The Environmental Protection Agency issued a notice in the Federal Register of November 27, 2020, opening a 60-day comment period on the draft nationwide biological evaluations for the registration review of the pesticide glyphosate relative to the potential effects on threatened and endangered species and their designated critical habitats. This document extends the comment period for 45 days, from January 26, 2021 to March 12, 2021. In reviewing the documentation provided by EPA, NALP took notice that use patterns described by the agency did not match real world scenarios experienced by lawn and landscape professionals, significantly overestimating uses based upon models the agency has developed. Our commentary is aimed at informing not only EPA but also the U.S. Fish and Wildlife Service and the National Marine Fisheries Service, the two agencies that review the document and comments after EPA.
