Montague, Kathryn V. From: Montague, Kathryn V
. Sent: To: Tuesday, March 31 , 2015 12:40 PM Montague, Kathryn V. Subject: FW: 2,4 -D cho lin e and Eskimo curlew effects determ i nation 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: Es kimo 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. E dward @ 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. Us e 

### ofthe pesti cide will limited to ground spray application using a fo rmulation 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 itse lf).

1Our 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 curlew 1 , we have determined that individuals ofthe 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 cons istent with a determination ofNot 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 ofPesticide Program s United States Environmental protection Agency 703-305-6449

1 Eskimo Curlew (Numenius boreali s) 5

- Year Review: Summary and Evaluation, August 31 , 2011 , U.S. Fish and Wildlife Service, Fairbanks Fish and Wildlife Field Office , Fairbanks Alaska

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