The Obama Administration’s National Pollinator Strategy, released in May, encouraged the Environmental Protection Agency to pursue near-term steps to preserve and protect bees and other pollinators.
So what has the EPA done since then?
As its first announced initiative, the EPA proposed a new rule that would prohibit foliar applications — spraying — of 76 pesticides, potentially affecting 1,000 products judged “acutely toxic to bees” on crops in bloom “when bees are present” under “a contract for pollination services.”
Sounds sensible. What could be more reasonable if you’re out to protect bees from near-term extinction than preventing them being sprayed with acutely toxic pesticides while they’re foraging for the pollen and nectar with which they’ll feed themselves and their young and store up food to last the winter?
So why would beekeepers be against it? For that matter, why would USDA be against it?
Politics separates USDA and EPA on bee recomendations
The answer is: for lots of reasons.
According to an article in Aggrow, an industry publication [behind paywall here], the EPA’s plan “could undermine existing efforts by beekeepers and farmers to ensure that contracted pollinators are protected from legal pesticide uses,” and has not incorporated a cost benefit analysis of the economic impact of its recommendations.
The proposed action denies farmers the use of established best management practices to mitigate harms to pollinators, providing little flexibility to farmers in managing pests at bloom time,” wrote Sheryl Kunickis, director of the USDA’s Office of Pest Management Policy, in an August letter.
Farmers and beekeepers form an ages-old partnership. Because beekeepers generally don’t own enough land on which their bees can forage amid varied plant life all summer long, they need access to farmers’ vast acreage, with its crops and other vegetation, to support their bees. Farmers have traditionally welcomed beekeepers’ hives onto their lands, since, at worst, the bees do no harm and, at best, they help pollinate any crops requiring pollination that the farmer may be growing. Indeed, pollination is so critical for some crops that farmers or growers hire beekeepers to place hives among their crops to pollinate them. But even when this isn’t essential or even helpful for farm production, beekeepers and farmers have long traditions of making informal verbal or hand-shake deals through which the beekeepers get access to the farmer’s lands so that the bees can forage there. Often the farmer agrees to take a share of the beekeeper’s honey production as compensation.
Some farmers and bee keepers believe that the EPA’s new draft rule limiting foliar pesticide applications, ostensibly to protect bees, threatens to disrupt this farmer-beekeeper partnership.
According to the California State Beekeepers Association, EPA’s proposal would likely result in a reduction in demand for beekeeper’s pollination services for melon, seed and fruit crops because it would prevent growers from effectively controlling predatory insects, which would, in turn, lead to a reduction in acreage planted.
“The lasting effect would be a decrease in the honey bee population” ultimately putting “great pressure on the national food supply,” noted the CSBA, concluding, “While there are many obstacles that face our industry and bees in general, we believe this proposal would not be significantly beneficial to bees and would in fact be detrimental to commercial beekeepers.”
Randy Oliver, California beekeeper and author of the scientific beekeeper blog, has pointed out a number of problems with EPA’s proposal.
- The proposed rule’s exclusive focus on bees under contract to pollinate crops forces growers to choose between pollinating their crops and protecting them from pests — a choice, if presented that starkly, that has the potential of “making beekeepers into pariahs on agricultural lands.”
- Without a very careful definition of ‘contract’, the traditional ‘handshake deals’ through which farmers welcome beekeepers’ hives onto their lands could be affected and disrupted – further restricting the acreage to which bees have access for forage.
- In any case, the risks to bees under contract for pollination services are already effectively handled in the contracts themselves, which typically require indemnification of the beekeeper for any pesticide-related loss or damage to the hives.
What’s more, Oliver noted, EPA’s new draft rule ignores the potential pesticide threats to wild, native pollinators, which EPA also has a responsibility to protect. It also does nothing to prevent bees from being harmed by pesticides used on adjoining farms that don’t have pollination services contracts for bees (foraging bees can’t recognize or respect property lines!). EPA’s brittle rule-making approach could allow a farmer to ‘game the system’ by concentrating bee hives contracted for pollination services on a small, separate parcel of land merely to circumvent the foliar spray rule. In this way, a farmer could retain complete freedom to spray pesticides on vast acres of adjoining cropland, which would, of course, be visited by the bees but where their pollination services wouldn’t actually be ‘under contract.’
The USDA has pointed to other flaws in EPA’s proposed new rule. It noted that the EPA failed to demonstrate in many cases any actual risk to bees from chemicals on its target list, since a number of them are applied to the soil (where they doesn’t affect bees) before plants have even emerged or in their early growth stages, long before flowing and bee foraging. Further, the USDA noted, that the EPA:
- Failed to consider real-world factors, such as product formulation, application rate and timing, and residual toxicity, that could minimize or render negligible any risk to bees from spray applications during bloom of the many products affected by its new rule;
- Failed to perform the required cost-benefit analysis to account for the adverse impact of its proposed new rule on farmers’ crops;
- Pre-empted documented, effective ‘best management techniques’ that would enable pesticides to be spray-applied during bloom in bee-safe manner;
- Possibly bypassed proper procedures for issuing a regulation of this scope and consequences.
The proposed Federal action targeted to protect bees end could end up threatening to damage bees and their keepers by imposing a rigid, ‘one-size-fits-all’ regulation. The action seems particularly curious considering that the honey bee crisis is now recognized as overblown and populations are at an all-time high in Europe and North America. In the U.S., it was reported in August that honey bee hives are at a 20-year record. Why such an obsessive focus on pesticides by the EPA when it is all but universally recognized that the problems affecting honey bee health today are complex and multi-factorial–with pesticides playing a comparatively minor role?
The EPA, USDA and the White House are clearly under fierce and conflicting pressure from environmentalists, beekeepers, farmers and the bee and pesticide industries. That’s all the more reason that they should base their decisions on the latest data and established science.
Jon Entine, executive director of the Genetic Literacy Project, is a Senior Fellow at the World Food Center’s Institute for Food and Agricultural Literacy, University of California-Davis. Follow @JonEntine on Twitter