•  Step 1 (EPA). Initial exposure modeling would answer the question, Do the areas where the pesticide will be used overlap spatially with the habitats of any listed species? The Services, which have extensive knowledge of the natural history of listed species, could help EPA to identify overlaps of areas where a pesticide might be used and the habitats of listed species. EPA’s DANGER program would be useful in this step.

•  Step 2 (EPA). If area overlaps are identified in Step 1, EPA would confer with the Services to identify relevant environmental compartments (for example, pond vs stream), associated characteristics (for example, sandy vs silty soils), and critical times or seasons in which environmental exposure concentrations need to be estimated. With that knowledge, suitable model parameter values could be chosen and used. The goal of EPA’s initial exposure modeling would be to identify the most important environmental compartments for exposure modeling (water, soil, air, or biota). Models—such as GENEEC2, SIP, and SPIR—would be useful in this step. If the models indicate that substantial amounts of pesticides move off the application site and into the surrounding ecosystems, more sophisticated fate and transport processes could be incorporated. At that point, the pesticide-fate model could be simplified to remove processes that are unimportant in the specific regions of the listed species and set up to estimate time-varying and space-varying pesticide concentrations in typical habitats (for example, 10-cm-deep shallow regions along streams vs 2-m-deep farm ponds) with associated uncertainties. The committee emphasizes that inputs should include statistical distributions of each parameter to enable probabilistic modeling of exposure scenarios. During Step 2, EPA could direct the terrestrial exposure modeling at specific size classes of taxonomic groups that represent the listed species of concern. On the basis of the modeling results, EPA could then make a decision about the need for formal consultation with the Services.

•  Step 3 (Services). During a formal consultation, the Services would further refine the exposure models to develop quantitative estimates of pesticide concentrations and their associated distributions for the particular listed species and their habitats. To that end, the models would use site-specific input values—for example, actual pesticide application rates, locally relevant geospatial data to characterize such quantities as wind speed and organic contents of soils, and time-sensitive life stages of listed species. The exposure analysis would be completed with propagated errors on exposure estimates.

Some issues associated with the exposure models or modeling practices need to be emphasized. First, pesticide-fate models are not always well tested with field data for specific pesticide applications at sites whose properties are knowable. Bird et al. (2002) tested AgDRIFT, and Loague and Green (1991) tested PRZM. However, a comprehensive treatment of the use of EXAMS with pesticides is largely lacking. Burns (2001) did list six studies involving field observations of diverse compounds that could be compared with EXAM model-



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