Environmental Impact Statements; Availability, etc.: Grasshopper and Mormon Cricket Suppression Program

The Xerces Society for Invertebrate Conservation, representing nearly 4,000 individuals, submitted a petition requesting specific protections and transparency measures in the proposed Grasshopper and Mormon Cricket Suppression Program. They advocate for ending spraying on sensitive public lands, implementing non-chemical prevention methods, and establishing comprehensive buffers for all western streams and wetlands.

The Global Locust Initiative (GLI) at Arizona State University supports the proposed suppression program but recommends specific amendments to Alternative 4. They advocate for a formalized framework to register and adopt the specialist biopesticide Metarhizium acridum, requesting a clear distinction between generalist and specialist strains and a comprehensive cost-benefit analysis comparing biopesticides to chemical pesticides.

New Mexico Wild, representing nearly 1,000 individual commenters, urges APHIS to adopt Alternative 2, which ends the use of chemical insecticides in the Grasshopper and Mormon Cricket Suppression Program. They argue that current practices pose risks to wildlife, water quality, and human health, and call for addressing root causes like overgrazing and providing better public notification.

The Center for Biological Diversity, representing over 11,000 supporters, opposes the proposed grasshopper and Mormon cricket suppression program. They urge APHIS to overhaul its approach, stop using insecticides on public lands, and prioritize the protection of wildlife and people.

The Prairie Hills Audubon Society, a nonprofit conservation organization, supports the proposed program but requests that the PEIS include more rigorous analysis of food-web effects on birds, landscape-scale impacts on pollinators, and explicit protections for sensitive habitats. They also advocate for the evaluation of non-chemical alternatives, updated Endangered Species Act consultations, and improved public notification.

The Center for Biological Diversity submitted a research report highlighting a significant biodiversity crisis and population decline in North American birds, particularly in grasslands. The submission provides scientific context regarding habitat loss and avian decline but does not explicitly state a position on the specific grasshopper and Mormon cricket suppression program.

A coalition of environmental and conservation organizations is submitting comments on the APHIS Notice of Intent to prepare a programmatic environmental impact statement for the grasshopper and Mormon cricket suppression program. They argue that APHIS should shift from a pesticide-centered approach to one that prioritizes integrated pest management (IPM), preventative measures, and greater transparency and tribal consultation.

Christopher Lish, a private individual, opposes the proposed program because it relies too heavily on insecticides rather than integrated pest management. He argues that the program harms native species, lacks transparency regarding public exposure, and fails to protect the integrity of the ecosystem.

Charissa Callison, a private citizen and mother, opposes the proposed suppression program due to concerns regarding insecticide exposure and its harmful effects on pollinators, water quality, and biodiversity. She advocates for specific protections for wildlife and clear public notification if spraying is deemed necessary.

Rachel Whitmore opposes the use of insecticides on public lands to control grasshoppers and Mormon crickets. She argues that such "blanket" chemical approaches harm essential pollinators and suggests that promoting native species diversity to encourage natural predators is a better solution.