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  • Writer's picturePollinator Stewardship Council

ESA Workplan Lacks Pollinator Protection

We believe that the EPA has a legal obligation to provide a higher level of pollinator protection than described in the ESA Work Plan Update based on the outcome of Case No. 3:13-cv-01266-LB, in which a Federal Court ruled that the Environmental Protection Agency (EPA) had systematically violated the Endangered Species Act (ESA).  In this ruling, the plaintiffs (including PSC President, Steve Ellis) understood the court-mediated and mandated agreement would require the EPA to implement immediate fundamental changes to their neonicotinoid pesticide registration policies. EPA has determined that these systemic insecticides do pose risk to endangered species and pollinators, but the Work Plan fails to implement actual change such as the appropriate next step of immediate cancellation of these systemic insecticides. Instead, the EPA provides pollinator protection language which creates the illusion of action but does not actually address any of the legal requirements for change according to the outcome of Case No. 3:13-cv-01266-LB. 


The mission of EPA is to protect human health and the environment. We currently face a veritable avalanche of scientific evidence which include studies conducted by the EPA, showing a clear pattern of negative and dangerous impacts by pesticides on organisms throughout the entire food web.  This is especially egregious considering that many of these dangerous pesticides offer negligible benefits to farmers. The EPA has been well aware of this for years, as clearly evidenced by the Agency’s own study published almost a decade ago which “...concludes that these seed treatments provide negligible overall benefits to soybean production in most situations.”  EPA cannot be true to its mission by only addressing lawsuits and action driven by court order.  The EPA cannot expect to make progress without significant changes to their own procedures.  It is critical that the EPA utilize Adverse Outcome Pathways and risk-benefit analysis in order to make accurate assessments of registered pesticides. The current approach to decision making which balances profit of industry with conservation/protection policies is a dereliction of the EPA’s duty and responsibility to protect the environment and wildlife.  Beekeepers are a crucial component of our food system and they must be protected now. 

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