November 24, 2014
U.S. Environmental Protection Agency Docket Center
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001
RE: Docket No. EPA-HQ-OPP-2014-0806 Pollinator Health Task Force
The National Cotton Council (NCC) appreciates the opportunity to submit comments to the President's Pollinator Health Task Force. We would like to inform you of activities that the NCC has been engaged towards improving honey bee health as well as to make suggestions for federal actions.
We appreciate the White House's recognition of the science which indicates that there are multiple factors involved in the decline of honey bee health. The NCC believes it is of critical importance that the White House communicates this science to the media and the general public in a manner that clarifies these multiple causes and encourages participation in the numerous opportunities for public involvement in efforts to improve pollinator health.
This communication may help expand the media's current focus on agricultural pesticides, which only serves to divert public attention away from truly meaningful ways to engage in practices to improve pollinator health.
Among the numerous factors that have been identified as having an impact on honey bee health are: appropriate habitat including adequate sources of nutrition; disease; parasites; genetics; and exposure to pesticides. The Administration can play an important role in improving honey bee health by ensuring that each of these factors is appropriately addressed through continued discussions with stakeholders and in actions that the Administration may choose to take.
The NCC was encouraged to hear discussions recognizing the significant threat of the varroa mite and EPA's efforts to provide beekeepers with additional tools through section 18 exemptions that aid in the control of this pest.We would encourage EPA to also expedite the registrations of new miticides for varroa control.
The NCC coordinated support for a request by the American Honey Producers Association asking USDA to host a "Varroa Summit." The support letters to USDA-ARS, EPA and USDA-OPMP were signed by 16 other commodity/association groups. The Varroa Summit was held on February 18-19, 2014.The White House should encourage USDA-ARS to publicize and to more openly engage the public on the results of this summit.
The NCC was encouraged to hear discussions of planting pollinator habitat in utility right-of-ways, Federal lands, and even on the sites of various business entities. Many of these sites would provide pollinator habitat in areas removed from intensive agriculture production, where the potential for pollinator exposure to crop protection products is higher. The NCC has urged caution in planting habitat adjacent to crop fields which would attract pollinators within close proximity of a cropping system. The NCC recognizes the delicate balance between protecting crops from yield loss to insects, diseases, and weeds while minimizing adverse impacts on the environment.
In terms of a federal role in pollinator habitat, the Department of Interior should review policies and regulations that prohibit beekeepers' access to public lands suitable for healthy bee habitat.
Other federal agencies managing federal parks and lands should consider providing specific areas to be designated as apiary locations, possibly requiring permit applications and minimum fees. Federal parks and recreational areas should consider featuring pollinator gardens to demonstrate to the public how everyone can participate in habitat plantings.
USDA's Natural Resource Conservation Service and Farm Service Agency should continue promoting the voluntary planting of pollinator habitat through conservation programs administered by these agencies. These programs are highly utilized by producers and could be key in increasing pollinator habitat. It is imperative that pollinator habitat growth practices can be utilized in all areas of the country.
In recognition that agricultural pesticides are among the factors contributing to a decline in pollinator health, the NCC is engaged in efforts to minimize the impact of these products on pollinators. We have been actively encouraging cotton states to develop pollinator stewardship plans within their respective states. Mississippi has developed its "Mississippi Honey Bee Stewardship Program" which would provide cooperative standards that should exist between producers and beekeepers. This plan involves improved communication and information sharing between beekeepers and farmers and the use of flags to identify the location of hives. Other states are at some stage of either adopting the Mississippi plan or developing their own and these states include Arizona, Louisiana, North Carolina, Georgia, Tennessee, Texas, Florida, and California.
The NCC will continue efforts to brief state producer leaders and encourage consideration of state pollinator plans that meet the needs at the state level – which may vary significantly among states and among regions within a state. The White House could help this effort by recognizing states that have taken proactive measures to address pollinator protection at the local level.
The NCC is interested in improving communication between beekeepers and agricultural producers, and supporting a mutual understanding of the practices that both producers and beekeepers should consider when both utilizing land in agricultural production. A good reference on this subject is the recently published book, "Honeybee pesticide poisoning: A risk management tool for Australian farmers and beekeepers." Unfortunately, it is too often the case that while producers and beekeepers may share similar space, they often have little, if any, communication.
The NCC initiated a survey of beekeeper and producer pairs that had at least a two-year history of working together. The goal of this undertaking was to identify cooperative management practices that provide coexistence of crop protection and honey bees. The survey helped underscore the need for improved communications between the beekeeper and the crop producer.
Cotton, along with several other crops, is self-pollinating and does not require pollinators. Often times, beekeepers do not have the land resources to provide forage for their bees and will seek out a crop producer and ask to place bees on his property. The NCC's survey responses showed the communication often ended there. Producers often did not know how to contact the beekeeper and had no way to advise them of pesticide applications, where to place the bees, who maintains weeds around the hives, or how often the hives are checked and by whom.
The NCC also discovered that few producers were aware of the honeybee health decline and the efforts by various groups to place a focus on agricultural pesticides instead of the multiple factors contributing to this decline. To that end, the NCC provided its Environmental Task Force with a briefing on the pollinator issue and invited a presentation from EPA. We included a pollinator issue panel discussion at the annual American Cotton Producers meeting. The NCC developed a fact paper highlighting the issues between honeybee protection activities and crop protection products, and released the paper at our annual Beltwide Cotton Conference. In addition, the paper was provided to extension and other groups to increase producer awareness of the serious nature of honey bee health decline. The NCC included a focus on pollinator research at the annual Beltwide Cotton Conference to increase awareness and understanding of producers, consultants, media, and other researchers.
In terms of a federal role in outreach and education, USDA, through the National FFA Organization, 4-H and Vocational Agricultural programs, could seek partnerships for the planting of demonstration pollinator habitat gardens at schools and in communities. Many of these vocational agricultural programs have greenhouses. If provided with initial seed, students could raise milkweed and similar plants suitable for pollinator habitat to sell as fundraisers or give to the public.The activity would involve students, raise awareness of the importance of pollinators, and, through demonstration, engage the community.
The NCC has provided research needs to ARS and has urged the agency to make sure crop and bee researchers collaborate to ensure the science is field relevant. The NCC continues to engage university scientists and anticipates additional Cotton Foundation funding for pollinator research. An area of particular interest is generating data to provide a better understanding of the time of year and time of day that crops are least utilized by pollinators to minimize exposure potential. The White House could help these efforts by encouraging ARS to collaborate with university scientists for maximum utility of research investment.
The NCC will continue engagement with ARS researchers to suggest research needs that apply to row crop production with reduced risk to pollinators. The NCC will continue to encourage ongoing research on the role that varroa mites and other parasites play in honey bee health. The White House can help by encouraging ARS to engage stakeholders about research needs and inform the public about the multiple factors that contribute to pollinator health decline.
Thank you for including the NCC in this very important undertaking. We also appreciate the opportunity to share our views and respond to the questions.
Sincerely,
E. Keith Menchey
Manager, Science & Environmental Issues