On September 30, a group of 60 politicians sent a letter to EPA Administrator McCarthy, encouraging the Agency to follow the lead of the Fish & Wildlife Service (which cited a "precautionary approach" in its decision to prophylactically ban use of neonicotinoid insecticides on its lands) and providing a series of policy recommendations for EPA to "examine and consider." Unfortunately, this letter contains a number of inaccuracies and portrays an incomplete story.
The letter starts claiming commercial beekeepers in the US "experienced extremely high colony losses this past winter." While it is true that managed honeybee overwintering losses have been very high since 2006 (and probably before that), the loss for 2013-2014 was ~ 22% (as compared to 2012-2013's 31% loss). The reality is that last year's loss was much milder than the recent past. These overwintering data are collected by the Bee Informed Partnership, which receives a majority of its funding from the National Institute of Food and Agriculture. Native bumble bees have also "experienced sharp population declines at the national level" but this is not as well-studied as managed honey bee populations.
The letter goes on to attempt to associate the decline of the "iconic monarch butterfly" with the plight of the bees (in more than one spot). Given that neonics are modern synthetic variants of previous nicotine compounds used as insecticides, it is reasonable to want to link declines in two insect species to an insecticide. In both cases, however, a major reason for lack of these species thriving is lack of habitat. In the case of the bees, lack of flowering habitat is the issue with some estimates of habitat loss as high as 87% over the last 20 years. In the case of the Monarchs, it is lack of diverse habitat with sufficient milkweed that is the issue. Insecticide use is unrelated to habitat loss for bees and butterflies.
The Congress cites the International Union for Conservation of Nature Task Force on Systemic Pesticides (identified incorrectly in the letter written by Congress) and the FWS decision as rationale for its assertions; however, the authors did not consider the findings and conclusions of the EPA and USDA. The Task Force's "official" IUCN page is here; however, much more information can be found the web site that the Task Force appears to have set up on its own. In fact, the TF uses its own small communications company rather than use the IUCN staff and uses it web site to distribute the sill-incomplete series of reports called the Worldwide Integrated Assessment of the Impact of Systemic Pesticides on Biodiversity and Ecosystems (referred to in the letter).
EPA and USDA held a National Stakeholders Conference on Honey Bee Health in October 2012, which led to the release of a joint "comprehensive scientific report on honey bee health" in May 2013. Here's some of the findings from that report:
"The parasitic Varroa mite is recognized as the major factor underlying colony loss in the U.S. and other countries."
"Nutrition has a major impact on individual bee and colony longevity. A nutrition-poor diet can make bees more susceptible to harm from disease and parasites... Federal and state partners should consider actions affecting land management to maximize available nutritional forage to promote and enhance good bee health..."
"There is a need for informed and coordinated communication between growers and beekeepers and effective collaboration between stakeholders on practices to protect bees from pesticides."
"The most pressing pesticide research questions relate to determining actual pesticide exposures and effects of pesticides to bees in the field and the potential for impacts on bee health and productivity of whole honey bee colonies."
he letter goes on to make some rather draconian policy suggestions, including suspension of the use of neonics on ornamental plants, rejecting applications for the use of "prophylactic insecticides," re-classify neonics as restricted use pesticides, and initiate consultations with the FWS (or National Marine Fisheries Service) under the Endangered Species Act for all registered neonics, Finally, the letter make some policy suggestions that are of dubious origin, as they appear to be taken from recent NGO reports or are just incorrect. For example, one policy suggestion involves phasing out conditional registrations - an option clearly allowed under FIFRA and well-documented by EPA, yet not to the liking of all stakeholders. Another policy suggestion states that "[p]esticide seed treatments should be fully assessed ... [and] not exempted from federal pesticide regulations, as EPA currently allows." This suggestion completely missed the fact checker unfortunately -- here's one example of a fee category to register a seed treatment pesticide at EPA.
While we should all be concerned with crashing bee populations (if substantiated), making expensive and labor-intensive policy decisions based on a selective and incomplete read of the scientific knowledge is probably not helpful in the long-run.