ACTION ALERT: Comments Needed on the EPA’s Vulnerable Listed Species Pilot Project

Deadline: August 6

The Environmental Protection Agency (EPA) has drafted a potentially devastating proposal for growers that would effectively ban or restrict pesticide use in parts of the mid and south Willamette Valley.

The Oregon Seed Council submitted this comment letter on the proposal. Available here.

We are asking growers to submit comments as well to illustrate the impact of this proposal on the seed industry. A draft template is available here.

Please submit comments here by August 6.


Proposed Mitigation Area:
Click here for EPA map

Draft Plan:
Click here to download and review the draft pilot project plan

Oregonians for Food and Shelter (OFS) Talking Point Resource:
Click here to view a talking point resource from Oregon Seed Council partner OFS if you would like additional information to tailor your comments.

This proposal is called the Vulnerable Species Pilot project. This plan is EPA’s approach to adopting protections for what they consider the most vulnerable species while they wait to complete their work on the broader Endangered Species Act (ESA) consultations for these species. There are 27 species included in the pilot.

EPA has identified critical habitat areas for each of these species, and within these areas, EPA is suggesting either 1) mitigations, which would apply broadly to all conventional outdoor-use pesticides, or in some areas 2) pesticide use limitation areas, where use restrictions would be imposed on ALL conventional outdoor-use pesticides except for rodenticides and avicides, which will be addressed in another EPA plan.

One of the 27 species included in this draft plan is the Taylor’s checkerspot butterfly, which has two areas of critical habitat in Oregon identified by EPA. The EPA is proposing these two habitat areas in Oregon as a pesticide use limitation area – in other words, no conventional outdoor pesticides would be allowed within these areas.

This would significantly impact acreage of agriculture in both the mid and south Willamette Valley.

Precedent and timeframe are of considerable issue. It often can take decades to work through such processes.

If you have any questions, feel free to reach out to me.

We appreciate your help!

Megan Chuinard
Executive Director
Oregon Seed Council