The U.S. EPA recently came to a decision about our Clothianidin Emergency Citizen Petition (dated 3/20/2012) to remove clothianidin from the market based on imminent hazard to honeybees. That partial decision was, in essence, that the evidence presented failed to meet the imminent hazard criteria. The decision is a disappointment in that it emphasizes our regulators’ failure to act with precaution when chemically altering our environment. EPA clearly favors reactionary clean up after preventable tragedy strikes; a pattern long established in industry as well (see Silent Spring, 1962).
As indicated in the EPA response, our petition requested four steps:
1. Cure clothianidin’s allegedly unlawful conditional registration.
2. Prevent alleged imminent harm by suspending clothianidin’s registrations and initiating special review and cancellation proceedings.
3. Suspend and stop sale of allegedly misbranded clothianidin products.
4. Address Endangered Species Act consultation obligations for clothianidin.
The EPA response addresses ONLY step 2. The partial response specifically opens a window of opportunity for the public in general and beekeepers in particular. I think this is actually very good news.
“The EPA is posting this response for public comment on its website along with the petition (including the petition exhibits and supplemental filings). After reviewing the public comments submitted in connection with this response and the EPA’s posting of the petition, the EPA will respond to the remaining issues in the petition. In addition, the EPA will determine in connection with that review whether the comments received support the reconsideration of this partial response.”
Here’s another bright spot in the partial decision: “agency is not ruling today on the petitioners’ request that clothianidin registrations be cancelled.”
Let us not get lost in a time-wasting battle over “imminent hazard” for clothianidin. Let us go for the jack pot. I propose a write-in campaign to light up their website for docket EPA_HQ-OPP-2012-0334. Frankly, our case is stronger for neonicotinoids in general than it is for clothianidin specifically. Here’s a guide to help, but obviously, you can create your own text as you wish.
I think hand-written is best because it emphasizes to EPA that the writer is so serious about the issue that they spent significant time writing. Still, it's better to copy and paste this text than to not write at all. Consider writing this by hand:
Subject: Docket EPA_HQ-OPP-2012-0334
Dear Ms. Jackson,
Thank you for agreeing in your petition response that neonicotinoids are “widespread and common in use,” that they are “persistent and stable across a wide range of soil conditions and in aquatic environments,” and that they are “found in soil, in some cases, more than a year after planting of treated seed.” Thank you also for acknowledging in your document, csr_PC-044309_28-Sep-05_a, that “42 to 59% of the applied remained in the soil approximately 3 to 4 years following the first of the two applications, and residues were primarily undegraded clothianidin.” Beekeepers are grateful that the EPA agrees neonicotinoids are “acutely toxic to bees,” and are happy that you recognize “neonicotinoid insecticides [are] in plant tissues including pollen, nectar and guttation water.” It is great that the “EPA reviewed the cited literature and agrees that these studies indicate that concurrent exposure to insecticides at sublethal levels is associated with some increased sensitivity to Nosema infestations.”
Given your position on these important issues summarized above, you must be anxious to remove neonicotinoids from our environment. Isn’t it great that you have the responsibility and power to do just that? Please act now to terminate the on-going damage that is being done by neonicotinoids.
Put your comment in an envelope, put a full postage stamp on the envelope and mail it to:
Lisa Jackson
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave NW
Washington, DC 20460
We need 500,000 letters to hit the EPA by 08/17/2012, one month hence the EPA partial response. Please do it now. We must not delay. The actual due date for public response is 9/25/2012. While you are at it, type up a similar letter and send it to your local newspaper as a “letter to the editor” to promote local participation. Share this with your beekeepers club and solicit their participation. This will get the EPA's attention. This will say the public is paying attention. This will say we truly care about our environment, our insects and our selves. Every letter should be posted on the docket by the EPA. We can all follow along with our progress.
... dons
