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

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Reduction in Prey<br />

Freshwater spawning, rearing, <strong>and</strong> migratory habitats must provide forage areas that support<br />

juvenile development. A reduction in the abundance of prey items will decrease the<br />

conservation value of these habitats, as they will support fewer individuals, especially during a<br />

salmonid’s first year of survival. Given the environmental baseline conditions of the aquatic<br />

systems, the existing invertebrate community is already depauperate in many of these areas <strong>and</strong><br />

requires longer periods for recovery following each pesticide application event. The a.i.s in<br />

surface runoff <strong>and</strong> pesticide drift entering freshwater rearing habitats will exacerbate reductions<br />

in insect communities that are salmonid prey items in these degraded systems. We expect that<br />

designated critical habitats that support juvenile feeding <strong>and</strong> growth will be contaminated by the<br />

proposed uses of carbaryl, carbofuran, <strong>and</strong> methomyl to the extent that the habitat is precluded<br />

from serving its intended role in the survival <strong>and</strong> recovery of listed salmonids. The overall<br />

conservation value of designated critical habitat, whether low, medium, or high, will not meet its<br />

intended role to support the survival <strong>and</strong> recovery of the species.<br />

Reduction in Water Quality<br />

Drift <strong>and</strong> runoff from areas of intensive urban <strong>and</strong> agricultural development will likely contain<br />

carbaryl, carbofuran, <strong>and</strong> methomyl in addition to other pesticides - particularly other AChEinhibiting<br />

pesticides, chemical pollutants, <strong>and</strong> sediments that also degrade water quality.<br />

Depending on the available water flow, amount of shade from LWD <strong>and</strong> intact riparian zones,<br />

<strong>and</strong> water temperature in aquatic habitats, the toxicity of carbaryl, carbofuran, <strong>and</strong> methomyl in<br />

tributary <strong>and</strong> stream waters may become more pronounced. Reductions in water quality may<br />

reduce the conservation value of designated habitats used for spawning, rearing, <strong>and</strong> migration.<br />

Furthermore restoration actions promoted in many of the salmonid recovery plans focus on<br />

increasing flood plain connectivity <strong>and</strong> creating new off-channel habitats. These actions are<br />

proposed in agricultural <strong>and</strong> urban flood plains that overlap with uses of the three insecticides.<br />

Water quality (as well as prey availability) may be degraded in these newly constructed habitats<br />

from the stressors of the action- effectively precluding intended benefits to rearing juvenile<br />

salmonids. We expect that proposed uses may contaminate these areas, thereby precluding<br />

habitat from its intended purpose in supporting the survival <strong>and</strong> recovery of listed Pacific<br />

salmonids.<br />

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