LEAD for Pollinators, Inc. seeks your support and comments concerning the Environmental Protection Agency PROPOSED INTERIM DECISION ON NEONICOTINOIDS. Please submit your comments to support regulations which protect honey bees and native pollinators, or feel free to copy and paste our letter below and submit it by May 4th. Let EPA know you want pollinators protected from the impact of pesticides to ensure pollinator and ecosystem health and sustainability. Please submit your comments by May 4, 2020.
Please note: At Regulations.gov, where comments can be submitted to the docket, there is a “5000 character with spaces” limitation in the text box. A sample letter below is available for you to copy the text, select the link to Regulations.gov, click on the Comment Now button, and paste the text (which is less than 5000 characters) into the text box. Feel free to edit the sample comments and type your own, just remember you are limited to 5000 characters including spaces.
Copy and Paste Text of the draft letter below.
Dear Chemical Review Managers:
I join with LEAD for Pollinators, Inc. to comment upon the Proposed Interim Decision on Neonicotinoids.
Environmental effects of neonicotinoid pesticides have been studied more than any other insecticide, with the possible exception of DDT. There is a preponderance of literature showing harmful effects to managed honey bees, native pollinators, and other organisms. The impact upon honey bees by this class of pesticide results in:
• A 24% decline in overwintering success of honey bee colonies
• Natural forage areas contaminated with bee toxic pesticides
• Reduced flight capacity in honey bees, decreasing food-collecting ability
• Impaired basic motor coordination of honey bees
• Invertebrate toxic levels found in surface water after rain events, in wetlands, and in snowmelt (A bee colony can drink up to three gallons of water daily.)
• Contaminated pollen and nectar being returned to the hive leading to sub-lethal levels of toxins fed to honey bee larvae
• Reduced reproductive capability in queens and drones
• Contaminated soil, water, and plant products which translocate into the pollen and nectar
• Synergism with other pesticides increasing the toxicity levels of herbicides, fertilizers, fungicides, adjuvants, and surfactants in the pesticide tank mix
• Wildflower contamination. 97% of neonicotinoids brought to the hive were collected from wildflowers, not crops, showing the drift through the soil, water, and air of these pesticides to natural forage areas
• Decreased immunocompetence of honey bees leading to impaired disease resistance
• The spread and abundance of pathogens and parasites among honey bees
It is imperative we work to save the biodiversity not only of aquatic ecosystems, but all other ecosystems linked by the food web. Since the prophylactic use of seeds treated with neonicotinoids is responsible for most of the soil and aquatic contamination, while many studies point to little productivity gain, one obvious solution is to stop the marketing of seeds coated with these insecticides and use alternative and carefully targeted methods for pest control in agriculture, such as integrated pest management (IPM). At the same time, remediation systems based on photolytic processes and wetlands phyto-remediation should be implemented to reduce as much as possible the current and legacy contamination by these and other pesticides.
Federal action for protecting pollinators has included amending labels and requiring States to develop Managed Pollinator Protection Plans (MP3). These amended labels have advisory language which “facilitates” MP3s advising beekeepers to either cover or move managed bees. The naïve reliance on MP3 recommendations does not equal regulation, funded mandates, and complete product research prior to releasing these chemicals into the ecosystem.
Wild bee populations are in decline across many landscapes. (Koh, 2015) Research indicates that wild bees are at particular risk from insecticide applications at different times than managed pollinators. (Park, Mia, 2015) Wild pollinators are most affected by pesticides after plant bloom periods, as they continue to forage in and around pesticide-treated areas after managed colonies have moved on. Researchers, Rundolf, et.al (2015) conclude that “pesticide effects on honey bees cannot always be extrapolated to wild bees.”
Beekeepers value deeply their relationships with farmers, ranchers, and specialty crop producers. It is important to bee health to examine all stressors, including pesticides. EPA has misinformed farmers especially to the hazards of pesticides coated on seeds, and allowed long-term chemical contamination of farmland, other crops, surrounding crop and wild lands, waterways, and the ecosystem.
I join with LEAD for Pollinators, Inc, in calling for the revocation of the registration of all neonicotinoid class of pesticides, including removing pesticide coated seeds from the EPA treated article exemption. In addition, we encourage EPA to take the following actions to update its pesticide registration regulation process through the following recommendations:
1. Revise pesticide registration regulations to take into account all pesticide ingredients (active, inert and adjuvant) and their effects on the environment.
2. Revise pesticide registration regulations to require whole pesticide formulation and tank mixture testing to take into account synergistic effects.
3. Revise pesticide registration regulations to require inert ingredients and whole pesticide formulations testing for chronic toxicological effects and degradation.
4. Revise pesticide registration regulations to require Endangered Species Act (ESA) consultation on the effects of whole pesticide formulations and tank mixtures on threatened and endangered species.
5. Comply with the above requirements in conducting statutorily mandated registration reviews of pesticides.
SELECT THIS LINK TO Regulations.gov
Paste the copy of the letter above (or write your own) into the text block at Regulations.gov .
When you have completed your comment you will see a screen page with your confirmation number. If you provide your email, Regulations.gov will email you a confirmation. Comments typically appear in the docket within 24-48 hours.
Please submit your comments by May 4, 2020. Thank you!!
For more information go to this link at EPA .