A federal program to severely restrict pesticide use in the forests and farm lands where endangered species roam may itself be endangered because of a lack of federal dollars. The U.S. Environmental Protection Agency opened a 90-day public comment period March 9 on a plan to enforce the Endangered Species Act in areas where pesticide use overlaps with the habitat of endangered species. Remaining hearings are scheduled for April 28 in Kansas City, Mo., May 3 in Sacramento, and May 6 in Phoenix, Ariz. The 1973 Endangered Species Act requires all federal agencies to ensure their activities or those they monitor do not harm critical wildlife habitat. The EPA's problem, according to several officials close to the agency's program, is that it doesn't have the funds to monitor and enforce pesticide restrictions. ``We don't have the money,'' EPA spokesman Al Heier said in a telephone interview from Washington, D.C. ``We're hoping in the meantime that where there are endangered species that people would voluntarily protect them where that's possible.'' ``Most of the farmers would try to comply,'' said Merlin Fagan of the California Farm Bureau. ``But if one would look at the thousands of dollars it could cost, we might be asking a lot.'' Fagan said the presticide program ``is a joke'' without the money to monitor pesticide use and verify the presence of endangered wildlife. Jay Feldman of the National Coalition Against the Misuse of Pesticides contends the EPA is claiming empty coffers to avoid taking action that would affect farmers. ``I think hidden behind the excuse of money is a real reluctance on the part of the EPA to regulate pesticides that are seen to have a impact on agricultural production,'' he said. ``It's a lack of decisive action that plagues the agency, not a lack of resources.'' One example of an animal's potential impact on agriculture is the San Joaquin kit fox. This endangered creature roams 340,000 prime acres in Fresno County, an area with crops valued at $58.4 million that could be ruled off-limits to pesticides. The push to protect wildlife stems from a 1986 EPA internal report that slammed the agency for failing to implement the Endangered Species Act. The report included hundreds of complaints filed by the U.S. Fish and Wildlife Service alleging the EPA had neglected to protect wildlife where pesticides are used, according to Laurie Mott of the Natural Resources Defense Council in San Francisco. Asked about the report, Heier said, ``What it said was that we were not implementing the Endangered Species Act for old pesticides.'' The report, coupled with criticism from environmentalists, prompted the EPA to propose strict regulation, within specific habitats, of any pesticide registered before 1978, Heier said. Pesticides registered after 1978, when new rules required more complete chemical information, comply with the law, he said. Angry farmers last fall forced a delay of the program's scheduled February start because the EPA's maps of rare plants and animal habitat were inaccurate. Fish and Wildlife Service director Frank Dunkle wrote last October that enforcing the program based on bad maps could ``develop a backlash among pesticide users.'' The EPA plan affects 900 counties nationwide. Pesticide labels would list specific counties where chemicals could threaten endangered species. Growers then would obtain a map to determine restrictions on the chemicals' use. Violations of the law can be punishable by fines of up to $20,000 and one-year prison terms. Last year's plan proposed restrictions on: _ 24 chemicals for forestry use, affecting 58 plant and animal species. _ 9 mosquito larvacides affecting 78 species. _ 29 pesticides for use on rangeland affecting 182 species. _ 64 chemicals for croplands affecting 45 species. County agricultural commissioners would be a farmer's main source for chemical restriction information, said James Wells, chief of the California Food and Agriculture Department's pesticide enforcement unit. As for money to implement and enforce this vast program on the local level, Wells said, ``That's one of the problems. Nobody in EPA has said anything about money. In fact, they said there is no money.'' Without federal funds, Wells speculated the state of California would have to absorb the program's cost. The state would have to help with mapping and enforcement or divert federal funds now used for other programs. Heier said it would probably take two years before the program gets into full swing.