Dear Director Housenger,
Study after study on neonics has found them to be a significant contributing factor to colony collapse disorder. As a result, U.S. beekeepers lost an average of 45 percent of their colonies between the end of 2012 and the end of 2013, and hives are producing 85 percent fewer queens.
It's understandable that companies that profit off the sale of neonics would argue that the benefits gained from their use outweighs the harm to the bee population, but now that your own study on the impact of neonics on soy crops found "little or no increase in soybean yields using most neonicotinoid[s]…when compared to using no pest control at all," it's clearer than ever that these harmful pesticides are definitely not worth the risk.
To continue to use a pesticide that is known to cause harm to pollinators and may not even increase crop yields is dangerous. In fact, the massive decline in the bee population threatens the very survival of the fruits and vegetables neonics attempt to protect.
You have stated that your goal in this review process is to ensure that each pesticide "continues to satisfy its intended function without causing unreasonable adverse effects on human health or the environment." It's clear that neonics do not fit this requirement, and it's time to ban their use.
[City, State ZIP]
If you read the EPA Document Summary, the details are all there. Why would John Bennett or David Suzuki miss that part?
The Biological and Economic Analysis Division (BEAD) analyzed the use of the nitroguanidine
neonicotinoid seed treatments for insect control in United States soybean production.
Imidacloprid, thiamethoxam, and clothianidin are applied to seeds at mostly downstream seed
treating facilities prior to distribution to growers prior to planting. BEAD concludes that these seed treatments provide negligible overall benefits to soybean production in most situations. Published data indicate that in most cases there is no difference in soybean yield when soybean seed was treated with neonicotinoids versus not receiving any insect control treatment.
Furthermore, neonicotinoid seed treatments as currently applied are only bioactive in soybean foliage for a period within the first 3-4 weeks of planting, which does not overlap with typical periods of activity for some target pests of concern. This information, along with current usage data, suggest s that much of the existing usage on soybeans is prophylactic in nature. Multiple foliar insecticides are available in instances where pest pressure necessitates a pest management tactic and such foliar insecticides have been found to be as efficacious as neonicotinoid seed treatments for target pests. These alternatives to neonicotinoid seed treatments include foliar
sprays of organophosphates ( acephate, chlorpyrifos ), synthetic pyrethroids (bifenthrin, cyfluthrin, gamma-cyhalothrin, lamba-cyhalothrin, deltamethrin, esfenvalerate, zetacypermethrin, permethrin), neonicotinoids (imidacloprid, thiamethoxam, clothianidin), and the recently registered sulfoxaflor, which works in a similar way to neonicotinoids. In most cases, these alternatives are comparable in cost to one another and to neonicotinoid seed treatments.
The cost of application was considered in this comparison, although because these alternatives can be tank-mixed with other chemicals that are typically applied to soybeans, additional passes over a field would not be necessary. In comparison to the next best alternative pest control measures, neonicotinoid seed treatments likely provide $0 in benefits to growers and at most $6 per acre in benefits (i.e., a 0%-1.7% difference in net operating revenue). Some neonicotinoid seed treatment usage could provide an insurance benefit against sporadic and unpredictable
pests, particularly in the southern United States. However, BEAD did not find information to support the real-world significance of this benefit, and overall evidence indicates that any such potential benefit is not likely to be large or widespread in the United States.