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prerequisite for defensible “Jeopardy” and “No Jeopardy” determinations. EPA and the 

services must assess the adverse impacts of imazapyr in critical habitat.

Response: EPA has reviewed the comments from CBD on the registration review docket 

opening for imazapyr and plans to address many of the concerns raised by CBD as part of the 

implementation plan for assessing the risks of pesticides to listed species based on the 

recommendations of the April 2013 National Academy of Sciences (NAS) report. EPA will 

address concerns specific to imazapyr in connection with the development of its final registration 

review decision for this pesticide.

In November 2013, the EPA, along with the Services and the USDA, released a summary of 

their joint Interim Approaches for assessing risks to endangered and threatened (listed) species 

from pesticides. The Interim Approaches were developed jointly by the agencies in response to 

the NAS recommendations and reflect a common approach to risk assessment shared by the 

agencies as a way of addressing scientific differences between the EPA and the Services. The 

NAS report outlines recommendations on specific scientific and technical issues related to the 

development of pesticide risk assessments that EPA and the Services must conduct in connection 

with their obligations under the ESA and FIFRA. 

The joint Interim Approaches were released prior to a stakeholder workshop held on November 

15, 2013. In addition, the EPA presented the joint Interim Approaches at the December 2013 

Pesticide Program Dialogue Committee (PPDC) and State-FIFRA Issues Research and 

Evaluation Group (SFIREG) meetings. The agencies also held stakeholder workshops in April 

and October 2014, allowing additional opportunities for stakeholders to comment on the Interim 

Approaches. Additional workshops are planned to enhance stakeholder involvement. As part of 

a phased, iterative process for developing the Interim Approaches, the agencies will also 

consider public comments on the Interim Approaches in connection with the development of 

upcoming registration review decisions. The details of the joint Interim Approaches are 

contained in the white paper, Interim Approaches for National-Level Pesticide Endangered 

Species Act Assessments Based on the Recommendations of the National Academy of Sciences 

April 2013 Report, dated November 1, 2013. 

Given that the agencies are continuing to develop and work toward implementation of the 

Interim Approaches to assess the potential risks of pesticides to listed species and their 

designated critical habitat, the ecological problem formulation supporting this Final Work Plan 

for imazapyr does not describe the specific ESA analysis, including effects determinations for 

specific listed species or designated critical habitat, to be conducted during registration review. 

In the ecological problem formulation document for imazapyr, EPA described the screeninglevel risk assessment to determine the potential effects of imazapyr on all taxa of non-target 

wildlife and plants, which will assume that listed species and their designated critical habitats 

may be present in the vicinity of the application of imazapyr. This screening-level assessment 

will allow EPA to focus its future evaluations on the types of species where the potential for 

effects exists once the scientific methods being developed by the agencies have been fully vetted. 

While the agencies continue to develop a common method for ESA analysis, the planned 

screening-level risk assessment for the registration review of imazapyr will describe the level of 

ESA analysis completed for this particular registration review case. Once the agencies have fully 

developed and implemented the scientific methods necessary to complete risk assessments for 
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endangered and threatened (listed) species and their designated critical habitats, these methods 

will be applied to subsequent analyses for imazapyr as part of completing this registration 

review.