Montague, Kathryn V. 

From: Montague, Kathryn V. 

Sent: 

To: 

Tuesday, March 31, 2015 12:40 PM 

Montague, Kathryn V. 

Subject: FW: 2,4-D choline and Eskimo curlew effects determination concurrence 

From: Swem, Ted [mailto:ted swem@fws.gov] 

Sent: Friday, March 27, 2015 2:03PM 

To: Odenkirchen, Edward 

Cc: Brady, Donald; Pease, Anita; Cowles, James 

Subject: Re: Eskimo Curlew 

Dr. Odenkirchen: 

We concur with your evaluation and conclusion regarding the potential for effects of the use of2,4-D on 

Eskimo Curlew. Unfortunately, the species is very likely extinct, and thus effects to the species are extremely 

unlikely to occur, if not impossible, and can be considered discountable. 

Thank you, 

Ted Swem 

Branch Chief, Endangered Species 

Fairbanks Fish and Wildlife Field Office 

U.S. Fish and Wildlife Service 

101 12th Ave, Rm 110 

Fairbanks, AK 99701 

On Fri, Mar 27,2015 at 9:56AM, Odenkirchen, Edward <Odenkirchen.Edward@epa.gov> wrote: 

Ted Swem, Chief, 

Endangered Species Branch, 

Fairbanks Fish and Wildlife Field Office, 

US Fish and Wildlife Service (907) 456-0441 

Dear Mr. Swem 

The USEP A Office of Pesticide Programs is in the process of making an effects determination for the 

registration of the herbicide 2,4-D choline on com and soybean fields in Texas, Nebraska and Oklahoma. Use 

of the pesticide will limited to ground spray application using a formulation and spray equipment in · 

combination to spray drift setbacks that result in pesticide application areas of concern limited to only the 

actual on-field treatment site (the targeted com or soybean field itself). 

1 
Our review of available species location information suggests a potential for a migrant Eskimo curlew 

(Numenius borealis) passing through Texas, Nebraska and Oklahoma to encounter a treated field with 2,4-D 

choline residues. Our analysis indicates that if such an encounter occurred, the residue levels that would 

trigger a concern for adverse effects to the bird. However, in reviewing the available information on the status 

of the Eskimo curlew1

, we have determined that individuals of the species are extremely rare. This rarity of 

individuals indicates to us that the chance of an individual curlew to encounter a 2,4-D choline treated com or 

soybean field would be extremely unlikely to occur. Therefore any effects of2,4-D choline to an Eskimo 

curlew would be extremely unlikely to occur. 

An effect that is extremely unlikely to occur would be considered discountable in regards to an effects 

determination and would be consistent with a determination of Not Likely to Adversely Affect. We therefore 

have determined that the proposed use of2,4-D choline on corn and soybeans in Texas, Nebraska and 

Oklahoma will Not Likely to Adversely Affect individual Eskimo curlews. 

Does the United States Fish and Wildlife Service concur with our effects determination? 

Sincerely, 

Edward W. Odenkirchen, Ph.D 

Senior Science Advisor 

Environmental fated and Effects Division 

Office of Pesticide Programs 

United States Environmental protection Agency 

703-305-6449 

1 Eskimo Curlew (Numenius borealis) 5-Year Review: Summary and Evaluation, August 31 , 2011 , U.S. Fish 

and Wildlife Service, Fairbanks Fish and Wildlife Field Office, Fairbanks Alaska 

2