When one discounts the 8,476 acres in sagebrush and rock outcroppings, 56% of the acreage on Tule Lake National Wildlife Refuge (NWR) is in agricultural crops, with 49% being in pesticide intensive, commercially leased land. Thus, on Tule Lake NWR more acreage is devoted to agricultural production than to waterfowl wetlands habitats. Much of Lower Klamath National Wildlife Refuge is also devoted to commercial agriculture, instead of providing for waterfowl wetland needs.

For 2002 there 63 approved Pesticide Use Proposals (or "PUPS") comprising 56 total pesticide products which contain a total of 46 different pesticides (e.g. there are 4 different products which contain the pesticide Mancozeb, and 3 different products containing the pesticide Imidocloprid. Also there are 4 different 2-4-D products or formulations.)

Of these chemicals approved for wildlife refuge use: 2 are neurotoxins, 14 are endocrine disrupters, and 11 are identified carcinogens. (While 63 pesticide products are actually listed on the refuges approved total PUP or pesticide list for 2002, some of the same products are used on more than one crop. For example, Roundup is listed for use in four instances for "non-crop" (right-a-way areas), small grains, onions and potatoes.)

Also, approved for 2002, Gaucho, Admire and Provado all are pesticide products that are simply different formulations of the pesticide Imidacloprid. Weedmaster, Weedar 64, Weedestroy and Amine 4CA are all pesticide products that contain the endocrine disruptor 2-4-D. Rodeo, Roundup Original and Roundup Ultra--all contain the pesticide Glyphosate.

To its credit, in 2002 the refuge has finally eliminated two toxic insecticides from the previous year 2000 approved pesticide list. These are Sevin (Carbaryl) and Disulfoton (Disyston). This removes two neurotoxins and one endocrine disruptor previously used on these National Wildlife Refuge lands.

List of Pesticides Used on Tule Lake and Lower Klamath National Wildlife Refuges in 2002

More than 20,000 acres of commercial agriculture occurs within the borders of the Tule Lake and Lower Klamath Lake National Wildlife Refuges (NWRs). One of the many problems associated with this activity is the great number of pesticide products approved for use on the refuges - many of which are so dangerous that they require a 12 to 72 hour waiting period after application before even a large mammal like a human is allowed entry to treated fields.

For 2002, 56 pesticide products have been approved for use on the above NWRs. The EPA has designated many of the pesticide products used on these NWRs as highly toxic or very highly toxic to fish, wildlife, and other organisms. Among the 56 pesticide products approved, The Pesticide Action Network has identified 2 neurotoxins, 11 carcinogens and 14 endocrine disruptors (see list below).

• Telone (1,3 dichloropropane) - a carcinogen AND highly or very highly toxic to mammanls, fish & aquatic invertebrates
• Weedmaster (2-4-D) - endocrine disruptor
• Amine 4 CA (2-4-D)  - endocrine disruptor
• Weedar 64 (2-4-D)  - endocrine disruptor
• Weedestroy AM 40 (2-4-D)  - endocrine disruptor
• Bravo (Chlorothlonil) - a carcinogen AND highly or very highly toxic to mammals, fish & aquatic invertebrates
• Ridomil Gold Bravo (mefenoxam/Chlorothlonil) - a carcinogen
• Lorsban (Chlorpyrifos) - endocrine disruptor AND neurotoxin AND highly toxic to birds, fish, aq. inverts & bees
• Rovral 4F (Iprodione) - carcinogen
• Malathion - endocrine disruptor AND neurotoxin AND very highly toxic or highly toxic to fish, aq. inverts, & bees
• Vapam (Metam Sodium) - carcinogen
• Lexone DF (Metribuzin) - endocrine disruptor
• Sencor DF (Metribuzin)  - endocrine disruptor
• Pounce (Permethrin) - endocrine disruptor AND carcinogen AND very highly toxic or highly toxic to mammals, Fish, aquatic invertebrates & bees
• Ambush (Permethrin) - endocrine disruptor AND carcinogen
• Baythroid 2 (Cyfluthrin)  - endocrine disruptor AND carcinogen
• Ridomil Gold MZ  - endocrine disruptor AND carcinogen
• Dithane  - endocrine disruptor AND carcinogen
• Maxim MZ (Mancozeb/Fludioxin)--endocrine disrupter & carcinogen