Georgia Farm Bureau recently submitted comments to the EPA regarding the agency's "Proposal to Mitigate the Exposure to Bees from Acutely Toxic Pesticide Products."
On May 29 the EPA published a proposed rule that would prohibit foliar application of pesticides that are acutely toxic to bees on fields where bee colonies are under contract for pollination services. The proposed rule included a list of 76 pesticides that would be subject to additional label restrictions.
In an Aug. 26 letter, GFB President Zippy Duvall urged the EPA to re-evaluate the proposed rule that "limits the relationship between beekeepers and producers while doing little to prevent pollinator decline."
Duvall noted that an inordinate amount of blame is being placed on pesticide use for declines in bee populations, citing the 2012 Report on the National Stakeholders Conference on Honeybee Health. The report, which was written by a group of apiary researchers from across the country, concluded that while multiple factors have contributed to declining bee populations, the varroa mite is the single detrimental pest to honeybees.
In proposing the rule, the EPA cited a directive from President Barack Obama to assess the effect of pesticides, singling out neonicotinoids. GFB supports the continued use of neonicotinoid pesticides for agricultural and horticultural crops. Duvall pointed out that neonicotinoids were developed in the mid-1990s in large part because they showed reduced toxicity to honeybees compared to previously used organophosphate and carbamate pesticides.
Duvall also noted that arbitrarily assigning blame for bee decline to pesticides lacks scientific justification and will not reverse the decline of bee populations.
The EPA also proposed that states and tribes work to reduce pesticide exposures through development of locally-based measures, specifically through managed pollinator protection plans, though the existence of a farmer/beekeeper contract would require additional label restrictions without regard to the individual state pollinator protection plans.
Duvall also expressed concern about the "under contract" portion of the proposed rule, which does not define the term "contract," and does not take into consideration the informal nature of many pollination agreements, or how the rule would affect those relationships.
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