I would like to urge the Environmental Protection Agency to suspend the registration of Rozol Prairie Dog Bait in accordance with petitions from the WWF and FWS. In light of the deaths already recorded due to secondary exposure of Rozol in predators of prairie dogs and the potential for increased occurrence of such deaths if Rozol use becomes wide-spread, it appears that the balancing test required under the Federal Insecticide, Fungicide, and Rodenticide Act is met in favor of erring on the side of caution and redacting the approval of Rozol use. Additionally, because other forms of prairie dog bait are available and are much less protracted in their effects -- both in the length of time required to kill the baited prairie dogs and potential for secondary-species poisoning -- any benefits incurred through the purported efficiency of Rozol use are negated by the potential wide-spread damage to endangered and threatened species.
I urge the EPA to consider the possible disasterous effects of allowing Rozol use and to cancel its application until at least such time as further studies can be made as to the ill-effects of secondary exposure to other species and particularly migratory birds; the balancing test required by FIFRA should be examined in light of the Endangered Species Act and the Migratory Bird Treaty Act and substantial deference given to these Congressional directives.
Anonymous public comment
This is comment on Notice
Receipt of Petition Requesting EPA to Suspend the Registration of Rozol Prairie Dog Bait and Cancel Certain Application Sites; Opening of Comment Period
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