EPA has been using the Tier I model in AgDRIFT, which had many erroneous and outdated assumptions, including the typical droplet size used, aircraft type reflecting the industry, weather conditions during the application, and boom drop. The AgDRIFT model calculates the estimated drift from aerial applications, as well as ground and airblast applications, by assessing a number of variables related primarily to aircraft setup, droplet size, and weather.
The Tier I model used inaccurate outdated assumptions about aerial applications that resulted in unrealistic aerial drift estimates, which in turn were used in environmental and human health risk assessments. The result has been pesticide registration risk assessments and decisions that have overstated the risk aerial application presents to our environment and fellow citizens.
NAAA has advocated to the EPA for many years to utilize the Tier III model in AgDRIFT and use more realistic assumptions for aerial applications. In a support document for EPA’s recently released insecticide strategy, EPA indicated they had accepted NAAA’s recommendations and used the Tier III AgDRIFT model and most of NAAA’s suggested assumptions when drafting the insecticide strategy. The support document strongly suggests EPA will use the more accurate Tier III model with updated assumptions for all ecological risk assessments going forward. Similar EPA policies related to the reregistration of pesticides have also resulted in the agency moving towards Tier III of AgDRIFT and using wind directional buffers—points advocated by NAAA.