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Date:         Thu, 20 Jun 2013 14:05:49 -0400
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From:         Laurel Hopwood <[log in to unmask]>
Subject: Letter to Obama: Urgent Appeal - neonicotinoid insecticides
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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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<!doctype html public "-//W3C//DTD W3 HTML//EN">
<html><head><style type="text/css"><!--
blockquote, dl, ul, ol, li { padding-top: 0 ; padding-bottom: 0 }
 --></style><title>Letter to Obama: Urgent Appeal - neonicotinoid
insecticide</title></head><body>
<div><font face="Helvetica">We contributed to this
action.</font></div>
<div><font face="Helvetica">Laurel Hopwood, Chair, Sierra Club Genetic
Engineering Action Team</font></div>
<div><font face="Helvetica"><br></font></div>
<div><font face="Helvetica">June 20, 2013</font></div>
<div><font face="Helvetica">President Barack Obama<br>
The White House 1600 Pennsylvania Avenue NW Washington, DC
20500</font></div>
<div><font face="Helvetica"><br>
Urgent Appeal - neonicotinoid insecticides</font></div>
<div><font face="Helvetica"><br>
Dear Mr. President,<br>
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.</font></div>
<div><font face="Helvetica"><br>
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</font></div>
<div><font face="Helvetica"><br>
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.</font></div>
<div><font face="Helvetica"><br></font></div>
<div><font face="Helvetica">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.</font></div>
<div><font face="Helvetica"><br>
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.</font></div>
<div><font face="Helvetica"><br></font></div>
<div><font face="Helvetica">Further, there was not consensus among the
stakeholders on the statements in the final report.</font></div>
<div><font face="Helvetica">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:<br>
* They acknowledged EPA's enforcement guidance for neonicotinoid
use was inadequate.<br>
* They acknowledged EPA's bee kill incident reporting system was
inadequate.</font></div>
<div><font face="Helvetica">* 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.</font></div>
<div><font face="Helvetica">* 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.</font></div>
<div><font face="Helvetica">* They acknowledge that bee health and
populations, and crop pollination, are in a near-crisis state based on
several synergistic factors including insecticide use.<br>
* 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.</font><br>
</div>
<div><font face="Helvetica">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.</font></div>
<div><font face="Helvetica"><br>
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.</font></div>
<div><font face="Helvetica"><br>
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):<br>
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.</font></div>
<div><font face="Helvetica"><br>
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.</font></div>
<div><font face="Helvetica"><br>
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.</font></div>
<div><font face="Helvetica"><br>
Thank you for your consideration of this urgent appeal. We look
forward to your response.* 4</font></div>
<div><font face="Helvetica">Sincerely,</font></div>
<div><font face="Helvetica">American Bird Conservancy</font></div>
<div><font face="Helvetica">Beyond Pesticides</font></div>
<div><font face="Helvetica">Californians for Alternatives to Toxics
Center for Environmental Health</font></div>
<div><font face="Helvetica">Center for Food Safety</font></div>
<div><font face="Helvetica">Defenders of Wildlife</font></div>
<div><font face="Helvetica">Food &amp; Water Watch</font></div>
<div><font face="Helvetica">Friends of the Earth</font></div>
<div><font face="Helvetica">Northwest Coalition for Alternatives to
Pesticides</font></div>
<div><font face="Helvetica">Pesticide Action Network North
America</font></div>
<div><font face="Helvetica">Sierra Club</font></div>
<div><font face="Helvetica">The Xerces Society</font></div>
<div><font face="Helvetica"><br>
CC: Tom Vilsack, Secretary of Agriculture<br>
Sally Jewell, Secretary of the Interior<br>
Nancy Sutley, Chair, Council on Environmental Quality</font></div>
<div><font face="Helvetica">Bob Perciasepe, Acting Administrator,
EPA</font></div>
</body>
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