The U.S. Environmental Protection Agency (EPA) has introduced the Vulnerable Species Action Plan (VSAP), effective September 2024. This comprehensive strategy aims to reduce pesticide exposure for 27 federally listed endangered species in the contiguous U.S. The plan is a significant step in mitigating population-level impacts on wildlife, targeting species particularly susceptible to chemical exposure.
What is the Vulnerable Species Action Plan?
The Vulnerable Species Action Plan (VSAP) is a newly launched initiative by the EPA designed to protect endangered species vulnerable to pesticide exposure. The plan applies to non-residential, outdoor pesticide uses across the contiguous United States (CONUS) and prioritizes the conservation of species at high risk of population decline due to chemical exposure.
The EPA developed the VSAP in response to the growing concern over how pesticides, including herbicides and insecticides, impact wildlife and plants that are already facing extinction risks. The plan builds on prior initiatives like the Herbicide Strategy and Insecticide Strategy while addressing pesticide risks to species not covered by these frameworks.
Key Objectives of the Plan
The Vulnerable Species Action Plan focuses on reducing the stressor of pesticide exposure for endangered species, aiding in their conservation and recovery. The EPA aims to achieve this by identifying mitigation measures that can be implemented during pesticide registration or review. The plan includes protections for various exposure pathways, such as spray drift, runoff, and less common routes like bioaccumulation and volatilization.
The plan also establishes Pesticide Use Limitation Areas (PULAs), geographic zones where certain pesticide use restrictions will apply to protect vulnerable species from exposure.
The Three-Step Framework
The Vulnerable Species Action Plan follows a consistent three-step framework:
- Assessing Population-Level Impacts:
EPA will evaluate pesticides to determine their potential population-level impacts on vulnerable species. For instance, exposure assessments for agricultural pesticides like malathion will consider species like the Attwater's prairie chicken, a bird known to forage on agricultural fields. - Implementing Mitigation:
Based on the identified risks, the EPA will impose mitigation strategies such as spray drift buffers, runoff controls, or changes in pesticide application methods. Pesticide applicators will have the flexibility to choose mitigation options best suited to their operations, allowing them to reduce risks while maintaining crop health. - Geographically Targeted Mitigation:
The EPA will use PULAs to specify the geographic areas where mitigation measures must be applied. This ensures that protection efforts are focused on high-risk areas where species overlap with pesticide usage.
Species in Focus
The plan currently targets 27 species that the EPA identifies as highly vulnerable, including birds like the Attwater's prairie chicken, aquatic species like the Ozark cavefish, and plants like Mead’s milkweed. These species are characterized by small populations, limited geographic range, and exposure to pesticide-prone habitats. The goal is to alleviate pesticide-induced stress and prevent further population declines.
The EPA developed this list in collaboration with the U.S. Fish and Wildlife Service (FWS) and will continue to expand the scope of species included in the VSAP.
A Comprehensive Approach
The EPA’s Vulnerable Species Action Plan reflects the agency's commitment to fulfilling its obligations under the Endangered Species Act (ESA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The plan aligns with ongoing efforts to protect endangered species while promoting sustainable pesticide use.
In addition to agricultural lands, the plan addresses non-agricultural pesticide uses, such as mosquito adulticide applications, forestry, and invasive species management. These non-agricultural uses often have significant impacts on wildlife, and the EPA intends to work closely with stakeholders to develop mitigation measures for these sectors.
