Proposed changes to protect endangered species from pesticide use “would greatly inhibit agriculture on a significant amount of land,” the American Soybean Association says. 

EPA's Vulnerable Species Pilot Project (VSPP) proposes eliminating or restricting pesticide use to protect 27 species, using a framework that would allow the agency to avoid making separate determinations that examine the impacts of each pesticide.

The strategy is in response to numerous court decisions that have chided the agency for not moving quickly enough under the Endangered Species Act to evaluate the impacts of crop protection chemicals. In addition to the VSPP, EPA has proposed a herbicide strategy that takes a similar approach.

EPA's proposal would rely on avoidance and mitigation. Avoidance areas, the most restrictive, require advance coordination with the Fish and Wildlife Service before applications.

Mitigation to address runoff differs by crop type. Rice growers, for instance, must implement four mitigation measures, but “have no discretion in selecting the qualifying practices,” since only four mitigation measures are available, the analysis by ASA economist Scott Gerlt says.

Field crop growers need to choose four out of 13 options but will face high costs to implement them, $37 per acre annually for cover crops, $330 for a riparian buffer, $233 for vegetative filter strips, and $150 per treated acre for a controlled drainage structure, according to the analysis. 

The VSPP also applies to organic farming, including some organic-approved pesticides. Conservation practices like no-till farming and cover crop termination also rely on herbicides, increasing expenses for farms in VSPP areas, even for organic producers.

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In all, the VSPP would affect about 13 million acres of cropland, including 5 million acres of soybeans, ASA said.

The pilot project proposal covers significant soybean acreage in Arkansas, Nebraska, Minnesota, Iowa, Missouri, Wisconsin, Illinois and Indiana. 

“EPA’s proposed broad approach to ESA compliance will likely result in hundreds of thousands to millions of acres of farmland being removed from production due to an outright inability to use pesticides or due to the cost of mitigations exceeding the agricultural productivity of the land,” the analysis says. 

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