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With all the talk about bees and colony collapse disorder (CCD), posting the Letter to the Editor, below, from the Cleveland Plain Dealer seemed appropriate.
One of the many factors affecting our bees and other pollinators is also related to our own human drinking water sources. This includes the Great Lakes, which are the largest area of surface freshwater on the planet, and a main source of water for eight states and two Canadian provinces.
This blog post starts with Laurel Hopwood's LTE, then continues with excerpts from a deposition I wrote, at Laurel’s request, in July 2016.
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Plain Dealer - Letter to the Editor:
One of the many factors affecting our bees and other pollinators is also related to our own human drinking water sources. This includes the Great Lakes, which are the largest area of surface freshwater on the planet, and a main source of water for eight states and two Canadian provinces.
This blog post starts with Laurel Hopwood's LTE, then continues with excerpts from a deposition I wrote, at Laurel’s request, in July 2016.
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Plain Dealer - Letter to the Editor:
By Laurel
Hopwood, Ohio Sierra Club Agriculture Chair, Cleveland
Neonicotinoid
is in the Great Lakes and fish and birds are at risk
Updated Jan
29, 10:14 AM; Posted Jan 29, 10:14 AM
Fish,
birds and entire ecosystems of the Great Lakes may be at risk. A new critical
study revealed the presence of neonicotinoid (neonic) pesticides pervasive the
Great Lakes and its tributaries.
The study
comes as draft legislation is circulating in Congress that would remove
requirements that the U.S. EPA consult with the U.S. Fish and Wildlife
Department and the National Marine Service over pesticides' impact on
threatened and endangered species.
Neonics
are the most heavily used insecticides on the planet. Exposure to these nerve
poisons is linked with bee die-offs and bird population decline. Losing these
pollinators can have a tremendous impact on our food supply.
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Adding some background to Laurel’s LTE,
above, the
following are excerpts from my deposition.
From your blogger, Linda Sekura:
“I am
aware that neonicotinoid pesticides formulated with clothianidin and
thiamethoxam are part of a non-sustainable agricultural system that impacts
pollinators, whether honeybees or native pollinators. I am concerned about the impact to honeybees,
but my main concern as a sustainability specialist and an ecologist is the
impact of neonicotinoids on native pollinators and other native insects/organisms.
“I am
concerned about the impacts of pesticides, in general, on any native organisms (including
humans); and I am aware that neonicotinoid pesticides formulated with
clothianidin and thiamethoxam have the potential to move up the food chain and
impact birds, including threatened and endangered species, but also many of our
common bird (and other) species, which have been in decline, and that are just
as important to our ecosystems and sustainable food production. We can never
know the complex role of every organism in these systems all life depends on
for survival.
“The EPA’s
fact sheet issued in May 20, 2003, for the conditional registration of
clothianidin states that “… assessments show that exposure to treated seeds
through ingestion may result in chronic toxic risk to non-endangered and
endangered small birds (e.g., songbirds) and acute/chronic toxicity risk to
non-endangered and endangered mammals. Clothianidin has the potential for toxic
chronic exposure to honeybees, as well as other nontarget pollinators, through
the translocation of clothianidin residues in nectar and pollen.”
“From an
ecological point of view, there are a number of stressors that negatively
impact threatened and endangered (and common) species, including birds, bees,
and other wildlife, such as habitat loss and climate change. Neonicotinoid pesticides formulated with
clothianidin and thiamethoxam are an additional stressor to threatened, endangered
and common species. Additionally, it is
not clear that those pesticides are beneficial, either as to whether the
intended results are achieved, or, if achieved, with enough intended benefit to
justify the unintended impacts. There can
be a timing issue as to when pesticides are applied versus when the target
species of insects arrive. In certain
situations, neonicotinoid pesticides are applied to plants and seeds, but the
target species may never come into contact with these plants and seeds. And, since neonicotinoid pesticides are
persistent, many nontarget species, including diverse pollinators, but also a
multitude of above- and below-ground organisms will likely come into contact
with plants and seeds, and the soil and water the pesticides will leach into, and
these other nontarget organisms will be affected.
“It does
not matter whether neonicotinoids are the driving cause of massive bee deaths
or other impacts to threatened, endangered, and common species; what is
important is that the massive use of neonicotinoids formulated with clothianidin
and thiamethoxam are affecting honeybees, native bees and other pollinators,
and other wildlife, including birds, and when that is combined with the
cumulative impacts of other stressors, it may be the straw that breaks the
camel’s back for some of these species.
“… An Ohio
farming website indicated that neonicotinoids generally are the most popular
insecticides being used; neonicotinoids are applied to 135 million acres
treated annually, of which 56 percent is on cotton, soy, corn, and wheat, which
are crops grown on farms in Ohio.
“…Neonicotinoids
formulated with clothianidin and thiamethoxam have been approved by the EPA for
use on corn and soy, as well as lawns, golf courses, and landscaped areas. I am concerned that massive amounts of
neonicotinoids formulated with those ingredients may be, or already being, applied
in areas where I live, and this may impact threatened and endangered (and
common) species that I care about. I
live in Northeast Ohio, but I frequently go to Northwest Ohio because of the international
migratory bird flyway. Many of the farms
in Northwest Ohio grow corn and soy.
Agriculture is already causing algae blooms in waterways, and I am
concerned that neonicotinoid pesticides formulated with clothianidin and
thiamethoxam are being applied to the corn and soy and are then leaching into
the water, which may negatively impact migratory and locally-nesting birds.
“Neonicotinoid
pesticides formulated with clothianidin and thiamethoxam are highly water
soluble, which may impact birds feeding on invertebrates, or diminish the
amount of these food sources available. The
above-mentioned EPA fact sheet states that “[b]ased on laboratory and field
studies, the available data on clothianidin show that the compound is
persistent and mobile, stable to hydrolysis, and has potential to leach to
ground water and be transported via runoff to surface water bodies.”
“I also
live near many parks, playgrounds, lawns, golf courses and landscaped areas
where I am told that neonicotinoid pesticides formulated with clothianidin and
thiamethoxam may be applied. In
Northeast Ohio, most of the population lives within walking or biking distance
of a park or golf course, where these pesticides could be applied. In Northwest Ohio most live within walking or
biking distance of a farm. There are at least six golf courses within a 30
minute drive from my home.”
“…It has
been explained to me that the EPA was required to consult the U.S. Fish and
Wildlife Service (FWS) under the Endangered Species Act (ESA) prior to
approving and registering neonicotinoid pesticides formulated with clothianidin
and thiamethoxam, since most pesticides, and in particular neonicotinoids, are
shown to cause harm to the environment and wildlife. To argue that neonicotinoids are not a driving
cause of this harm does not justify their approval without meticulous review. When more than one or two stressors already exist,
the likely danger of adding to the cumulative impact neonicotinoid pesticides
formulated with clothianidin and thiamethoxam should be apparent. A smoking gun should not be the threshold for
determining whether consultation is required.
“…In sum, I
am concerned about the threats to endangered, threatened, and common species,
and the natural processes and ecosystems they (and we) depend on for survival -
and professional, recreational, and personal interests for myself, my family, and
fellow coworkers and citizens, as a result of the EPA’s decision to register and maintain
neonicotinoid pesticides formulated with clothianidin and thiamethoxam,
especially considering that the EPA did not consult the FWS prior to approving
the pesticides, and that there does not appear to be an adequate risk
assessment and public review process in place.”
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