美国作物生命 (CLA) 向内政部和国家海洋渔业局 (NMFS) 提交了一份请愿书，要求改进对《濒危物种法》(ESA) 下的联邦机构行动的评估。具体而言，这些改进将扩大申请人在根据《联邦杀虫剂、杀真菌剂和灭鼠剂法案》（FIFRA）进行农药登记咨询过程中的作用。
CLA, and its members, have highlighted several problems in how the current ESA consultation process is conducted, most notably that the process is often delayed, not based on the “best scientific and commercial data available,” and often excluding entities with the most pertinent information, such as crop protection and public health product registrants. These problems result in flawed scientific analysis by the Services, and unnecessary litigation that prevent farmers and others from using vital crop protection and other essential products necessary to produce America’s food and fiber and serve other pubic needs.
所要求的改进将编纂在欧空局咨询期间经常被忽略的现有指导，并加强申请人的作用，超出目前提供的范围，但以完全符合欧空局和实施条例的方式。请愿书强调了欧空局在农药审查中需要更多结构。 EPA 和服务，包括 NMFS 和美国鱼类和野生动物管理局 (FWS)，对评估风险的方法有很大不同的看法，必须修改当前系统，以促进更简化和透明的流程，并获得更多申请者的意见。
“Several court decisions and out-of-court settlements related to the failure of the agencies to comply with the consultation process have forced the EPA and the Services to conduct hasty and unsound consultations,” said Jay Vroom, president and CEO of CLA. “Most often their decisions are based on outdated or incomplete information. It is CLA’s hope that our recommendations are considered so that all parties involved can have a voice in this important and necessary process.”
Among the improvements suggested by CLA, include making documents used by the Services during consultation, including documents and studies, available to the applicant; providing a role for the applicant in an informal consultation; and providing for a comment period following the required submission of the agency’s biological assessment to any state(s) affected by the agency action and the response by the Service to any state-written comments on the assessment.
Detailed information on the Endangered Species Act, including CLA’s position paper, can be found （链接在这里）.