July 12 2000

Ms. Carol Browner
Environmental Protection Agency
401 "M" Street SW
Washington, D.C. 20460

Re: Diazinon

Dear Ms Browner:

The Mountaineers is the oldest and one of the largest environmental and recreation organizations in the State of Washington. For many years we have been concerned about protecting the wild environment and the fisheries and wildlife resources of the State of Washington.

The EPA has recently published a Draft Environmental Risk Assessment for the pesticide diazinon. Many existing studies show that Diazinon kills birds and aquatic species and contaminates surface water. Infact, 10 percent of total wildlife mortality incidents are attributable to Diazinon. Diazinon is highly toxic to freshwater, estuarine, and marine mammals. Studies show that Diazinon has effects on salmon and other fish which interfere with fish behaviors important for survival. This is very important in the State of Washington because two salmon species in Puget Sound have been listed as threatened under the Endangered Species Act. Further, in studies conducted between 1987 and 1998, Diazinon was found in concentrations which exceed the maximum levels recommended by the National Academy of Sciences in streams in the Puget Sound area.

Considering these major impacts of diazinon, the Mountaineers recommend that the EPA issue a proposed Rule severely restricting Diazinon to levels which would protect fish, wildlife, and water quality.


The Mountaineers

Edward M. Henderson, Jr.