Anonymous public comment

Document ID: EPA-HQ-OPP-2009-0684-0024
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: October 08 2009, at 12:00 AM Eastern Daylight Time
Date Posted: October 11 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: October 7 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: November 6 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80a3eebb
View Document:  View as format xml

View Comment

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.

Related Comments

    View All
Total: 22
Comment submitted by S. Cotten
Public Submission    Posted: 10/11/2009     ID: EPA-HQ-OPP-2009-0684-0019

Nov 06,2009 11:59 PM ET
Comment submitted by D. Buscemii
Public Submission    Posted: 10/11/2009     ID: EPA-HQ-OPP-2009-0684-0020

Nov 06,2009 11:59 PM ET
Comment submitted by Dr. John Alcock
Public Submission    Posted: 10/11/2009     ID: EPA-HQ-OPP-2009-0684-0021

Nov 06,2009 11:59 PM ET
Comment submitted by E. Rose
Public Submission    Posted: 10/11/2009     ID: EPA-HQ-OPP-2009-0684-0022

Nov 06,2009 11:59 PM ET
Anonymous public comment
Public Submission    Posted: 10/11/2009     ID: EPA-HQ-OPP-2009-0684-0024

Nov 06,2009 11:59 PM ET