Presentations at the Environmental Modeling Public Meeting (EMPM) Virtual Meeting at EPA – 23 June 2022, under the Topic of Endangered Species Assessment

Presentations at the Environmental Modeling Public Meeting (EMPM) Virtual Meeting at EPA - 23 June 2022, under the Topic of Endangered Species Assessment

Our staff, Leah Duzy, Annie Krueger, and Ashlea Frank presented at the Environmental Modeling Public Meeting (EMPM) Virtual Meeting at EPA – 23 June 2022.

Leah Duzy's Picture

Leah Duzy

Principal Consultant


Session Title: AMMPS: Informing Discussions on Avoidance, Minimization, and other Measures for Pesticides and Species

Presenter: Leah M. Duzy, Ashlea R. Frank, Tony Burd, and Lula Ghebremichael – Compliance Services International, Syngenta Crop Protection LLC

Abstract: While evaluating potential risk of pesticides to species is highly complex and requires processing and analysis of many datasets, it also presents an opportunity for the Environmental Protection Agency (EPA), Fish and Wildlife Service, National Marine Fisheries Service (collectively referred to as Services), United States Department of Agriculture, and pesticide registrants to explore innovative ways to further advance ecological risk assessment and the FIFRA/ESA process. With these considerations, Compliance Service International (CSI), in collaboration with Syngenta, developed AMMPS, a tool for informing discussions on Avoidance, Minimization, and other Measures for Pesticides and Species. The purpose of the AMMPS is to sequence species by their degree of potential risk and vulnerability to assist EPA, the Services, and applicants in discussions about suitable and practical mitigation options using a data-focused approach. AMMPS can aid in discussions prior to and during new active ingredient pesticide registration and the registration review process including consultation. While AMMPS has been a proprietary tool, CSI is currently developing a public version of AMMPS to allow access by a wider audience.

Annie Krueger's Picture

Annie Krueger

Senior Consultant

New Mexico

Session Title: The Mitigation Strategy Tool – A Guide for Evaluating Mitigation Measures in FIFRA/ESA Consultations

Presenter: Annie J. Krueger1, Andrew Clawson1, Leah Duzy1, Ashlea Frank1, Caleb Pearson2, Rachel Lattimore2, Manojit Basu2 – Compliance Services International1, CropLife America2

Abstract: On January 11th, 2022 EPA announced their new Endangered Species Policy stating their intent to evaluate the potential effects of any new conventional pesticide active ingredient on federally threatened or endangered (listed) species, and their designated critical habitats before granting registration. To aid their assessment, EPA has asked for input on “practical measures to avoid, minimize, or offset pesticide effects to federally listed endangered and threatened species and their designated critical habitats,” and “mitigation or specific label language to reduce on- and off-site exposures from spray drift and runoff.” In 2021, Compliance Services International (CSI) began working on a project supported by Crop Life America (CLA) to compile resources evaluating pesticide mitigation measures and factors contributing to their effectiveness and ease of implementation. CSI has compiled existing pesticide label language, peer reviewed papers, and technical documents from USEPA, USFWS, and USDA. Using those resources, CSI has built a web-based application to help users explore mitigation options to reduce potential pesticide exposure based on the exposure route of concern. The user is then provided a list of mitigation measures, ranked by most effective to least effective where practices have been sufficiently evaluated. CSI and CLA will provide a demonstration of the tool and discuss the strengths, limitations and future development opportunities.

Ashlea Frank's Picture

Ashlea Frank

Principal Consultant


Session Title: Collaborative Approaches to Practical Pesticide Mitigation Measures

Presenter: Ashlea Frank – Compliance Services International as directed by FESTF’s 17 member companies

Abstract: The FIFRA Endangered Species Task Force (FESTF) has been involved in pesticide and endangered species data aggregation and delivery for over 25 years. Over these years, FESTF’s core mission of data collection, aggregation and delivery has also allowed us to define additional FESTF efforts responsive to information needs. The presentation will discuss two FESTF projects focused on pesticide mitigation measures that involve collaboration with a variety of stakeholders. Specifically: 1) a project that explores mitigation measures in the context of an agricultural production system through a collaborative effort with the University of Nebraska-Lincoln and involving other regional, state, and local stakeholders, and 2) an education and outreach program developed collaboratively with experts, that is directly relevant to recovery of ESA-listed species in a way that would allow it to be incorporated as part of mitigation packages for pesticide registrations. Through these projects, FESTF will collect data and information to inform mitigation actions proposed by agencies or registrants. Such information can further define when and where mitigation measures may be needed, bring transparency and consistency to the process, and help to ensure measures are not only effective for the species but also workable for the end-user. Metrics to be included in data collection are existing conservation and application practices in place, knowledge base before and after education program, and number of people reached by education program materials.

Experienced Support For:

  • Global Regulatory Strategy
  • Registration Dossier Preparation & Submission
  • Ecological Risk Assessment
  • Environmental Fate & Exposure Modeling
  • Endangered Species Act Compliance
  • Economic Impact Analysis
  • Study Design, Placement & Monitoring
  • Spatial Analysis & Data Systems
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Leah Duzy
Principal Consultant

Expertise: Agricultural Economics

With a background in production agriculture and working lands conservation, Leah applies economic principles to risk and conservation decision-making to support agrochemical product development, assessment, and defense. She also provides applied economics research support through collaboration on federal grants and other projects. Her skills support pesticide benefit assessments and endangered species assessments.

Leah previously worked for the USDA Natural Resource Conservation Service and the USDA Agricultural Research Service as an agricultural economist for 15 years. She has worked in both the Federal conservation program and agricultural research arenas conducting applied economic research on conservation production systems, cover crops, and herbicide-resistant weed management, and preparing cost-benefit analyses for Federal conservation programs as part of the rulemaking process. 

Ph.D., Agricultural Economics, Auburn University.
M.S., Agricultural Economics, Purdue University.
B.A., Economics, The University of the South.

Annie Krueger
Senior Consultant

Expertise: Environmental Toxicology & Pollinator Risk Assessment

As a member of our Ecological Risk Assessment team, Annie assists clients with technical and regulatory planning and strategic support for risk and conservation decision making related to agriculture, pesticides, and endangered species issues.

Annie has spent more than 6 years working in environmental toxicology, pesticide regulation, and pollinator risk assessment.  She has worked in a contract research laboratory and in pollinator safety for an agrochemical company where she conducted Good Laboratory Practice (GLP) effect studies with non-target arthropods and non-target plants and assisted in GLP field residue trials to comply with FIFRA.  Annie has 8 years of research, conservation, and product stewardship experience working with honey bees, bumble bees and monarch butterflies.  Annie has authored numerous publications and made presentations at various industry trade associations.

Ph.D., Entomology, University of Nebraska-Lincoln.
B.S., Zoology, Minor in Chemistry, University of Wyoming.

Ashlea Frank
Principal Consultant

Expertise: Endangered Species

Ashlea offers technical and regulatory planning and strategic support for risk and conservation decision-making related to agriculture, pesticides, and endangered species issues.

Ashlea enjoys finding workable solutions that support end users and promote environmental stewardship by integrating sound science with management decisions.  Over the past 20 years she has acted as Visiting Scientist at the Queensland Institute of Medical Research conducting research on the efficacy of vector control products and Research Assistant at the Texas A&M Extension Agency helping growers find solutions to plant disease transmission in vineyards. She serves as Technical Consultant to the FIFRA Endangered Species Task Force (FESTF) providing endangered species and pesticide data analysis and agency interaction support for regulatory decisions under the US FIFRA and the Endangered Species Act (ESA).

M.S., Entomology, University of Queensland.
B.A., Physical Anthropology, Southwestern University.