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Protect Endangered Species: Comment by End of Today—Monday, October 25
(Beyond Pesticides, October 25, 2021) The Environmental Protection Agency (EPA) is requesting public comments on its draft Biological Evaluations (BEs) for neonicotinoid insecticides imidacloprid, clothianidin, and thiamethoxam by 11:59 pm (EDT) on Monday, October 25, 2021. The BEs will factor into EPA’s registration review decisions on the three bee-toxic insecticides. Written comments must be submitted through Regulations.gov. Please feel free to cut and paste parts of Beyond Pesticides’ comments (linked here) or cut and paste into Regulations.gov the suggested comment language at the very bottom of this alert.
Tell EPA to protect endangered species from pesticides.
EPA’s Biological Evaluations for these highly toxic chemicals make no agency conclusion or recommendation that would trigger a request to initiate formal Endangered Species Act (ESA) §7(a)(2) consultations with the U.S. Fish and Wildlife Service (USFWS) to determine a possible jeopardy finding for the listed species and requisite mandatory use restrictions of the relevant pesticide. This, despite the fact that for imidacloprid the agency’s draft Biological Evaluation made a May Affect determination for 89% of the 1821 species considered and 90% of the 791 critical habitats considered. Strikingly, a May Affect determination was made for 100% of amphibian and avian listed species and their critical habitat. It was also determined that imidacloprid is Likely to Adversely Affect 100% of the listed amphibian species exposed. The Biological Evaluation for each of the three neonicotinoids makes effects determinations—NE (no effect), MA (may affect), NLAA (not likely to adversely affect), or LAA (likely to adversely affect)—that could affect 1821 listed species, and 791 designated critical habitats.
These serious risk findings for endangered and threatened species made for imidacloprid, clothianidin, and thiamethoxam account for existing product labels and mitigation efforts. The Endangered Species Act requires, “Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency…is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species….”
The complete Biological Evaluations (BEs)—with all determinations and species considered—must be included with the formal consultation request and not just the LAA determinations. This will allow USFWS to also corroborate the agency findings of NLAA and LAA as part of the consultation.
A No Effect determination was made for only 11% of listed species considered because these species have a limited geographic distribution and would likely not be exposed to imidacloprid under the existing label use and mitigation instructions. Thus, any species listed and exposed to imidacloprid is potentially adversely affected.
For clothianidin, a similar May Affect determination was made for 86% of listed species considered and 83% of the critical habitats considered. Likely to Adversely Affect findings overall were made for 67% of listed species and 56% of critical habitats considered. As imidacloprid, 100% of listed amphibian species are likely to be adversely affected by clothianidin uses.
Thiamethoxam degrades to clothianidin and therefore shares similar fate and behavior in the environment. May Affect determinations were made for 88% of species and 89% of critical habitats considered. Likely to Adversely Affect findings overall were made for 77% of listed species and 81% of critical habitats considered. As reported for the other neonicotinoids, 100% of amphibian species and critical habitat are likely to be adversely affected.
EPA should also include the American bumble bee (Bombus pensylvanicus) in its revised Biological Evaluations for the neonicotinoid insecticides. Although this insect is not a currently listed species, the Fish and Wildlife Service has recently determined a petition including substantial scientific and commercial information indicating that listing the American bumble bee as an endangered or threatened species may be warranted. Bumble bee species are highly susceptible to neonicotinoid exposures and are likely jeopardized by continued use of these insecticides.
Must we wait until species are listed as threatened or endangered to protect them? Given the systemic character of neonicotinoids and their extreme toxicity to insects, EPA must assume that they will ultimately lead to the demise of insects that consume nectar, pollen, plant exudates, or plant tissues. The burden of proof is on the registrant(s) to demonstrate that these products will not further exacerbate the ongoing insect apocalypse—and lead to further biodiversity loss through decimation of this essential link in food webs.
Furthermore, EPA must use organic production as the standard against which pesticide “benefits” are weighed. Any crop that can be produced with chemical-intensive methods can be produced organically. Organic producers use very few synthetic pesticides and no neonicotinoids. Therefore, the potential jeopardy of extinction to the 1445+ species identified by these biological evaluations must be considered unreasonable under the definition in FIFRA.
EPA has determined unequivocally that neonicotinoids pose risks to the environment that cannot be acceptably mitigated in any long-term, sustainable way. The agency in its proposed interim decisions for these chemicals identifies several uses for imidacloprid and clothianidin that must be cancelled. However, EPA believes that the benefits of other uses outweigh these serious risks and is proposing limited or no mitigation measures. Given the frequency of detection in U.S. waterways, soil, and plants, the recognized acute and chronic risks posed to pollinators, aquatic invertebrates, vertebrate wildlife, and human health, the risk/benefit determination is pitifully insufficient, especially in light of the BEs identifying the majority of listed species as potentially jeopardized by these neonicotinoid insecticides. Therefore, EPA must quickly suspend all remaining neonicotinoid uses as it pursues the ESA §7(a)(2) consultations with the Services. Additional data to address existing uncertainties and gaps will not alter or lessen the environmental and health risks already unmistakably recognized.
Submit comments to EPA using Regulations.gov.
Suggested Comment To EPA (feel free to cut and paste the following into Regulations.gov):
EPA has determined unequivocally that neonicotinoids pose risks to the environment that cannot be acceptably mitigated in any long-term, sustainable way. The agency in its proposed interim decisions for these chemicals identifies several uses for imidacloprid and clothianidin that must be cancelled. However, EPA believes that the benefits of other uses outweigh these serious risks and is proposing limited or no mitigation measures. Given the frequency of detection in U.S. waterways, soil, and plants, the recognized acute and chronic risks posed to pollinators, aquatic invertebrates, vertebrate wildlife, and human health, the risk/benefit determination is pitifully insufficient, especially in light of the Biological Evaluations identifying the majority of listed species as potentially jeopardized by these neonicotinoid insecticides.
The agency’s draft Biological Evaluation made a May Affect determination for 89% of the 1821 species considered and 90% of the 791 critical habitats considered. Strikingly, a May Affect determination was made for 100% of amphibian and avian listed species and their critical habitat.
Therefore, EPA must quickly suspend all neonicotinoid uses as it pursues the Endangered Species Act §7(a)(2) consultations with the U.S. Fish and Wildlife Service. Additional data to address existing uncertainties and gaps will not alter or lessen the environmental and health risks already unmistakably recognized.
Thank you for your consideration.
I hardly see bees anymore, I live in a neighborhood that uses pesticides heavily. Please help us !
October 22nd, 2021 at 7:18 pmEPA has determined unequivocally that neonicotinoids pose risks to the environment that cannot be acceptably mitigated in any long-term, sustainable way.
These also kill birds, so BAN them!
October 23rd, 2021 at 9:38 pmPlease be careful for the bees. Bumbles have changed over the years in my area, having black, smooth not hairy back half. I am glad they can survive but want them to live!!
October 24th, 2021 at 7:44 amUltimate importance to save the pollinators.
October 25th, 2021 at 11:47 amPlease don’t approve the use of any pesticide toxic to pollinators. Thank you.
October 25th, 2021 at 5:09 pmI have worked hard for the last 12 years to establish and provide a healthy little ecosystem around my home, and up to about 5 years ago, I saw an increase in all sorts of insects, beneficial’s, pollinators, and such including bees. I also saw an increase in birds. In the last 5 years, I have seen a steady decrease though I grow a greater diversity of plants now. Our town is surrounded by industrial agriculture.
October 25th, 2021 at 9:06 pmNeoNic pesticides are damaging bees and other pollinators, we need less not more. Instead of bumblebees now I see mainly carpenter bees. I am not sure how much is pesticide use and how much climate change etc, but I pay taxes and I would appreciate if wiser heads prevailed over payoffs from the chemical industry. (not saying they pay off the EPA but I am beginning to suspect it.) Neonics don’t go away, just say no
October 25th, 2021 at 10:34 pmSave the bees! We need them to live. Please stop the use of harmful and toxic chemicals.
October 26th, 2021 at 7:22 amPlease stop killing our wonderful pollinators!!!
October 30th, 2021 at 10:24 amPlease save the pollinators!!!! We cannot live without them.
November 10th, 2021 at 1:35 pmWe need pollinators in our yards and in agriculture area. Labels need to be larger and Readable to Warn the home Gardner or Landscapers that a product is harmful to Pollinators. Our Bee’s are the Canary in the Coal Mine. Pay Attention to Science. Stop Killing the Bee’s. PS: I only saw one bumble bee and very few honeybees all spring and summer long.
November 13th, 2021 at 11:16 pm