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  • Writer's picturePollinator Stewardship Council

Action Alert- Submit A Public Comment


Please submit a public comment on the important 65-NGO Petition to EPA, which provides feedback on neonics. Neonicotinoids are devastating to birds and insects. One seed coated with a neonicotinoid can kill a songbird-- and with the indiscriminate usage of these pesticides, millions of birds, as well as other species are impacted.  The Petition urges the EPA to rein this in by amending key language in its regulations on registering new products, plus re-registering existing products.


Below we have a starting comment that we suggest, but please customize it in some way by adding your personal statement. It could be about your enjoyment of wildlife/nature, concerns about toxic pollution, and so on. If you customize your comment, EPA will treat yours as an individual comment, but if everyone submits exactly the same language then they all will be treated as if they were one comment. More background information is can be found here.


Comments are due by March 25, 2024 and can be readily filed on “Pesticides: Petition Seeking Rulemaking for Registration of Neonicotinoid Insecticides and Other Systemic Insecticides” at: https://www.regulations.gov/commenton/EPA-HQ-OPP-2023-0428-0097


To: Office of Pesticide Programs, EPA


I strongly support the Petition Seeking Rulemaking for Registration of Neonicotinoid Insecticides and Other Systemic Insecticides (EPA-HQ-OPP-2023-0428). You should promptly amend EPA’s existing regulations under the Federal Insecticide, Rodenticide, and Fungicide Act to require all applicants and registrants of neonicotinoid and other systemic insecticides to provide performance (efficacy) data to EPA in applications for registration and during registration review. We are deeply concerned that neonicotinoids used as seed treatments contribute directly to declines in the populations of grassland and insectivorous birds, pollute waterways that aquatic life and other species depend on, kill or weaken honey bees and other beneficial insects, and threaten ecosystem viability for many years. Although EPA registered these powerful insecticides without first requiring data on their efficacy, which is especially concerning because numerous scientific studies now show that they are not effective and thus they are not needed as seed treatments in most applications, I believe granting the Petition will help to correct the existing regulatory shortfalls for the systemic insecticides. We look forward to amendment of your regulations per the Petition to crack down on the overuse of these toxic neonicotinoid seed treatments. Your mission is to protect the environment; please carry it out.

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