Of highest importance.--Tom
In a message dated 6/20/2013 1:07:38 P.M. Central Daylight Time,
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We contributed to this action.
Laurel Hopwood, Chair, Sierra Club Genetic Engineering Action Team
June 20, 2013
President Barack Obama
The White House 1600 Pennsylvania Avenue NW Washington, DC 20500
Urgent Appeal - neonicotinoid insecticides
Dear Mr. President,
We write to highlight a very important concern: the negative environmental
and economic impacts of outdoor uses of the EPA-approved neonicotinoid
insecticides: imidacloprid, clothianidin, thiamethoxam, dinetofuran and
acetamiprid. On April 29, the European Union voted for a two-year suspension on
major uses of the three most common neonicotinoids: imidacloprid,
clothianidin and thiamethoxam. The decision came on the heels of comprehensive,
peer-reviewed research conducted by the European Food Safety Authority (EFSA),
which indicated that those three insecticides pose both acute and chronic
hazards to honey bees and that significant gaps exist in the data needed to
assess their safety. The EU decision signals the way forward for your
Administration to suspend neonicotinoids in the United States.
The undersigned groups are very concerned with EPA's past approvals of
these insecticides. Agency officials have acknowledged that here, as in
Europe, the original risk assessments and registration data requirements focused
on acute honey bee mortality and failed to adequately consider other key
risks to colony health. This means the hundreds of EPA-approved neonicotinoid
products were approved based on inadequate assessments. This is
unacceptable in view of the fact that honey bee pollination is a $20 to 30 billion
per year contributor to U.S. agriculture and vital to the majority of fruit
and vegetable produce. 2
In the face of severely declining bee colonies nationally - with
beekeepers reporting record losses this year - it would not be responsible to
continue to allow these threatening compounds to be used so broadly. Independent
scientists and commercial beekeepers attribute dramatic bee die-offs to a
combination of factors, but exposure to neonicotinoids is a key contributor.
We are asking you as Chief Executive to direct the EPA to follow the EU
and EFSA lead and recognize the risks are unacceptably high. Pollination
services provided by honey bees and the other even less-studied wild bees are
far too important for agriculture, gardens and wild plants to treat them in
a non-precautionary manner. Many thousands of beekeeper livelihoods, and
indeed the future viability of commercial beekeeping and the crops relying on
these pollination services, are potentially in jeopardy. Experts have
identified the potential for "domino effects" of cascading inadequate crop
pollination due to shortage of viable pollinators. This could rapidly evolve
into devastating, perhaps irreversible, losses to farmers, consumers and the
economy as a whole, which relies on domestically-produced bee-pollinated
food and fiber crops.
In recent statements about the EU's decision, EPA officials highlighted a
recent USDA report, the Report on the National Stakeholders Conference on
Honey Bee Health - National Honey Bee Health Stakeholder Conference Steering
Committee. Unlike the peer-reviewed, scientific EFSA report, the USDA
report was not peer-reviewed; it derived from a meeting of numerous
stakeholders including many non-scientists. It is dated and not comprehensive.
Further, there was not consensus among the stakeholders on the statements
in the final report.
We would like to bring your attention to recent acknowledgments of key
facts by EPA officials, made in public statements at recent meetings, in media
statements, in EPA documents and other venues:
* They acknowledged EPA's enforcement guidance for neonicotinoid use was
inadequate.
* They acknowledged EPA's bee kill incident reporting system was
inadequate.
* They have stated the labels on neonicotinoid products are inadequate to
mitigate adverse environmental effects, specifically to avoid seed
dust-mediated mortality to honey bees and other beneficial insects in or near corn
fields.
* They recognize the current corn planting machinery poses significant
dust-off risks and needs changing, while also recognizing that such changes
will likely take many years and stating that EPA lacks authority to mandate
machinery changes.
* They acknowledge that bee health and populations, and crop pollination,
are in a near-crisis state based on several synergistic factors including
insecticide use.
* They indicated the agency has not consulted with the U.S. Fish and
Wildlife Service on potential effects on threatened or endangered species under
Sec. 7 of the Endangered Species Act for the neonicotinoid insecticides.
Despite the above, EPA has refused to exercise its regulatory power to
address the one factor it could address tomorrow - the major contribution of
these insecticide to bee declines - and instead has pointed to land use
decisions, crop planting choices by farmers, pathogens, bee nutrition and other
factors over which EPA has no authority. Indeed, no other Federal agency 3
has the power to help stem bee declines by addressing any of those
synergistic factors within a reasonable timeframe.
We would like to further highlight a broader threat: water contamination
by imidacloprid, clothianidin, thiamethoxam and the other compounds, the
effect of which is to "sterilize" much of the invertebrate food chain,
threatening insects, fish, amphibians and other taxa, including, but not limited
to, aquatic and insectivorous birds. Recently, the American Bird Conservancy
(ABC) released a report, The Impact of the Nation's Most Widely Used
Insecticides on Birds, researched by an internationally-recognized avian
toxicologist, Pierre Mineau, who examined the key EPA risk assessment documents
and found numerous failures in the agency's approvals. The report showed high
direct and indirect mortality risks to a broad suite of birds, as well as
to aquatic invertebrates and ecosystems generally. It found that the
observed acute threats from water contamination by EPA-approved neonicotinoids
"may be totally unprecedented in the history of pesticide registration". It
also stated: "EPA has not been heeding the warnings of its own
toxicologists". Dr. Mineau examined the approved product labels and found them
inadequate, stating "regulators are clearly mistaken in believing that exposure to
treated seed can be minimized by label statements or adherence to good
agricultural practices". The report describes EPA's analysis as "scientifically
unsound". It urges the agency to suspend use of these products and to ban
neonicotinoid seed treatments altogether.
The leeway for your Administration to somehow disregard the ABC report was
drastically reduced by the peer-reviewed publication in PLOS ONE on May 1
of this year of a major Dutch study, Macro-Invertebrate Decline in Surface
Water Polluted with Imidacloprid. This multi-year, comprehensive, field
study states (emphasis added):
While a large amount of evidence exists from laboratory single species and
mesocosm experiments, our study is the first large scale research based on
multiple years of actual field monitoring data that shows that
neonicotinoid insecticide pollution occurring in surface water has a strong negative
effect on aquatic invertebrate life, with potentially far-reaching
consequences for the food chain and ecosystem functions.
In short, we could face a second "Silent Spring" above and beyond the
threats to managed and wild pollinators. Unfortunately, EPA's planned deadline
of completing its Registration Reviews for the major neonicotinoids by 2018
is far too slow in view of their potentially calamitous risks.
We trust you do not want to preside over this pending crisis. Directing
EPA to follow the EU's lead would be a first step but even more protective
measures are needed, including a minimum two-year suspension for all outdoor
uses of neonicotinoid insecticides pending resolution of their risks.
Thank you for your consideration of this urgent appeal. We look forward to
your response.* 4
Sincerely,
American Bird Conservancy
Beyond Pesticides
Californians for Alternatives to Toxics Center for Environmental Health
Center for Food Safety
Defenders of Wildlife
Food & Water Watch
Friends of the Earth
Northwest Coalition for Alternatives to Pesticides
Pesticide Action Network North America
Sierra Club
The Xerces Society
CC: Tom Vilsack, Secretary of Agriculture
Sally Jewell, Secretary of the Interior
Nancy Sutley, Chair, Council on Environmental Quality
Bob Perciasepe, Acting Administrator, EPA
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