As we reported last week, farmers’ cost of production has been at record levels six consecutive years; that is a good context for the EPA’s latest Vulnerable Species Pilot (VSP) program which is likely to add production costs and reduce crop production, despite EPA’s promise to drop some of the most restrictive requirements.  Under the Endangered Species Act (ESA), EPA is required to consider the impact on endangered species of pesticide registration. Over the years, EPA’s pesticide registration and re-registration has been subject to several lawsuits. In fact, the agency is now subject to 18 court ordered deadlines to complete reviews over the next six years. That includes a case, originally filed in 2011 by t...