In most cases, pesticides have the potential to affect a listed species indirectly—not through direct exposure but through effects on other species in the community. For example, the prey of a listed species might be reduced in abundance or eliminated by the pesticide, and this would affect the survival of the species. As in the case of sublethal effects, EPA and the Services differ about the degree to which indirect effects can be included in an assessment. The committee recommends that indirect effects that can be quantified relatively easily be incorporated into the effects analysis. However, determining and quantifying most indirect effects can be challenging and can require complex models. When such modeling is conducted, uncertainties should be estimated quantitatively in a realistic and scientifically defensible manner and should be propagated formally and explicitly through the analysis.
A risk assessor must also consider cumulative effects. They are defined by regulation under the ESA as “those effects of future State or private activities, not involving Federal activities that are reasonably certain to occur within the action area of the Federal action subject to consultation” (50 CFR 402.02). However, cumulative effects typically are more broadly defined as effects that interact or accumulate over time and space. The committee could not determine a scientific basis for excluding past and present conditions (the environmental baseline) from the consideration of cumulative effects and therefore used that broad definition in its evaluation. The committee concluded that population models provide a framework for incorporating baseline conditions and projected future cumulative effects into an effects analysis.
One problem that arises in an effects analysis is how to extrapolate toxicity information on tested species to listed species. Although the idea of identifying an appropriate surrogate species is appealing, the committee finds such identification problematic because different species often respond differently to chemical exposures, and the sensitivity differences can be large. Furthermore, different life histories can complicate the extrapolation. A scientifically defensible alternative approach is to define a range of sensitivities within which the sensitivity of a listed species could reasonably be expected to occur or a range of sensitivities that could be used to make reasoned extrapolations from information on species that have been tested by using inferences based on other chemicals. Further details are provided in Chapter 4 of this report.
EPA and the Services use different approaches to determine the potential effects of a pesticide on a listed species and its critical habitat. EPA addresses population effects simply as extensions of individual effects: if survival or reproduction is affected, EPA assumes population-level consequences and enters consultation with the Services. The Services use population models to address the question of population persistence explicitly. Population models are used to estimate population-level end points—such as population growth rate, probabil-