I write on behalf of the North Dakota Grain Growers Association (NDGGA) to comment on Docket ID number EPA-HQ-OPP-2008-0844, the Preliminary Pollinator Risk Assessment to Support the Registration Review of Imidacloprid.  NDGGA, through its contracts with the North Dakota Wheat Commission and the North Dakota Barley Council, works on domestic policy issues on behalf of North Dakota’s 19,000 wheat farmers and 4000 barley farmers.
For farmers, it is vital that they have access to modern technologies like imidacloprid, which is critical to an integrated pest management program (IPM).  While NDGGA understands the importance of pollinators to agriculture, science has clearly shown that imidacloprid can be safely used without affecting bee populations.
Many vocal opponents of crop protection products do not understand modern agriculture or the importance of neonics to current IPM practices.  Nor do they seem to care that these products have helped reduce potential exposures to pollinators by reducing the use of broad-spectrum sprays once needed to control harmful pests.  Considering the lack of bee incidents associated with most farm operations and the fact that many crops do not need bees for pollination, additional restrictions on neonics seems like a solution in search of a problem.  This fact is corroborated by EPA’s preliminary report which indicates that most uses of imidacloprid have a very low risk potential to bees.
Before EPA finalizes its report or make any recommendations, our Association would ask that EPA seek the involvement of the growers who are most impacted by your decisions.  As a member of EPA’s Pollinator Protection Workgroup NDGGA has opposed a one-size-fits-all label change or arbitrary restrictions on certain crops; a one-size-fits-all label change will only hurt agriculture and will not improve bee health.  NDGGA understands the need to protect bees and pollinators; however those protections ought not to be at the expense of flexibility and options that diminish agriculture’s successful pest management practices.  NDGGA encourages EPA to consider state-supported Managed Pollinator Protection Plans, adoption of best management practices, and bee-box restrictions that would better address the needs of growers and beekeepers.
In conclusion, it’s important for EPA to recognize that farmers and beekeepers have worked together successfully for decades.  Farmers and beekeepers agree that crops must be protected; there are many ways to cooperate without incident.  It is the responsibility of both farmers and beekeepers to work to accomplish this goal.  Over regulation in this regard will not be the solution, it will be the problem.