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

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levels expected to kill fish, if AChE measurements were taken of the fish carcass and correlate to fish death, if pesticides were applied in the general area, and if pesticide drift or runoff was witnessed or apparent. NMFS notes that with increased monitoring and study of the impact of these pesticides on water quality, particularly water quality in off-channel habitats, NMFS will be able to refine this incidental take statement, and future incidental take statements, to allow other measures of the extent of take. Reasonable and Prudent Measures The measures described below are non-discretionary, and must be undertaken by the EPA so that they become binding conditions of any grant or permit issued to the applicant(s), as appropriate, for the exemption in section 7(o)(2) to apply. The EPA has a continuing duty to regulate the activity covered by this incidental take statement. If the EPA (1) fails to assume and implement the terms and conditions or (2) fails to require the applicant(s) to adhere to the terms and conditions of the incidental take statement through enforceable terms that are added to the permit or grant document, the protective coverage of section 7(o)(2) may lapse. In order to monitor the impact of incidental take, the EPA must report the progress of the action and its impact on the species to NMFS OPR as specified in the incidental take statement. [50 CFR§402.14(i)(3)]. To satisfy its obligations pursuant to section 7(a)(2) of the ESA, the EPA must monitor (a) the direct, indirect, and cumulative impacts of its long-term registration of pesticide products containing carbaryl, carbofuran, and methomyl; (b) evaluate the direct, indirect, or cumulative impacts of pesticide misapplications in the aquatic habitats in which they occur; and (c) the consequences of those effects on listed Pacific salmonids under NMFS’ jurisdiction. The purpose of the monitoring program is for the EPA to use the results of the monitoring data and modify the registration process in order to reduce exposure and minimize the effect of exposure where pesticides will occur in salmonid habitat. The EPA shall: 498
1. Minimize the amount and extent of incidental take from use of pesticide products containing carbaryl, carbofuran, and methomyl by reducing the potential of chemicals reaching the water; 2. Monitor any incidental take or surrogate measure of take that occurs from the action; and 3. Report annually to NMFS OPR on the monitoring results from the previous season. Terms and Conditions To be exempt from the prohibitions of section 9 of the ESA, within one year following the date of issuance of this Opinion, the EPA must comply with the following terms and conditions. These terms and conditions implement the reasonable and prudent measure described above. These terms and conditions are non-discretionary. 1. a. EPA shall include the following instructions requiring reporting of fish kills either on the labels for all products containing carbaryl, carbofuran, and methomyl or in ESPP Bulletins: NOTICE: Incidents where salmon appear injured or killed as a result of pesticide applications shall be reported to NMFS OPR at 301-713-1401 and EPA at 703-305-7695. The finder should leave the fish alone, make note of any circumstances likely causing the death or injury, location and number of fish involved, and take photographs, if possible. Adult fish should generally not be disturbed unless circumstances arise where an adult fish is obviously injured or killed by pesticide exposure, or some unnatural cause. The finder may be asked to carry out instructions provided by NMFS OPR to collect specimens or take other measures to ensure that evidence intrinsic to the specimen is preserved. b. EPA shall report to NMFS OPR any incidences regarding carbaryl, carborfuran, or methomyl effects on aquatic ecosystems added to its incident database that it has classified as probable or highly probable. c. Do not apply pesticide products when wind speeds are greater than or equal to 10 mph as measured using an anemometer immediately prior to application. When applying pesticide products, commence applications on the side nearest the aquatic habitat and proceed away from the aquatic habitat. 2. For all uses do not apply pesticide products when soil moisture is at field capacity, or when a storm event likely to produce runoff from the treated area is forecasted by NOAA/NWS (National Weather Service), to occur within 48 h following application. 499
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Ms. Debbie Edwards Director, Office
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National Marine Fisheries Service E
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Snake River Spring/Summer-Run Chino
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Commercial, Recreational, and Subsi
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Critical Habitat Risk Hypotheses ba
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Table of Figures Figure 1. Stressor
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Table of Tables Table 1. Registered
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Table 31. Area of Land Use Categori
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Table 67. . Examples of published f
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Agency: Activities Considered: Nati
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This Opinion is based on NMFS’ re
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activities that may improve EPA’s
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affect but is not likely to adverse
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On November 13, 2008, EPA provided
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On January 21, 2009, the agencies a
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in California, Idaho, Oregon, and W
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On that same date, EPA e-mailed NMF
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After registering a pesticide, EPA
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isk assessment. With these and othe
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Typically, formulations are combine
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EPA also issued generic and product
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pecans, peppers, pistachios, plums,
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Use Site plants, woody plants CRP a
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are subject to a four year phase-ou
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Table 2. Registered uses and applic
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mildews and other fungal diseases.
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methomyl are 32.4 lb a.i./acre/year
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would not likely adversely affect C
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In the final steps of our analyses,
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Evidence Available for the Consulta
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sustaining in the natural environme
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Stressors of the Action (see Figure
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Species Risk Hypotheses We construc
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habitats is then assessed. This por
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The problem formulation phase as ar
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Risk Characterization We follow the
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the probability of risk. In the Ris
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Figure 5. Map showing extent of inl
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Opinion. Summaries of the status an
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Chinook salmon are dependent on the
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Eureka Figure 6. CC Chinook salmon
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Table 6. CC Chinook salmon--prelimi
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Table 7 identifies populations with
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The CV drainage as a whole is estim
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have greatly reduced or eliminated
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Portland Salem Figure 9. LCR Chinoo
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important life history type remains
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Table 9. UCR Chinook salmon - preli
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In the most recent five-year geomet
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Figure 11. Puget Sound Chinook dist
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Status and Trends Puget Sound Chino
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flow, temperature, sediment load, w
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San Francisco Figure 12. Sacramento
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of historic spawning areas. Additio
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Status and Trends SR fall-run Chino
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Critical Habitat Critical habitat f
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Portland Seattle Spokane Figure 14.
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and five-year old fish, after two t
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surface and ground water and degrad
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Life History UWR Chinook salmon exh
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Bay, California. Historically, chum
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quality in the freshwater, estuarin
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Life History Chum salmon return to
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catastrophic events. Overall, the p
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Figure 17. Hood Canal Summer-run Ch
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improvements in 2000, with upward t
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ground water and degrade water qual
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San Francisco Figure 18. CCC Coho s
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Information on the abundance and pr
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Table 16 identifies populations wit
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Life History Although run time vari
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programs. The three major river sys
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Data on population abundance and tr
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Figure 21. Oregon Coast Coho salmon
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Preliminary spawner survey data for
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channels, backwaters, terrace tribu
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Figure 22. Ozette Lake Sockeye salm
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the 1997 status review due to resam
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Seattle Portland Figure 23. SR Sock
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Adult returns to Redfish Lake durin
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esume migration in early spring to
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Central California Coast Steelhead
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Status and Trends The CCC steelhead
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San Francisco Figure 25. California
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and Jackson 1996; McEwan 2001). Ste
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Olympia Portland Salem Figure 26. L
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hatchery fish in naturally-spawning
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species includes the only populatio
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Life History Most MCR steelhead smo
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Critical Habitat Critical habitat w
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Eureka Figure 28. Northern Californ
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may affect steelhead migration patt
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Of the 21 populations in the Puget
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Seattle Spokane Figure 30. SR Basin
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and spawner estimates for the Tucan
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San Jose Figure 31. S-CCC steelhead
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Figure 32. Southern California stee
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extinction,” with the remaining 1
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Portland Figure 33. UCR Steelhead d
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“low” for the Wenatchee and Met
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Figure 34. UWR Steelhead distributi
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Molalla/Pudding, Yamhill, Tualatin,
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Natural Mortality Factors Available
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Marine Mammal Predation Marine mamm
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downstream of Bonneville Dam. Socke
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Oceanographic Features and Climatic
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coincides with relatively poor ocea
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from streams in watersheds with agr
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chemicals used has decreased (Table
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California, Idaho, Oregon, and Wash
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to disease, decrease the ability of
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characterized by emergent aquatic p
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subregions and accounting units for
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Region USGS Subregion Central Calif
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Table 31. Area of Land Use Categori
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Table 33. Land uses and population
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(Table 34). See species ESU/DPS map
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undeveloped sites in the Santa Ana
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and grazing. Dams and water diversi
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Artificial Propagation Anadromous f
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water resources is handled by Calif
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containers at time of use. • Cond
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Table 36. Area of land use categori
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Columbia River Basin The most notab
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Ranching practices have led to incr
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17% of mainstem Yakima River sample
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detected in samples from all sites,
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Whitney 1979). Similarly, over one
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nation’s silver output has come f
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(USBR 1998 in (FCRPS 2008); providi
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The States of Oregon and Wasington
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Columbia River chum salmon are not
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including brown and brook trout, At
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density residential with some agric
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Although urban areas occupy only 2%
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Habitat Modification Much of the re
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Table 42. Pollutants of Concern in
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the 1950s. The vast majority of the
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pugettensis). An NPDES permit is re
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Habitat loss through wetland fills
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afted and moved to market or downst
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Oregon is in the process of develop
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Effects of the Proposed Action The
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Carbaryl dissipates in the environm
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high water solubility, low Kow, and
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Table 46. Environmental fate charac
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Species General Life History Descri
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Table 48. Examples of registered us
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Table 49. PRZM-EXAMS exposure estim
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estimate do not represent the highe
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BE provides a peak EEC of 5.5 μg/L
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alcoves, channel edge sloughs, over
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Carbaryl can also be applied at 8 l
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habitat had a downwind width of 10
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Depth of aquatic habitat (meters) B
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monitored in California, Idaho, Ore
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5.2 μg/L for carbofuran, 0.0150 -
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Summary information for carbaryl, c
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after flooding (Nicosia, Carr et al
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pesticide concentrations in the dis
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flowing water habitats, it is not s
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egistered products that contain mor
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potential ingredients in tank mixtu
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low maximum application rate. Howev
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occupy shoreline habitats of only a
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vertebrates and invertebrates (Walk
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Temperature and toxicity We found n
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exposure concentrations. Moreover,
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Summary of Toxicity Information Pre
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at several times during an experime
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Table 64. Assessment endpoint toxic
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fish, number of eggs per mature fem
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varigatus), an estuarine species, b
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included a NOAEC of 9.8 μg/L and a
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730 μg/L for D. magna (freshwater
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TEP) are contained in Appendix D-1.
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the uncertainties related to experi
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capacity (Little and Finger 1990).
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consumed relative to unexposed fish
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24 hr exposure (Zinkl, Shea et al.
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We located studies that measured ol
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endpoints of salmonids remains a re
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items (Courtemanch and Gibbs 1980;
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single pulse of chlorpyrifos was in
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Table 65. Study designs and results
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Chemical Taxa/species Assessment me
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Chemical Taxa/species carbofuran ca
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Chemical Taxa/species carbofuran ca
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macroinvertebrate community did not
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Jardine, MacLatchy et al. 2005; Luo
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Risk Characterization In this secti
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survival appears to be the most sen
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factor in the degree of toxicity of
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Figure 41. Methomyl exposure concen
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Table 67. . Examples of published f
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Additionally, the macroinvertebrate
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Measured Concentrations in Willapa
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up to 100 m off the carbaryl applic
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average initial concentration from
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• Unrelated (0): Conclusive evide
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the fish to determine the cause of
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Dose-addition assumes the cumulativ
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Table 73. Predicted AChE inhibition
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habitats during aerial applications
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The second line of evidence is whet
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D. Impair swimming which leads to r
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F. Exposure to mixtures of carbaryl
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used surfactant/adjuvant mixed with
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In a second modeling exercise, we t
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Carbaryl’s thresholds for the fou
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Table 75. Modeled output for Stream
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Table 77. Modeled output for Sockey
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The likelihood of scenarios 2 and 3
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The three insecticides are highly t
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A. B. C. Figure 43. Probability plo
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elatively low survival EC50 values
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dominated by agricultural or urban
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Figure 45. Percent change in lambda
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Table 80. Multiple application scen
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Because olfaction plays an importan
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expect co-occurrence of the three i
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support one or more lifestages. For
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We attempted to compare expected co
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Cumulative Effects Cumulative effec
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entry into freshwater systems. Carb
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Integration and Synthesis The Integ
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carbofuran applications could cause
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The Status of Listed Resources and
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also exposed to poor water quality
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Given the life history of LCR Chino
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Chinook salmon. Furthermore, there
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all three a.i.s are expected to be
Page 465 and 466: completing migration to the Pacific
Page 467 and 468: The major threats to this ESU ident
Page 469 and 470: Land use data indicate that the Col
Page 471 and 472: Central California Coast Coho Salmo
Page 473 and 474: Pesticide use and detections in LCR
Page 475 and 476: effects. In several streams, one or
Page 477 and 478: ESU is evergreen forest. Between 19
Page 479 and 480: miles where agricultural crops are
Page 481 and 482: The Status of Listed Resources and
Page 483 and 484: carbofuran application to potatoes,
Page 485 and 486: The major threats to this DPS ident
Page 487 and 488: lowland areas (below 1,000 ft eleva
Page 489 and 490: consequences and subsequent populat
Page 491 and 492: and surface waters within the heavi
Page 493 and 494: 1994). Most juvenile steelhead spen
Page 495 and 496: salmon, Northern California steelhe
Page 497 and 498: natural cover such as submerged and
Page 499 and 500: The precise change in the conservat
Page 501 and 502: coho salmon, LCR coho salmon, South
Page 503 and 504: Table 81. Jeopardy and Non-Jeopardy
Page 505 and 506: Reasonable and Prudent Alternatives
Page 507 and 508: The RPA is comprised of six require
Page 509 and 510: Table 83. Mandatory pesticide no ap
Page 511 and 512: items will die from these exposures
Page 513 and 514: action will attain this level in th
Page 515: proposed action. Therefore, inciden
Page 519 and 520: met within the next 15 years, then
Page 521 and 522: Arunachalam, S., K. Jeyalakshmi, et
Page 523 and 524: Bortleson, G. C. and J. C. Ebbert (
Page 525 and 526: CDFG (1995). "Letter dated 30 March
Page 527 and 528: Davies, P. E. and L. S. J. Cook (19
Page 529 and 530: FCRPS (2008). "Endangered Species A
Page 531 and 532: Haggerty, M. J., A. C. Ritchie, et
Page 533 and 534: IEPSPWT (1999). "Monitoring, assess
Page 535 and 536: government from 1896 to 1945." Repo
Page 537 and 538: Matthews, G. M. and R. S. Waples (1
Page 539 and 540: NMFS (2004). Five-year integrated p
Page 541 and 542: PSAT (2004). "State of the Sound 20
Page 543 and 544: Schroder, S. L. (1977). "Assessment
Page 545 and 546: Tufts, D. F. (1990). "Control of bu
Page 547 and 548: Williams, A. K. and C. R. Sova (196
Page 549 and 550: Introduction To assess the potentia
Page 551 and 552: ocean-type and stream-type Chinook
Page 553 and 554: incorporates empirical data when av
Page 555 and 556: given a percentile value of 50 (i.e
Page 557 and 558: species-appropriate growth period (
Page 559 and 560: For Figure 3C, an exposure pulse wo
Page 561 and 562: the n x n square matrix (A) by assi
Page 563 and 564: spawn (Pess et al. 2002). Survival
Page 565 and 566: distributed survival and reproducti
Page 567 and 568:
Figure 1: Life-History Graphs and T
Page 569 and 570:
Table 1. List of values used for co
Page 571 and 572:
Table 4. Matrix transition element
Page 573 and 574:
Figure 2. 555
Page 575 and 576:
Figure 4. 557
Page 577 and 578:
Brewer, S.K., Little, E.E., DeLonay
Page 579 and 580:
Higgs, D.A., MacDonald, J.S., Levin
Page 581 and 582:
Morgan, M.J., and Kiceniuk, J.W. 19
Page 583 and 584:
Scholz, N.L., Truelove, N.K., Frenc
Page 585 and 586:
Appendix 2. Species and Population
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Chinook Salmon (continued) ESU Popu
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Chum Salmon ESU Population λ - H=0
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Coho Salmon (continued) ESU Populat
Page 593 and 594:
Steelhead (continued) DPS Populatio
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Appendix 3: Abbreviations 7-DADMax
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FQPA Food Quality Protection Act ft
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PPE Personal Protection Equipment P
Page 601 and 602:
Appendix 4: Glossary 303(d) waters
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Salmon fall to head upriver to its
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Main channel The stream channel tha
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Smolt A juvenile salmon or steelhea
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WQS “A water quality standard def
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