Protect Endangered Species: Comment by the end of today – Monday October 25th

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(Beyond pesticides, October 25, 2021) The Environmental Protection Agency (EPA) is request public comments on their draft Biological Assessments (BEs) for the neonicotinoid insecticides imidacloprid, clothianidin, and thiamethoxam by 11:59 p.m. EDT on Monday, October 25, 2021. The BEs will take into account the decisions of the EPA regarding the registration examination for the three bee-toxic insecticides. Written comments must be submitted over Regulations.gov. Please feel free to cut and paste portions of the comments from Beyond Pesticides (linked here) or in Regulations.gov, the suggested comment language at the bottom of this notification.

Tell the EPA to protect endangered species from pesticides.

The EPA’s biological assessments for these highly toxic chemicals are not intended to provide a conclusion or recommendation by any agency requesting formal consultations with the U.S. Fish and Wildlife Service (USFWS) under Section 7 (a) (2) of the Endangered Species Act (ESA ) would trigger to a possible endangerment finding for the listed species and necessary mandatory restrictions on the use of the plant protection product concerned. This despite the fact that for Imidacloprid the draft biological assessment of the agency made a determination for the May affect for 89% of the species considered in 1821 and 90% of the 791 critical habitats. Remarkably, a May-affect determination was carried out for 100% of the listed amphibian and bird species and their critical habitat. Imidacloprid was also found to be likely to affect 100% of the listed exposed amphibian species. The biological assessment for each of the three neonicotinoids makes determinations of effect – NE (no effect), MA (may affect), NLAA (likely not to affect adversely), or LAA (likely to adversely affect) – which could affect 1821 listed species, and 791 identified critical Habitats.

These severe endangered and threatened species risk results for Imidacloprid, Clothianidin and Thiamethoxam are responsible for existing product labels and risk mitigation measures. The Endangered Species Act states: “Each federal agency must, in consultation with and with the assistance of the Secretary, ensure that any action approved, funded, or carried out by such agency … any endangered species or threatened species or lead to the destruction or adverse change in the habitat of these species … “

The full biological assessments (BEs) – with all provisions and species considered – must be attached to the formal request for advice and not just the LAA provisions. This will allow USFWS to confirm the results of the NLAA and LAA agencies as part of the consultation.

For only 11% of the listed species considered, a determination was carried out with no effect, as these species have a limited geographical distribution and would probably not be exposed to imidacloprid under the existing labeling and protection regulations. Thus, any listed species exposed to imidacloprid is potentially adversely affected.

For clothianidin, a similar determination of the May-Affect was carried out for 86% of the listed species and 83% of the critical habitats considered. For 67% of the listed species and 56% of the considered critical habitats, overall results were made on probable negative effects. As an imidacloprid, 100% of the listed amphibian species are likely to be affected by the use of clothianidin.

Thiamethoxam is broken down to clothianidin and therefore shares a similar fate and behavior in the environment. For 88% of the observed species and 89% of the critical habitats, determinations on May-Affect were carried out. Overall, results on probable negative effects were made for 77% of the listed species and 81% of the critical habitats examined. As reported for the other neonicotinoids, 100% of the amphibian species and critical habitats are likely to be compromised.

EPA should also include the American bumblebee (Bombus pensilvanicus) in their revised biological ratings for the neonicotinoid insecticides. Although this insect is not currently a listed species, the Fish and Wildlife Service is recently decided a petition containing essential scientific and commercial information suggesting that listing the American bumblebee as an endangered or threatened species may be warranted. Bumblebee species are very susceptible to neonicotinoid exposure and are likely to be at risk from continued use of these insecticides.

Do we have to wait for species to be listed as threatened or endangered to protect them? Given the systemic nature of neonicotinoids and their extreme toxicity to insects, the EPA has to assume that they will ultimately lead to the death of insects that consume nectar, pollen, plant exudates or plant tissue. The burden of proof rests with the registrant (s) to demonstrate that these products do not exacerbate the ongoing insect apocalypse – and lead to further biodiversity loss by the decimation of this essential compound in food webs.

In addition, the EPA must use organic production as the standard against which the “benefits” of pesticides are weighed. All plants that can be produced by chemically intensive methods can be produced organic. Organic producers use very few synthetic pesticides and no neonicotinoids. Therefore, the potential threat to extinction of the 1445+ species identified by these biological assessments must be considered unreasonable as defined in FIFRA.

The EPA has clearly established that neonicotinoids pose risks to the environment that cannot be acceptably contained in a long-term and sustainable manner. The Agency identifies several uses for imidacloprid and clothianidin in its proposed interim decisions for these chemicals that need to be deleted. However, the EPA believes that the benefits of other uses outweigh these serious risks and suggests limited or no mitigation measures. Given the frequency of discoveries in U.S. waterways, soils and plants, the recognized acute and chronic risks to pollinators, aquatic invertebrates, vertebrates and human health, the risk-benefit balance is pitifully inadequate, especially given the identification of the BEs the majority of the population listed species as potentially endangered by these neonicotinoid insecticides. Therefore, the EPA must quickly suspend all remaining neonicotinoid uses while continuing ESA §7 (a) (2) consultations with the Services. Additional data to remedy existing uncertainties and gaps will not change or reduce the already clearly identified environmental and health risks.

Submit comments to the EPA through Regulations.gov.

Suggested Comment on EPA (Feel free to cut and paste the following into Regulations.gov):

The EPA has clearly established that neonicotinoids pose risks to the environment that cannot be acceptably contained in a long-term and sustainable manner. The Agency identifies several uses for imidacloprid and clothianidin in its proposed interim decisions for these chemicals that need to be deleted. However, the EPA believes that the benefits of other uses outweigh these serious risks and suggests limited or no mitigation measures. Given the frequency of discoveries in U.S. waterways, soils and plants, the recognized acute and chronic risks to pollinators, aquatic invertebrates, vertebrates and human health, the risk-benefit balance is pitifully inadequate, especially given the biological assessments identified by the majority of the population listed species as potentially endangered by these neonicotinoid insecticides.

The agency’s draft biological assessment made a determination for May for 89% of the 1821 species and 90% of the 791 critical habitats. Remarkably, a May-affect determination was carried out for 100% of the listed amphibian and bird species and their critical habitat.

Therefore, the EPA must quickly suspend all neonicotinoid uses while continuing consultations with the US Fish and Wildlife Service under Section 7 (a) (2) of the Endangered Species Act. Additional data to remedy existing uncertainties and gaps will not change or reduce the already clearly identified environmental and health risks.

Thanks for your consideration.


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