Endangered Species


Endangered Species

In the U.S., the Endangered Species Act (ESA) of 1973 aims to conserve and recover threatened and endangered species and their habitats. In consultation with the Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS), federal agencies must ensure that all activities they authorize, fund, or carry out, are not likely to jeopardize the continued existence of ESA-listed species or adversely modify designated critical habitat.

At CSI, our primary focus includes the complex interface between the ESA and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the regulation under which the Environmental Protection Agency (EPA) registers pesticides. We assess risk to ESA-listed species from the use of pesticides and help identify ways to mitigate potential impacts. Our staff are experts in applying best available data and regulatory insights to develop informed and defensible recommendations to support each step of the risk assessment and consultation process. Current projects combine landscape analysis, risk assessment, economics, species status, GIS technology, conservation, agronomics, and industry knowledge to assist clients in identifying solutions that are workable for the registrant and end-users and protective of species. We maintain, and continue to strengthen, collaborative relationships with multiple organization-levels within the EPA, FWS, NMFS, USDA, state and regional-level agencies, and other entities.

While our primary expertise is in the intersection between FIFRA and ESA, the same principles can be applied to all regulated industries. Our strength comes not only from being able to provide strategic support to a variety of industries, but by anticipating and applying new regulatory, economic, and environmental strategies that are tailored to specific projects and needs.

Experienced Support For:

  • Project Scoping
  • Agency Interaction
  • Spatial Analysis & Data Systems
  • Conservation & Mitigation Measures
  • Economic Impact Analysis
  • Information Management & Reporting
  • Endangered Species Policy
  • Task Force Representation & Administration
  • Programming & Statistical Analysis

Endangered Species Analysis & Strategic Support

Project Scoping

We provide clients with an idea of the expected process and likely results from EPA’s biological evaluations (BE) and subsequent biological opinions (BO) from FWS and NMFS. We consider on-the-ground activities and environmental baselines to prepare more realistic work plans and analyses.


Agency Interaction

CSI has a proven record of regulatory success with multiple organization-levels within the EPA, FWS, NMFS, and USDA. We engage the agencies throughout the biological evaluation and opinion process. Through these interactions, we obtain feedback on data sources, processes, and outcomes in support of our clients’ products and needs.


Spatial Analysis & Data Systems

We provide workable solutions and help clients to effectively communicate outcomes using spatial analysis. From identifying potential areas at risk to visualizing outcomes and solutions to developing model scenarios, we know data and how to use it effectively.


Conservation & Mitigation Measures

We work with clients to explore conservation measures to help mitigate potential risk to at-risk species. We combine our knowledge of economics, species, conservation, and agricultural systems to help clients understand potential impacts of various avoidance, minimization, and mitigation measures, providing them with information and solutions that are invaluable in the registration process and beyond. We have established relationships with Federal and State agencies, local organizations, and other entities that can help to facilitate a comprehensive and successful strategy.


Economic Impact Analysis

To support FIFRA registration and review and public comment development on risk assessments, registration decisions, biological evaluations and opinions, and critical habitat designations, we can investigate a variety of economic topics related to endangered species and land use that can be integrated into spatial analysis to quantify, analyze, and present findings. 


Endangered Species Policy

We provide clients with advice on regulatory and endangered species policy topics that may impact current and future registrations, as well as global agricultural production. We have experience in analyzing the impact of regulatory decisions related to pesticide registration review, evaluating the impact of changes in endangered species policy, and examining the interface between agricultural production and species protection. 


Task Force Representation & Administration

CSI provides client representation on industry trade association consortia. We serve in management, administrative and lead technical roles on chemical task forces, specifically the FIFRA Endangered Species Task Force (FESTF).


Programming & Statistical Analysis

Our staff is experienced with various scripting languages to facilitate statistical analysis and processing efficiencies, including Python, SQL, R, and SAS.

Endangered Species Note:

There are currently two biological opinions from the National Marine Fisheries Service (NMFS) open for public comment. The dockets for both biological opinions will be open for 60 days and will close on April 20, 2021.  

Click below for Biological Opinions Available for Public Comment  | Protecting Endangered Species from Pesticides | US EPA

Endangered Species Experts

Ashlea Frank's Picture

Ashlea Frank

Principal Consultant


Leah Duzy's Picture

Leah Duzy

Principal Consultant


Rick Kemman's Picture

Rick Kemman

Senior Consultant

Washington State

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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.

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.

Rick Kemman
Senior Consultant

Expertise: Environmental Science

Rick is a curator of threatened and endangered species status, distribution, and natural history, including habitat, reproduction, diet, and location. Rick maintains up-to-date records on the listing status, distribution, and the latest rules and guidance issued from USFWS, state agencies, and local species experts. 

Rick has been with CSI for over 29 years and has been involved with a myriad of projects including preparation of analytical chemistry reports, data compensation, and managing FIFRA RAC (Raw Agricultural Commodities) and PF (Processed Fraction) studies. Rick also served as Good Laboratory Practice (GLP) Quality Assurance Specialist.     

M.S., Environmental Toxicology, Clemson University.
B.A., Biology, Whitworth University.