(Beyond Pesticides, April 13, 2017) With pesticide use rising in Southeast Asia, a new study is highlighting the importance of education and social dynamics in driving farmers’ decisions to spray. When women oversee agricultural pesticide use, according to the study, these farms use approximately 42% less pesticide than other farms. The research, published in Science of the Total Environment this month, aims to provide insight on methods that may be used to intervene and reduce pesticide dependence. The investigation comes at a critical time, as international bodies like the United Nations indicate that rampant pesticide use has the potential to negatively impact human rights, especially in developing countries. In Cambodia, Laos, and Vietnam, pesticide imports are growing at an annual rate of 61%, 55%, and 10%, respectively. These trends have international implications, as food imported from these countries is subsequently found contaminated with pesticides, with for example, 33% of crops imported to the European Union from Vietnam containing pesticide residue above maximum acceptable limits. To uncover the factors driving increased pesticide use in the region, researchers queried 900 vegetable farming households on their knowledge, attitude, and practices. Knowledge included understanding about best practices in agriculture, such as the difference between […]

(Beyond Pesticides, April 12, 2017) Earlier this week, the Maryland General Assembly took action to protect pollinators found in designated state pollinator habitat by passing SB 386/HB 830, Pollinator Habitat Plans- Plan Contents- Requirements and Prohibition, with bipartisan support. With this bill, the legislature will require pollinator habitat plans developed by any state agency to be as protective of pollinators as the Maryland Department of Agriculture’s managed pollinator protection plan requires. This translates to prohibiting, with some exceptions, the use of neonicotinoid pesticides or neonicotinoid-treated seeds or plants on state land designated as pollinator habitat. The bill’s passage represents the third major legislative victory to protect bees and other pollinators coming out of Maryland in the past year. Last spring, in a historic move, the Maryland legislature voted to become the first state in the nation to ban consumers from using products containing neonicotinoid pesticides, a class of bee-toxic chemicals that has been linked to the startling decline in bees and other pollinators around the world. The Maryland Pollinator Protection Act (Senate Bill 198/House Bill 211), which also received bipartisan support, stipulates that consumers will not be allowed to buy pesticide products containing neonicotinoids starting in 2018. However, the legislation’s reach does not extend […]

(Beyond Pesticides, April 11, 2017) New data presented last week at a children’s health conference show that glyphosate, the active ingredient in the popular Roundup weed killer, is detected in pregnant women and could lead to adverse pregnancy outcomes, including shorter gestation times and lower birth weights. The researchers here are calling for more biomonitoring of the presence of glyphosate in the public, in spite of industry and government efforts to undermine the science surrounding the human health impacts of the herbicide. Researchers tested and tracked 69 expectant mothers and found that the presence of glyphosate levels in their bodily fluids correlated with unfavorable birth outcomes. The research is still in preliminary stages and is a project of the Children’s Environmental Health Network (CEHN), which is studying the reproductive and children’s health impacts of rising herbicide use in the Midwest. The preliminary results were presented at CEHN’s conference last Thursday in Washington DC. Learn more about the project here. This is a huge issue,” said Paul Winchester, M.D., member of the research team involved with this study, medical director of the neonatal intensive care unit at the Franciscan St. Francis Health system and professor of clinical pediatrics at Riley Hospital for […]

(Beyond Pesticides, April 7, 2017) On Wednesday, Earthjustice, representing the Natural Resources Defense Council (NRDC) and the Pesticide Action Network North America (PANNA) turned to the courts to order the U.S. Environmental Protection Agency (EPA) to ban chlorpyrifos. Their action comes on the heels of EPA Administrator Scott Pruitt’s decision last week to reject the conclusions of EPA scientists and reverse a proposed agency decision to revoke food residue tolerances of chlorpyrifos. In the new petition, the environmental groups assert that, “Because EPA has sidestepped this Court’s orders and failed to act on the substance of the petition, PAN/NRDC respectfully ask the Court to [give] EPA 30 days to act on its findings that chlorpyrifos exposures are unsafe and to establish deadlines for the next steps in the revocation and cancellation process.” In an interview with The Intercept, Patti Goldman, managing attorney of Earthjustice’s Northwest regional office in Seattle, WA, stated that, “It’s outrageous that the new EPA administrator would reject the scientific findings of its own agency and defy the law and court orders to keep this nasty pesticide on the market.” In its most recent analysis of chlorpyrifos, EPA determined that children between one and two years of age […]

(Beyond Pesticides, April 5, 2017) A new study, Occurrence of Neonicotinoid Insecticides in Finished Drinking Water and Fate during Drinking Water Treatment, has detected neonicotinoids, a class of insecticides known for their detrimental effects on bees, in treated drinking water. This marks the first time that these insecticides have been found in water sourced straight from the tap. Federal regulators have not yet addressed safe levels of neonicotinoids in drinking water, so at this point, any detection of these chemicals is cause for concern. The study authors “report for the first time the presence of three neonicotinoids in finished drinking water and demonstrate their general persistence during conventional water treatment.” Drinking water samples “collected along the University of Iowa treatment train” over a seven week period, May through July, 2016 directly after corn and soy planting, find three neonicotinoids, clothianidin, imidacloprid, and thiamethoxam at levels ranging from 0.24 to 57.3 ng/L (nanogams per liter). The University of Iowa tap water is run through a water treatment plant that uses conventional treatment methods.  In contrast, the Iowa City water treatment methods (granular activated carbon filtration) result in substantially lower levels of the neonicotinoids. Additionally, the researchers found that extensive transformation of clothianidin […]

(Beyond Pesticides, April 4, 2017) Exposure to commonly used pyrethroid insecticides results in the early onset of puberty in boys, according to a study presented at the 99th meeting of the Endocrine Society in Orlando, Florida this week. Pyrethroids, which exhibit endocrine disrupting properties, have the ability to interfere with the proper regulation of the human body’s hormonal system. This research is the first to investigate not only the association between pyrethroids and accelerated puberty, but also the causal mechanisms involved in the physiological changes taking place within the human body. For the study, Jing Liu, PhD, and colleagues from Zhejuang University in China, analyzed the urine in 463 Chinese boys aged 9 to 16 for the presence of metabolites from the pyrethroid insecticide cypermethrin. Results show that a 10% increase in the metabolite 3-PBA is associated with a roughly 4% increase in luteinizing and follicle-stimulating hormones, which facilitate puberty and sperm production. The author’s note that, “Boys with increased urinary levels of 3-PBA have a significantly increased risk of earlier pubertal onset, in which the odds of being in an advanced pubertal stage are increase by 73% to 110%.” The study, acknowledging the limitation in determining causality, further investigates the […]

(Beyond Pesticides, April 3, 2017) The European Union (EU) has approved a $130 billion mega-merger between two agrochemical giants, Dow Chemical Company and DuPont Company, heralding a new round of takeovers that environmental and farm groups fear will reduce farmer choice, seed diversity, and endanger the future of sustainable food production. The consent to the merger was given with the requirement that Dow sells off its pesticide business, which it plans to do as part of a $1.6 billion asset swap with the FMC Corporation, a pesticide manufacturer. The Dow Chemical-DuPont deal is one in a series of mergers in the agriculture-chemicals sector being considered in the EU and also the U.S. The Dow-DuPont merger is happening alongside proposed mergers of Bayer and Monsanto, and Syngenta and ChemChina. On March 27th, a letter signed by 200 organizations across Europe was delivered to European Competition Commissioner Margrethe Vestage. The letter says that about 60% of commercial seed supplies will be centralized in the hands of just three multinational corporations if the mergers are all approved, and calls on EU regulators to step in and stop the deals and protect European farmers, and the European food system. The letter, organized by Friends of the Earth […]

(Beyond Pesticides, March 31, 2017) On Wednesday, Scott Pruitt, the new head of the Environmental Protection Agency (EPA), rejected the conclusions of EPA scientists, and independent scientific literature, and reversed a tentative decision from 2015 to revoke food residue tolerances of chlorpyrifos due to the chemical’s neurotoxic impacts. This would have effectively banned chlorpyrifos from agriculture. This decision stemmed from a petition and lawsuit filed by the Natural Resources Defense Council (NRDC) and Pesticide Action Network North America (PANNA)  ten years ago, calling for EPA to revoke all chlorpyrifos tolerances and cancel all registrations. A Federal Appeals court mandated that EPA take final action by March 31, 2017. Mr. Pruitt’s decision leaves the door open for continued neurotoxic dangers for humans, especially children, who have been shown to be especially vulnerable to chlorpyrifos. Chlorpyrifos is part of the organophosphate (OPs) class of pesticides, which were used in World War II as nerve agents. As potent neurotoxicants, organophosphates are extremely harmful to the nervous system, given that they are cholinesterase inhibitors and bind irreversibly to the active site of an enzyme essential for normal nerve impulse transmission. The scientific evidence of neurotoxic dangers associated with chlorpyrifos exposure is extensive and consistent. Epidemiological data also […]

(Beyond Pesticides, March 29, 2017) The U.S.  House of Representatives voted last week to pass H.R. 1029, the Pesticide Registration Enhancement Act of 2017 (PREA), reauthorizing the Pesticide Registration Improvement Act of 2003 (PRIA) under the nation’s pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). When passed in 2003, PRIA established the legal authority of the Environmental Protection Agency (EPA) to collect fees from pesticide makers for safety reviews and market approval. Over time, PRIA has been supported by pesticide manufacturers that are seeking approval for pesticide products, and public health and environmental groups seeking rigorous review and restriction of pesticides to protect human health and the environment. In a time of great uncertainty for the future of EPA, given proposed large-scale budget cuts, swift passage of H.R. 1029 with bipartisan support may signal acknowledgement by Congress that EPA performs a regulatory function that all sides agree is necessary, even though there is rarely agreement on the positions that the agency may take. Proposed reductions in EPA staff speak to the idiosyncrasies inherent in the Trump administration’s promise to reduce regulatory burdens while simultaneously making sweeping cuts to agency staff. E&E News points out that Trump’s plan to […]

(Beyond Pesticides, March 28, 2017) The U.S. Department of Agriculture (USDA) has abandoned its plans to test the U.S. food supply for the presence of glyphosate residues, according to a story from veteran reporter Carrey Gillam in The Huffington Post. The decision comes amid heated controversy over the carcinogenicity of glyphosate, which was cleared by a California judge for listing under California’s Prop 65 earlier this year. The federal government’s pesticide monitoring program, which is run jointly by USDA, the Food and Drug Administration (FDA), and the Environmental Protection Agency (EPA), was criticized by the Government Accountability Office (GAO) in 2014 for its failure to test for the widely used herbicide. In early 2016, Beyond Pesticides met with EPA regulators to discuss testing for glyphosate residues in the U.S. food supply. At the time, officials said that FDA was testing honey, and USDA would be conducting more extensive food testing beginning in 2017. USDA had tested soybeans for glyphosate residue in 2011, finding that 90% of samples contained residues between .26 ppm and 18.5 ppm, barely under the allowed food tolerance level of 20ppm. A 2014 Boston University study had indicated that both organic and conventional honey contained glyphosate concentrations despite […]

(Beyond Pesticides, March 27, 2017) The European Commission (EC) has proposed a complete ban of agricultural uses of the widely used bee-toxic neonicotinoid pesticides across Europe under draft regulations. The EC cites neonicotinoids’ “high acute risks to bees.” In 2013, three neonicotinoids were temporarily banned because of concerns about their high toxicity to bees. A vote by member states can happen as early as May 2017. According to Pesticide Action Network (PAN) Europe, the European Commission has presented to Member States its draft regulations to ban the neonicotinoids: imidacloprid, clothianidin and thiamethoxam. Three draft regulations to ban the three bee-toxic neonicotinoids across the entire EU were submitted to the Standing Committee on Plant, Animal, Food and Feed. These will be open to comments from Member States and a first vote on the Commission’s proposal could take place in May 2017. The new proposals are for a complete ban on the three neonicotinoid uses in fields, with the only exception being for plants grown in greenhouses.  There would need to be a positive vote from 55% of the Member States representing 65% of EU citizens (qualified majority) to implement the proposal. In 2013, the European Commission voted to suspend the use of […]

(Beyond Pesticides, March 23, 2017) We’re just over a month away from Beyond Pesticides’ 35th National Pesticide Forum! Join us for Healthy Hives, Healthy Lives, Healthy Land: Ecological and Organic Strategies for Regeneration, at the Humphrey School of Public Affairs, University of Minnesota, in Minneapolis, Minnesota on April 28-29, 2017. Click here to register now! Register Today: Get the Early Bird Discount (available until March 28)! As an Early Bird buyer, you can get a general rate for $40, a student rate for $20, or a business rate for $170. Scholarships are also available. All ticket price rates include organic meals: on Friday, organic beer, wine, and hors d’oeuvre; on Saturday, organic breakfast, lunch, and dinner, plus organic beer and wine at the evening reception. For more details about registration, click here. Forum Overview: The national forum highlights nationally renowned scientists, including professor emeritus of plant pathology at Purdue University, Don Huber, Ph.D., whose agricultural research has focused on the  epidemiology and control of soil borne plant pathogens with emphasis on microbial ecology, cultural and biological controls, and physiology of host-parasite relationships; Vera Krischik, Ph.D., a tenured faculty in the Entomology Department at the University of Minnesota whose lab does research on insect exposure to various insecticides, […]

(Beyond Pesticides, March 22, 2017) Today, a coalition of farmers and environmental and public health organizations filed a lawsuit against the Environmental Protection Agency (EPA) for approving agrochemical giant Dow Chemical’s toxic pesticide combo, Enlist Duo, among the newer more highly toxic pesticide mixtures used in genetically engineered (GE) herbicide-tolerant crops. Comprised of glyphosate and 2,4-D (50% of the mixture in the warfare defoliant Agent Orange), Enlist Duo is typically marketed alongside commercial crops like corn, cotton and soybeans that are engineered to withstand pesticide exposure, leading to problems of resistance and driving the evolution of super weeds. This is the third lawsuit challenging EPA approval of Enlist Duo by petitioners, which include Beyond Pesticides, National Family Farm Coalition, Family Farm Defenders, Pesticide Action Network North America, Center for Food Safety, and Center for Biological Diversity, represented jointly by legal counsel from Earthjustice and Center for Food Safety. The lawsuit charges that approval of Enlist Duo “will lead to sharply increased spraying of toxic pesticides, harming farmers, neighboring crops, and wildlife.” Specifically farmers’ health and financial positions stand to be heavily impacted by the approval of Enlist Duo, as increased use will result in increased pesticide drift, an alarming concern especially […]

(Beyond Pesticides, March 16, 2017) In a lawsuit filed by cancer victims, a federal judge on Tuesday unsealed documents that raise questions of collusion between officials at the U.S. Environmental Protection Agency (EPA) and Monsanto to fight a cancer classification for the company’s flagship product, Roundup (glyphosate). The judge’s ruling comes in a lawsuit against Monsanto, charging that the company’s herbicide caused the plaintiffs’ non-Hodgkin’s lymphoma. According to the New York Times, the court documents “include Monsanto’s internal emails and email traffic between the company and federal regulators [and] suggested that Monsanto had ghostwritten research that was later attributed to academics.” The California lawsuit was brought on following the determination and listing of glyphosate as a probable human carcinogen by the World Health Organization’s International Agency for Research on Cancer (IARC) in 2015. The released files show that Monsanto was “tipped off to the [IARC] determination by a deputy division director at the EPA, Jess Rowland, months beforehand. That led the company to prepare a public relations assault on the finding well in advance of its publication,” according to the released documents. According to Monsanto’s internal emails, Mr. Rowland had promised to fend off efforts by the Department of Health and Human Services […]

(Beyond Pesticides, March 14, 2017)  The U.S. Environmental Protection Agency (EPA) is opening an investigation into whether the Hawaii Department of Agriculture (HDOA) and the state Agribusiness Development Corporation (ADC) are discriminating against Native Hawaiians in their administration of the state’s pesticide program. The investigation comes after a number of local community groups, represented by the nonprofit environmental law organization Earthjustice, filed a complaint in September 2016 asking EPA to take action against systemic abuses of Native Hawaiian peoples. Local efforts to protect pesticide-exposed communities have been repeatedly stymied by giant pesticide corporations operating on the island, which filed lawsuits that ultimately struck down local laws. EPA’s investigation will focus on the state’s activity on the islands of Kauai and Moloka’i. “The External Civil Rights Compliance Office will investigate whether in administering the pesticides program and the leasing and licensing of the state land program the HDOA and/or ADC discriminated on the basis of race and/or national origin against farm workers and residents of West Kauai and Molokai, in violation of Title VI of the Civil Rights Act, and EPA’s implementing regulation,” wrote Lilian Dorka, director of EPA’s External Civil Rights Compliance Office(ERCO), in a letter to Earthjustice. Under Title […]

(Beyond Pesticides, March 9, 2017) A recent European Parliament (EP) report concludes that organic agriculture and food offer clear human health benefits over chemical-intensive agriculture. The report, Human health implications of organic food and organic agriculture, which was written by scientists from universities across Europe, used existing scientific literature to assess the human health effects from organic agricultural systems. The authors determined that organic agriculture has considerable benefits, including reduction in antibiotic resistance, lowered levels of cadmium in organic crops, and decreased dietary pesticide exposure levels. According to the EP report, “Overall, consumption of organic food substantially decreases the consumer’s dietary pesticide exposure, as well as acute and chronic risks from such exposure.” Organic farming is a systems approach that values healthy, biologically active soils to support plant life and provide critical environmental benefits, such as improved water infiltration, pest suppression, and carbon storage. It is through this preventive, systems approach that organic agriculture eliminates the necessity for pesticides, and instead relies upon soil health to prevent the problems that chemical-intensive agriculture cannot. This report adds to the growing body of evidence on impaired learning and lowered IQs in children prenatally exposed to low levels of certain pesticides, such as organophosphates. The […]

(Beyond Pesticides, March 8, 2017) A report released by the United Nations finds that human rights are adversely affected by pesticide use. With chemicals, like pesticides, long advanced by the synthetic pesticide and fertilizer industry as the answer to feeding the world, the Special Rapporteur on the right to food report concludes that industrialized agriculture has not succeeded in eliminating world hunger, and has only hurt human health and the environment in its wake. The report will be presented before the Human Rights Council today, and aims to give the international governing body an in-depth understanding of the state of global pesticide use in agriculture and its impact on human rights, specifically as it relates to food security. It also looks at the impact of pesticides on the environment, highlighting the need for a transition to more sustainable agricultural practices on a global scale. Authors of the report, Hilal Elver, Ph.D., the UN’s special rapporteur on the right to food, and Baskut Tuncak, the UN’s special rapporteur on toxics, highlight the overarching problem with their observation that “reliance on hazardous pesticides is a short-term solution that undermines the rights to adequate food and health for present and future generations.” They begin the report by […]

(Beyond Pesticides, March 7, 2017) Another study, published by a team of French scientists in the journal Occupational and Environmental Medicine, links childhood behavioral problems to pyrethroid insecticide exposure. Synthetic pyrethroids are a class of insecticides that have increased in use over the past decade due to assumptions that they pose fewer risks to human health than older pesticide chemistries, such as organophosphates. However, this latest study is part of a growing body of research showing that pyrethroids share similar neurocognitive health concerns as these older pesticides. .   In this research, scientists investigate the interplay between pyrethroid exposure and behavioral problems through a longitudinal cohort study, which tracks levels of pyrethroid metabolites, or breakdown products, in the urine of mothers beginning between six and 19 gestational weeks and then in their children up through six years of age. Children’s behavior is measured through a screening questionnaire known as the Strengths and Difficulties Questionnaire (SDQ). SDQ measures how social a child is (altruism), whether the child has difficulty sharing problems or asking for help (internalizing disorders), as well as how defiant or disruptive a child is (externalizing disorders). The study controlled for a number of confounding factors, such as weight, education, location (rural or […]

(Beyond Pesticides, March 3, 2017) A new report identifies antibiotic use in conventional plant and animal agriculture as contributing to bacterial resistance to critical life-saving human medicines and the importance of organic agriculture in eliminating antibiotic use. The report, Agricultural Uses of Antibiotics Escalate Bacterial Resistance, published in the latest issue of Pesticides and You, finds that while antibiotic use in animal agriculture is widely acknowledged as harmful, the use of antibiotics in chemical-intensive crop production also pose unnecessary and significant risks. The World Health Organization in 2016 identified bacterial resistance to antibiotics as “one of the biggest threats to global health.” The report notes that the herbicide glyphosate, one of the most widely used pesticides in the U.S., is patented by its manufacturer, Monsanto, for its antibacterial properties. As a result, glyphosate leads as the most   widely used antibiotic in agriculture and around homes, gardens, schools, and communities in the U.S. Other antibiotics used widely in apple and pear production are oxytetracycline and streptomycin, which is also used in the production of peaches, beans, celery, peppers, tomatoes and potatoes. These uses at environmentally relevant levels increase bacterial resistance to important antibiotics in medicine. “Resistant bacteria move from farms […]

(Beyond Pesticides, March 2, 2017) On Tuesday, the European Commission (EC) refrained from voting on proposed scientific criteria that would have identified endocrine disrupting chemicals (EDC) and led to regulation on their use in EU countries. This sends the Commission back to the drawing board on the proposal, on which they hope to eventually take a formal vote. The failure to move forward with defined criteria on these hazardous chemicals, which are present in pesticides, biocides, and self-care products, is still largely due to the disagreements of voting member states over the rules reflecting hazard or risk-based criteria. There have been several other meetings of the member states on this proposal, including a meeting in December which highlighted the inadequacies of the criteria. After this meeting, according to Bas Eickhout, of the Greens-European Free Alliance, “Under the Commission’s criteria, it is likely that not a single substance would be identified as an endocrine disrupter, and they would effectively escape specific regulation.” This all follows on the weak regulations issued by the EC in June 2016 to regulate endocrine disruptors in pesticide products, which ultimately undermine the precautionary legal standard that governs pesticide usage in Europe. Many scientists and advocacy organizations criticized […]

(Beyond Pesticides, February 23, 2017) Male pesticide applicators who experienced a pesticide spill or another related accident are more likely to harbor changes in their DNA associated with an increased risk of prostate cancer, according to a recent paper published in the journal, Environmental and Molecular Mutagenesis. While the relationship between pesticide exposure and prostate cancer is not new, this study adds to the growing body of evidence that high exposure to specific pesticides may lead to the development of prostate and other cancers. The analysis finds that after experiencing one of these exposure events, men are more likely to have higher DNA methylation of a gene linked with an increased risk of developing prostate cancer. DNA methylation is a form of gene regulation that, if disturbed, can result in gene expression changes that can cause cancer. The researchers used data from the ongoing Agricultural Health Study (AHS), which is a long-term cohort study evaluating cancer and other health outcomes of pesticides applicators and their spouses in North Carolina and Iowa. This paper, High pesticide exposure events and DNA methylation among pesticide applicators in the agricultural health study, analyzed a sample size of 596 male pesticide applicators who underwent three phases of […]

(Beyond Pesticides, February 17, 2017) We’re only two months away from our 35th National Pesticide Forum! Join us for Healthy Hives, Healthy Lives, Healthy Land: Ecological and Organic Strategies for Regeneration, held at the Humphrey School of Public Affairs in Minneapolis, Minnesota on April 28-29, 2017. Register Today Get the Early Bird Discount (available until March 28)! As an Early Bird buyer, you can get a general rate for $40, a student rate for $20, or a business rate for $170. Scholarships are also available. All ticket price rates include organic meals: on Friday, organic beer, wine, and hors d’oeuvre; on Saturday, organic breakfast, lunch, and dinner, plus organic beer and wine at the evening reception. For more details about registration, click here. Background The Forum offers a unique opportunity during a critical time in our nation’s history to chart a course that upholds principles, values, policies and practices that protect health and the environment. The Forum brings together speakers on the latest science on pesticides, from bee-toxic neonicotinoids to glyphosate, contrasted with practitioners utilizing organic management practices in agriculture and parks, and on athletic fields and rangeland. In sum, the Forum seeks to help hone public understanding of the […]

(Beyond Pesticides, February 16, 2017) On Tuesday, the Natural Resources Defense Council (NRDC) sued the Trump administration for reversing a February 10 rule, published in the Federal Register, that designated the Rusty Patched Bumblebee an endangered species under the Endangered Species Act (ESA). The reversal  of the endangered species listing establishes a new review period until March 21. As to their reasoning for such a sudden change, the U.S. Fish and Wildlife Service (FWS) cited the White House memo instructing federal agencies to postpone the effective date of any regulations that had been published in the Federal Register, but not yet in effect. As discussed several days ago, the order by the Trump administration means that despite FWS’ determination that without federal action the species will likely become endangered, the Trump administration has 60 days to evaluate the decision for the purpose of “reviewing questions of fact, law, and policy.” The lawsuit, filed in the U.S. District Court for the Southern District of New York, argues that FWS violated the notice and comment requirements of public rulemaking for the delay on the bumblebee listing. In the lawsuit, NRDC states that, “Without valid explanation, opportunity for public input, or other legally required process, FWS […]