24
Jun
Pollinator Week Ends; Pollinator Decline and Biodiversity Collapse Continue with Inadequate Restrictions
(Beyond Pesticides, June 24, 2024) National Pollinator Week ended last week, but the crisis associated with pollinator decline and biodiversity collapse continues. If there were not enough data to prove that regulators are woefully behind the curve in protecting pollinators, yet another study was published during Pollinator Week that reminded regulators, elected officials, farmers, gardeners, all eaters, and lovers of nature that federal, state, and local environmental laws in place have been an abject and unconscionable failure in protecting the biodiversity that supports all life. The study, “Insecticides, more than herbicides, land use, and climate, are associated with declines in butterfly species richness and abundance in the American Midwest,†published in PLOS ONE, cries out as a further warning that the U.S. Environmental Protection Agency’s (EPA) “mitigation measures,†which tinker with limited pesticide restrictions, represent a catastrophic disregard for the scientifically documented facts, according to environmental advocates.
Daily News will cover this study in more detail in a later piece, however, the abstract of the journal piece is worth reprinting here in reflecting on Pollinator Week:
“Mounting evidence shows overall insect abundances are in decline globally. Habitat loss, climate change, and pesticides have all been implicated, but their relative effects have never been evaluated in a comprehensive large-scale study. We harmonized 17 years of land use, climate, multiple classes of pesticides, and butterfly survey data across 81 counties in five states in the U.S. Midwest. We find community-wide declines in total butterfly abundance and species richness to be most strongly associated with insecticides in general, and for butterfly species richness the use of neonicotinoid-treated seeds in particular. This included the abundance of the migratory monarch (Danaus plexippus), whose decline is the focus of intensive debate and public concern. Insect declines cannot be understood without comprehensive data on all putative drivers, and the 2015 cessation of neonicotinoid data releases in the US will impede future research.â€
These issues are not new to readers of Daily News and those who follow the scientific literature. The United Nations states that 80 percent of the 115 top global food crops depend on insect pollination, with one-third of all U.S. crops depending on pollinators, according to the U.S. Department of Agriculture (USDA). However, research finds that many insect populations are in decline, including managed and wild pollinators. Monarchs are near extinction, and commercial beekeepers continue to experience declines that are putting them out of business. The continued loss of mayflies and fireflies disrupts the foundation of many food chains. Additionally, the decline in many bird species has links to insect declines. Since the 1970s, three billion birds have vanished. The United Nations Development Programme in announcing its COP15 (Conference of the Parties) stated: “Despite ongoing efforts, biodiversity is deteriorating worldwide, and this decline is projected to worsen with business-as-usual. The loss of biodiversity comes at a great cost for human well-being and the global economy.â€Â
All species—and ecosystems—are threatened by the failure of EPA to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA is required to register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.†Under ESA, EPA must, like all federal agencies, “seek to conserve endangered and threatened species and shall utilize their authorities in furtherance of the purposes†of the ESA—which are “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions†through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.â€
In registering and reregistering pesticides, EPA routinely allows uses of chemicals that harm humans, other organisms, and ecosystems. According to FIFRA, whether those harms are “unreasonable†depends on a weighing of costs and benefits. Under a related law, the Federal Food, Drug, and Cosmetic Act, EPA sets allowable residue limits of pesticides in food (tolerances) utilizing risk assessments that have embedded in them the assumption that toxic pesticides are necessary for crop production. In fact, EPA starts with the position that farmers cannot farm without these toxic chemicals, an assumption that clouds and undermines the regulatory process and keeps farmers on the pesticide treadmill. In its Draft Herbicide Strategy Framework update, EPA says, “Without certain pesticide products, farmers could have trouble growing crops that feed Americans and public health agencies could lack the tools needed to combat insect-borne diseases†Not true. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits†of pesticides are measured.
The only way to truly protect pollinators, insects, birds, and other species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Converting the world’s agricultural systems to organic would have a tremendously positive impact on threatened populations. Organic farming enhances biodiversity in the ecosystem and mitigates environmental degradation and climate change, all of which is necessary for recovery of threatened and endangered species.
By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. Organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world. Organic farming methods increase carbon sequestration in soils, reducing atmospheric carbon dioxide levels through practices that enhance soil organic carbon, such as using cover crops and organic soil amendments. Furthermore, organic farming reduces the reliance on fossil fuels by eliminating synthetic fertilizers and pesticides, which are energy-intensive to produce.
As part of its update to EPA’s ESA Workplan, EPA has created a “Mitigation Menu Website†for “reducing pesticide exposure to nontarget species from agricultural crop uses.†After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace†with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.†The strategy being employed by EPA has been characterized by commercial beekeeper Steve Ellis (more background), saying, “If it’s so complex that it’s impossible, then no one wins.â€
Mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are entirely voluntary. There is no enforcement mechanism and no way to ensure that the pesticides are used as directed or that mitigation measures are implemented properly. In addition, EPA is making allowances for use of a pesticide when impacts cannot be avoided. Specifically, EPA plans to allow the use of toxic chemicals that kill endangered species when the user provides “offsets†such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species.†How EPA will ensure that such offsets happen or that they successfully contribute to the conservation of a species of concern has not been described. It also does nothing to protect the habitat necessary for the long-term survival of the species in its ecosystem.
As mentioned above, the only way to truly protect endangered species, as well as the ecosystem as a whole, is to stop the use of pesticides completely. Instead of creating a complicated workaround that will not address the urgent health, biodiversity, and climate crises, Beyond Pesticides is urging EPA to cancel the registrations of pesticides that harm endangered species as part of an overall plan to end petrochemical pesticide and fertilizer and facilitate a society-wide conversion to organic practices.
Letter to EPA:
At the close Pollinator Week, I want to remind you that all species—and ecosystems—are threatened by the failure of EPA to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA may register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.†Under ESA, EPA must “seek to conserve endangered species and threatened species and . . . utilize their authorities in furtherance of the purposes†of the ESA—which are “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions†through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.â€
In registering and reregistering pesticides, EPA allows uses that harm humans, other organisms, and ecosystems. EPA starts with the position that farmers cannot farm without these toxic chemicals, which fails to eliminate unreasonable risk. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits†of pesticides are measured.
By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. By eliminating petrochemical pesticides and fertilizers, organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world.
As part of its update to EPA’s ESA Workplan, EPA created a “Mitigation Menu†for “reducing pesticide exposure to nontarget species from agricultural crop uses.†After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace†with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.†Farm groups that discussed possible mitigation measures in a series of workshops recognized the complexities in crafting restrictions and pesticide product label changes to protect endangered species. In the words of one participant, “If it’s so complex that it’s impossible, then no one wins.â€
Even if EPA can address complications, mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are voluntary, with no enforcement mechanism to ensure that the pesticides are used as directed or mitigation measures are implemented properly. Moreover, EPA makes allowances to use a pesticide when impacts cannot be avoided—allowing the use of toxic chemicals that kill endangered species when the user provides “offsets†such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species,†with unknown effectiveness.
The only way to protect endangered species and the ecosystem is to stop the use of pesticides. Instead of creating a complicated work-around that fails to protect, EPA must cancel registrations of pesticides that harm endangered species and facilitate a widescale conversion to organic practices.
Thank you.
Letter to U.S. Representative and Senators:
At the close Pollinator Week, I want to remind you that all species—and ecosystems—are threatened by the failure of EPA to perform its statutory duties under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA). Under FIFRA, EPA may register pesticides only when they pose no “unreasonable risk to man [sic] or the environment, taking into account the economic, social, and environmental costs and benefits.†Under ESA, EPA must “seek to conserve endangered species and threatened species and . . . utilize their authorities in furtherance of the purposes†of the ESA—which are “to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, to provide a program for the conservation of such endangered species and threatened species, and to take such steps as may be appropriate to achieve the purposes of the treaties and conventions†through which “the United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction.â€
In registering and reregistering pesticides, EPA allows uses that harm humans, other organisms, and ecosystems. EPA starts with the position that farmers cannot farm without these toxic chemicals, which fails to eliminate unreasonable risk. Organic farmers are not reliant on these pesticides. Organic practices must be used as the yardstick against which so-called “benefits†of pesticides are measured.
By avoiding synthetic pesticides and fertilizers, organic farms provide a safer habitat for a wide range of organisms, from soil microbes and insects to birds and mammals. The biodiversity provided by organic farms is crucial for ecosystem resilience and the provision of ecosystem services such as water purification, pollination, and nutrient cycling, that benefit all species. By eliminating petrochemical pesticides and fertilizers, organic farming also mitigates climate change, which is a significant contributor to the decline of species around the world.
As part of its update to EPA’s ESA Workplan, EPA created a “Mitigation Menu†for “reducing pesticide exposure to nontarget species from agricultural crop uses.†After court decisions forced EPA to develop a strategy to meet its statutory responsibility to protect endangered species from pesticide use, the agency recognized that it is, in its own words, “unable to keep pace†with its legal obligations. Therefore, instead of carrying out its charge under ESA, the agency says it will “provide flexibility to growers to choose mitigations that work best for their situation.†Farm groups that discussed possible mitigation measures in a series of workshops recognized the complexities in crafting restrictions and pesticide product label changes to protect endangered species. In the words of one participant, “If it’s so complex that it’s impossible, then no one wins.â€
Even if EPA can address complications, mitigations only reduce the chance of harmful impacts of pesticide use. Perhaps more importantly, the mitigation measures are voluntary, with no enforcement mechanism to ensure that the pesticides are used as directed or mitigation measures are implemented properly. Moreover, EPA makes allowances to use a pesticide when impacts cannot be avoided—allowing the use of toxic chemicals that kill endangered species when the user provides “offsets†such as “funding habitat restoration for the species, contributing to a captive rearing project at a zoo for the species, or other steps to conserve the species,†with unknown effectiveness.
The only way to protect endangered species and the ecosystem is to stop the use of pesticides. Please ensure that instead of creating a complicated work-around that fails to protect, EPA cancels registrations of pesticides that harm endangered species and facilitates a widescale conversion to organic practices.
Thank you.
