanisms and the conditions under which seeds germinate are not yet 

known. Young plants have been observed on reclaimed portions within gypsum mining 

areas. The proposed APHIS program will not likely adversely affect this species. Direct 

and indirect effects and PROTECTIVE MEASURES same as # 20.

28. Graham beardtongue (Penstemon grahamii): Found in Carbon, Duchesne and Uintah 

Counties. It is endemic to (occurs only in) the Uinta Basin in Carbon County, Duchesne 

County and Uintah County, Utah, and in immediately adjacent Rio Blanco County, 

Colorado. A member of the figwort family, this species is a perennial herb that is 5 to 20 

cm tall, with thick leathery leaves, and large, tubular, light to deep lavender flowers that 

bloom from late May to early June. Graham beardtongue grows on semi-barren knolls, 

ridges and steep slopes in a mix of fragmented shale and silty clay soils closely 

associated with the Mahogany zone (oil shale bearing) of the Green River Formation. It 

grows in sparsely vegetated communities of pinyon-juniper, desert shrub and Salina 

wildrye, at elevations ranging from 1430 to 2060 meters. The proposed APHIS program 

will not likely adversely affect this species. Direct and indirect effects and 

PROTECTIVE MEASURES same as # 20.

29. Heliotrope milkvetch (Astragalus montii) (Threatened): Found in Sanpete and Sevier 

Counties. This is a plant that occurs on the southern Wasatch Plateau in Sanpete County 
58

and Sevier County, Utah. A member of the bean family, this species is a dwarf tufted 

perennial herb with pink purple petals that have white wing-tips. It blooms from June to 

August. Heliotrope milkvetch grows in barren areas on shallow and very rocky soils 

derived from Flagstaff Limestone, at elevations ranging from about 3230 to 3322 meters.

It grows in subalpine communities of cushion plants and other low-growing species that 

are scattered within more extensive conifer, tall-forb, and grass communities. The 

proposed APHIS program will not likely adversely affect this species. Direct and indirect 

effects and PROTECTIVE MEASURES same as # 20.

30. Holmgren milkvetch (Astragalus holmgreniorum) (Endangered): Found in Washington 

County. It occurs in Washington County, Utah, and in immediately adjacent Mohave 

County, Arizona. A member of the bean family, this species is a dwarf, tufted, stemless 

perennial herb. It has pinkish-purple flowers with unique white-tipped wings; it blooms 

in April and May. Holmgren milkvetch grows in topographic sites where water runoff 

occurs and where the soil surface is covered by a stony or gravelly erosional pavement. 

The soils are derived from the Moenkopi Formation. Holmgren milkvetch grows in warm 

desert shrub communities, at elevations ranging from 805 to 914 meters. The proposed 

APHIS program will not likely adversely affect this species. Direct and indirect effects 

and PROTECTIVE MEASURES same as # 20.

31. Jones cycladenia (Cycladenia humilis var. jonesii) (Threatened): Found in Emery, 

Garfield, Grand and Kane Counties. This plant is restricted to the canyonlands of the 

Colorado Plateau in Emery County, Garfield County, Grand County, and Kane County, 

Utah, as well as in immediately adjacent Coconino County, Arizona. A member of the 

dogbane family, this species is a rhizomatous herb with round, somewhat succulent 

leaves, and small rose-pink hairy flowers that bloom from mid-April to early June. Jones' 

cycladenia grows in gypsiferous soils that are derived from the Summerville, Cutler, and 

Chinle formations; they are shallow, fine textured, and intermixed with rock fragments. 

The species can be found in Eriogonum-ephedra, mixed desert shrub, and scattered 

pinyon-juniper communities, at elevations ranging from 1219 to 2075 meters. The 

proposed APHIS program will not likely adversely affect this species. Direct and indirect 

effects and PROTECTIVE MEASURES same as # 20.

32. Kodachrome bladderpod (Lesquerella tumulosa) (Endangered): Found in Kane County. 

It is a plant that is a narrow endemic to (it occurs only in) Kane County, Utah. A member 

of the mustard family, this species is a perennial herb that forms densely matted and 

depressed mounds. It has a many-branched woody base with persistent leaf bases, has 

star-shaped hairs, and produces yellow flowers that bloom in May and early June. 

Kodachrome bladderpod is found on shallow soils that are fine textured, intermixed with 

shale fragments, and derived from the Winsor Member of the Carmel Formation. 

Kodachrome bladderpod grows on bare shale knolls and slopes in scattered pinyonjuniper communities, at elevations ranging from 1719 to 1845 meters. The proposed 

APHIS program will not likely adversely affect this species. Direct and indirect effects 

and PROTECTIVE MEASURES same as # 20.
59

33. Last Chance townsendia (Townsendia aprica) (Threatened): Found in Emery, Sevier and 

Wayne Counties. This plant is a member of the sunflower family, and is a stemless 

perennial herb with flower heads submersed in its ground-level leaves. The flowers 

bloom in late April and May, and have yellow to golden petals. Last Chance townsendia 

is found in clay, clay-silt, or gravelly clay soils derived from the Mancos Formation; 

these soils are often densely covered with biological soil crusts. The species grows in salt 

desert shrub and pinyon-juniper communities, at elevations ranging from 1686 to 2560 

meters. The proposed APHIS program will not likely adversely affect this species. 

Direct and indirect effects and PROTECTIVE MEASURES same as # 20.

34. Maguire primrose (Primula maguirei) Threatened): Found in Cache County. plant that 

is a narrow endemic to (it occurs only in) Logan Canyon, Cache County, Utah. A 

member of the primula family, this species is a perennial herb with broad, spatula-shaped 

leaves. Stems are approximately four to fifteen cm tall, with each bearing one to three 

showy rose to lavender-colored flowers that bloom in late April and May. Maguire 

primrose is found on either north-facing or well shaded south-facing moss covered sites 

on damp ledges, in crevices, and on over-hanging rocks along the walls near the bottom 

of the canyon. It grows at elevations ranging from 1550 to 2012 meters. The propose 

APHIS program will not likely adversely affect this species. Direct and indirect effects 

and PROTECTIVE MEASURES same as # 20.

35. Navajo sedge (Carex specuicola) (Threatened): Found in San Juan County, Utah, and in 

immediately adjacent Coconino County, Arizona. A member of the sedge family, this 

species is a loosely tufted perennial, 25 to 40 cm tall, with grass-like leaves that droop 

downward. Its flowers, seen in late June and July, are arranged in spikes, two to four 

spikes per stem. Navajo sedge is restricted to seep, spring, and hanging garden habitats in 

Navajo Sandstone, at elevations ranging from 1150 to 1823 meters. The proposed APHIS 

program will not likely adversely affect this species. Direct and indirect effects of 

treatment are the same as # 20. PROTECTIVE MEASURES: No aerial applications 

within 3 miles of occupied habitat and no ground applications within 300 feet of springs, 

seeps and hanging gardens.

36. Pariette cactus (Sclerocactus brevispinus) (Threatened): Found in Duchesne and Uintah 

Counties. A member of the cactus family, this taxon is a Uinta Basin endemic in northeast 

Utah, Duchesne County. It is known from “a series of small scattered populations...near 

Myton (Heil and Porter (1994).” It inhabits “stoney, gravelly, low hilly terrain, growing with 

desert grasses or low vegetation (Hochstätter 1993)”; the soils on which it grows are derived 

from the Uinta Formation (Specht, pers. comm. 2005). The proposed APHIS program will 

not likely adversely affect this species. Direct and indirect effects and PROTECTIVE 

MEASURES same as # 20.

37. San Rafael cactus (Pediocactus despainii) (Endangered): Found in Emery and Wayne 

Counties. A member of the cactus family, this species is a small, subglobose to ovoid 

cactus with usually solitary stems; the crown of the stem is at or very near ground level. 

Its flowers are born near the tip of the stem, are yellow bronze to peach bronze, rarely 

pink in color, and bloom during April and May. San Rafael cactus is found in fine 

textured soils rich in calcium derived from the Carmel Formation and the Sinbad Member 
60

of the Moenkopi Formation. It occurs on benches, hill tops, and gentle slopes in pinyonjuniper and mixed desert shrub-grassland communities, at elevations ranging from 1450 

to 2080 meters. The proposed APHIS program will not likely adversely affect this 

species. Direct and indirect effects and PROTECTIVE MEASURES same as # 20.

38. Shivwitz or Shem milkvetch (Astragalus ampullarioides) (Endangered): Found in 

Washington County. It occurs in only Washington County, Utah. A member of the bean 

family, Shivwits milkvetch is a perennial herb. Specimens are 20 to 45 cm tall, each with 

an underground, branching woody base and an erect flower stalk bearing yellow-white 

flowers that bloom from late April to early June. Shivwits milkvetch grows on the 

unstable clay soil of Chinle Shale in warm desert shrub and pinyon-juniper communities, 

at elevations ranging from 872 to 1116 meters. The proposed APHIS program will not 

likely adversely affect this species. Direct and indirect effects and PROTECTIVE 

MEASURES same as # 20.

39. Shrubby reed-mustard (Schoenocrambe suffrutescens) (Endangered): Found in Duchesne 

and Uintah Counties. A member of the mustard family, this species is a perennial clumpforming herb that produces yellow flowers that bloom from May through June. Shrubby 

reed-mustard grows along semi-barren, white-shale layers of the Green River Formation 

(Evacuation Creek Member), where it is found in xeric, shallow, fine textured soils 

intermixed with shale fragments. It grows in mixed desert shrub and pinyon-juniper 

communities, at elevations ranging from 1554 to 2042 meters. The proposed APHIS 

program will not likely adversely affect this species. Direct and indirect effects and 

PROTECTIVE MEASURES same as # 20.

40. Siler pincushion cactus (Pediocactus sileri) (Threatened): Found in Kane and 

Washington Counties. It is a plant that occurs in adjacent Coconino and Mohave 

counties, Arizona; the center of its distribution is in Mohave County. A member of the 

cactus family, this species is a small, globose cactus with solitary, occasionally clustered, 

stems typically 10 cm tall (as great as 45 cm), and spines that become white with age. Its 

flowers are yellow with purple veins, and bloom during March and April. Siler 

pincushion cactus is found on the white, occasionally red, gypsiferous and calcareous 

sandy or clay soils derived from the various members of the Moenkopi Formation. It is 

sometimes found, however, on the nearly identical Kaibab Formation. Siler pincushion 

cactus occurs on rolling hills, often with a badlands appearance, in warm desert shrub, 

sagebrush-grass, and, at its upper limits, pinyon-juniper communities, at elevations 

ranging from 805 to 1650 meters. The proposed APHIS program will not likely 

adversely affect this species. Direct and indirect effects and PROTECTIVE MEASURES 

same as # 20.

41. Uintah basin hookless cactus (Sclerocactus wetlandicus) (Threatened): Found in Carbon, 

Duchesne and Uintah Counties, Utah and in Delta, Garfield, Mesa, and Montrose 

counties, Colorado. A member of the cactus family, this species is a perennial herb with a 

commonly solitary, egg-shaped, three to twelve cm long stem that produces pink flowers 

late from April to late May. Uinta Basin hookless cactus is found on river benches, valley 

slopes, and rolling hills of the Duchesne River, Green River, and Mancos formations. It is 
61

found in xeric, fine textured soils overlain with cobbles and pebbles, growing in salt 

desert shrub and pinyon-juniper communities, at elevations ranging from 1360 to 2000 

meters. The proposed APHIS program will not likely adversely affect this species. Direct 

and indirect effects and PROTECTIVE MEASURES same as # 20.

42. Ute ladies’-tresses (Spiranthes diluvialis) (Threatened): Found in Daggett, Duchesne, 

Garfield, Juab, Salt Lake, Tooele, Uintah, Utah, Wasatch, Wayne and formerly Weber 

County. It also occurs in the states of Colorado, Idaho, Montana, Nebraska, Nevada, 

Washington, and Wyoming. A member of the orchid family, this species is a perennial 

herb with a flowering stem, 20-50 cm tall that arises from a basal rosette of grass-like 

leaves. The flowers are ivory-colored, arranged in a spike at the top of the stem, and 

bloom mainly from late July through August. Ute ladies'-tresses is found in moist to very 

wet meadows, along streams, in abandoned stream meanders, and near springs, seeps, 

and lake shores. It grows in sandy or loamy soils that are typically mixed with gravels. In 

Utah, it ranges in elevation from 1311 to 2134 meters. The proposed APHIS program 

will not likely adversely affect this species. Direct and indirect effects and 

PROTECTIVE MEASURES same as # 20.

43. Welsh’s milkweed (Asclepias welshii) (Threatened): Found in Kane County, Utah as 

well as in immediately adjacent Coconino County, Arizona. A member of the milkweed 

family, this species is a stout, rhizomatous perennial herb with large oval leaves and 

spherical clusters of flowers that are cream-colored with pink-tinged centers. It blooms 

from June to August. Welsh's milkweed grows on dunes derived from Navajo Sandstone. 

It is found in sagebrush, juniper, and ponderosa pine communities, at elevations ranging 

from 1542 to 1993 meters. The proposed APHIS program will not likely adversely affect 

this species. Direct and indirect effects and PROTECTIVE MEASURES same as # 20.

44. Winkler cactus ( Pediocactus winkleri) (Threatened): Found in Emery and Wayne 

Counties. A member of the cactus family, this species is a small, subglobose cactus with 

solitary or clumped stems; the crown of the stem is at or very near ground level. Its 

flowers are born near the tip of the stem, are peach to pink in color, and bloom late March 

to May. Winkler pincushion cactus is found in fine textured soils derived from the 

Dakota Formation and the Brushy Basin Member of the Morrison Formation. It occurs on 

benches, hill tops, and gentle slopes on barren, open sites in salt desert shrub 

communities, at elevations ranging from 1490 to 2010 meters. The proposed APHIS 

program will not likely adversely affect this species. Direct and indirect effects and 

PROTECTIVE MEASURES same as # 20.

45. Wright fishhook cactus (Sclerocactus wrightiae) (Endangered): Found in Emery, Sevier 

and Wayne Counties. A member of the cactus family, this species is a perennial herb 

with a solitary, hemispheric, ribbed, 6 to 12 cm tall stem that produces nearly-white to 

pink flowers from late April through May. Wright fishhook cactus is found in soils that 

range from clays to sandy silts to fine sands, typically in areas with well developed 

biological soil crusts. Wright fishhook cactus grows in salt desert shrub and widely 

scattered pinyon-juniper communities, at elevations ranging from 1305 to 1963 meters. 
62

The proposed APHIS program will not likely adversely affect this species. Direct and 

indirect effects and PROTECTIVE MEASURES same as # 20.
63

Appendix 4: APHIS response to public comments on the Utah draft EA’s (EA Number: 

UT-20-1, UT-20-2, UT-20-3, UT-20-4, UT-20-5 and UT-20-6).

USDA APHIS received two public responses to the publication of the Draft EA. Public 

comments were received from the Xerces Society and from the Center for Biological Diversity 

Center. Comments similar in nature were grouped under one response. Comments that were 

editorial in nature or requested additional citations are not addressed in the appendix but were 

incorporated into the final EIS, where appropriate. The Grasshopper Program has decided not to 

use chlorantraniliprole in Utah during 2020, any exposure scenarios which the commenters are 

concerned about are not relevant, and all references to this chemical was removed from the final 

EA.

Comment 1 

USDA APHIS received one comment about the EAs providing little in the way of solid 

information about where, how and when the treatments may actually occur within the counties 

covered under the EAs, during the year 2020, which makes it impossible to determine if effects 

would actually be significant or not. 

APHIS described the purpose and need for grasshopper suppression treatments, potential 

treatment options, the affected environment within the state and an analysis of the potential 

environmental consequences in the Draft EAs that were made available for public comment. 

These documents become programmatic because APHIS cannot precisely predict where an 

outbreak will occur each year; we only know that outbreaks will occur, and treatments in a 

timely manner will be absolutely necessary. The emergency response aspect is why site-specific 

treatment details cannot be known, analyzed, and published in advance. APHIS relies on its 

emergency provisions within its NEPA Implementing regulations (7 CFR 372.10) to address 

these situations.

Please be aware that local agreements with Tribal Nations may preclude disclosure of Tribal 

information to the public or outside of APHIS without the consent of the Tribal Administrator. 

Individuals may request information on the specific treatment areas on Tribal Lands from the 

individual Tribal Nations.

Comment 2 

USDA APHIS received one comment concerning the lack of transparency about the location of 

actual treatment areas, particularly on public lands, being a disservice to the public that prevents 

the public from reviewing sufficient information to be able to gauge justification for and the risks 

involved in the suppression effort. 

APHIS did not withhold the location of actual treatment areas while preparing the Draft EA, but 

rather those facts were not known at that time because economically damaging grasshopper 

populations had not become apparent. See previous comment concerning the prevention of the 

commenter’s ability to gauge the justification and risks of treatments within the proposed action 

areas. 

Comment 3
64

APHIS received one comment urging APHIS to provide the public with maps of specific 

treatment areas and proposed treatment strategies (including proposed date of application and 

chemical and rate to be used), immediately after approving any treatment and at least 14 days 

prior to implementation of any treatment. This comment suggested that this specific information 

be posted at the APHIS website as soon as it is available, sent to interested parties, and made 

available for public comment.

In most circumstances, APHIS is not able to accurately predict specific treatment areas 

and treatment strategies months or even weeks before grasshopper populations reach economic 

infestation levels. The need for rapid and effective response when an outbreak occurs limits the 

options available to APHIS to inform the public other than those stakeholders who could be 

directly affected by the actual application. APHIS typically does not have 14 days between 

planning a treatment and the actual application because of the rapid population growth 

and potential damage of grasshopper infestations. 

Comment 4

APHIS received one comment that mentioned “APHIS’ procedure to approve or disapprove 

treatments based on a cost-benefit analysis performed using the “Hopper” model” and that is 

site-specific data are not available or current, APHIS must use protective values as defaults in 

Hopper.”

The “Hopper” model is an older model and southwestern states (including NV) were never 

included in the model.

In Utah, general site specific data, which is used to determine treatments in real time and 

gathered at time of actual surveys and cannot be included in EA, are used to make treatment 

decisions. The general site specific data include: grasshopper and/or Mormon cricket densities, 

species complex, dominant species, dominant life stage, terrain, soil types, range 

conditions, local weather patterns (wind, temp., precipitation), slope and aspect for hatching 

beds, grazing status and number of livestock grazing the site/allotment and forage damage 

estimates. These are all factors taken into consideration during the survey season. 

Comment 5

APHIS received one comment concerning how analysis of projected economic injury levels and 

ultimately, treatment decisions, might be determined in the absence of site-specific data 

(specifically rangeland productivity and composition, precipitation and soil moisture, 

accessibility and cost of alternative forage, effectiveness of treatment, cost of treatment, timing 

of treatment, and grasshopper population density, life stage and species composition).

See comment 4 above. In Utah general site specific data, which is used to determine treatments 

in real time and gathered at time of actual surveys and cannot be included in EA, are used to 

make treatment decisions.

Comment 6

APHIS received one comment related to disclosing its analysis for each of the seven variables 

mentioned in comment 5.
65

The site specific data that is used to determine treatments in real-time is gathered at the time of 

actual surveys. This data is not available at the time that the environmental assessments are 

prepared. See comment 4 for an example of general site specific data used to determine 

treatments.

Comment 7

APHIS received one comment about providing the public with a more precise definition of when 

the threshold for spraying has been met.

Economic thresholds are variable based on the value of protected resources and management 

objectives. Baseline thresholds for Mormon crickets are 2 per sq. yd. and grasshoppers are 

8 per sq. yd., though neither of those thresholds guarantees justification for treatment alone. All 

of the site-specific data mentioned in comment 4 above are also considered for Utah.

Comment 8

APHIS received one comment urging APHIS to delay release of the EAs and the publication of a 

FONSI until after treatment requests are received and all treatment areas have been delineated 

and are identified to the public.

In Utah letters of request were received in mid-March from the BLM districts for the 2020 

treatment season. Treatment areas are delineated during the survey process which begins in late 

March to early April and may continue into late June. The grazing allotments which meet the 

treatment criteria are identified to the requesting land managers, and together, APHIS and the 

land management specialists determine potential forage loss and economic impact of the 

grasshopper infestation, all of which takes place within a matter of days. Treatment decisions 

require prompt action since grasshoppers grow quickly, and they are much more susceptible to 

insecticides during earlier instars. To delay release of the EA’s and FONSI’s until after all 

treatment requests are delineated and received and identified to the public would make it 

impossible to administer timely, effective grasshopper suppression projects.

Comment 9

APHIS received one comment regarding the EAs list four insecticide options (diflubenzuron, 

carbaryl, malathion and chlorantraniliprole) and states that the choice of which to use will be 

site-specific, without being clear about how that choice of insecticide is made.

In Utah diflubenzuron is the preferred insecticide for aerial treatments. Hot spot treatments are 

conducted using ground equipment primarily with carbaryl bait. The insecticides mentioned are 

options which could be used depending up the situation encountered at the time. The 

Grasshopper Program has decided not to use chlorantraniliprole in Utah during 2020.

The letters of request come from the individual land managers. In the case of early 

instars, diflubenzuron, the preferred insecticide, can produce 90 to 97% mortality. If the window 

for the use of diflubenzuron closes, as a result of treatment delays, then the only other option 

would be the use of Carbaryl 2% or 5% bait or malathion. Malathion would only be used in an 

extreme situation where immediate control was required to avoid an economic crisis or an 
66

immediate threat to public safety. There are no plans to use Malathion in Utah. There are 

certain species which are susceptible to carbaryl bait. If the species complex present in the 

outbreak is not susceptible to bait and the diflubenzuron window is closed, then no treatments 

will occur. This is discussed with the requesting land managers. 

The final EA has been updated to reflect the changes in the program.

Comment 10

APHIS received one comment concerning BeeREX calculating the expected environmental 

concentration (EEC) of diflubenzuron in pollen and nectar from foliar overspray as 1.76 mg/kg, 

which is equivalent to 1760 ppb.

Nectar and pollen values in BeeREX are based on residues that would be expected to occur from 

direct pesticide applications to long grass which is a food source EPA estimates in its T-REX 

model. These assumptions may overestimate expected residues of diflubenzuron in pollen and 

nectar. Available data for diflubenzuron pollen residues in crops show a low frequency of 

occurrence and low concentrations. The concentration in pollen will depend on application 

rates and when applications are made relative to flower bloom. Program applications of 

diflubenzuron are at the lower end of labeled use rates for Dimilin due to the sensitivity of 

Orthoptera. In addition, the Program uses rates less than the current labeled rates for 

grasshoppers and other labeled crops and makes only one application.

Comment 11

APHIS received one comment regarding chitin synthesis and its importance in the early life 

stages of insects, as they molt and form a new exoskeleton in various growth stages. The specific 

concern was that aquatic guideline tests, (or terrestrial invertebrate acute tests), which typically 

run for 48 hours, may not capture a molting stage, and thus underrepresent acute toxicity. Single 

doses may cause mortality, if received at a vulnerable time, and consequently, conclusions from 

RQs based on acute toxicity studies for invertebrates may not fully represent actual risk.

APHIS agrees that chitin synthesis is a critical function for terrestrial and aquatic invertebrates.

APHIS, in its risk assessments prepared for each Program insecticide, summarized available 

acute and chronic toxicity data. This would include studies of short duration such as 48 to 96 

hours as well as much longer term studies that would evaluate continuous exposures during 

critical life stages and development.

Comment 12

APHIS received the following comment, “For honey bees (the surrogate species for risk 

assessment in the absence of other data), USEPA (2018) reported a chronic 21-day ED50 and 

NOAEL of 0.012 and <0.0064 μg a.i./larva, respectively. Utilizing these values 

in BeeREX (EPA’s model that calculates risk quotients for bees) and assuming an application 

rate of 0.016 lb ai/ac, BeeREX calculates an acute dietary risk quotient of 18.13 and a chronic 

dietary risk quotient of 33.99. (A threshold value is 1.0). Risk quotients this high above 1.0 

indicate a high concern for exposed bees.

BeeREX is a tier one screening level model used by EPA to assess potential risk to pollinators. 

Estimates of risk quotients are used to determine if there is a presumption of risk that requires 
67

additional evaluation. APHIS also relies on available field data to further characterize the risks 

of Program insecticides to terrestrial and aquatic invertebrates, where available. A limitation 

of BeeREX is it does not account for pesticide degradation that would normally occur in 

Program treatments.

Nectar and pollen values in BeeREX are based on residues that would be expected to occur from 

direct pesticide applications to long grass which is a food source EPA estimates in its T-REX 

model. These assumptions may overestimate expected residues of diflubenzuron in pollen and 

nectar. Available data for diflubenzuron pollen residues in crops with higher use rates show a 

low frequency of occurrence and low concentrations. The concentration in pollen will depend 

on application rates and when applications are made relative to flower blooming.

Diflubenzuron Program applications are at the lower end of labeled use rates for Dimilin due to 

the sensitivity of Orthoptera. In addition, the Program uses rates less than the current labeled 

rates and makes one application.

Comment 13

APHIS received one comment, regarding the EIS discloses that under some 

circumstances, Dimilin may be quite persistent; field dissipation studies in California citrus and 

Oregon apple orchards reported half-live values of 68.2 to 78 days. Rangeland persistence is 

unfortunately not available, but diflubenzuron applied to plants remains adsorbed to leaf surfaces 

for several weeks.

Diflubenzuron persistence varies depending on site conditions. Diflubenzuron degradation is 

microbially mediated with soil aerobic half-lives much less than dissipation half-lives. While 

dissipation half-lives may extend up to 78 days, they have also been shown to be much less under 

other use patterns.

Comment 14

APHIS received the following comment, “APHIS discounted the pollinator risk by claiming that 

studies finding significant effects to pollinators utilized doses far above levels that would be used 

in grasshopper control. Unfortunately, this does not appear to be true for all studies 

cited. Mommaerts et al. (2006) conducted dose-response assays and found that exposure to 

diflubenzuron resulted in reproductive effects in Bombus terrestris, with only the doses at 0.001 

of maximum field recommended concentrations (MFRC) in pollen and 0.0001 in sugar water 

resulting in effects statistically similar to controls. The MFRC for diflubenzuron is listed in the 

study as 288 mg/L (equivalent to 288,000 ppb). At 1/10,000 of this level, diflubenzuron effects 

would be similar to controls only at levels at or below 28.8 ppb while at 1/1000 of this level, 

diflubenzuron “no effect” concentrations would be equivalent to 288 ppb. This analysis thus 

shows the opposite of what APHIS claims – that the effective dose for reproductive effects is 

actually far below the EEC expected for diflubenzuron at RAATS rates used in grasshopper 

suppression. This raises concern that the application of diflubenzuron at the specified RAATS 

rates may cause severe impacts to bee reproduction within treated areas.”

APHIS relied on available laboratory and field collected data for each Program insecticide to 

summarize risks to terrestrial invertebrates. In evaluating studies, APHIS also evaluated likely 
68

routes of exposure for Program treatments. Estimates of exposure using the EPA tier one 

screening model likely overestimate potential residues in pollen and nectar.

Comment 15

APHIS received 2 comments about chlorantraniliprole.

Chlorantraniliprole is not proposed for use in 2020. The final EA has been updated to reflect the 

changes in the program.

Comment 16

APHIS received one comment concerning malathion being found to cause jeopardy in 1,000

endangered species according to recent nationwide Biological Opinions

APHIS recognize that EPA and the Services are continuing to develop updated national level 

consultations. APHIS in Utah currently consults with the US Fish & Wildlife Service at the State 

level for the Grasshopper program to ensure program activities do not adversely affect protected 

species or their critical habitat.

See response to comment 9 for use of Malathion in Utah.

Comment 17

APHIS received one comment regarding the EPA determined that carbaryl is likely to adversely

affect 1,542 species.

The Endangered Species Act section 7 pesticide consultation process between the U.S. Fish and 

Wildlife Service and the National Marine Fisheries Service (the Services, collectively) and the 

EPA specifically concerns FIFRA pesticide registration and reregistration in the United States, 

including all registered uses of a pesticide. The state-level Biological Assessments for APHIS 

invasive species programs are separate from any consultations conducted in association with 

pesticide registration and reregistration process. The Agricultural Improvement Act of 2018 

(Farm Bill) created a partnership between USDA, EPA, the Services, and the Council on 

Environmental Quality to improve the consultation process for pesticide registration and 

reregistration. USDA is committed to working to ensure consultations are conducted in a timely, 

transparent manner and based on the best available science. The Revised Method for National 

Level Listed Species Biological Evaluations of Conventional Pesticides provides a directionally 

improved path to ensuring that pesticides can continue to be used safely for agricultural 

production with minimal impacts to threatened and endangered species.

APHIS provided information about use of carbaryl to EPA for the FIFRA consultation for 

carbaryl. The Grasshopper Program use of carbaryl has in the past comprised substantially less 

than 1% of the percent crop treated (PCT) for rangeland use of carbaryl. This is the case for the 

reasonably foreseeable future. For rangeland, in the EPA BE, the Grasshopper Program’s very 

low usage was rounded up to <1% PCT, which gives an overestimate of rangeland acres treated 

and thus endangered species risk. APHIS use of carbaryl is even smaller compared to all uses of 

carbaryl nationwide. Further, the Grasshopper Program consults directly with the Services to 

ensure program activities do not adversely affect protected species or their critical habitat.
69

Comment 18

APHIS received the following comment: The jeopardy and LAA calls for malathion and carbaryl 

should be included in the EAs and should preclude the use of these chemicals.

APHIS consults directly with the U.S. Fish and Wildlife Service on treatments and methods. The 

U.S. Environmental Protection Agency’s consultation on pesticide registration across all 

nationwide uses of program pesticides does not provide sufficiently detailed analysis or 

conclusions relevant to the Grasshopper Program consultations to comply with the Endangered 

Species Act.

Comment 19

APHIS received one comment that it should take into account the risk to native bees and 

butterflies from these treatments, especially those designated species of greatest conservation 

need. APHIS should constrain its treatments to take into account pollinator conservation needs, 

and improve its monitoring capability to try to understand what non-target effects actually occur 

as a result of the different treatments.

APHIS reduces the risk to native bees and pollinators through monitoring grasshopper and 

Mormon cricket populations and making pesticide applications in a manner that reduces the risk 

to this group of nontarget invertebrates. Monitoring grasshopper and Mormon cricket 

populations allows APHIS to determine if populations require treatment and to make treatments 

in a timely manner reducing pesticide use and emphasizing the use of Program insecticides that 

are not broad spectrum. Historical use of Program insecticides demonstrate that diflubenzuron 

is the preferred insecticide for use. Over 90% of the acreage treated by the Program has been 

with diflubenzuron. Diflubenzuron poses a reduced risk to native bees and pollinators compared 

to liquid carbaryl and malathion applications. In addition APHIS used RAATs to treat 

approximately 99% of the acres historically treated by the Program. APHIS also uses RAATs 

that are typically below the labeled RAAT rates further reducing the amount of insecticide used 

by the program. APHIS also emphasizes the use of carbaryl bait, where applicable, as a means 

to suppress pest populations while protecting native bees and pollinators. These methods 

of applications have been shown to be protective of non-target invertebrates. These studies are 

referenced and summarized in the EIS.

Comment 20

APHIS received the following comment, This EA and the EIS claim that the use of untreated 

swaths will mitigate impacts to natural enemies, bees, and other wildlife. However, the width of 

the skipped swaths is not designated in advance in the EA, and there is no minimum width 

specified.

APHIS assumes that the reduced amount of pesticide that would occur using untreated swaths 

over a given treatment block will result in reduced risk to non-target organisms by reducing 

exposure. The swath width can vary based on site specific conditions, however, the end result is 

reduced pesticide exposure over a treatment area. The EIS cites studies that demonstrate that the 

use of RAATs result in higher non-target invertebrate populations compared to treatment blocks 

that did not use RAATs.
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Comment 21

APHIS received two comments/recommendations about minimum swath widths, “Without 

knowing minimum (rather than maximum) swath widths that will be applied under this EA, it is 

hard to compare results from this study (Lockwood et al. 2000) to the results on non-targets 

expected under RAATS in this EA. 2). APHIS should commit to science-based methodologies to 

assess actual risk from the proposed treatments and institute minimum untreated swath widths 

wide enough to meaningfully minimize exposure to bees and other beneficials.”

Typically, APHIS employs 50% skip swaths when using RAATs. Swath widths and skips are 

determined by the type of plane doing the aerial application, the smallest being 75 feet, but the 

minimum skip swath is typically 100 feet because larger planes are often contracted.

The commenter references the work of Lockwood et al. 2000, this study 

looked at RAAT’s increasing swath widths by in some instances double skipping the untreated 

area. They also used ATV’s in their study which only have a minimum effect swath width of 30 

feet. Using modifications presently being done in Arizona, with the UTV’s ability to adjust 

hopper height, using the same ATV spreader, minimum effective swath width can be increased to 

40 feet. APHIS uses science-based methodologies to assess treatment related benefits or 

risks. APHIS has for decades funded the Science and Technology Research Lab in Phoenix, 

Arizona, which is specific to Rangeland Grasshopper and Mormon Cricket Program research 

and development. It is the only one of its kind in the U.S. The S&T Lab in cooperation with 

Arizona State University researchers have looked at non-target studies in the past and have 

made recommendations to the Program side of APHIS.

Comment 22

APHIS received the following comment, “Although the EIS included a quantitative analysis of 

drift anticipated from ULV aerial applications to estimate deposition into aquatic areas, an 

analysis is not presented or available to back up the assumption that untreated areas (skipped 

swath widths) will act as refugia for natural enemies, bees, and other wildlife.”

The EIS cites studies that demonstrate that the use of RAATs result in higher non-target 

invertebrate populations compared to treatment blocks that did not use RAATs.

Comment 23

APHIS received three comments about the drift analysis described in the EA, 1)“The drift 

analysis described in the EA assumed a droplet spectra size of fine to very fine (median diameter 

= 137.5 μm). However, labels do not require a minimum droplet size for ULV applications over 

rangeland, and other uses of ULV technology for pest control assume much smaller droplet 

sizes. EPA’s (2018) Ecological Risk Assessment for diflubenzuron uses AgDrift to estimate the 

drift fraction from aerial LV applications, although it is unclear whether AgDrift is validated for 

the purposes of predicting deposition of insecticides applied using ULV technology. EPA 

assumed a volume mean diameter (VMD) of 90 μm [note that this is approximately 2/3 of the 

VMD used in the APHIS analysis]. Under EPA’s analysis, the drift fraction comprises 19% at 

150 ft.”, 2) “APHIS should disclose its quantitative analysis and the percent drift it expects--by 

distance-- into untreated swaths for each application method it proposes”, and 3) “APHIS must 

also specify in its operational procedures the use of nozzles that will result in droplet spectra that 

accord with its analysis”.
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The VMD used by APHIS for diflubenzuron is the preferred median diameter used by the 

Program. APHIS recognizes that the range of droplet sizes can vary under a ULV application.

Comment 24

APHIS received a comment that it is “unrealistic that APHIS can comply with mitigation 

measures designed to protect bees on pesticide labels “(e.g., bumble bees fly earlier and later in 

the day, diflubenzuron is toxic to developing forms, if plants are flowering, bees are active, etc.).

APHIS utilizes diflubenzuron at far lower levels than allowed by the label, thereby minimizing 

risks to non-targets, such as bees. There have been several studies on diflubenzuron effects on 

bees, such as Schroeder et al., 1980 and insect growth regulator effects reviewed in Tasei, 2001, 

which support the idea that the diflubenzuron levels APHIS uses for grasshoppers and Mormon 

crickets are a minimal risk to bees. APHIS also complies with any label requirements designed 

to minimize impacts to pollinators.

Comment 25

APHIS received the following comment, “Except for untreated swath widths, the EA is silent on 

how it will avoid impact to pollinators. It has already been shown that within sprayed areas, risk 

quotients at expected application rates would be well above 1.0. Leaving skipped widths is also 

not a full solution at expected widths since, due to drift, untreated swaths are highly likely to be 

exposed to levels above risk quotients”.

As previously stated, APHIS utilizes diflubenzuron at far lower levels than allowed by the label, 

thereby minimizing risks to non-targets. Additionally, APHIS commonly incorporates untreated 

swaths into its treatment programs, which have consistently demonstrated reduced impacts on 

non-target arthropods (Lockwood et al., 1999, 2001; Norelius and Lockwood, 1999).

Comment 26

APHIS received one comment regarding that APHIS must not ignore requirements listed on 

pesticide labels, nor make assumptions about its compliance with these when RAATS measures 

that will actually be taken are vague and unspecified.

APHIS complies with all applicable Federal and State pesticide label language when making 

pesticide treatments.

Comment 27

APHIS received the following comment: “While flexibility with these may have been 

appropriate at the EIS stage, it is not appropriate at the EA stage. APHIS must fully disclose its 

RAATS plan for each treatment in the EA, including specifying application method, chemical to 

be used, rate, and width of untreated swaths.”

RAATs are a dynamic treatment method based on size of the treatment area, species complex and 

density of target species. Specific details regarding RAATs cannot be determined until sitespecific data is collected during the 2020 survey season and an appropriate chemical is 

identified. Once a treatment is determined necessary, application method, untreated swath 

widths, chemical choice and application rate are included in the bid for contracting.
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Comment 28

APHIS received one comment about to be consistent with the Pollinator-Friendly BMPs for 

Federal Lands (see Comment 7), APHIS must go beyond the general statements on the pesticide 

labels and specify more exactly how its spray plan will further reduce exposure and risk to bees.

See comments 24 and 25

Comment 29

APHIS received one comment, “For listed and proposed species under the purview of the US 

Fish and Wildlife Service, the EAs lists "Species for Federal listing state-listed species, and/or 

other sensitive species identified by or federal agencies within the area." 

Appendix 3 in each EA lists all the T&E and proposed T&E species in Utah, including the 

mitigation measures that APHIS will employ during suppression projects to insure that said 

species will not be adversely impacted . The information in this table is pulled from iPAC, a 

USFWS resource that is used as a planning tool to identify potential species that could occur in 

a given area. The Utah state office of the USFWS has worked with APHIS for 30 years to 

develop and maintain that list with its accompanying mitigation measures. 

Comment 30

APHIS received one comment, “The USFWS letter of concurrence is not included in the EA, 

and it is unclear if the letter of concurrence provided any mitigatons for the use of 

chlorantraniliprole or if the letter of concurrence adopted the mitigations for listed species 

provided in Appendix 3.”

These are documents used for interagency consultation between the Services and APHIS, as 

mandated by Section 7(a)(1) of the Endangered Species Act (ESA). There is no requirement 

under ESA or NEPA that requires consultation documents to be made available to the public for 

comment or review. The EA includes a section that discusses APHIS compliance with the ESA.

In Utah Chlorantraniliprole is not proposed for use in 2020. The final EA has been updated to 

reflect the changes in the program.

Comment 31

APHIS received one comment, “Table 2 is described in the document as a list containing “the 

mitigations to be followed by APHIS when conducting a suppression program to control 

grasshoppers with insecticides other than diflubenzuron.” Yet chlorantraniliprole consultation is 

not complete, so Table 2 does not actually cover uses of chlorantraniliprole or the use of any 

chemical "other than diflubenzuron." APHIS needs to be more precise in the way it presents and 

characterizes the mitigations that are prescribed and for which species and which chemicals.”

Chlorantraniliprole is a viable chemical choice options for the APHIS grasshopper program, 

therefore it is included in the EA. Utah will not be using Chlorantraniliprole for the 2020 

treatment season. USFWS is aware of the new chemical addition and it will be included in 

future consultations.
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Comment 32

APHIS received one comment “In addition, the general operational guidelines make no mention 

of the enhanced buffers required by NMFS, or the buffers or other specific requirements from 

USFWS imposed to protect listed, proposed, or candidate species.”

In Utah the general operational guidelines are provided in the EA’s to address protective 

measures for bodies of water. The additional buffers for T&E species are addressed in Appendix 

3 of each EA.

Comment 33

APHIS received one comment: “It appears that no consultation was completed for the use 

of chlorantraniliprole. APHIS must not utilize active ingredients for which consultation is 

incomplete.”

Chlorantraniliprole is not proposed for use in 2020. The final EA has been updated to reflect the 

changes in the program.

Comment 34

APHIS received two comments concerning operationally, how will listed species’ protected 

locations be identified for ground and aerial applicators? How will such locations, buffer widths 

listed in the protective measures, and any specific instructions (i.e. use of carbaryl bait only) for 

some species be mapped and communicated to applicators? APHIS must provide to applicators 

a set of clear set of directions outlining protective measures for the listed and proposed species 

found within this project area and not burden applicators with a confusing set of directions split 

between multiple tables.

 

APHIS, prior to any suppression project, consults with the biologists of the land-managing 

agency requesting treatment in order to identify any species of concern. Pilots are required to 

have GPS equipment capable of reading shapefiles which would include agreed-upon buffers for 

any T&E species or other sensitive sites. Conversations prior to treatment would identify and 

make applicators aware of any T&E species, sensitive sites, buffers and species of conservation 

concern that warrant extra protection. 

See additional information in comments 29 and 32.

Comment 35

APHIS received one comment about pesticide specific conservation measures for each listed 

species, where appropriate, should be explicitly addressed and adopted.

Agreed upon mitigation measures address specific chemicals when conservation measures are 

warranted.

Comment 36

APHIS received one comment that APHIS should adopt the following operational guideline 

across all site-specific EAs: “Use Global Positioning System (GPS) coordinates for pilot 

guidance on the parameters of the spray block. Ground flagging or markers should accompany 
74

GPS coordinates in delineating the project area as well as areas to omit from treatment (e.g., 

boundaries and buffers for bodies of water, habitats of protected species, etc.).”

Specific pilot guidance capabilities are outlined in the contract and statement of work. Within 

the contract put out for bid to the applicators, GPS with data-logging software requirements are 

the minimal standard for applicators to have prior to treatments. The pilot must be able to view 

shapefiles in the plane during the treatment to navigate the spray block. All sensitive sites are 

reviewed in the daily briefing with APHIS personnel who may be an applicator working on the 

treatment in a TDY capacity.

Comment 37

APHIS received one comment that, “APHIS states that it has no legal obligation to manage for 

vulnerable species not on the Endangered Species List. The essential role that pollinators play in 

the conservation of listed plant species is not addressed in the EAs and makes no mention of the 

fact that there are affirmative obligations incumbent on federal agencies with regard to protection 

of pollinators, regardless of whether they are federally listed including the 2014 Presidential 

Memorandum, the National Strategy to Promote the Health or Honey Bees and Other 

Pollinators, the Pollinator Friendly BMPs for Federal Land, and the Pollinator Research Action 

Item.”

APHIS considers the role of pollinators in any consultations conducted with the FWS to protect 

federally-listed plants. Mitigation measures, such as no-treatment buffers are applied with 

consideration of the protection of pollinators that are important to a particular listed plant 

species.

APHIS also implements several BMP practices in their treatment strategies that are designed to 

protect non-target invertebrates, including pollinators. APHIS minimizes insecticide 

use by using lower than labeled rates for all Program insecticides, alternating swaths during 

treatment, making only one application per season and minimizing use of liquid broad spectrum 

insecticides. APHIS also continues to evaluate new monitoring and control methods designed to 

increase the response to economically damaging populations of grasshoppers and Mormon 

crickets while protecting rangeland resources such as pollinators.

Comment 38

APHIS received one comment, “The EAs disclose species listed as sensitive but does not list 

Species of Conservation Concern, or whether the state of Utah designates any invertebrates as 

Species of Greatest Conservation Need.”

Species of Conservation Concern are discussed during site-specific consultation between APHIS 

personnel, Utah Department of Agriculture & Food, Utah Division of Wildlife Resources, 

USFWS and the land manager. Any species of conservation concern will have agreed upon 

mitigation measures in place before treatment will begin. 

Comment 39

APHIS received one comment regarding, the EAs, protections for at risk species, including the 

monarch butterfly which is currently being assessed for listing under the Endangered Species 

Act, are practically non-existent.
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Under FWS Section 7 Act there is no requirement to consult on sensitive species. However, in 

Utah when there is concern by land management agencies (federal, state, etc.)for certain 

species, APHIS implements protective measures for those species of concern when warranted.

Comment 40

APHIS received one comment, “In the face of declining pollinator populations and the existence 

of federal directives for agencies to support and conserve pollinators and their habitat, APHIS 

must not conduct business as usual. APHIS should identify the at-risk pollinator species 

potentially present in the geographic area of the EAs and map their ranges prior to approving any 

treatment requests. Prior to treatment, APHIS should survey for presence of host plants and 

ensure that it has identified specific, actionable measures it will take to protect monarch habitat 

and the habitat of at-risk butterfly species from contamination that may occur as a result of 

exposure to treatment, such as designating a 125-ft buffer around identified habitat. Some ways 

to enact protections for at-risk species above and beyond those included in the EAs include:

● Survey for butterfly host plants and avoid any applications to host plants.

● Time pesticide applications to avoid exposure to at risk species.

● Do not apply pesticides (especially insecticides) when monarchs (adult and immature) are 

present or expected to be present.

● Avoid aerial applications.

● Avoid using malathion and liquid carbaryl.

● Include large buffers around all water sources, including intermittent and ephemeral streams, 

wetlands, and permanent streams and rivers, as well as threatened and endangered species 

habitat, honey bee hives, and any human-inhabited area. For example, Tepedino (2000) 

recommends a three-mile buffer around rare plant populations, as many of these are pollinated 

by solitary bees that are susceptible to grasshopper control chemicals.”

APHIS includes many of the proposed measures to minimize risks to non-target organisms and 

human health. These are summarized in the recent EIS. For example no-treatment buffers are 

applied to all water bodies and to areas where the public potentially may be exposed to Program 

applications. APHIS also minimizes aerial insecticide use where possible; however, site 

conditions may dictate the need for aerial treatments. APHIS minimizes the use of liquid 

carbaryl and malathion which is reflected in the historical use for both insecticides. 

Diflubenzuron has long been the preferred insecticide for making Program suppression 

treatments. In addition APHIS has incorporated the use of RAATS into the Program as a means 

to reduce insecticide use, hence, providing reduced risk while meeting the goal of orthopteran 

suppression. APHIS continues to research and develop new techniques for management of 

grasshopper and Mormon cricket populations.

Comment 41

APHIS received the following comment, “While the mitigations that are identified for aquatic 

habitats in the EAs are heartening, APHIS should include monitoring for the presence and health 

of mussels in streams that traverse or are adjacent to treatment areas as part of its monitoring 

strategy.”

APHIS agrees that freshwater mussels should be protected, as well as other aquatic organisms, 

and uses ground and aerial application no-treatment buffers adjacent to all aquatic habitats. In 

addition APHIS uses reduced rates of Program insecticides compared to current labeled rates. 
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These mitigation measures are beyond label requirements for protection of aquatic habitats. The 

intent of these buffers is to reduce off-site drift and runoff of Program insecticides into aquatic 

habitats.

APHIS conducts environmental monitoring related to Program treatments. Monitoring is 

typically done adjacent to any sensitive habitats, including aquatic habitats, to determine 

pesticide residues. These data can be used to determine risk to non-target organisms based on 

available toxicity data.

Comment 42

APHIS received three comments about stock tanks, 1. “The EAs do not discuss water bodies of 

anthropogenic origin, such as stock tanks or stock ponds, “APHIS should recognize the potential 

for stock pond/tanks to contribute significantly to the diversity of aquatic invertebrates in 

rangelands”, and 3. APHIS should identify and map all stock tanks/ponds and specify a buffer 

around stock ponds/tanks from chemical treatment at least equivalent to that specified for 

wetlands, in order to protect aquatic diversity.”

All bodies of water are buffered according to the APHIS Guidelines in Appendix 1 of Draft EA. 

Stock tanks, stock ponds and other anthropogenic sources of water are buffered in the same 

manner as any other natural source of water in or around the treatment area. All anthropogenic 

sources of water, if they cannot be drained, covered or removed will be buffered in concurrence 

with our standard water buffer mitigations. Any sensitive species or species of conservation 

concern would be addressed with the land manager and mitigation measures agreed upon prior 

to treatment.

Comment 43

APHIS received one comment, “APHIS’ reactive strategy includes no mention of what is most 

sorely needed: cooperation and planning with land managers to take appropriate steps to prevent 

the types of grasshopper and cricket outbreaks that are now dealt with by chemical controls.”

APHIS is not a land management agency, but encourages IPM through past and current 

research and will continue to do so. 

APHIS supports the use of IPM in the management of grasshoppers and Mormon crickets. 

APHIS provides technical assistance to Federal, Tribal, State and private land managers 

including the use of IPM. However, implementation of on-the-ground IPM activities is limited to 

land management agencies and Tribes, as well as private land owners. In addition, APHIS’ 

authority under the Plant Protection Act is to treat Federal, State and private lands for 

grasshoppers and Mormon cricket populations. APHIS’ technical assistance occurs under each 

of the three alternatives proposed in the EIS. 

In addition to providing technical assistance, APHIS completed the Grasshopper Integrated Pest 

Management (GIPM) project, which is discussed in more detail on page 21 of this EIS. One of 

the goals of the GIPM is to develop new methods of suppressing grasshopper and Mormon 

cricket populations that will reduce non-target effects. RAATs are one of the methods that has 

been developed to reduce the amount of pesticide used in suppression activities, and is a 
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component of IPM. APHIS continues to evaluate new suppression tools and methods for 

grasshopper and Mormon cricket populations, including biological control, and as stated in the 

EIS, will implement those methods once proven effective and approved for use in the United 

States.

Comment 44

APHIS received one comment: “Emphasizing cultural techniques through appropriate grazing 

management could help to minimize pesticide application and allow natural enemies to regulate 

grasshopper and Mormon cricket populations to the greatest extent possible. While more 

research is needed to develop species- and region-specific management treatments that use 

alternatives to pesticides (Vermeire et al. 2004), there is likely enough data to employ cultural 

techniques now.”

APHIS supports the use of IPM in the management of grasshoppers and Mormon Crickets. 

APHIS provides technical assistance to Federal, Tribal, State and private land managers 

including the use of IPM, including cultural techniques. However, implementation of on-theground IPM activities is limited to land management agencies and Tribes, as well as private land 

owners. In addition, APHIS’ authority under the Plant Protection Act is to treat Federal, State 

and private lands for grasshoppers and Mormon cricket populations.

Comment 45

APHIS received one comment that, “APHIS must elevate the expectation of preventative 

approaches in its cooperative agreements with other land management agencies. APHIS can 

collaborate with agencies (such as the Natural Resource Conservation Service (NRCS), the Farm 

Service Agency (FSA), and State Extension program) to facilitate discussion and disseminate 

information to ranchers about preventative measures that can be taken and alternatives to 

pesticide use.”

APHIS supports the use of IPM in the management of grasshoppers and Mormon Crickets. 

APHIS provides technical assistance to Federal, Tribal, State and private land managers 

including the use of IPM, including cultural techniques. However, implementation of on-theground IPM activities is limited to land management agencies and Tribes, as well as private land 

owners. In addition, APHIS’ authority under the Plant Protection Act is to treat Federal, State 

and private lands for grasshoppers and Mormon cricket populations.

APHIS has maintained cooperative relationships with state and federal land managers as well as 

private landowners and Indian tribes for decades. Those relationships have allowed APHIS to 

provide consistent and continual recommendations on land management practices which might 

help mitigate orthopteran infestations.

Disseminating information to ranchers, private landowners, state extension programs and other 

government agencies is one of the objectives of APHIS in Utah, and holding public meetings with 

cooperators has been one of the most effective ways to do so. Public meetings have been held in 

Utah every year for over 30 years. Meetings were held in June 2019 in Uintah, Daggett, Millard 

and Sevier relative to potential grasshopper treatments in 2020. Numerous other county officials 

were contacted as were federal, state, tribal and private individuals.
78

Comment 46

APHIS received one comment that, “APHIS and/or collaborating agencies should investigate and 

implement opportunities to incentivize healthy range management practices.”

As part of its ongoing IPM strategy to manage grasshoppers and Mormon cricket outbreaks, 

APHIS collaborates with scientists and land managers focused on rangeland health.

Comment 47

APHIS received one comment that, “APHIS and its partners should be approaching the problem 

by keeping a focus on the potential to reduce grasshopper carrying capacity by making the 

rangeland environment less hospitable for the pests. APHIS must not take a limited view of its

role and responsibilities, and should utilize any available mechanism to require land management 

agencies to diminish the severity, frequency and duration of grasshopper outbreaks by utilizing 

cultural management actions. Memoranda of Understanding (MOUs) should be examined and 

updated to ensure that land management agencies are accountable in utilizing cultural techniques 

to diminish the carrying capacity of pest species.

APHIS supports the use of IPM in the management of grasshoppers and Mormon Crickets. 

APHIS provides technical assistance to Federal, Tribal, State and private land managers 

including the use of IPM. However, implementation of on-the-ground IPM activities is limited to 

land management agencies and Tribes, as well as private land owners. In addition, APHIS’ 

authority under the Plant Protection Act is to treat Federal, State and private lands for 

grasshoppers and Mormon cricket infestations.

Comment 48

APHIS received a comment, “Longer-term strategic thinking should include:

• Prevent conditions that allow pest populations to survive and reproduce.

• Employ diverse management techniques (e.g., biological, physical, and cultural).

• Select pesticides to minimize risks to nontarget organisms.

• Implement frequent and intense monitoring to identify populations that can be controlled 

with small ground-based pesticide application equipment.

• Monitor sites before and after application of any insecticide to determine the efficacy of 

the pest management technique as well as if there is an impact on water quality or nontarget species.”

APHIS currently monitors for grasshopper and Mormon cricket populations. These measures 

are employed to allow APHIS to respond with treatment, where warranted, treating the smallest 

area possible and if practical using ground-based equipment. APHIS, due to its monitoring 

efforts, has been able to rely on diflubenzuron as the primary insecticide used in the Program. 

Diflubenzuron is a more selective insecticide compared to carbaryl and malathion posing less 

risk to non-target organisms. APHIS also uses environmental monitoring to assess application 

success and to determine if Program insecticides are reaching sensitive areas, including aquatic 

habitats. APHIS supports the use of IPM in the management of grasshoppers and Mormon 

Crickets. APHIS provides technical assistance to Federal, Tribal, State and private land 

managers including the use of IPM. However, implementation of on-the-ground IPM activities is 

limited to land management agencies and Tribes, as well as private land owners. In addition, 
79

APHIS’ authority under the Plant Protection Act is to treat Federal, State and private lands for 

grasshoppers and Mormon cricket populations. APHIS continues to research and develop new 

methods for assessing and controlling grasshopper and Mormon cricket populations that can be 

incorporated into IPM practices. 

Comment 49

APHIS received one comment that, “The EAs do not make mention of any specific protections to 

be accorded to special status lands such as Wilderness areas, Wilderness study areas, Research 

Natural Areas, National Wildlife Refuges, and designated or proposed Areas of Critical 

Environmental Concern. These special status areas have been designated for specific purposes 

and generally discourage human intervention with the natural ecosystem. Grasshopper 

suppression should not be undertaken in such areas.”

APHIS does not make treatments on lands of special status without a request from that agency 

and an evaluation of whether the projects are necessary. Additional protection measures for 

these types of lands are established by the agency requesting treatment and are followed by 

APHIS.

Comment 50

APHIS received the following comment regarding, “We appreciate that public notice of this sitespecific EA and its comment period was posted at the APHIS website. It does not appear to have 

been the practice to post the Draft EAs in the last several years, but limiting public notice is 

contrary to the spirit of the NEPA process. Grasshopper suppression efforts are of more than 

local concern and as federal actions, should be noticed properly, i.e. beyond local stakeholder 

audiences, local newspapers, etc. We recommend that, in the future, notice of open public 

comment periods for all site-specific EAs for grasshopper suppression be posted in the Federal 

Register, and documents made available for review at regulations.gov and at the APHIS 

grasshopper website.”

Public involvement under the CEQ Regulations for Implementing the Procedural Provisions of 

NEPA distinguishes federal actions with effects of national concern from those with effects 

primarily of local concern (40 CFR 1506.6). Our EIS process for the GHMC program was 

published in the Federal Register (APHIS-2016-0045), and met all applicable notice and 

comment requirements for a federal action with effects of national concern. This process 

provided individuals and national groups the ability to participate in the development of 

alternatives and provide comment. Our subsequent state-based actions have the potential for 

effects of local concern, and we publish them according to the provisions that apply to federal 

actions with effects primarily of local concern. This includes the USDA APHIS NEPA 

Implementation Procedures, which allows for EAs and FONSIs, where the effects of an action 

are primarily of regional or local concern, to normally provide publication in a local or area 

newspaper of general circulation (7 CFR 372.7(b)(3)). Notification of all 6 EA’s was published 

on March 15, 2020 in the Salt Lake Tribune and Deseret News, which are the largest 

newspapers in Utah and both having statewide distribution. These publications provide 

potentially locally-affected individuals an additional opportunity to provide input into the 

decision-making process. Utah also provides additional opportunities for local public 

involvement, such as public meetings.
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Comment 51

APHIS received the following comments, “The Draft Environmental Assessments Frustrate 

Public Participation.” “APHIS frustrated public participation by failing to inform interested 

parties of the existence of the EAs.”

“Scoping” is the process APHIS uses through which the agency and the public identify 

alternatives and issues to be considered during the development of a grasshopper or Mormon 

cricket suppression program. Scoping was helpful in the preparation of the draft Environmental 

Assessments (EAs). The process can occur formally and informally through meetings, 

conversations, or written comments from individuals and groups.

Prior to the treatment season, APHIS conducted meetings or provided guidance for public 

participation in the decision making process. In addition, APHIS notified Federal, State and 

Tribal land managers and private landowners of the potential for grasshopper and Mormon 

cricket outbreaks on their lands. 

Request for Treatment Letters for the 2020 treatment season were received in mid-March. Public 

meetings were held in multiple affected areas (Fillmore, Richfield, Roosevelt and Vernal) in June 

2019 to discuss Draft EA and local concerns. Notice of public comment was published in local 

newspapers which have statewide distribution (Deseret News and Salt Lake Tribune) on March

15, 2020 and distributed to various state and county stakeholders for distribution to other 

interested parties. The comment period opened March 15th, 2020 and expired April 16th, 2020. A 

report of grasshopper “survey season and a treatments conducted” annual report is provided to 

Land Managers and/or stakeholders on an annual basis.

Comment 52

APHIS received the following comment, “APHIS did not providing information for the 

submission of public comments including where and when to submit comments by.”

APHIS works to inform all interested parties about draft EA’s for comment. When an interested 

party asks to be informed, APHIS ensures contact information is added to the list of interested 

stakeholders. Each local office works to inform interested parties of the availability of an EA for 

comment. Any omission of an interested party is not intentional.

A notice of public comment was sent to all parties who expressed interest in the past or at public 

meetings in addition to the local newspapers, tribal nations, and state, county and extension 

cooperators. A letter of notice clearly defining the 30 day comment period and the contact 

information of local APHIS personnel responsible for drafting the state EAs was also sent out to 

the respective parties. Notice of public comment was published in local newspapers which have 

statewide distribution (Deseret News and Salt Lake Tribune) on March 15, 2020 and distributed 

to various state and county stakeholders for distribution to other interested parties. The comment 

period opened March 15th, 2020 and expired April 16th, 2020 

Comment 53
81

APHIS received the following comments, “APHIS limited public notice to local papers.” “This 

local notice is insufficient as it excludes countless other interested parties.”

Public involvement under the CEQ Regulations for Implementing the Procedural Provisions of 

NEPA distinguishes federal actions with effects of national concern from those with effects 

primarily of local concern (40 CFR 1506.6). Our EIS process for the GMC program was 

published in the Federal Register (APHIS-2016-0045), and met all applicable notice and 

comment requirements for a federal action with effects of national concern. This process 

provided individuals and national groups the ability to participate in the development of 

alternatives and provide comment. Our subsequent state-based actions have the potential for 

effects of local concern, and we publish them according to the provisions that apply to federal 

actions with effects primarily of local concern. This includes the USDA APHIS NEPA 

Implementation Procedures, which allows for EAs and FONSIs where the effects of an action are 

primarily of regional or local concern to normally provide publication in a local or area 

newspaper of general circulation (7 CFR 372.7(b)(3)). These publications provide potentially 

locally-affected individuals an additional opportunity to provide input into the decision-making 

process. Some states also provide additional opportunities for local public involvement, such as 

public meetings.

A notice of public comment was sent to all parties who expressed interest in the past or at public 

meetings in addition to the local newspapers, tribal nations, and state, county and extension 

cooperators. A letter of notice clearly defining the 30 day comment period and the contact 

information of local APHIS personnel responsible for drafting the state EAs was also sent out to 

the respective parties. Notice of public comment was published in local newspapers which have 

statewide distribution (Deseret News and Salt Lake Tribune) on March 15, 2020 and distributed 

to various state and county stakeholders for distribution to other interested parties. The comment 

period opened March 15th, 2020 and expired April 16th, 2020

Comment 54

APHIS received the following comments, “APHIS provided a short public comment period 

during this COVID-19 pandemic.” “The 30 day comment deadline for the Draft EAs is wholly 

inappropriate during the current COVID-19 pandemic, where both staff and members of the 

concerned public have limited capacity, given the challenges associated with a global pandemic 

including but not limited to increased childcare demands, illness, etc.”

The comment period was in accordance with CEQ regulations, 40 C.F.R. § 1501.4(e)(2), In 

determining whether to prepare an environmental impact statement the Federal agency shall: (e) 

Prepare a finding of no significant impact, if the agency determines on the basis of the 

environmental assessment not to prepare a statement. (2) In certain limited circumstances, which 

the agency may cover in its procedures under § 1507.3, the agency shall make the finding of no 

significant impact available for public review (including State and areawide clearinghouses) for 

30 days before the agency makes its final determination whether to prepare an environmental 

impact statement and before the action may begin. CEQ guidance also notes: When preparing 

an EA, the agency has discretion as to the level of public involvement. The CEQ regulations state 

that the agency shall involve environmental agencies, applicants, and the public, to the extent 

practicable, in preparing EAs. Sometimes agencies will choose to mirror the scoping and public 
82

comment periods that are found in the EIS process. In other situations, agencies make the EA 

and a draft FONSI available to interested members of the public. APHIS would have considered 

extending the comment period if there had been a reason to believe that additional substantive 

issues remained, or that the pandemic itself created new issues.

Comment 55

APHIS received the following comment, “the proposal in question is controversial and deals 

with issues of significant public interest.”

The USDA became involved in grasshopper control on Federal rangeland in the 1930s. During 

that decade, grasshopper infestations covered millions of acres in 17 Western States. 

Unsuccessful efforts to control grasshopper outbreaks on a local basis proved that grasshoppers 

needed to be dealt with on a broader basis. In 1934, Congress charged USDA with controlling 

grasshopper infestations on Federal rangeland. Thereafter, USDA was the lead agency in 

cooperative efforts among Federal agencies, State agriculture agencies and private ranchers to 

control grasshopper outbreaks. 

APHIS is not aware of any controversy in the program. Every year APHIS works with local 

stakeholders to gather information and discuss the grasshopper program. The grasshopper 

program requires a written request to treat on any land and discussions with the land owner or 

manager determine the course of the final action. APHIS acts in partnership with stakeholders 

through agreements and Memorandum of Understanding on all activities in the program.

APHIS operates under an act of Congress and is mandated to provide support to communities 

affected by grasshopper and Mormon cricket outbreaks as funding is available. The 

grasshopper program in UT has not raised concerns about pesticide use but rather concerns 

about NOT suppressing damaging infestations of grasshoppers that significantly reduce range 

forage for wildlife and livestock. In every public meeting that has been convened in Utah where 

private landowners have attended, individuals have expressed the concern and need for pesticide 

applications to suppress grasshopper or Mormon cricket infestation numbers. APHIS’ failure to 

act in a timely manner threatens the livelihood of farmers, ranchers and wildlife managers who 

depend upon the land for subsistence.

Comment 56

APHIS received the following comment, “The Draft EAs also limit public participation by 

failing to provide contact information for the submission of written or electronic comments.”

The local offices send out public notice to a list of stakeholders that they have collected over the 

years and also announced the open comment period in the local media. Those notices have the 

link for the EA’s for comment and the point of contact. In an attempt to be more transparent 

APHIS has placed Program EA’s on the website for people to access. When an interested party 

asks to be informed, APHIS ensures their contact information is added to the list of interested 

stakeholders. Each local office works to inform interested parties of the availability of an EA for 

comment. Any omission of an interested party is not intentional. 

Comment 57
83

APHIS received the following comment, “Nowhere on the webpage for the Draft Environmental 

Assessment Rangeland Grasshopper and Mormon Cricket Suppression Program is there any 

information on where to submit comments.”

The local offices send out public notice to a list of stakeholders that they have collected over the 

years and they also announced the open comment period in the local media. Those notices have 

the link for the EA’s for comment and the point of contact. In an attempt to be more transparent, 

APHIS has placed Program EA’s on to the website for people to access. When an interested 

party asks to be informed, APHIS ensures there contact information is added to the list of 

interested stakeholders. Each local office works to inform interested parties of the availability of 

an EA for comment. Any omission of an interested party is not intentional. 

Comment 58

APHIS received the following comment, “Staff for USDA-APHIS that have been involved with 

the environmental review for this program were unable to readily provide information for the 

submission of public comment.”

The local offices send out public notice to a list of stakeholders that they have collected over the 

years and they also announce the open comment period in the local media. Those notices have 

the link for the EA’s for comment and the point of contact. In an attempt to be more transparent, 

we have put all of our EA’s on to the website for people to access. When an interested party asks 

to be informed APHIS ensures there contact information is added to the list of interested 

stakeholders. Each local office works to inform interested parties of the availability of an EA for 

comment. Any omission of an interested party is not intentional. Contact information for Utah’s 

EA’s is on the cover page of the Draft EA’s. Also included with the distribution of the EA’s was 

a letter of notice clearly detailing the 30 day comment period extending from March 15th through 

April 16th. 

APHIS is not aware of the direct personnel communication cited by the commenter. APHIS 

personnel are engaged in a wide variety of activities to protect American agriculture and not 

every staff member is completely informed about the details of the Grasshopper Program NEPA 

compliance procedures. 

Comment 59

APHIS received the following comment, “there is no information on when the comment period 

opened or closed on the EAs provided on the webpage.”

The local offices send out public notice to a list of stakeholders that they have collected over the 

years and they also announce the open comment period in the local media. Those notices have 

the link for the EA’s for comment and the point of contact. In an attempt to be more transparent, 

we have put all of our EA’s on to the website for people to access. When an interested party asks 

to be informed, APHIS ensures there contact information is added to the list of interested 

stakeholders. Each local office works to inform interested parties of the availability of an EA for 

comment. Any omission of an interested party is not intentional.
84

Contact information for the Utah state office is on the cover page of the Draft EA. Included with 

the distribution of the EAs was a notice of public comment clearly stating the website and 

address for EA documents, where to send comments and the closing date of April 16th, 2020.

Comment 60

APHIS received the following comment, “APHIS has failed to comport with NEPA’s threshold 

requirements.”

APHIS did not fail to perform NEPA’s threshold requirements for public outreach and 

engagement, but rather exceeded them. See previous comments concerning how APHIS informed 

interested parties of the availability of EAs for public comment, including public meetings, where 

to send comments and the closing date for the comment period.

Comment 61

APHIS received the following comment, “The Draft EAs further limit public participation by 

failing to post notices in the Federal Register or on regulations.gov, unlike earlier versions of the 

environmental review.”

APHIS further involves the public in the scoping process by the publication of notices of 

availability for EAs and a Findings of No Significant Impact (FONSIs). When an individual State 

level EA is written, a notice is published in the legal section of the local newspaper, advertising 

the availability of the EA during an open comment period. The notices published in local 

newspapers was conducted in accordance with APHIS’ NEPA Implementation Procedures, 

372.7 (b)(3), Notification of the availability of environmental assessments and findings of no 

significant impact for proposed activities will be published in the FEDERAL REGISTER, unless 

it is determined that the effects of the action are primarily of regional or local concern. Where 

the effects of the action are primarily of regional or local concern, notice will normally be 

provided through publication in a local or area newspaper of general circulation and/or the 

procedures implementing Executive Order 12372, “Intergovernmental Review of Federal 

Programs.”

Public involvement under the CEQ Regulations for Implementing the Procedural Provisions of 

NEPA distinguishes federal actions with effects of national concern from those with effects 

primarily of local concern (40 CFR 1506.6). Our EIS process for the GMC program was 

published in the Federal Register (APHIS-2016-0045), and met all applicable notice and 

comment requirements for a federal action with effects of national concern. This process 

provided individuals and national groups the ability to participate in the development of 

alternatives and provide comment. Our subsequent state-based actions have the potential for 

effects of local concern, and we publish them according to the provisions that apply to federal 

actions with effects primarily of local concern. This includes the USDA APHIS NEPA 

Implementation Procedures, which allows for EAs and FONSIs where the effects of an action are 

primarily of regional or local concern to normally provide publication in a local or area 

newspaper of general circulation (7 CFR 372.7(b)(3)). These publications provide potentially 

locally-affected individuals an additional opportunity to provide input into the decision-making 
85

process. Some states also provide additional opportunities for local public involvement, such as 

public meetings.

In Utah, Draft EA’s are emailed upon request from the public, stakeholders, etc. There have 

been no comments on Draft EA’s in recent history in Utah.

Comment 62

APHIS received the following comment, “[The Center for Biological Diversity] have been 

informed that there was notice in local newspapers. This local notice is insufficient as it excludes 

countless other interested parties.”

See previous response

Comment 63

APHIS received the following comment, “APHIS has failed to meet NEPAs requirements for 

public involvement in these EAs.”

APHIS also notes CEQ guidance for public involvement in the NEPA process of agencies, “A 

Citizen’s 12 Guide to the NEPA” states: “When preparing an EA, the agency has discretion as 

to the level of public involvement. The CEQ regulations state that the agency shall involve 

environmental agencies, applicants, and the public, to the extent practicable, in preparing EAs. 

Sometimes agencies will choose to mirror the scoping and public comment periods that are 

found in the EIS process. In other situations, agencies make the EA and a draft FONSI available 

to interested members of the public”.

Contact information for the Utah state office is on the cover page of the Draft EA’s. The notice 

of public comment clearly stated the website and address for EA documents and where to send 

comments and the closing date of April 16th, 2020.

Public meetings were held to discuss Draft EA and local concerns. A notice of public comment

was released with the Draft EA’s outlining the comment period beginning March 15th, 2020 and 

expired April 16th, 2020.

Comment 64

APHIS received the following comment, “the range of alternatives offered by APHIS is woefully 

inadequate.”

APHIS structured and analyzed the risk of the substantial program alternatives available to the 

agency.

Comment 65

APHIS received the following comment, “[The alternatives] are, “No Action,” “Insecticide 

Applications at Conventional Rates or Reduced Agent Area Treatments with Adaptive 

Management Strategy” (preferred alternative). While the RAATs are an improvement over 

conventional approval rates, this alternative should actually be two, one, Insecticide Applications 

at Conventional Rates and two, Reduced Agent Area Treatments with Adaptive Management 
86

Strategy. Lumping the two together means that supporting this alternative could mean pesticide 

application at conventional rates without RAATs. APHIS must break these into different 

alternatives.”

The EA states “Under Alternative A, the No Action alternative, APHIS would not conduct a 

program to suppress grasshopper infestations. Under this alternative, APHIS may opt to provide 

limited technical assistance, but any suppression program would be implemented by a Federal 

land management agency, a State agriculture department, a local government, or a private 

group or individual.”

Under Alternative B, the Preferred Alternative, APHIS would manage a grasshopper treatment 

program using potentially any of pesticides and application methods described in the EA 

Alternative B to suppress outbreaks. The grouping of conventional methods and pesticide rates 

with the more commonly used RAATs procedures reflects the variety of approaches that the 

agency may need depending on treatment specific circumstances.

Comment 66

APHIS received the following comment, “APHIS does not include an alternative that utilizes 

Integrated Pest Management.”

APHIS technical guidance is part of each alternative proposed, and is not unique to any one 

alternative. An example of APHIS technical guidance is the agency’s work on integrated pest 

management (IPM) for the grasshopper program. IPM for grasshoppers includes biological 

control, chemical control, rangeland and population dynamics, and decision support tools. 

APHIS has funded the investigation of various integrated pest management (IPM) strategies for 

the grasshopper program. Congress established the Grasshopper Integrated Pest Management 

(GIPM) to study the feasibility of using IPM for managing grasshoppers.

The major objectives of the APHIS GIPM program were to: 1) manage grasshopper populations 

in study areas, 2) compare the effectiveness of an IPM program for rangeland grasshoppers with 

the effectiveness of a standard chemical control program on a regional scale, 3) determine the 

effectiveness of early sampling in detecting developing grasshopper infestations, 4) quantify 

short- and long-term responses of grasshopper populations to treatments, and 5) develop and 

evaluate new grasshopper suppression techniques that have minimal effects on non-target 

species (Quinn, 2000). 

The results for the GIPM program have been provided to managers of public and private 

rangeland including ways to manage grasshopper populations in the long-term, such as livestock 

grazing methods and cultural control by farmers.

APHIS issued the GIPM User Handbook describing biological control, chemical control, 

environmental monitoring and evaluating, modeling and population dynamics, rangeland 

management, decision support tools, and future directions.
87

Federal and State land management agencies, State agriculture departments, and private groups 

or individuals may carry out a variety of preventative IPM strategies that may reduce the 

potential for grasshopper outbreaks. Some of these activities include grazing management 

practices, cultural and mechanical methods, and prescribe-burning of rangeland areas. These 

techniques have been tried with varying success in rangeland management, and some have been 

associated with the prevention, control and or suppression of harmful grasshopper populations 

on rangeland. 

Regardless of the various IPM strategies taken, the primary focus of the risk analysis contained 

in the EAs is on the potential impacts from chemical treatments needed during an outbreak of 

economic importance. While APHIS provides technical expertise regarding grasshopper 

management actions, the responsibility for implementing most land management practices lies 

with other Federal (i.e., BIA, BLM and USDA’s FS), State and private land managers.

The final EA will be updated to reflect APHIS support for IPM strategies in the grasshopper and 

Mormon cricket suppression program.

Comment 67

APHIS received the following comment, “Given that much of APHIS’s work on grasshopper and 

Mormon cricket suppression is on federal public lands or adjacent to federal public lands in 

Utah, it only makes sense that it would conform to their IPM mandates in these EAs.” 

See previous response. APHIS supports the use of IPM to prevent grasshopper outbreaks on or 

near Federal lands. These actions are and should continue to be considered by agencies as part 

of proper land management. APHIS treatments are a component of the IPM strategies that may 

be employed by Federal land management agencies. APHIS also adheres to any restrictions 

proposed by Federal land management agencies that may be part of their IPM strategies. 

Comment 68

APHIS received the following comment, “APHIS must adopt an alternative that harmonizes its 

mandates in regard to grasshoppers and Mormon crickets with the IPM mandates of the federal 

lands that it operates on.”

See previous response. A Memorandum of Understanding between land management agencies, 

i.e., the Department of Interior’s Bureau of Indian Affairs and Bureau of Land Management, and 

USDA’s Forest Service, indicates that while APHIS provides technical expertise, namely advice, 

regarding grasshopper management actions, the responsibility for implementing most land 

management practices, including IPM measures, lies with other Federal (i.e., BIA, BLM, and 

USDA’s FS), State, and private land managers (page 32 of the 2019 EIS).

Comment 69

APHIS received the following comment, “APHIS must enlist IPM experts to craft an alternative 

that is land-use and pest-specific, using the minimum level of pest suppression necessary, relying 

on prevention, avoidance, monitoring, and suppression techniques in order to decrease pest 

pressure with the least harmful controls possible.”
88

See comment 66

Comment 70

APHIS received the following comment, “APHIS does not provide a single citation or any other 

evidence to support its assertions that the pesticides proposed to be used ‘pose no risk of direct 

toxicity, carcinogenicity, neurotoxicity, genotoxicity, reproductive toxicity, or developmental 

toxicity.’”

The quote referenced in the comment has been removed from the final EA. The risk analysis in 

the EA is tiered to the two Environmental Impact Statements (2002 and 2019) and the four 

Human Health and Ecological Risk Assessments as described in sections I.C. About this Process, 

II.A. Alternatives (where an internet link to the more in-depth risk analysis documents is 

provided on page 7), in the second paragraph of section IV. Environmental Consequences (a link 

is also provided there), and many other locations in the EA.

Comment 71

APHIS received the following comment, “Perhaps APHIS is attempting to claim that because 

‘there is a lack of any adverse health effects reported from these projects.’”

Discussions regarding risk to human health in the EA is based on available data that was 

summarized in the human health and ecological risk assessments that were prepared to support 

the updated EIS published in 2020. APHIS would take into account any adverse effects noted 

during program use of a pesticide; however, a lack of effects on its own would not be used to 

make a conclusion that there are no adverse health effects.

Treatments exclude areas where humans are present including the avoidance of occupied 

dwellings, campgrounds, work-sites, etc.

Comment 72

APHIS received the following comment, “APHIS must conduct an adequate analysis of human 

health effects.”

APHIS prepared and published separate Final Human Health and Ecological Risk Assessments 

for all the pesticides used by the Grasshopper Programs (November 2019). 

Adherence to label requirements and additional Program measures designed to reduce exposure 

to workers (e.g., PPE requirements include long-sleeved shirt and long pants and shoes plus 

socks) and the public (e.g., mitigations to protect water sources, mitigations to limit spray drift

and restricted-entry intervals) result in low health risk to all human population segments.

Comment 73

APHIS received the following comment, “there is no description of how APHIS plans to identify 

or contact these individuals in order to advise them to avoid treatment areas.”

In areas considered for treatment, State-registered beekeepers and organic producers shall be 

notified in advance of proposed treatments. APHIS will notify residents within treatment areas,
89

or their designated representatives, prior to proposed operations, and advise them of the control 

method to be used, proposed method of application and precautions to be taken.

Comment 74

APHIS received the following comment, “APHIS’s failure conduct any analysis of their impacts 

to human health is a far cry from the level of analysis demanded by NEPA and basic due care for 

public health.” 

See responses to comment 73. APHIS prepared and published separate Final Human Health and 

Ecological Risk Assessments for all the pesticides used by the Grasshopper Programs 

(November 2019). These documents were incorporated by reference into the draft EA. 

Comment 75

APHIS received the following comment, “APHIS fails to look at the effects of the proposed 

action on migratory birds.”

Executive Order 13186 directs Federal agencies taking actions with a measurable negative 

effect on migratory bird populations to develop and implement a Memorandum of Understanding 

with the USFWS that promotes the conservation of migratory bird populations. On August 2, 

2012, a Memorandum of Understanding between APHIS and the USFWS was signed to facilitate 

the implementation of this Executive Order.

Specifically to the grasshopper and Mormon cricket program, APHIS evaluated potential 

impacts to birds in the final EIS and associated human health and ecological risk assessments. 

These documents are incorporated by reference into the final EA.

For decades APHIS in UT has consulted with and received concurrence from the state office of 

the USFWS. Together, mitigation measures have been developed and maintained for all listed 

and proposed T&E species within the state. These measures, which are listed in Appendix 3 of 

each EA, are employed in every treatment project wherein said species occur.

Comment 76

APHIS received the following comment, “APHIS needs to take a hard look at the impacts of the 

proposed action, including direct and indirect effects.”

The EA incorporated the analysis from the EIS and associated human health and ecological risk 

assessments into the analysis. The EIS, and in particular, the risk assessments evaluated 

potential indirect effects to non-target organisms, relying on available toxicity data and 

estimates of risk. 

Comment 77

APHIS received the following comment, “A direct effect of not spraying insecticides is abundant 

food for migratory birds. Conversely, a direct effect of spraying is reduced abundance of food for 

insectivorous migratory birds. Another potential direct effect of insecticide spraying is 

poisoning. An example of an indirect effect is the cumulative effect of continuous low level 
90

pesticide exposure from numerous sites over many years. APHIS must take a hard look at all 

these impacts”.

The routine use of Reduced Area Agent Treatment (RAAT) procedures results in the temporary 

reduction of insects that birds prey upon within the treated swaths. This indirect effect is 

mitigated by the unchanged abundance of prey in nearby untreated swaths. The EIS analyzes the 

toxicological effects of Grasshopper applied insecticides on birds (carbaryl p. 42-43, 

diflubenzuron p.50-52, malathion p.61-63, and chlorantraniliprole p.75). The EIS also describes 

the potential effects on birds caused by loss of prey (diflubenzuron p. 52, malathion p. 63, 

generally p. 88-89).

Comment 78

APHIS received the following comment, “APHIS’s handling of impacts to non-target species 

and species of concern wholly fails to meet NEPA’s requirement that the agency take a hard look 

at the impacts of its proposed action.”

APHIS prepared and published separate Final Human Health and Ecological Risk Assessments 

for all the pesticides used by the grasshopper and Mormon cricket suppression program 

(November 2019). The EIS and risk assessments evaluated available effects data and risk to nontarget species. These documents are incorporated by reference into the final EA. The risk 

assessments provided the basis for summary statements in the EA that is tiered to the EIS. 

The U.S. FWS defines "Species of concern" is an informal term that refers to those species which 

may require some conservation actions but which are not threatened with extinction. The 

conservation actions needed will vary depending on the health of the populations and types and 

degree of threats. At one extreme, there may only need to be periodic monitoring of populations 

and threats to the species and its habitat. At the other extreme, a species eventually may require 

listing as a Federal threatened or endangered species and become the subject of a Federal 

recovery program. Species of concern receive are not provided legal protection under the 

Endangered Species Act, and the use of the term does not necessarily mean that the species will 

eventually be proposed for listing as a threatened or endangered species. Based on U.S. FWS 

funding and staffing levels discussions with APHIS about species of concern may occur during 

broader ESA consultations and result in specific protections measures observed by the 

Grasshopper Program. 

Comment 79

APHIS received the following comment, the EA cannot be finalized until APHIS actually takes a 

hard look at the impacts on non-target and species of concern.

See previous response. Under FWS Section 7 Act there is no requirement to consult on sensitive 

species. However, in Utah when there is concern by land management agencies, federal, state, 

etc., APHIS has implemented protective measures for those species of concern. This is a 

cooperative effort by APHIS between FWS, Tribal Nations, Utah Division of Wildlife Resources 

and/or the requesting land management agency.

Comment 80
91

APHIS received the following comment, “APHIS doesn’t even consider many sensitive or 

culturally important species. For example, monarch butterflies fly through Utah.”

APHIS prepared and published separate Final Human Health and Ecological Risk Assessments 

for all the pesticides used by the Grasshopper Programs (November 2019). The risk assessments 

and EIS considered available field and laboratory data regarding impacts to Lepidoptera, 

including moths and butterflies. 

Comment 81

APHIS received the following comment, “APHIS also doesn’t consider the impacts of spraying 

on the hundreds of native bee species that reside in Nevada, including many that are exceedingly 

rare.”

APHIS works with Tribal, Federal and State land managers and their local biologists, natural 

resource specialists, and range conservationists to implement measures that reduce risks of 

Program treatments to native bees. These measures may include reduced insecticide applications 

associated with RAATS, avoidance measures and use of carbaryl bait, where applicable. APHIS 

also prepared and published separate Final Human Health and Ecological Risk Assessments for 

all the pesticides used by the Grasshopper Programs (November 2019). The risk assessments 

summarized available effects data for non-target species including pollinators. 

Comment 82

APHIS received the following comment, “The EAs have not adequately analyzed the cumulative 

impacts of the program with other governmental or private entity actions.”

APHIS discussed the potential of overlapping chemical treatments in the areas where outbreaks 

of grasshoppers have occurred or could occur in the future in the cumulative impacts section of 

the draft EIS, from page 79 to 83. It is unlikely there would be significant overlap between 

APHIS programs and the grasshopper program and coordinated treatments would mitigate 

impacts if there is ever overlap; current label and mitigations minimize significant exposure of 

soil, water and air to Program insecticides; grasshopper chemical treatments are not expected to 

persist or bioaccumulate in the environment; and, there is a lack of significant routes of 

exposure (page 82 to 83 of draft EIS).

APHIS consults with all its land managers within treatment blocks prior to project 

commencement and insures that any planned herbicide treatments are in harmony with the 

objectives of the project. 

Comment 83

APHIS received the following comment, “The EA does not take into account the background 

level of exposure to humans and animals from pesticides and other pollutant sources that exist in 

the environment from other actions or the synergistic effects of the enhanced toxicity that many 

mixtures exhibit.”

The commenter assumes that the rangeland in Utah which is covered by the Draft has been 

exposed to pesticides and pollutants and that there is a synergistic effect which enhances toxicity 

to the environment. The land managers that manage the areas covered in the EAs, document all 
92

pesticide applications. If these remote areas were at risk, the land manager would not request 

APHIS’s services. The activities, or lack thereof, are discussed in the cumulative impacts section 

of the final EA.

Comment 84

APHIS received the following comment, “[the EA] does not account for the range of cumulative 

exposures that would be anticipated. There was no mention of widespread mosquito spraying 

that takes place in many areas.”

Any areas considered for treatment in Utah would not overlap with any mosquito treatments. 

Mosquito treatments in Utah are not wide spread and are restricted to riparian areas which are 

avoided and buffered in Mormon cricket and grasshopper treatment programs.

Comment 85

APHIS received the following comment, “as cattle are grazing these pesticides will be washed 

off their bodies or excreted through waste and contaminate surrounding land and water bodies.”

The labels for Dimilin 2L and Carbaryl 2% bait specify that there is no grazing restrictions. 

Any pesticide residues that may be present on forage in treated areas after treatment is typically 

metabolized and excreted as metabolites that have lower toxicity than the parent compound. In 

addition, the low application rates employed by APHIS relative to the current maximum labelled 

rates for each Program insecticide would result in very low residues in livestock waste. 

Comment 86

APHIS received the following comment, “A lot of rangeland is adjacent to lands used for plant 

agriculture, and the EAs state that they also aim to protect these agricultural lands. These areas 

generally have a high potential for crossover contamination through drift or runoff of pesticides. 

Large quantities of pesticides, including insecticides and fungicides that may be synergistic with 

the insecticides included in the EAs, may be used on these lands. In addition, herbicide use on 

crops already significantly impacts insects by destroying habitat and food sources in agricultural 

lands”.

APHIS in Utah does not include cultivated agricultural land in grasshopper/Mormon crickets 

spray projects.

The pesticide labels which APHIS uses prohibits their use on specific crops, agricultural lands 

etc. The labels and their rates of application are specific to rangeland or pasture land use, and a 

200-foot buffer is maintained around agricultural areas.

Comment 87

APHIS received the following comment, “None of these issues were disclosed or analyzed in the 

Draft EIS and add to the already large cumulative exposures from pesticides used in 1) the boll 

weevil eradication program, 2) fruit fly cooperative eradication program, 3) the gypsy moth 

cooperative eradication program, and 4) invasive plant control”.
93

The commenter refers to the Draft EIS. The EIS has been finalized and the ROD has been signed. 

The final EIS does address the cumulative exposures from other APHIS programs on a 

programmatic level. The documents in question are the Draft EA’s. The programs mentioned by 

the commenter are not relevant to the Rangeland Grasshopper and Mormon Cricket Suppression 

Program. 

There is no geographic overlap in Utah now or in the foreseeable future between pesticide 

applications of the Grasshopper Program and the pest control programs mentioned by the 

commenter. 

Comment 88

APHIS received the following comment, “These cumulative exposures can not only adversely 

affect human and environmental health but can also negatively impact biological control 

programs that try to manage insect and weed pests with natural predators”.

APHIS works very closely with the Utah Department of Agriculture and the Weed and Pest 

Districts in Utah with respect to biological control. Before any grasshopper project takes place, 

APHIS conducts extensive consultation with land managers so that established biological 

control agents are not adversely impacted.

Comment 89

APHIS received the following comment, “How these pesticides act in conjunction with one 

another to additively or synergistically increase toxicity is not discussed and no mitigation 

measures were proposed. Therefore, APHIS must fully analyze the impacts from cumulative 

exposures and identify ways in which risk can be mitigated or prohibited”.

The Grasshopper Program does not apply treatments more than once per year to any rangeland 

area. Therefore, synergistic or additive toxicity between program applied insecticides is not 

possible. Cumulative exposures from pesticides applied by external parties because of 

coordination between APHIS, land managers and other cooperators, also typically eliminate the 

possibility of multiple pesticide applications per year. The EA details many procedures APHIS 

employs to mitigate risk.

Comment 90

APHIS received the following comment, “The project is vague and ill-defined, it improperly 

precludes the disclosure of environmental effects because the information on the project and its 

impacts is incomplete”.

The proposed Grasshopper treatment program described in the EA could occur within a specific 

area, using a limited number of insecticides and application methods. The environmental 

consequences of suppressing or not suppressing grasshopper infestations on multiple ecological 

parameters of the treatment areas are thoroughly described in the EA and other programmatic 

risk analysis documents.

Comment 91
94

APHIS received the following comment, “APHIS’s explanation of a “level of economic 

infestation,” which is the trigger for insecticide spraying, does not give the public any sense 

whatsoever of when that threshold is met. The definition is too vague and ill-defined to meet 

NEPA’s purposes and mandates. The agency could spray with minimal infestation levels if it 

saw fit whenever it decided to do so. There must be a more concrete definition that identifies 

specific thresholds that must be met for the agency to determine an economic level of infestation 

has been met”.

APHIS utilizes and provides links to extensive resources for determining when a grasshopper 

outbreak is exceeding IPM thresholds including, “a level of economic infestation”. The Purpose 

and Needs section of the EA and supporting documents adequately define the multiple factors 

that must be evaluated before APHIS decides a treatment is necessary.

The following footnote is in the Draft EAs page 6.

The “economic infestation level” is a measurement of the economic losses caused by a 

particular population level of grasshoppers to the infested rangeland. This value is determined 

on a case-by-case basis with knowledge of many factors including, but not limited to, the 

following: economic use of available forage or crops; grasshopper species, age, and density 

present; rangeland productivity and composition; accessibility and cost of alternative forage; 

and weather patterns. In decision-making, the level of economic infestation is balanced against 

the cost of treating to determine an “economic threshold” below which there would not be an 

overall benefit for the treatment. Short-term economic benefits accrue during the years of 

treatments, but additional long-term benefit may accrue and be considered in deciding the total 

value gained by treatment. Additional losses to rangeland habitat and cultural and personal 

values (e.g., aesthetics and cultural resources), although a part of decision-making, are not part 

of the economic values in determining the necessity of treatment.

Comment 92

APHIS received the following comment, “The EA’s description of the preferred alternative that 

includes “reduced agent area treatments” (“RAATs”) is similarly vague and ill defined”.

RAATs has long been in use, is public knowledge and is one of APHIS’s preferred IPM 

strategies. It is supported by decades of research. 50% skip swaths are the most common RAATs 

choice, leaving 50% of the block untreated to maximize refugia for non-target arthropods while 

simultaneously inducing target Orthoptera mortality at desired levels. RAATs are also described 

in detail in the final EIS that is incorporated by reference in the EA.

Comment 93

APHIS received the following comment, “It is unclear whether RAATs will even be used and 

how they will be used in the site specific area”.

APHIS typically does use the RAATs procedures to reduce both program costs and potential 

environmental effects. However the program could decide to apply insecticides at conventional 

rates and total area coverage if a damaging grasshopper infestation warrants that level of 
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suppression. An explanation of the uncertainties involved with predicting grasshopper 

populations before they emerge is provided in section I.C. about this Process.

Comment 94

APHIS received the following comment, “APHIS could use the pesticide at 95% of the labelled 

rate and still call the application a RAAT.”

RAAT’s is defined as Reduced Agent and/or Area Treatments. The current pesticide labels for 

use in the Program do not allow applications at 95% of the labeled rate to be called RAATs. 

This information was also summarized in the final EIS. The commenter will find that EPA has 

approved the verbiage for the pesticide labels. The labels clearly state which rates are allowed 

to meet a RAAT rate. In the case of Dimilin 2L label, which clearly states the application rates 

for RAAT’s is 0.75 - 1 ounce per acre. “Use on rangeland only, in a RAAT’s application on early 

instars. A RAAT’s application is an IPM strategy that takes advantage of grasshopper movement 

and conservation biological control to allow Dimilin 2L to be applied on rangeland on a 

reduced treated area and at reduced rates, while sustaining acceptable control.”

The applicator can only use the RAAT’s rate of .75 or 1 ounce per acre. The label rate, if not 

using RAAT’s is 2 ounces/acre. The RAAT’s rate would be 50% of the label rate not 95% of

labeled rate. 

In the case of using Carbaryl 5% bait the label rate is 20-40 lbs per acre. APHIS uses the 

RAAT’s rate of 10lbs/acre. In the case of Carbaryl 2% bait, the label clearly states for ground 

applications 25 pounds/acre. It clearly states for U.S. Federal Government and State affiliated 

Grasshopper/Mormon Cricket Suppression Programs using aerial applications the rate of 

application is 10 pounds/acre. So clearly the RAAT’s applications are 50% or less than the 

labeled rates.

The RAAT procedures used by the program are flexible to allow for a reduction of pesticide use. 

Typically the RAAT procedures will result in half the amount of pesticide being applied to a 

treatment block than conventional rates and total coverage. Program managers may reduce the 

rate at which the pesticide is sprayed from the aircraft or increase the distance between swaths 

that are sprayed based on factors specific to grasshopper populations being suppressed. It 

should be noted that APHIS average RAAT rates are lower than the labeled RAAT rates further 

reducing pesticide loading into the environment.

The commenter will find that EPA has approved the verbage for the pesticide labels. In the case 

of Dimilin 2L label, which clearly states the application rates for RAAT’s is 0.75 - 1 ounce per 

acre. “Use on rangeland only, in a RAAT’s application on early instars. A RAAT’s application is 

an IPM strategy that takes advantage of grasshopper movement and conservation biological 

control to allow Dimilin 2L to be applied on rangeland on a reduced treated area and at reduced 

rates, while sustaining acceptable control.”

The applicator can only use the RAAT’s rate of .75 or 1 ounce per acre. The label rate, if not 

using RAAT’s states the rate is 2 ounces/acre. Thus, the RAAT’s rate would be 50% of the label 

rate. 
96

In the case of using Carbaryl 5% bait the label rate is 20-40 lbs per acre. APHIS uses the 

RAAT’s rate of 10lbs/acre. In the case of Carbaryl 2% bait, the label clearly states for ground 

applications 25 pounds/acre. It clearly states for U.S. Federal Government and State affiliated 

Grasshopper/Mormon Cricket Suppression Programs using aerial applications, the rate of 

application is 10 pounds/acre. So clearly the RAAT’s applications are 50% or less than the 

labeled rates. In the case of a full coverage treatment the total acreage is treated. In the case of 

reduced area portion of RAAT’s the treatment area would be 50% less than a full coverage 

treatment. The reduced area is achieved through alternating the treated and untreated swath 

widths. The RAAT’s application rates are described in detail in the Draft EA’s and depending 

on the pesticide used in a treatment the Label will also specify or clarify what the RAAT’s rate of 

application would be also. Thus the reduced agent use. The reduced area is achieved by 

skipping a treated swath. For example, if the swath width of the treatment equipment is 40 feet, 

then the treated swath would be 40 feet. Then the adjacent swath would be skipped or untreated. 

The next treated swath would then be applied. So across the treatment block would be treated 

and untreated swaths. Thus the reduced area of actual treated ground, instead of a conventional 

blanketed treatment.

The RAAT procedures used by the program are flexible to allow for a reduction of pesticide use. 

Typically the RAAT procedures will result in half the amount of pesticide being applied to a 

treatment block than conventional rates and total coverage. Program managers may reduce the 

rate at which the pesticide is sprayed from the aircraft or increase the distance between swaths 

that are sprayed based on factors specific to grasshopper populations being suppressed.

APHIS typically does use the RAATs procedures to reduce both program costs and potential 

environmental effects. However the program could decide to apply insecticides at conventional 

rates and total area coverage if a damaging grasshopper infestation warrants that level of 

suppression.

Comment 95

APHIS received the following comment, “The agency must give the public a more precise 

definition of when the threshold for spraying has been met (i.e. number of grasshoppers or 

crickets/acre and a full description of the economic interests at stake).”

The commenter is asking for survey data to be submitted to the public. This data is accumulated 

during the nymphal survey season and is not available when compiling the EA’s. APHIS utilizes 

and provides links to extensive resources for determining when a grasshopper outbreak is 

exceeding IPM thresholds including, “a level of economic infestation”. The Purpose and Needs 

section of the EA and supporting documents adequately define the multiple factors that must be 

evaluated before APHIS decides a treatment is necessary. Establishing a treatment threshold 

based on the number of grasshoppers ignores a variety of factors that must be considered by 

program managers before treatments. Some examples include how voracious the individual 

species are that compose a grasshopper infestation and the hardiness of rangeland vegetation 

within a proposed treatment block. These factors are also discussed in the recently published 

final EIS and are incorporated by reference in the final EA.

See previous responses for economic thresholds.
97

Comment 96

APHIS received the following comment, “APHIS must also convey what metrics will be used to 

determine the area that will be sprayed in any given outbreak”.

The size and exact configuration of a treatment block cannot be forecast prior to the emergence 

of the grasshoppers, requests from land managers and other cooperators, and other 

environmental considerations such as buffers from water and sensitive species. The program 

procedures and mitigation measures are adequately described in the EA and supporting 

documents. 

APHIS is unable to predict exactly what areas will be treated before conducting surveys and 

completing the EA. For ground applications, the terrain is key to be able to treat safely. If the 

terrain is too rough to safely drive an ATV, then the area is not treated even though other factors 

warrant a treatment. There are many variables taken into account before an area is treated.

Another factor that must be considered is the movement of populations. If for any number of 

reasons, a treatment can be delayed there is a risk that, depending on species, the boundaries 

will have to be readjusted to account for the movement of populations.

For example, it is documented that Melanoplus sanguinipes, the Migratory Grasshopper can 

swarm and fly up to 5-10 miles normally. The longest migrations recorded in 1938 were made 

by swarms that traveled from northeastern South Dakota to the southwestern corner of 

Saskatchewan, a distance of 575 miles (Pfadt 1994). This is why it is critical to have a rapid 

response to outbreaks. The planning and logistics is critical and cannot be documented and 

accounted for in the NEPA process. Population dynamics is always a fluid situation.

Comment 97

APHIS received the following comment, “The agency must accurately and comprehensively 

disclose and analyze the range of rare, sensitive, threatened and endangered species, ecological 

areas, communities, Native American gathering grounds and sensitive receptors that could 

potentially be significantly affected by the proposed project” Without this baseline data the EA 

cannot disclose the environmental effects of the project”.

In Utah, Native American gatherings are considered by some Tribes as Holy 

Ground and is only made available to APHIS when necessary. This will not be published or 

disclosed to the public as per Local Tribal Agreements. It is addressed in general terms when 

published in the EA. The more specific details are addressed with each individual Tribal Nation 

during the Tribal meetings. T&E species have been analyzed during years of FWS Section 7 

consultations. APHIS adheres to protective measures which have been formulated and agreed 

upon with FWS. APHIS also works with Federal and State land-managing agencies to protect 

T&E’s and other sensitive resources managed on their lands.

APHIS adequately summarized available data for current baseline conditions in the draft 

EA. This includes cultural resources as well as the potential for any overlap of federally listed 

species with the proposed areas of treatment.

Comment 98
98

APHIS received the following comment, “APHIS’s description of the environmental effects of 

the pesticides at issue failed to properly capture many of their environmental effects”.

APHIS prepared and published separate Final Human Health and Ecological Risk Assessments 

for all the pesticides used by the Grasshopper Programs (November 2019). These documents and 

the associated final EIS are incorporated by reference at http://www.aphis.usda.gov/planthealth/grasshopper.

Comment 99

APHIS received the following comment, “Long-term exposure to carbaryl is associated with 

decreased egg production and fertility in birds”.

APHIS would make a single application per year to a treatment area, and could apply 

insecticide at an APHIS rate conventionally used for grasshopper suppression treatments, or 

more typically as reduced agent area treatments (RAATs). Carbaryl has a reported half-life on 

vegetation of three to ten days, therefore long-term exposure to birds is not anticipated.

The study cited by the commenter noted, Carbaryl is practically nontoxic to birds on both an 

acute oral exposure (LD50 >2,000 mg/kg) and subacute dietary exposure basis (LC50 >5,000 

mg/kg of diet). In addition, no chronic effects were observed at a dietary exposure of 300 mg/kg 

of diet.

Comment 100

APHIS received the following comment, “Carbaryl is considered moderately toxic to mammals 

with decreased pup survival being the most sensitive effect”.

APHIS would make a single application per year to a treatment area, and could apply 

insecticide at an APHIS rate conventionally used for grasshopper suppression treatments, or 

more typically as reduced agent area treatments (RAATs). Carbaryl has a reported half-life on 

vegetation of three to ten days, therefore the chronic exposure to mammals that resulted in 

decreased pup survival is not anticipated.

Comment 101

APHIS received the following comment, “EPA has designated carbaryl as “highly toxic” to bees 

on a short-term exposure basis and ranged from moderately to highly toxic to other insects, mites 

and spiders”.

Although the Grasshopper Program has used the liquid formulation of carbaryl in the past, all 

carbaryl applications this year and for the foreseeable future will be a bait. The potential 

exposures of bees and other pollinators to carbaryl bait are minimal. The risks of carbaryl to 

bees and other non-target organisms are summarized in the human health and ecological risk 

assessment that was prepared to support the final EIS. This analysis is incorporated by 

reference into the final EA.

Comment 102
99

APHIS received the following comment, “Carbaryl is considered “highly toxic” to certain 

species of fish when exposed to short-term bursts and can reduce the number of eggs spawned 

when fish are exposed to lower levels over a longer period of time”.

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Carbaryl Rangeland Grasshopper and 

Mormon Cricket Suppression Applications are published. Comparison of the distribution of 

acute, sublethal and chronic effects data for fish to the residues estimated using ground and 

aerial ultra-low volume spray and bait applications show that the range of residues do not 

overlap with acute toxicity values, suggesting there is no acute risk to fish species. APHIS 

determined there is some overlap with chronic and sublethal effect values and estimated 

residues. However, carbaryl half-lives in water are typically short and with the proposed one 

time application chronic exposure and risk to fish is not anticipated. Effects from consumption of 

contaminated prey are also not expected to be a significant pathway of exposure, based on the 

low residues and low bioconcentration factor values reported for carbaryl.

APHIS guidelines to buffer bodies of water, streams and rivers were addressed in appendix 1 of 

Draft EA’s. The FWS Section 7 consultations and FWS letters of concurrence all reduce the 

exposure to fish species.

Comment 103

APHIS received the following comments, “Carbaryl has been designated “very highly toxic” to 

aquatic invertebrates on an acute exposure basis by the EPA and mesocosm studies that analyze 

how the pesticide affects aquatic community structure have found significant negative effects at 

low levels”.

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Carbaryl Rangeland Grasshopper and 

Mormon Cricket Suppression Applications are published. The risk assessment summarizes the 

available laboratory and field effects data for aquatic invertebrates and carbaryl. The risk 

assessment also summarized the potential exposure and risk to aquatic invertebrates. The EIS 

and carbaryl risk assessment are incorporated by reference into the EAs.

Comment 104

APHIS received the following comment, “The EPA identified potential interactions between 

carbaryl and the androgen pathway in fish, indicating that carbaryl is an endocrine disruptor in 

male aquatic vertebrates”.

Carbaryl half-lives in water are typically short and with the proposed one time application 

chronic exposure and endocrine disruption risk to fish is not anticipated. Effects from 

consumption of contaminated prey are also not expected to be a significant pathway of exposure, 

based on the low residues and low bioconcentration factor values reported for carbaryl. Chronic 

risk is also a conservative estimate because chronic toxicity data is based on long-term 

exposures that what would not be expected to occur from a single application, based on the 

environmental fate of carbaryl in aquatic environments.
100

APHIS guidelines to buffer bodies of water, streams and rivers were addressed in appendix 1 of 

Draft EA’s. The FWS Section 7 consultations and FWS letters of concurrence all reduce the 

exposure to fish species.

Comment 105

APHIS received the following comment, “On March 12, 2020, the EPA released a draft 

biological opinion finding that carbaryl is likely to adversely affect 1542 out of 1745, or 86% 

percent of all listed species in the U.S. and 713 out of 776 designated critical species’ habitats 

across the U.S.”.

The Endangered Species Act section 7 pesticide consultation process between the U.S. Fish and 

Wildlife Service and the National Marine Fisheries Service (the Services, collectively) and the 

EPA specifically concerns FIFRA pesticide registration and reregistration in the United States, 

including all registered uses of a pesticide. The state-level Biological Assessments for APHIS 

invasive species programs are separate from any consultations conducted in association with 

pesticide registration and reregistration process. 

The Agricultural Improvement Act of 2018 (Farm Bill) created a partnership between USDA, 

EPA, the Services and the Council on Environmental Quality to improve the consultation process 

for pesticide registration and reregistration. USDA is committed to working to ensure 

consultations are conducted in a timely, transparent manner and based on the best available 

science. The Revised Method for National Level Listed Species Biological Evaluations of 

Conventional Pesticides provides a directionally improved path to ensuring that pesticides can 

continue to be used safely for agricultural production with minimal impacts to threatened and 

endangered species.

APHIS provided information about use of carbaryl to EPA for the FIFRA consultation for 

carbaryl. The Grasshopper Program use of carbaryl has in the past comprised substantially less 

than 1% of the percent crop treated (PCT) for rangeland use of carbaryl. This is the case for the 

reasonably foreseeable future. For rangeland, in the EPA BE, the Grasshopper Program’s very 

low usage was rounded up to <1% PCT, which gives an overestimate of rangeland acres treated 

and thus endangered species risk. APHIS use of carbaryl is even smaller compared to all uses of 

carbaryl nationwide. Further, the Grasshopper Program consults directly with the Services to 

ensure program activities do not adversely affect protected species or their critical habitat.

Comment 106

APHIS received the following comment, “EPA found many Utah species were likely to be 

adversely affected. This is a chemical far too toxic for APHIS to consider using across wide 

swaths of land in Utah.”

Carbaryl is presently approved by the EPA and registered in Utah. The APHIS proposed use for 

carbaryl in Utah is not for treatment across wide expanses of the state but in small grazing 

allotments that require a suppression treatment, and where ground bait applications are the 

most logical choice. It should be noted that the current labeled uses for carbaryl grasshopper 

treatments are at much higher rates and can be applied with more frequency than what APHIS is 

proposing for use in Utah. In addition carbaryl use by the Program is minor compared to the 
101

preferred alternative diflubenzuron. APHIS has evaluated the risk of carbaryl use in the 

Program and in general the conclusions are consistent with other risk assessments 

demonstrating low risk when adhering to label requirements. Additional mitigation measures 

used by APHIS further reduces the risk to human health and the environment.

As stated in the final EIS APHIS has completed programmatic consultation with the National 

Marine Fisheries Service (NMFS). APHIS has reinitiated programmatic consultation with 

NMFS to include chlorantraniliprole. In the interim APHIS will consult with NMFS at the State 

level if there is a proposal to apply chlorantraniliprole. The NMFS consultation does not apply 

to species in Nevada since there are no federally listed species under NMFS jurisdiction however 

the information was provided in response to comments regarding the final EIS. APHIS 

submitted a programmatic biological assessment to the FWS in 2015. APHIS is currently 

working with the FWS to update and complete the biological assessment and receive 

concurrence. The intent of the programmatic biological assessment is to provide consistent 

mitigation measures for listed species that may co-occur with Program treatments. Consultation 

with the FWS is still being completed at the local level prior to any treatments. No APHIS 

treatments are made in States without prior concurrence from the FWS or NMFS regarding 

federally-listed species. This information is also summarized in the final EIS.

Local FWS Section 7 consultations were entered into prior to the DRAFT EAs. 

APHIS consulted with the FWS on federally-listed species that may occur within the county or 

areas where grasshopper and Mormon cricket treatments may be required. APHIS works 

closely with the FWS to determine the application of protection measures and where those 

measures should be applied prior to any treatments. APHIS also evaluated the potential direct 

and indirect impacts to non-target species which is summarized in the final human health and 

ecological risk assessments for each insecticide. 

Comment 107

APHIS received the following comment, “The European Union banned carbaryl in 2007 due to, 

among other things, “...a high long-term risk for insectivorous birds and a high acute risk to 

herbivorous mammals, a high acute and long-term risk to aquatic organisms and a high risk for 

beneficial arthropods”.

APHIS summarizes the risk of carbaryl to non-target organisms in final human health and 

ecological risk assessment that was part of the recently published final EIS. Available effects 

data and the exposures that would be expected from proposed use in the grasshopper and 

Mormon cricket program are reduced based on mitigation measures (ex. RAATS, aquatic 

buffers) and application methods and formulation types which further reduce risk. 

Comment 108

APHIS received the following comments, “Carbaryl is classified as “likely to be carcinogenic to 

humans” based on treatment-related hemangiosarcoma development in mice”.

The levels of carbaryl that caused the above-mentioned effects to mice are above exposure 

concentrations that would be expected to occur for the public as well as workers and applicators 

in the APHIS grasshopper and Mormon cricket suppression program. The risk to human health 

from carbaryl use, including the proposed APHIS use, have been evaluated by APHIS and are 

discussed in the final human health and ecological risk assessment for carbaryl. It should be 
102

noted that other agencies have evaluated the risk to carbaryl at much higher application rates 

than those used in the grasshopper and Mormon cricket program.

Comment 109

APHIS received the following comments, “EPA has determined that humans can be exposed to 

more than 4 times the amount of carbaryl known to cause neurotoxicity from some legal uses of 

the pesticide. EPA also found that the current labelled uses of carbaryl may result in neurotoxic 

harms to mixers, loaders and applicators.”

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Carbaryl Rangeland Grasshopper and 

Mormon Cricket Suppression Applications are published. APHIS evaluated the potential human 

health risks from the proposed use of carbaryl ULV sprays and carbaryl bait applications and 

determined that the risks to human health are low. The lack of risk to human health is based on 

the low probability of human exposure and the favorable environmental fate and effects data. 

APHIS treatments are conducted in rural rangeland areas where agriculture is a primary 

economic factor. Rural rangeland areas consist of widely scattered, single dwellings in ranching 

communities with low population density. Risk to the general public from carbaryl ground or 

aerial applications is also expected to be minimal due to the low-population areas proposed for 

treatment, adherence to label requirements, and additional Program measures designed to 

reduce exposure to the public.

APHIS is not obligated to analyze the risk posed by all legal uses of carbaryl, but rather the 

Grasshopper Program formulations and application rates.

The proposed use of carbaryl as a ULV spray or a bait and adherence to label requirements 

substantially reduces the potential for exposure to humans. APHIS does not expect adverse 

health risks to workers because of the low potential for exposure to carbaryl when applied 

according to label directions and use of personal protective equipment during applications. 

APHIS quantified the potential risks associated with accidental exposure of carbaryl for workers 

during mixing, loading, and application. The quantitative risk evaluation results indicate no 

concerns for adverse health risk for Program workers from carbaryl applications in accordance 

with program standard operating procedures for safety.

Comment 110

APHIS received the following comment, “EPA has found that all use scenarios of 

chlorantraniliprole can result in direct or indirect effects to all listed species”.

The Endangered Species Act section 7 pesticide consultation process between the U.S. Fish and 

Wildlife Service and the National Marine Fisheries Service (the Services, collectively) and the 

EPA specifically concerns FIFRA pesticide registration and reregistration in the United States, 

including all registered uses of a pesticide. The state-level Biological Assessments for APHIS 

invasive species programs are separate from any consultations conducted in association with 

pesticide registration and reregistration process. 

As previously stated, the Grasshopper Program will not be using chlorantraniliprole in Utah

during 2020. Therefore, any chlorantraniliprole exposure scenarios which the commenter is 

concerned about are not relevant at this time. 
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Comment 111

APHIS received the following comment, “Chlorantraniliprole is considered “very highly toxic” 

to freshwater invertebrates and EPA found that many uses of it can result in acute and chronic 

harms to aquatic invertebrates. This was the case for both aerial and ground spray applications. 

Sublethal doses can impair locomotion in bees more than seven days post exposure. A 2013 

European Food Safety Authority analysis of chlorantraniliprople found that the use of the 

pesticide poses a high risk to soil macro-organisms, aquatic invertebrates and sediment dwelling 

organisms.” and “APHIS must consider chlorantraniliprole substantial environmental impacts, 

including population level effects”.

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Chlorantraniliprole Rangeland Grasshopper 

and Mormon Cricket Suppression Applications is published. The document summarizes 

available effects data and characterizes risk to human health and non-target organisms based on 

the use pattern proposed by the Program. Results from the risk assessment suggest low risk of 

chlorantraniliprole to non-target aquatic organisms and most terrestrial invertebrates. 

As previously stated, the Grasshopper Program will not be using chlorantraniliprole in Utah

during 2020. Therefore any chlorantraniliprole exposure scenarios which the commenter is 

concerned about are not relevant at this time.

Comment 112

APHIS received the following comments, “Diflubenzuron is considered “highly” to “very highly 

toxic” to aquatic invertebrates. In a 2018 analysis, EPA found that the registered, labeled uses of 

diflubenzuron may result in freshwater invertebrate exposure at up to 550 times the level known 

to cause harm. Diflubenzuron exposure to honeybees and other pollinators at the larval stage was 

estimated to be more than 500 times the level known to cause harm. Although arthropods are not 

a part of EPA’s ecological risk assessment, the European Food Safety Authority found that 

“Juvenile non-target arthropods were very sensitive to diflubenzuron. Very large in-field nospray buffer zones would be needed to protect non-target arthropods. There is no reason for 

APHIS to exclude consideration of impacts to arthropods in its analysis of this pesticide.” and 

“APHIS also acknowledges the pollinator impacts but attempts to diminish them without 

providing evidence on how or why they are not significant”.

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Diflubenzuron Rangeland Grasshopper and 

Mormon Cricket Suppression Applications are published. The EPA risk assessment evaluated 

risk to aquatic organisms and pollinators based on application rates, methods of application and 

use patterns that would result in greater exposure and risk to aquatic and terrestrial 

invertebrates. APHIS evaluated risks to these groups of non-target organisms based on methods 

of application consistent with Program applications and other mitigation measures for 

diflubenzuron. The exposure potential is reduced compared to label uses due to many factors.

This includes but is not limited to reduced application rates, one application per season, use of 

RAATs and buffers from aquatic habitats. APHIS relied on laboratory and field collected data 

regarding diflubenzuron effects to aquatic and terrestrial invertebrates to show that risk is low 

for most non-target invertebrates. 
104

Characterization of risk to aquatic species from Program-specific diflubenzuron applications 

was made by comparing the residue values in the exposure analysis from ground and aerial 

applications to the distribution of available acute and chronic fish toxicity data. Residue values 

were below the distribution of acute and chronic response data, suggesting that direct risk to 

aquatic species is not expected from diflubenzuron applications. More specifically, the 

distribution of aquatic invertebrate toxicity data is above the residues estimated from spray drift 

models for Grasshopper Program ground and aerial applications of diflubenzuron.

The Endangered Species Act section 7 pesticide consultation process between the U.S. Fish and 

Wildlife Service and the National Marine Fisheries Service (the Services, collectively) and the 

EPA specifically concerns FIFRA pesticide registration and reregistration in the United States, 

including all registered uses of a pesticide. The Grasshopper Program treatments employ 

methods and diflubenzuron application rates that result in substantially lower freshwater 

invertebrate exposures than the rate cited by the EPA and the commenter.

The EPA Preliminary Risk Assessment to Support Re-registration Review examines all legal uses 

of diflubenzuron, of which the Grasshopper Program constitutes a small fraction. APHIS is not 

obligated to examine all legal uses of the pesticide, but rather those contemplated by the 

program. The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS 

and Final Human Health and Ecological Risk Assessment for Diflubenzuron Rangeland 

Grasshopper and Mormon Cricket Suppression Applications are published. Characterization of 

risk to aquatic species from diflubenzuron applications was made by comparing the residue 

values in the exposure analysis from ground and aerial applications to the distribution of 

available acute and chronic fish toxicity data. Residue values were below the distribution of 

acute and chronic response data, suggesting that direct risk to aquatic species is not expected 

from diflubenzuron applications. More specifically, the distribution of aquatic invertebrate 

toxicity data is above the residues estimated from spray drift models for Grasshopper Program 

ground and aerial applications of diflubenzuron.

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Diflubenzuron Rangeland Grasshopper and 

Mormon Cricket Suppression Applications are published. The APHIS analysis noted 

Diflubenzuron has low toxicity and risk to some non-target terrestrial invertebrates, including 

pollinators such as honey bees.

Comment 113

APHIS received the following comment, “APHIS also acknowledges the pollinator impacts but 

attempts to diminish them without providing evidence on how or why they are not significant. It 

does not mention that Utah is home to an amazing abundance of native bees and pollinators, and 

improperly uses honeybees as a surrogate for pollinators, when native pollinators are far more 

sensitive due to the lack of hive buffering effects. This is not a pesticide that should be applied to 

broad swaths of land. It is highly toxic to far too many species of importance in Utah.”

Grasshopper IPM field studies have shown diflubenzuron to have a minimal impact on ants, 

spiders, predatory beetles, and scavenger beetles. There was no significant reduction in 

populations of these species from 7 to 76 days after treatment. Although ant populations 
105

exhibited declines of up to 50%, these reductions were temporary, and population recovery was 

described as immediate (Catangui et al., 1996). No significant reductions in flying non-target 

arthropods, including honey bees, were reported. Within one year of diflubenzuron applications 

in a rangeland environment, no significant reductions of bee predators, parasites or pollinators 

were observed for any level of diflubenzuron treatment (Catangui et al., 1996).

Comment 114

APHIS received the following comment, “Diflubenzuron is present in the excreted manure and 

urine of cattle where they range and the cumulative exposure must be considered in accordance 

with the ESA and NEPA’s mandate that an action agency take into account the environmental 

baseline”.

APHIS recognizes that some diflubenzuron residues may be present in urine and feces from 

cattle that feed on forage immediately after diflubenzuron treatment; however, this pathway of 

exposure is expected to be minor based on the proposed use pattern of diflubenzuron in the 

Program. Low application rates applied only once per season will reduce the amount of 

diflubenzuron present in manure and urine. In addition some metabolism of diflubenzuron 

occurs in animals and there will be further environmental degradation once excreted. 

Comment 115

APHIS received the following comment, “Malathion is considered “very highly toxic” to all 

aquatic and terrestrial invertebrates, as well as aquatic vertebrates such as fish. In addition 

indirect effects to taxa should be considered.’

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Malathion Rangeland Grasshopper and 

Mormon Cricket Suppression Applications are published. The risk assessment summarizes 

available laboratory and field collected aquatic and terrestrial effects data for malathion and 

then estimated risk based on conservative estimates of exposure. APHIS recognizes in the risk 

assessment that malathion can be toxic to sensitive non-target species however the effects have 

to be considered in relation to the potential for exposure to estimate risk as well as historical use 

in the Program which is negligible. 

Comment 116

APHIS received the following comment, “When exposed to malathion for longer periods of 

time, female birds displayed regressed ovaries, reduced number of hatched eggs and enlarged 

gizzards”.

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Malathion Rangeland Grasshopper and 

Mormon Cricket Suppression Applications are published. 

Several reproductive and developmental studies have been conducted with birds. The lowest 

median lethal dose to chicken embryos (eggs) was 3.99 mg per egg for 4-day embryos 

(Greenberg and LaHam, 1969). The median lethal concentration for field applications of 

malathion to mallard duck eggs was found to be 4.7 lbs a.i./acre (Hoffman and Eastin, 1981). 
106

This is approximately five times greater than the maximum rate for rangeland grasshopper 

(0.928 lbs a.i./acre), 7.6 times greater than the maximum APHIS application rate (0.619 lbs 

a.i./acre), and nearly 19 times greater than the average RAATs rate applied by APHIS. 

No effect on reproductive capacity of chickens was found at dietary concentrations as high as 

500 ppm in feed (Lillie, 1973). Based on the results from chronic reproduction studies using the 

bobwhite quail and mallard duck, the NOEC values were 110 and 1,200 ppm, respectively. The 

most sensitive endpoint in the quail study was regressed ovaries and reduced egg hatch at the 

next highest test concentration (350 ppm). The effect endpoint in the mallard study was growth 

and egg viability at the 2,400 ppm level Lowest Observed Effect Concentration (LOEC).

APHIS expects that direct avian chronic effects would be minimal for most species. The 

preferred use of RAATs during application reduces these risks by reducing residues on treated 

food items and reducing the probability that they will only feed on contaminated food items. In 

addition, malathion degrades quickly in the environment and residues on food items are not 

expected to persist.

Comment 117

APHIS received the following comments, “Malathion degrades into maloxon, which has been 

shown to be at least 22 times more toxic than the parent molecule”.

Similar to other organophosphate pesticides, malathion inhibits the enzyme AChE in the central 

and/or peripheral nervous system. Malathion is metabolized to malaoxon, which is the active 

AChE inhibiting metabolite. AChE inhibition is through phosphorylation of the serine residue at 

the active site of the enzyme, and leads to accumulation of acetylcholine and ultimately 

neurotoxicity. Malaoxon goes through detoxification with subsequent metabolism. Absorption 

and distribution of malathion and malaoxon are rapid with extensive metabolism and no 

accumulation in tissues.

Carboxylesterase detoxifies malathion and malaoxon to polar and water-soluble compounds for 

excretion. A rat metabolism study showed 80 to 90% of malathion excretion in the urine in the 

first 24 hours of exposure. Mammals are less sensitive to the effects of malathion than insects 

due to greater carboxylesterase activity resulting in less accumulation of malaoxon.

Available aquatic toxicity data show that malaoxon is approximately 1.5 to 6 times more toxic to 

fish and 1.8 to 93 times more toxic to amphibians. FMC (2019) reports that malaoxon is 0.80 to 

2.58 times more toxic to fish than malathion based on data that were determined to meet their 

criteria for acceptability. The conversion of malathion to malaoxon in aquatic environments can 

range from approximately 1.8 to 10% (CDPR, 1993; Bavcon et al., 2005; USEPA, 2012a). The 

estimated 24-hour EC50 malaoxon value for C. tentans is 5.4 μg/L. 

While APHIS assumed that malaoxon is most likely more toxic to aquatic invertebrates than the 

parent; however, due to its low percentage of occurrence in aquatic systems and its rapid 

breakdown, malaoxon is not anticipated to pose a greater aquatic risk when compared to 

malathion.

Comment 118

APHIS received the following comment, “A 2017 EPA biological evaluation also found that the 

use of malathion is likely to adversely affect 1778 out of 1835 listed species in the U.S. and 784 
107

out of 794 critical species’ habitats across the U.S. These findings were based on methodology 

recommended by the National Academy of Sciences. EPA found many Utah species were likely 

to be adversely affected, such as the yellow billed cuckoo. The U.S. Fish and Wildlife Service 

later drafted a biological opinion finding that malathion is likely to jeopardize the continued 

existence of 1284 threatened and endangered species. This is an astounding number of jeopardy 

calls for a single pesticide, and makes it even more astounding that APHIS would continue to 

consider using it for grasshopper and cricket control.”

The Endangered Species Act section 7 pesticide consultation process between EPA and the

Services specifically concerns FIFRA pesticide registration and reregistration in the United 

States, including all registered uses of the pesticide. The Grasshopper Program use of malathion 

comprised nearly none of the percent crop treated for rangeland in the past, and this remains 

APHIS’ expectation for the foreseeable future. Further, the Grasshopper Program consults 

directly with the Services to ensure program activities do not adversely affect protected species 

or their critical habitat.

Comment 119

APHIS received the following comment, “California’s Proposition 65 list of chemicals known to 

cause cancer and has been designated as having suggestive evidence of carcinogenicity by the 

EPA for instances of liver, oral palate mucosa and nasal respiratory epithelium tumor formation 

in mice.”

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and Final 

Human Health and Ecological Risk Assessment for Malathion Rangeland Grasshopper and 

Mormon Cricket Suppression Applications are published.

Comment 120

APHIS received a comment that, “EPA has determined that humans can be exposed to more than 

6 times the amount of malathion known to cause neurotoxicity from some legal uses of the 

pesticide. EPA also found that the current labelled uses of malathion may result in neurotoxic 

harms to those exposed to pesticide drift from aerial applications at labelled rates”. The 

commenter also pointed out that occupational applicators, mixers and loaders can be exposed to 

malathion through inhalation and dermal absorption at levels above what the EPA considers safe 

– even when using required personal protective equipment”

APHIS evaluated the risk to human health, including neurotoxicity data in its finale human 

health and ecological risk assessment. The risk assessment was prepared based on APHIS use 

patterns and Program mitigations that reduce risk to human health. APHIS is not obligated to 

ensure the EA and supporting documents analyze the risk posed by all legal uses of malathion, 

but rather the Grasshopper Program methods and application rates.

Malathion exposure to the general public is not expected from the program use based on label 

requirements and program standard operating procedures that prevent potential exposure. Only 

protected handlers may be in the area during application, and entry of the general public into 

the treated area is not allowed during the re-entry interval period. APHIS treatments are 

conducted on rural rangelands, where agriculture is a primary economic factor and widely 

scattered dwellings in low population density ranching communities are found. The program 
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requires pilots avoiding flights over congested areas, water bodies and other sensitive areas. 

Aerial applications are not allowed while school buses are operating in the treatment area; 

within 500 feet of schools or recreational facilities; when wind velocity exceeds 10 miles per 

hour (mph) (unless a lower wind speed is required under State law); when air turbulence could 

seriously affect the normal spray pattern; and/or temperature inversions could lead to off-site 

movement of spray. The Grasshopper Program also notifies residents within treatment areas, or 

their designated representatives, prior to application to reduce the potential for incidental 

exposure.

APHIS acknowledges workers in the program are the most likely human population segment to 

be exposed to malathion during grasshopper treatments. Occupational exposure to malathion 

may occur through inhalation and dermal contact during ground and aerial applications. Direct 

contact exposure from the application of a malathion ULV spray will be minimal with adherence 

to label requirements, the use of personal protective equipment (PPE), general safety hygiene 

practices, and restricted entry intervals into treated areas after application. EPA estimates of 

risk to workers is based on use patterns and rates that result in greater exposure to malathion 

than would occur in the APHIS program. APHIS evaluated the risk from program specific uses 

of malathion and demonstrated low risk to applicators. It should also be noted that historical 

malathion use in the Program is negligible further reducing the potential for any types of human 

health risk.

Comment 121

APHIS received the following comment, “APHIS touts EPA-approval as an indication that the 

pesticides that the agency proposes to use are safe. However, under our nation’s pesticide laws, 

EPA-approval is an indication that use of the pesticide won the agency’s cost-benefit analysis, 

and should not be misconstrued as a finding of safety.”

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and 

human health and ecological risk assessments for pesticides used by the Grasshopper Program 

are published. APHIS does not assert the FIFRA registration of the pesticides by the EPA 

demonstrates that the Grasshopper Program uses are safe. Instead the extensive risk analysis 

published by APHIS considered whether the suppression of grasshopper population will have 

significant environmental impacts, in accordance with NEPA.

Comment 122

APHIS received the following comment, “APHIS does not discuss or account for how pesticides 

impact overall soil health or the health of any organisms that reside in soil.”

The EA provided links to APHIS’ Grasshopper Program webpage where the 2019 EIS and 

HHERA for pesticides used by the Grasshopper Program are published. The HHERA contain 

extensive analysis of pesticide effects on terrestrial vertebrates, many of which reside in soil.

Comment 123

APHIS received the following comment, “Impacts on soil health can impact listed and non-listed 

plants by impacting nutrient cycling, soil oxygenation and soil water retention, as well as listed 

and non-listed animals that rely on plants or soil organisms for their survival.”
109

The Grasshopper Program applies pesticides in accordance with current label restrictions 

and program operational procedures that are mitigations to minimize significant exposure of 

soil, water and air to insecticides; grasshopper chemical treatments are not expected to persist 

or bioaccumulate in the environment. APHIS evaluated these effects in human health and 

ecological risk assessments that were prepared along with the final EIS for the grasshopper and 

Mormon cricket suppression program.

Comment 124

APHIS received the following comment, “Carbaryl was ranked as extremely toxic to earthworms 

in a lab test rating pesticide toxicity from relatively nontoxic, moderately toxic, very toxic, 

extremely toxic, and super toxic.”

The study was a comparison of the toxicology of 45 pesticide to determine the LC50. These 

studies exposed earthworms to varying concentrations of carbaryl to determine toxicological 

endpoints. Based on the extremely high doses, the impact to the survival of earthworms was not 

only unsurprising, but the object of the studies. APHIS would like to note this laboratory dosing 

procedure is not comparable to any exposure levels resulting from the use of carbaryl ultra-low 

volume sprays by the Grasshopper Program.

Comment 125

APHIS received the following comment, “A single application of carbaryl in a field study caused 

a 38% reduction in survival of total Lumbricidae, and a 78% reduction in total earthworms for at 

least 5 weeks.”

APHIS would like to note the “single application” involved applying carbaryl 6 times on a 

weekly interval to its assigned plots at the highest recommended dose (i.e. Sevin at 9.12 mg/m2), 

a rate that is greater than 16 times the Grasshopper ultra-low volume liquid rate (0.56 mg/m2). 

The Grasshopper program only makes one application per year, rather than six weekly 

treatments. Also, the field study found carbaryl significantly inhibited earthworm feeding activity 

for at least three weeks without leading to any earthworm death. 

In addition, the 78% reduction in earthworm casts noted in the comment resulted from an 

application of a combination of clothianidin and bifenthrin pesticides.

Comment 126

APHIS received the following comment, “Carbaryl significantly impacted the survival or 

population abundance of E. fetida, E. Andrei, Lumbricus terrestris, and Lumbricus rubellus, 

Aporrectodea caliginosa, and Allolobophora chlorotica.”

These studies exposed earthworms to varying concentrations of carbaryl to determine 

toxicological endpoints (NOEC, LC50). Based on the extremely high doses, the impact to the 

survival of earthworms was not only unsurprising, but the object of the studies. For example in 

Lima et. al. 2011, ten adult worms with individual fresh weight between 300 and 600 mg, were 

exposed to different carbaryl concentrations (20, 40, 60, 80, 100 mg/kg). APHIS would like to 
110

clarify the Grasshopper Program applies carbaryl ultra-low volume spray at a rate of half a 

pound active ingredient per acre. 

Comparison of the results of paper contact test with those obtained in soils clearly demonstrates 

that the contact test has no predictive values for the toxicity of an insecticide in soils, though it is 

important for the initial screening of the environmental chemicals. The differences between 

lowest and highest LC50 values of insecticides for M. posthuma and E. fetida in paper contact 

method were only 6.9 and 2.5-fold respectively while in soil they were over 38 and 26-fold. 

These data demonstrated that worms could tolerate higher concentrations in soil than on moist 

filter paper. This difference in the behavior of the insecticide may probably due to the rate of 

diffusion/uptake of insecticide from the medium into the body of the earthworm. It is well 

reported in the literature that insecticides are adsorbed on soil medium through strong binding 

by organic matter contents in soils (Davis, 1971, Van Gestel and Van Dis, 1988). Hence, the 

availability of insecticide for diffusion will be less from the soil than the impregnated filter 

paper. Contact filter paper test can be used as an initial screening technique to assess the 

relative toxicity of chemicals; however it fails to represent the situation in the soil ecosystem. 

Artificial soil test is more representative of the natural environment of earthworms and acute 

toxicity data on several insecticides can be used in the ecological risk assessment on soil 

ecosystems. 

Comment 127

APHIS received the following comment, “In another study, carbaryl induced an avoidance 

response in E. fetida. Soil structure changes were observed between the control and carbaryl 

treated sites, with higher treatments of carbaryl causing significantly more lumps in the soil due 

to earthworm inactivity.”

The commenter cited a study where worms were rinsed in tap water and transferred to the flasks 

containing 2 ml solution per worm. The flasks were gently tilted every 5 min and the exposure 

was terminated after 30 min. The worms were removed, rinsed in cold tap water and transferred 

to Petri dishes (five worms in each) containing soil but no pesticide. The worms were inspected 

at intervals during 80 days or until all the worms were dead or had recovered. The structure of 

the soil in the Petri dishes was observed in order to get an idea about the ability to work the soil 

after pesticide treatment. APHIS would like to note this laboratory dosing procedure is not 

comparable to any exposure scenario resulting from the use of carbaryl ultra-low volume sprays 

by the Grasshopper Program. 

Noteably, E. foetida could tolerate high concentrations of carbaryl without dying, although low 

concentrations severely affected its ability to work the soil or to disappear from the soil surface. 

The researchers believe the solutions were equivalent to 64, 32, 16, 8 and 4 mg/kg of pesticide, 

and found that carbaryl did not kill E. foetida in concentrations up to 64 mg/kg, from the 800 

mg/l solution. 

The avoidance test is a behavioral test with several advantages (simple, quick and cheap) but 

one drawback: this is not a measure of toxicity but rather a measure of repellence (Capowiez 

and Bérard, 2006), and thus is termed ‘measure of habitat modification’. As there is not always 
111

a direct relationship between avoidance and toxicity, an improvement of this test was recently 

proposed by Sanchez-Hernandez (2006). 

APHIS would like to clarify the Grasshopper Program applies carbaryl ultra-low volume spray 

at a rate of half a pound active ingredient per acre. If a cubic foot of rangeland soil weighs 75 

pounds, 1 acre (43,560 ft.2) of soil two inches deep would weigh 544,500 pounds, or 246,981 

kilograms. The maximum rate used by the Grasshopper Program to apply carbaryl as an ultralow volume spray is half a pound (226796 mg) active ingredient per acre. Therefore, the 

maximum concentration of 0.92 mg carbaryl spray per kg of soil could result from program 

applications. However, this analysis assumes none of the foliar spray settled on vegetation, and 

all of the carbaryl is instantaneously absorbed into the top two inches of soil. In addition, this 

maximum concentration was less than the lowest concentration which the researchers 

determined has significant effects on the reduction of the P. excavatus hatching rate (1.51 mg 

carbaryl per kg of soil). 

Comment 128

APHIS received the following comment, “Carbaryl negatively affected the biomass of E. Andrei, 

Perionyx excavates, total earthworms, and Lumbricus terrestris at a tenth of the recommended 

dose.”

The carbaryl concentrations used for each test species was chosen based on the LC50/EC50 

previously carried out and reported by Lima et al. (2011). This was also a toxicological endpoint 

study where the acute toxicity was determined by exposing the worms to a nominal concentration 

range of 20 to 100 mg/kg of technical grade carbaryl. The application rate was 850 grams per 

hectare of Sevin L85 which is equal to 1.12 pounds active ingredient carbaryl per acre, 

compared with Sevin XLR which is 44.1 % applied at half a pound active ingredient per acre by 

the Grasshopper Program. 

This study was primarily designed to validate the production of casts by earthworms as a 

biomarker for behavioral effects. While the significant effects in earthworm weight observed at 

low concentrations of carbaryl are concerning, Grasshopper program applications of foliar 

sprays are unlikely to result in the subsurface soil becoming saturated at the concentrations 

created in the laboratory. 

Comment 129

APHIS received the following comment, “A 60-99% reduction in earthworm biomass and 

density due to carbaryl treatment lasted 20 weeks. Burial of organic matter was also negatively 

affected. Casting activity of earthworms was reduced by 90%, and 71% and 81% after 3 and 5 

weeks, respectively.”

The researchers made two applications of carbaryl at a rate of 8 lbs ai/acre, 16 times greater 

than the maximum spray rate employed by the Grasshopper Program. The Grasshopper 

Program only makes one application per year. In addition, the foliar spray of ultra-low volume 

carbaryl over rangeland is unlikely to result in subsurface soil concentrations comparable to the 

direct turfgrass application made in this study.
112

Comment 130

APHIS received the following comment, “Carbaryl negatively affected growth in E. fetida, and 

the feeding rate of Diplocardia spp. Total cast production of L. terrestris was significantly 

impacted at one-tenth of the recommended field rate.”

The lowest test concentration that effected E. fetida resulted from saturation of the test media 

with 25 mg/kg of carbaryl. Another field study found a single application of carbaryl 

significantly inhibited earthworm (Diplocardia spp.) feeding activity for at least three weeks 

without leading to any earthworm death. APHIS would like to note the “single application” 

involved applying carbaryl 6 times on a weekly interval to its assigned plots at the highest 

recommended dose (i.e. Sevin at 9.12 mg/m2), a rate that is greater than 16 times the 

Grasshopper ultra-low volume liquid rate (0.5 lbs a.i./acre). The Grasshopper program only 

makes one application per year, rather than six weekly treatments.

Comment 131

APHIS received the following comment, “Reproduction of E. fetida, and Perionyx excavatus 

was negatively affected, with the hatching rate of P. excavatus reduced by 87% at sublethal 

concentrations lower than the recommended field rate. A total loss of burrowing was observed at 

4 and 8 mg/kg after 40 minutes and at 1 and 2 mg/kg after 80 minutes.”

The lowest test concentration that effected E. fetida resulted from saturation of the test media 

with 25 mg/kg of carbaryl. In another study the reduction of the P. excavatus hatching rate was 

observed at a concentration of 1.51 mg carbaryl per kg of soil. 

APHIS would like to clarify the Grasshopper Program applies carbaryl ultra-low volume spray 

at a rate of half a pound active ingredient per acre. If a cubic foot of rangeland soil weighs 75 

pounds, 1 acre (43,560 ft.2) of soil two inches deep would weigh 544,500 pounds, or 246,981 

kilograms. The maximum rate used by the Grasshopper Program to apply carbaryl as an ultralow volume spray is half a pound (226796 mg) active ingredient per acre. Therefore, the 

maximum concentration of 0.92 mg carbaryl spray per kg of soil could result from program 

applications (0.92 mg/kg). However, this analysis assumes none of the foliar spray settled on 

vegetation, and the carbaryl instantly absorbed into the top two inches of soil, thus mirroring the 

laboratory conditions. In addition, this maximum concentration was less than the lowest 

concentration which the researchers determined has significant effects on the reduction of the P. 

excavatus hatching rate (1.51 mg/kg).

Comment 132

APHIS received the following comment, “Morphological abnormalities and histological changes 

in E. andrei and M. posthuma were observed at very low, sublethal doses ranging from 0.24-1.20 

mg/kg and 0.5-1.20 mg/kg, respectively.”

The cited study did not test E. andrei but rather E. fetida a closely related species. The sublethal 

doses were derived from anecdotal observations during filter paper tests where concentrations 

were measured in μg/cm2 not mg/kg. APHIS would also like to note the researchers skepticism 

about toxicity tests where the worms are dosed on saturate filter paper. They wrote: 
113

Comparison of the results of paper contact test with those obtained in soils clearly demonstrates 

that the contact test has no predictive values for the toxicity of an insecticide in soils, though it is 

important for the initial screening of the environmental chemicals. The differences between 

lowest and highest LC50 values of insecticides for M. posthuma and E. fetida in paper contact 

method were only 6.9 and 2.5-fold respectively while in soil they were over 38 and 26-fold. 

These data demonstrated that worms could tolerate higher concentrations in soil than on moist 

filter paper. This difference in the behavior of the insecticide may probably due to the rate of 

diffusion/uptake of insecticide from the medium into the body of the earthworm. It is well 

reported in the literature that insecticides are adsorbed on soil medium through strong binding 

by organic matter contents in soils (Davis, 1971, Van Gestel and Van Dis, 1988). Hence, the 

availability of insecticide for diffusion will be less from the soil than the impregnated filter 

paper. Contact filter paper test can be used as an initial screening technique to assess the 

relative toxicity of chemicals; however it fails to represent the situation in the soil ecosystem. 

Artificial soil test is more representative of natural environment of earthworms and acute 

toxicity data on several insecticides can be used in the ecological risk assessment on soil 

ecosystem.

Comment 133

APHIS received the following comment, “Carbaryl impacted multiple biochemical biomarkers in 

E. andrei, including Acetylcholinesterase (AChE), methoxyresorufin-O-deethylase (MROD), and 

NADH and NADPH red cytochrome reductase.”

This study exposed earthworms to carbaryl in artificial soil at concentrations of 12, 25 and 50 

mg/kg. The research showed that carbaryl inhibited biotransformation enzyme activities but did 

not induce oxidative stress. Since carbaryl is a cholinesterases inhibitor changes detected in 

acetylcholinesterase activities were not surprising. The acetylcholinesterase activity reduction 

was not complete and the residual activity was stable whatever the dose or the exposure duration 

because of the presence in E. andrei of a non-inhibited, non-specific cholinesterases.

APHIS would like to note the lowest tested soil concentration of carbaryl that caused these 

effects (12 mg/kg) is approximately 12 times greater than the hypothetical concentrations that 

could result from Grasshopper Program treatments where none of the foliar ultra-low volume 

spray settles on vegetation, and the chemical is instantly and uniformly mixed into the top two 

inches of soil.

Comment 134

APHIS received the following comment, “AChE activity was inhibited in E. fetida in two 

studies, one of which resulted in muscular paralysis that directly impacted earthworm burrowing 

capabilities.”

In the first study, carbaryl stock solution was prepared in acetone and water to yield final 

concentrations of 1, 2, 4 and 8 parts per million. Five earthworms were individually exposed for 

5, 10, 20, 40 and 80 minute intervals in a 50ml beaker containing 2.0ml of various 

concentrations of test solution. The researchers asserted the test concentrations used in the study

were close to expected residues in the soil without any evidence or analysis as proof. They also 

used higher concentrations to exert significant inhibition of AChE activity and loss of burrowing 
114

in earthworms for establishing a dose effect “correlationship”. These higher exposures occurred 

after the individual worms were rinsed in tap water, their borrowing rate was measured, they 

were rinsed again, then placed back into the solution. Needless to say this systematic dosing in a 

pesticide solution does not match any exposure levels that could result from the application of 

ultra-low volume sprays. 

While the significant reduction in the ability of worms to burrow in soil was clearly evident at 

the lowest test concentration (1 ppm) and the earliest period of exposure (5 min), all worms were 

alive and fully recovered to normal behavior (no tremors, efficient burrowing) 18 hrs postexposure to 1 ppm carbaryl.

The second study cited by the commenter measured AChE responses in earthworms exposed to 

carbaryl on filter paper and in a soil media. APHIS has previously noted the difficultly 

extrapolating between filter paper toxicological tests to actual exposure scenarios relevant to the 

Grasshopper Program treatments. While the AChE inhibition reached significance after one day 

of exposure to 0.48 mg/kg carbaryl, the researchers did not conclude there was a reduction of 

burrowing capacity. Pure carbaryl was used as a liquid solution, while Zoril 5 was applied as a 

powder spread on the soil. Zoril 5 was thus more abundant on the superficial soil fraction, and 

was immediately in contact with the animals, whereas pure carbaryl penetrated into the soil and 

probably became bioavailable later. APHIS would also like to note the tested application rate of 

17.8 pounds per acre carbaryl 5% powder formulation (Zoril 5), that was estimated to result in a 

concentration of 4.29 mg/kg was nearly twice the maximum Grasshopper Program carbaryl bait 

rate and had no effect on earthworm AChE activity or the lysosomal membrane stability of E. 

andrei.

Comment 135

APHIS received the following comment, “In addition to earthworms, carbaryl negatively 

affected collembola population abundance and reproduction.”

The first and second studies cited by the commenter did not investigate carbaryl or collembola 

(Panda and Sahu, 2004, and Stepić, et al., 2013). The third paper cited used carbaryl as a toxic 

standard for comparison of the effects of other pesticides (Larson et al., 2012). The researchers 

applied carbaryl at a rate of 8.17 lbs a.i./acre. Researchers conducting the fourth study cited by 

the commenters (Potter et al., 1990) made two applications of carbaryl at the same rate of 8.17 

lbs ai/acre, 16 times the maximum rate used by the Grasshopper Program in ultra-low volume 

sprays. The Grasshopper Program only makes one application per year. Therefore this study 

used 32 times the carbaryl rate as the program. In addition, the foliar spray of ultra-low volume 

carbaryl over rangeland is unlikely to result in subsurface soil concentrations comparable to the 

direct turfgrass application made in this study.

The next study cited by the commenters (Joy and Chakravorty, 1991) investigated carbaryl 

toxicity to collembola. Adult specimens of Cyphoderus sp. and Xenylla sp. and Lancetoppia sp. 

were exposed to soils saturated with solutions ranging from 0.5 to 10 ml/l. Although they noted 

the standard agricultural doses of carbaryl 50 WP was 6.25 ml/l, the researchers did not 

provide a sufficient description of their methods for APHIS to make a valuable comparison of the 
115

exposure rates of the collembola in the experiment to potential exposure levels resulting from 

Grasshopper Program treatments.

The commenters cited another study to suggest carbaryl effected collembola reproduction. Three 

nominal concentrations of carbaryl (1, 4 and 7 mg/kg) in soil chemical behavior and toxicity 

were investigated at different temperatures. After 15 days from soil spiking, it was observed that 

carbaryl concentration in soil decreased to 30% and 33% of the initial concentration at the 

temperature extremes of 8 °C and 28 °C, respectively, and 22.8% of the initial concentration 

under a 20 °C temperature regime. The collembola survival and reproduction were significantly 

affected at 4 and 7 mg/kg concentrations, approximately 4 and 7 times greater than hypothetical 

soil concentrations resulting from Grasshopper Program ultra-low volume sprays (see previous 

comments for estimations parameters).

Comment 136

APHIS received the following comments, “Carbaryl also negatively impacted Prostigmata mites, 

and Tiphia vernalis, a wasp that feeds on scarab beetle larvae in the soil.”

In the first study cited carbaryl applied at a rate of 8.18 lbs ai/acre, greater than 16 times the 

Grasshopper Program’s maximum rate, as a toxic standard for comparison of various pesticide 

control efficacy. The effects on oribatid and mesostigmatid mites was not surprising or 

comparable to exposure levels resulting from applications of carbaryl ultra-low volume sprays. 

The commenters are mistaken, in that the research cited did not find effects on Tiphia vernalis 

(Helson et al., 1994).

Comment 137

APHIS received the following comment, “Carbaryl can be particularly toxic to ground-nesting 

bees, like Andrena erythronii, Bombus terrestris, and Bombus terricola.”

The commenters cited a toxicology study where carbaryl was applied topically to the thorax of 

the bees to investigate lethal doses and determine the concentration values in units of μg ai/g 

body weight and of μg ai/bee. This dosing method is not comparable to any exposure scenario 

resulting from the Grasshopper Program treatments using ultra-low volume sprays. APHIS 

would like to note that of the six insecticides tested, carbaryl had the second lowest relative 

toxicity, rather than as the commenter characterized being particularly toxic to ground-nesting 

bees. The researchers noted their study does not suggest an inherent, physiological relationship 

between size and pesticide susceptibility, and they further suggested that bumble bees may be at 

relatively little risk from carbaryl, contrary to the commenter’s suggestion of particular toxicity 

to Bombus terricola. The researchers elaborated carbaryl previously was not found to have 

significant effects on bumble bees, citing Hansen and Osgood (1984). 

The acute effects of carbaryl on B. terrestris were investigated for ingestion and topical contact 

in another cited study. The researchers found the calculated hazard ratio for oral exposures of 

carbaryl (309) was below the mean (1399) and the median (381) of the 14 pesticides tested and 

reported. Carbaryl was not found to be toxic through topical exposure at the “highest dose 
116

advised on the label.” The hazard ratio values permit only a comparative evaluation between the 

different active compounds tested.

Comment 138

APHIS received the following comment, “Carbaryl caused 100% mortality in Nomia melanderi 

when exposed to field-rate pesticide residues 3 hours post-application, 97% mortality with 8 

hours post-application, and 78% mortality 2 days post application. Carbaryl was more toxic than 

DDT.”

APHIS does not use DDT during Grasshopper Program treatments and does not agree the 

relative toxicity to carbaryl is a concern. The study cited by the commenter did not test carbaryl 

toxicity on bees, but rather included data from earlier studies. The application rate of carbaryl 

emulated in the earlier studies was I.0 lbs 80% wettable powder per acre, approximately twice 

the maximum ultra-low volume rate used by the Grasshopper Program. APHIS found the 

literature did not provide sufficient details for a reasonable comparison of the carbaryl 

application methods and rates for additional effects analysis.

Comment 139

APHIS received the following comment, “Bombus impatiens colony vitality (as measured by 

colony weight, worker weight) and the number of workers, honey pots, and brood chambers was 

reduced following carbaryl exposure.”

The researchers noted the confinement of the bee colonies within cages represent a worst case 

scenario in that the workers were caged on the sprayed plots for two or four weeks. Wholecolony consequences of a smaller proportion of the workers foraging on insecticidecontaminated weeds in an open system likely would be less severe. In addition, the researchers 

explained extent to which an insecticide is hazardous to pollinators is determined by its inherent 

toxicity as well as the formulation and manner in which it is applied (Stark et al. 1995). For 

example, pollen contamination, which can decimate honey bee colonies, may be exacerbated by 

wettable powder or microencapsulated formulations that have high affinity for binding to pollen 

(Johansen et al. 1983).

APHIS would also like to note the direct application of carbaryl to turfgrass at rates ten times 

greater (5.44 lbs ai/acre) than the maximum rate used by the Grasshopper Program (0.5 lbs 

ai/acre) is not comparable to ultra-low volume foliar spray treatments.

Comment 140

APHIS received the following comment, “In a laboratory study, chlorantraniliprole negatively 

inhibited the enzymes acetylcholinesterase and glutathione-S-transferase in Eisenia fetida.”
117

As previously stated, the Grasshopper Program will not be using chlorantraniliprole in Utah

during 2020. Therefore, any chlorantraniliprole exposure scenarios which the commenter is 

concerned about are not relevant at this time.

Comment 141

APHIS received the following comment, “Chlorantraniliprole negatively affected Folsomia 

candida (collembola) reproduction.”

As previously stated, the Grasshopper Program will not be using chlorantraniliprole in Utah

during 2020. Therefore any chlorantraniliprole exposure scenarios which the commenter is 

concerned about are not relevant at this time.

Comment 142

APHIS received the following comment, “Microscopic examination in an avoidance test 

revealed that the collembola were paralyzed from the chlorantraniliprole treatment and couldn't 

migrate, clarifying an observed avoidance at 1 mg/kg, but no avoidance at any higher 

concentrations. The authors note that chlorantraniliprole may be more toxic to non-target 

arthropods closely related to insects than to other soil invertebrates.”

As previously stated, the Grasshopper Program will not be using chlorantraniliprole in Utah 

during 2020. Therefore any chlorantraniliprole exposure scenarios which the commenter is 

concerned about are not relevant at this time.

Comment 143

APHIS received the following comment, “In the field, ground-nesting bumble bees (Bombus 

impatiens) treated with chlorantraniliprole consumed less pollen than control bees.”

As previously stated, the Grasshopper Program will not be using chlorantraniliprole in Utah

during 2020. Therefore any chlorantraniliprole exposure scenarios which the commenter is 

concerned about are not relevant at this time.

Comment 144

APHIS received the following comment, “Staphylinidae (Coleoptera) population abundance was 

slightly but significantly suppressed.”

As previously stated, the Grasshopper Program will not be using chlorantraniliprole in Utah

during 2020. Therefore any chlorantraniliprole exposure scenarios which the commenter is 

concerned about are not relevant at this time.

Comment 145
118

APHIS received the following comment, “After one application of diflubenzuron, myriapoda 

populations were nearly eradicated (73% reduction), gamasina mites were reduced by 40%, and 

uropodina mites were reduced by 57%. Diflubenzuron treatment reduced the populations of 

oribatid mites, prostigmata mites, and soil arthropod larvae, mostly comprised of coleoptera and 

diptera, by nearly 15%.”

The cited research does not suggest Grasshopper Program applications of diflubenzuron will 

result in significant impacts to soil microfauna. The researchers applied diflubenzuron to plots 

and investigated the effects on Collembola, Insecta, Myriapoda and 4 groups of mites for 6 

months. The observed taxa abundance fluctuated seasonally, but for a majority of taxa no 

significant differences were noticed between the control and exposed plots. The total number of 

microarthropods was insignificantly lower in exposed groups. While myriapods were the only 

taxon that was close to extinction after a single exposure to diflubenzuron the pesticide was 

applied directly to the soil at a rate four times greater than the maximum conventional 

application rate used by the program. The researchers noted their data proved that soil has some 

buffering capacity, and this fact should always be taken into consideration when estimating the 

risk for the environment.

Comment 146

APHIS received the following comment, “In a field study, collembola populations were 

negatively affected by diflubenzuron and did not recover for one and a half years. The 

earthworms, Dendrobaena rubidus and Lumbricus rubellus were reduced in plots treated with 

concentrations of diflubenzuron at half the recommended field rate. Gamasid and oribatid mite 

populations were additionally reduced, and oribatida were observed migrating into deeper soil 

layers to avoid the pesticide.”

The commenters have cited a study where the researchers applied two treatments of 

diflubenzuron wettable powder directly to the forest floor at a rate 37% higher than the 

maximum rate used by the Grasshopper Program. Contrary to the characterization of the 

research findings presented by the commenter, the mean population size of earthworms did not 

differ significantly during the potential effect phase between control and the 137% of the 

Grasshopper Program rate treatment plot. The populations of the enchytraeid species E. 

buchholzi, E. minutus, E. norvegicus and M. clavata did not respond to this 137% treatment of 

diflubenzuron applied twice per growing season. While the number of oribatids decreased after 

the application of the insecticides in all experimental plots including the control, these 

differences were only significant in the plot were diflubenzuron was applied directly to the forest 

floor at a rate nearly 14 times greater than the maximum Grasshopper Program rate. 

Where Brachychthoniid populations declined significantly in the diflubenzuron treated plots, the 

reductions were in part compensated by changes in numbers of the dominant genus Oppiella. 

The researchers explained the half-life of diflubenzuron in soil is reported to range from 1 to 27 

days, which was borne out by their data. Therefore, residue accumulations in the organic layer 

is unlikely if diflubenzuron is only applied once per year. 

The researchers acknowledged there could be several potential reasons for differences in 

populations of soil invertebrates between the study plots. First, the plots could differ independent 

of any treatment. APHIS agrees this is a reasonable interpretation because of the small sample 
119

sizes during the pre-application, potential effect and early recovery data recording phases (I.e. 

four plots including the control, five sample dates, two replicates, n=10). The testing of natural 

variation during the 9 month pre-application phase may not have been sufficient. They decided 

to interpret deviations as a response to a treatment, if numbers in the potential effect phase were 

different to those in the other phases in the same plot and to the control in the same phase.

Comment 147

APHIS received the following comment, “Diflubenzuron treatment resulted in a total loss in 

brood production of male Bombus terrestris, and 100% inhibition of egg hatching success and 

larval growth. Transovarial transport and accumulation of the pesticide in deposited eggs 

explained the total loss of reproduction. Abnormal cuticle formation, which can lead to 

mechanical weakness and death, was observed in dead larvae that worker bees were observed 

removing from treated nests.”

The commenters have cited a study where the B. terrestris was directly dosed with diflubenzuron 

to test acute toxicity. Adult worker bees were exposed via contact by topical application and 

orally via drinking sugarwater and by eating pollen. For contact application, 50 μL of the 

aqueous concentration was topically applied to the dorsal thorax of each worker with a 

micropipette. The worker bumblebees were also provided diflubenzuron treated sugar-water for 

drinking for 11 weeks. Bumblebees can also be exposed orally to pollen sprayed until saturation 

with a diflubenzuron concentration. Both the sugar water and pollen were supplied for unlimited 

oral consumption. 

While APHIS acknowledges the effects of acute diflubenzuron exposures on the egg hatching and 

larval stages of bumble bees is a concern, the direct dosing conducted by the researchers is not 

comparable to any exposure levels that could result from the Grasshopper Program 

diflubenzuron ultra-low volume spray treatments. 

In addition, APHIS would like to note, no acute mortality was observed after topical application, 

nor after oral exposure to treated sugar-water or treated pollen. In all cases, the number of dead 

worker bees in the treated nests over a period of 11 weeks was not above that of the control 

groups using water (0–10%).

Comment 148

APHIS received the following comment, “Multiple studies have observed AChE inhibition in 

earthworms when malathion was applied. Malathion effected the sperm count and viability and 

testicular histology of male E. fetida at sublethal concentrations, potentially impairing population 

abundance.”

APHIS agrees with the commenter that the main acute poisonous effect of malathion is the 

inhibition of the enzyme acetylcholinesterase, and acute poisoning such as was carried out by 

the researchers with direct exposures to high concentrations of the pesticide could occur in many 

types of organisms including earthworms. The direct dosing of earthworms to validate their use 

as toxicological test organisms does not mimic any exposure scenario resulting from the 

Grasshopper Program use of ultra-low volume sprays of malathion. 
120

To further illustrate the disparity between exposures resulting from laboratory toxicity tests and 

grasshopper suppression treatments, APHIS would like to note the lowest tested concentration 

was 80 mg/kg of soil. The Grasshopper Program applies malathion ultra-low volume spray at a 

rate of 0.62 pounds active ingredient per acre. If a cubic foot of rangeland soil weighs 75 

pounds, 1 acre (43,560 ft.2) of soil two inches deep would weigh 544,500 pounds, or 246,981 

kilograms. The maximum rate used by the Grasshopper Program to apply malathion as an ultralow volume spray is 0.62 pounds (281227 mg) active ingredient per acre. Therefore, the 

maximum concentration of 1.14 mg malathion spray per kg of soil could result from program 

applications. However, this analysis assumes none of the foliar spray settled on vegetation, and 

the malathion instantly absorbed into the top two inches of soil. This hypothetical soil 

concentration resulting from ultra-low volume sprays should not be compared in a risk analysis 

with the 80 mg/kg tested for sub-lethal effects in the laboratory.

Comment 149

APHIS received the following comment, “In addition to AChE, the biochemical biomarkers 

glutathione-S-transferase, and catalase were also inhibited by malathion in studies with Eisenia 

Andrei. Malathion has also been observed to negatively affect the reproduction of E. andrei.”

The commenters have cited research that confirms malathion inhibits AChE in earthworms. 

While APHIS does not dispute this effect, the agency doubts such effects could result in 

significant impacts. Notably the researchers found the inhibition period suggests lengthening of 

retreatment intervals to 45 days is the appropriate conclusion from the study. APHIS only makes 

one suppression treatment per year to grasshopper infested rangeland.

Comment 150

APHIS received the following comment, “Malathion had a severe effect on AChE activity in 

Drawida willsi. Growth, casting activity, and respiration of D. willsi was negatively affected by 

malathion treatment and did not recover for 75, 60, and 30 days, respectively.”

The commenters have cited research that confirms malathion inhibits AChE in earthworms. 

While APHIS does not dispute this effect, the agency doubts these biomarker effects could result 

in significant impacts. 

The study cited by the commenters described malathion’s recommended agricultural dose as 2.7 

to 4.0 kg ai/ha and calculated the equivalent 1.5 to 2.22 mg ai/kg soil, which APHIS would like 

to note are comparable to the concentration estimation provided above. However the toxicity 

results for a single dose of malathion were reported for a concentration of 2.2 mg ai/kg which is 

equivalent to double the dose of 4.0 kg ai/acre, nearly six times the application rate used by the 

Grasshopper Program. 

Comment 151

APHIS received the following comment, “In addition to AChE, the biochemical biomarkers 

glutathione-S-transferase, and catalase were also inhibited by malathion in studies with E. andrei. 

Malathion has also been observed to negatively affect the reproduction of E. andrei.”
121

The commenters have cited two toxicology studies where earthworms were placed in test tubes 

lined with malathion saturated filter paper to determine acute effect concentrations, extrapolated 

from the biomarker, AChE reduction. The dosing methods and units of ug ai/cm2 are not 

comparable to any exposure levels that could result from the application of malathion ultra-low 

sprays by the Grasshopper Program. The study cited by the commenter did not make any 

conclusions regarding malathion affecting reproduction of E. andrei. 

Comment 152

APHIS received the following comment, “In a lab test rating the toxicity of 45 pesticides to E. 

fetida, malathion was ranked moderately toxic with an LC50 of 114.4 ug/cm.”

The study cited by the commenter was a comparison of the toxicology of 45 pesticide to 

determine the LC50. These studies exposed earthworms to varying concentrations of carbaryl to 

determine toxicological endpoints. Based on the extremely high doses, the impact to the survival 

of earthworms was not only unsurprising, but the object of the studies. APHIS would like to note 

this laboratory dosing procedure is not comparable to any exposure scenario resulting from the 

use of malathion ultra-low volume sprays by the Grasshopper Program.

Comment 153

APHIS received the following comment, “Malathion caused a 40% decrease in survival of the 

ground-nesting bee, Nomia melanderi.”

The study cited by the commenter did not test malathion toxicity on bees, but rather included 

data from earlier studies. The application rate of malathion emulated in the earlier studies was 

I.0 lb of emulsifiable concentrate per acre, significantly greater than the maximum ultra-low 

volume rate used by the Grasshopper Program. APHIS found the literature did not provide 

sufficient details for a reasonable comparison of the malathion application methods and rates 

for additional effects analysis.

Comment 154

APHIS received the following comment, “The EAs an agency action subject to this consultation 

requirement, must be prepared “concurrently with and integrated with environmental impact 

analyses . . . required by . . . the Endangered Species Act of 1973.”

The commenter has confused the EAs prepared by APHIS for the Grasshopper Program in Utah

with other environmental risk analysis documents. See the response to comment 155, below. 

Comment 155

APHIS received the following comment, “In order to properly provide information to the public 

for commenting on the EIS and the EAs, the section 7 process should be completed prior to the 

completion of NEPA. APHIS must ensure that consultation addresses all species and critical 

habitat that could be directly and indirectly affected by the proposed project.” The comment also 

states that APHIS has not complied with its responsibilities under Section 7 of the ESA. 

Concerns were raised about specific species in Utah such as the yellow-billed cuckoo,

southwestern willow flycatcher and other listed and sensitive species.
122

As stated in the final EIS APHIS has completed programmatic consultation with the National 

Marine Fisheries Service (NMFS). APHIS has reinitiated programmatic consultation with 

NMFS to include chlorantraniliprole. In the interim APHIS will consult with NMFS at the State 

level if there is a proposal to apply chlorantraniliprole. The NMFS consultation does not apply 

to species in Utah since there are no federally listed species under NMFS jurisdiction; however,

the information was provided in response to comments regarding the final EIS. APHIS 

submitted a programmatic biological assessment to the FWS in 2015. APHIS is currently 

working with the FWS to update and complete the biological assessment and receive 

concurrence. The intent of the programmatic biological assessment is to provide consistent 

mitigation measures for listed species that may co-occur with Program treatments. Consultation 

with the FWS is still being completed at the local level prior to any treatments. No APHIS 

treatments are made in States without prior concurrence from the FWS or NMFS regarding 

federally-listed species. This information is also summarized in the final EIS.

APHIS has on-going consultation with the FWS on federally-listed species that may occur within 

the counties or areas where grasshopper and Mormon cricket treatments may be required. 

APHIS has worked closely with the FWS to determine the application of protection measures and 

where those measures should be applied prior to any treatments. APHIS also evaluated the 

potential direct and indirect impacts to non-target species which is summarized in the final 

human health and ecological risk assessments for each insecticide. 

Comment 156

APHIS received the following comment, “Because the site specific project is vague and fails to 

describe the breadth of cumulative effects it cannot comply with the ESA or NEPA. Any 

discrepancy between the project described in the EAs and the documents provided to the U.S. 

Fish and Wildlife Service must be rectified.”

APHIS believes that the site specific information described in the draft EA is adequate to allow 

completion of Section 7 compliance with the FWS. Information discussed in the draft EA is also 

shared with the FWS during consultation so there is no discrepancy between actions described in 

the EA and other documents. 

Comment 157

APHIS received the following comment, “APHIS would unlawfully be making an irreversible or 

irretrievable commitment of resources if it allows insecticide application on rangeland 

grasshoppers and/or Mormon crickets to occur prior to receipt of a final biological opinion from 

FWS. APHIS will run afoul of its Section 7 ESA requirements if it chooses to move forward, and 

it will also likely violate the ESA’s prohibition against the take of endangered species as 

described by Section 9 of the statute if it moves forward with this project prior to properly 

completing its Section 7 duties. Even where there is a letter of concurrence, APHIS would still 

fail to comply with the ESA because informal consultation does not authorize the incidental take 

of federally-listed species nor does it authorize the adverse modification or destruction of critical 

habitat.”
123

APHIS in Utah and the state office of the USFWS, 15 years ago, together developed speciesspecific protective measures and buffers for all T&E and proposed T&E species in Utah relative 

to the Utah Rangeland Grasshopper/Mormon cricket Suppression Program. Based on APHIS’s 

biological assessment, the USFWS concurred with APHIS’s “’not likely to adversely affect’ 

determination for threatened and endangered species and critical habitat for the subject 

project.” Since that time APHIS has kept updated its T&E list through consultation with the 

USFWS and has continued to assign together species-specific protective measures and buffers 

that protect the aforementioned species from potential adverse impacts from 

grasshopper/Mormon cricket suppression projects.

The commenter errs in assuming that any of APHIS’s projects will result in “incidental take” 

since the agreed-upon mitigation measures, included in Appendix 3 of each EA, were developed 

to preclude such. Neither will APHIS projects modify or destroy critical habitat. Quite the 

contrary, the failure to suppress severe grasshopper infestations pose the real inherent risk of 

“take” of T&E species and “adverse modification or destruction of critical habitat” due to 

overfeeding, often causing defoliation of nurse plants and consumption of sensitive plants, 

themselves. 

Comment 158

APHIS has received the following comment: “If APHIS is relying on a letter of concurrence with the 

FWS, it failed to provide it in the six EAs and must reopen the comment period for these EAs so that 

the public may view them and consider their contents in commenting on this proposal. 

The EA’s mysteriously state that “the proposed APHIS program will not likely adversely effect this 

species.” These conclusive statements, unsupported by documentation of any manner of ESA 

consultation, fail to meet the ESA’s requirements.”

See response to Comment 157.

Comment 159

APHIS has received the following comment: “APHIS has failed to meet its consultation requirements 

with the U.S. Fish and Wildlife Service. There is no programmatic biological opinion that covers 

these EAs. There is no biological opinion that covers the pesticides that are included in these EAs, or 

the species that have been listed since the 1995 Biological Opinion was completed. And, conditions 

have changed substantially enough that there is no question that the 1995 Biological Opinion is 

inadequate.” 

During the lengthy Local FWS Section 7 consultations which have taken place throughout the 

years, and regarding each of the 45 species listed as T&E and with critical habitat and all 

species of concern within the state, each species was discussed point by point. APHIS protective 

measures were determined using the FWS Recommended Protection Measures for Pesticide 

Applications.

Comment 160

APHIS has received from the commenter a list of T&E and sensitive species called, “Description 

of Endangered Species at Issue.” Potential impacts from pesticides are addressed within these 

paragraphs which the commenter claims that the APHIS grasshopper program might cause to 

these sensitive species.
124

APHIS completed informal consultation with the FWS regarding the Program at the State level

years ago after having developed agreed-upon mitigation measures for all T&E and Proposed 

T&E species relative to GH/MC suppression projects in Utah. The USFWS has concurred with 

APHIS’s assessment that the Utah GH/MC suppression program is not likely to adversely affect 

species of concern. That consultation/concurrence has continued throughout the years as the 

T&E list has evolved. Formal consultation has not been required since the FWS has concurred 

with the APHIS determinations of not likely to adversely affect, including any associated critical 

habitat. Since APHIS has complied with Section 7 through informal consultation, APHIS has not 

violated Section 9 of the ESA, nor has formal consultation been required resulting in a biological 

opinion.

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