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Carbaryl, Carbofuran, and Methomyl - National Marine Fisheries ...

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elatively low survival EC50 values when exposed to current use insecticides (Johnson, Jepson et<br />

al. 2008), including carbaryl (Peterson, Jepson et al. 2001; Johnson, Jepson et al. 2008).<br />

The selection of the 10 th percentile is a reasonable choice in keeping with general risk<br />

management practices of protecting the aquatic community. The st<strong>and</strong>ard procedure the U.S.<br />

EPA Office of Water uses in establishing Aquatic Life Criteria is to protect to the 5th percentile<br />

of a species sensitivity distribution that includes all genera of aquatic species for which valid<br />

data are available (EPA 1995). Their procedure involves combining species data into a genus<br />

mean value so that multiple tests on one sensitive species do not unduly influence the outcome,<br />

<strong>and</strong> evaluating a specified group of taxa. As we had already selected for the sensitive end of the<br />

spectrum by using salmonid prey items, <strong>and</strong> did not collapse species data into a genus mean, we<br />

used the 10 th percentile. In the probabilistic risk assessment for carbofuran (EPA 2005), OPP<br />

evaluated effects on the 5 th , 50 th , <strong>and</strong> 95 th percentiles of separate species sensitivity distributions<br />

for fish <strong>and</strong> invertebrates, although it was not clear in the document which was the preferred<br />

percentile for risk management.<br />

Modeling availability of unaffected prey<br />

Reductions in benthic invertebrate densities can lead to long-term reductions in prey availability<br />

<strong>and</strong> reductions in fish growth (Davies <strong>and</strong> Cook 1993). That said, prey densities are not usually<br />

reduced to zero (Wallace, Lugthart et al. 1989). Therefore, it is assumed that regardless of the<br />

exposure scenario, prey abundance would not drop below a specific “floor” of prey availability.<br />

This floor is included in the model to reflect an assumption that a minimal yet constant terrestrial<br />

subsidy of prey <strong>and</strong>/or an aquatic community with tolerant individuals would be available as<br />

prey, regardless of pesticide exposure <strong>and</strong> in addition to the constant recovery rate (see below).<br />

Therefore, even in extreme exposure scenarios, some prey will be available, as determined by the<br />

value assigned to the floor; in some highly degraded systems this may or may not be the case.<br />

No studies have quantified this floor for the purpose of estimating prey availability, but several<br />

studies have documented reductions in overall benthic insect densities of 75-98% (Wallace,<br />

Lugthart et al. 1989; Anderson, Hunt et al. 2003; Anderson, Phillips et al. 2006). Because<br />

benthic densities are typically correlated with drift densities (Hildebr<strong>and</strong> 1974; Waters <strong>and</strong><br />

Hokenstrom 1980), these reductions likely result in similar reductions of prey. Therefore,<br />

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