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

services must assess the adverse im pacts 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 concer ns 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 Acad emy of Sciences (NAS) report. EPA will address concerns specific to imazapyr in connecti on with the development of its final registration review decision for this pesticide.

In November 2013, the EPA, along with the Serv ices 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 a pproach 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 a ssessments that EPA and the Services must conduct in connection with their obligations un der the ESA and FIFRA.

The joint Interim Approaches were released prio r to a stakeholder workshop held on November 15, 2013. In addition, the EPA presented the join t 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 fo r 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 Appro aches 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 Natio nal-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 de velop and work toward implementation of the Interim Approaches to assess the potential risk s of pesticides to listed species and their designated critical habitat, the ecological probl em formulation supporting this Final Work Plan for imazapyr does not describe the specific ESA analysis, including effects determinations for specific listed species or designate d critical habitat, to be cond ucted during registration review. In the ecological problem formulation docum ent for imazapyr, EPA described the screeninglevel risk assessment to determin e the potential effects of ima zapyr 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 regist ration review case. Once the agencies have fully developed and implemented the scientific methods necessary to complete risk assessments for3 endangered and threatened (listed) species and their designated cr itical habitats, these methods will be applied to subsequent analyses for imazapyr as part of completing this registration

review.