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

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sustaining in the natural environment (McElhaney, Ruckleshaus et al. 2000; McElhaney,<br />

Chilcote et al. 2007).<br />

In determining the effect of an action to populations, we first address whether individual<br />

fitness level consequences are likely <strong>and</strong> whether those consequences affect populations.<br />

We evaluate whether identified VSP parameters of populations such as abundance <strong>and</strong><br />

productivity are reduced by individual fitness effects. If populations are likely to be<br />

adversely affected by reductions in VSP parameters, we analyze the potential effects to<br />

the species as a whole. In parallel, if designated critical habitats are likely to be exposed<br />

<strong>and</strong> PCEs are adversely affected, then we evaluate the potential for reductions in the<br />

conservation value of the habitats. We devise risk hypotheses based on identified PCEs<br />

that are potentially affected by the stressors of the action. If the best available data<br />

indicate that PCE-specific risk hypotheses are supported, then we discuss whether critical<br />

habitat will remain functional to serve the intended conservation role for the species in<br />

the Conclusion section.<br />

General conceptual framework for assessing risk of EPA’s pesticide actions to listed<br />

resources.<br />

We evaluate the risk to listed species <strong>and</strong> designated critical habitat in the Effects of the<br />

Proposed Action section by applying an ecological risk assessment framework that<br />

organizes the available information in three phases: problem formulation, analysis, <strong>and</strong><br />

risk characterization (EPA 1998; McElhaney, Ruckleshaus et al. 2000). We adapted the<br />

EPA framework to address ESA-specific considerations (Figure 2). The framework<br />

follows a process for organizing, evaluating, <strong>and</strong> synthesizing the available information<br />

on listed resources <strong>and</strong> the stressors of the action. Below, we briefly describe each phase<br />

in the Effects of the Proposed Action section.<br />

Problem Formulation<br />

The first phase of the framework is problem formulation. In this phase, we generate<br />

conceptual models from our initial evaluation of the relationships between stressors of the<br />

action (pesticides <strong>and</strong> identified chemical stressors <strong>and</strong> potential receptors (listed species,<br />

habitat). We represent these relationships in conceptual models presented as diagrams<br />

43

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