[House Hearing, 114 Congress]
[From the U.S. Government Publishing Office]
HEARING TO REVIEW THE FEDERAL
COORDINATION AND RESPONSE REGARDING
POLLINATOR HEALTH
=======================================================================
HEARING
BEFORE THE
SUBCOMMITTEE ON
BIOTECHNOLOGY, HORTICULTURE, AND RESEARCH
OF THE
COMMITTEE ON AGRICULTURE
HOUSE OF REPRESENTATIVES
ONE HUNDRED FOURTEENTH CONGRESS
FIRST SESSION
__________
MAY 13, 2015
__________
Serial No. 114-14
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Printed for the use of the Committee on Agriculture
agriculture.house.gov
________
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94-750 PDF WASHINGTON : 2015
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COMMITTEE ON AGRICULTURE
K. MICHAEL CONAWAY, Texas, Chairman
RANDY NEUGEBAUER, Texas, COLLIN C. PETERSON, Minnesota,
Vice Chairman Ranking Minority Member
BOB GOODLATTE, Virginia DAVID SCOTT, Georgia
FRANK D. LUCAS, Oklahoma JIM COSTA, California
STEVE KING, Iowa TIMOTHY J. WALZ, Minnesota
MIKE ROGERS, Alabama MARCIA L. FUDGE, Ohio
GLENN THOMPSON, Pennsylvania JAMES P. McGOVERN, Massachusetts
BOB GIBBS, Ohio SUZAN K. DelBENE, Washington
AUSTIN SCOTT, Georgia FILEMON VELA, Texas
ERIC A. ``RICK'' CRAWFORD, Arkansas MICHELLE LUJAN GRISHAM, New Mexico
SCOTT DesJARLAIS, Tennessee ANN M. KUSTER, New Hampshire
CHRISTOPHER P. GIBSON, New York RICHARD M. NOLAN, Minnesota
VICKY HARTZLER, Missouri CHERI BUSTOS, Illinois
DAN BENISHEK, Michigan SEAN PATRICK MALONEY, New York
JEFF DENHAM, California ANN KIRKPATRICK, Arizona
DOUG LaMALFA, California PETE AGUILAR, California
RODNEY DAVIS, Illinois STACEY E. PLASKETT, Virgin Islands
TED S. YOHO, Florida ALMA S. ADAMS, North Carolina
JACKIE WALORSKI, Indiana GWEN GRAHAM, Florida
RICK W. ALLEN, Georgia BRAD ASHFORD, Nebraska
MIKE BOST, Illinois
DAVID ROUZER, North Carolina
RALPH LEE ABRAHAM, Louisiana
TOM EMMER, Minnesota
JOHN R. MOOLENAAR, Michigan
DAN NEWHOUSE, Washington
______
Scott C. Graves, Staff Director
Robert L. Larew, Minority Staff Director
______
Subcommittee on Biotechnology, Horticulture, and Research
RODNEY DAVIS, Illinois, Chairman
GLENN THOMPSON, Pennsylvania SUZAN K. DelBENE, Washington,
AUSTIN SCOTT, Georgia Ranking Minority Member
CHRISTOPHER P. GIBSON, New York MARCIA L. FUDGE, Ohio
JEFF DENHAM, California JAMES P. McGOVERN, Massachusetts
TED S. YOHO, Florida ANN M. KUSTER, New Hampshire
JOHN R. MOOLENAAR, Michigan GWEN GRAHAM, Florida
DAN NEWHOUSE, Washington
(ii)
C O N T E N T S
----------
Page
Davis, Hon. Rodney, a Representative in Congress from Illinois,
opening statement.............................................. 1
Prepared statement........................................... 3
Submitted letter............................................. 31
DelBene, Hon. Suzan K., a Representative in Congress from
Washington, opening statement.................................. 4
Witnesses
Johansson, Ph.D., Robert, Acting Chief Economist, U.S. Department
of Agriculture, Washington, D.C................................ 5
Prepared statement........................................... 7
Jones, Hon. Jim, Assistant Administrator, Office of Safety and
Pollution Prevention, Environmental Protection Agency,
Washington, D.C................................................ 9
Prepared statement........................................... 11
HEARING TO REVIEW THE FEDERAL
COORDINATION AND RESPONSE REGARDING
POLLINATOR HEALTH
----------
WEDNESDAY, MAY 13, 2015
House of Representatives,
Subcommittee on Biotechnology, Horticulture, and Research,
Committee on Agriculture,
Washington, D.C.
The Subcommittee met, pursuant to call, at 1:31 p.m., in
Room 1300, Longworth House Office Building, Hon. Rodney Davis
[Chairman of the Subcommittee] presiding.
Members present: Representatives Davis, Thompson, Scott,
Denham, Yoho, Moolenaar, Newhouse, DelBene, McGovern, Kuster,
and Graham.
Staff Present: Haley Graves, Jessica Carter, John Goldberg,
Mary Nowak, Mollie Wilken, Patricia Straughn, Ted Monoson,
Keith Jones, Liz Friedlander, and Nicole Scott.
OPENING STATEMENT OF HON. RODNEY DAVIS, A REPRESENTATIVE IN
CONGRESS FROM ILLINOIS
The Chairman. This hearing of the Subcommittee on
Biotechnology, Horticulture, and Research to review the Federal
coordination and response regarding pollinator health, will
come to order.
At this point, I would like to give my own opening
statement. Good afternoon. I would like to welcome everyone to
this hearing in which we will continue to examine the aspects
of pollinator health. As many of you are aware, the Agriculture
Committee has had a long interest in examining and promoting
pollinator health. In both the 2008 and 2014 Farm Bills,
provisions were included to authorize pollinator research and
extension programs, improve capacity and infrastructure within
the USDA to promote long-term pollinator health, and authorize
expanded surveillance of pests and diseases affecting
pollinators.
Following the passage of the 2014 Farm Bill, this
Subcommittee commenced an oversight process focusing on
specific threats to pollinator health under the leadership of
former Chairman Austin Scott. In a hearing held just over a
year ago, we heard from public and private sector scientists.
While there were many factors discussed contributing to
pollinator health, one factor leading most lists was the threat
associated with the parasitic mite known as the Varroa
destructor. The lead bee researcher at USDA, Dr. Jeff Pettis,
referred to this mite as a modern honey bee plague and
suggested it has been responsible for the deaths of massive
numbers of colonies both within the United States and
worldwide. Nevertheless, despite the overwhelming consensus
within the scientific community regarding the relative
importance of the various factors contributing to overall
pollinator health, the factor near the bottom of the scientific
community's list seems to be the factor highest on the list of
activist groups.
Pesticides and, in particular, a new family of pesticides
known as neonics seem to be attracting the lion's share of
media and public interest attention. Neonics can be applied to
the plant or used as a seed treatment. They are highly
effective and have seen very rapid adoption rates among
producers because of the significant benefits they offer. It is
frustrating that efforts to innovate and employ new, proven
technologies to enhance our ability to produce food, feed, and
fiber, are constantly under attack.
Shortly after our hearing last year, the President issued
an Executive Memorandum establishing a White House task force
to review pollinator health. The main focus of the work was to
be on expanding habitat for pollinators. I should note that the
task force findings were supposed to be released at the end of
2014. But, unfortunately, 5 months later, we are still waiting
on this report. The Order also directed the various departments
and agencies assigned to the task force to work together to
develop a national pollinator health strategy. While
coordination and communication were understood to be a central
tenet of this Executive Order, only days after receiving the
Order, the National Wildlife Refuge System announced a ban on
neonics and biotech plants without a single effort to
communicate with either the USDA or the EPA their intentions or
justification.
I would note that the Secretary of Agriculture and
Administrator of the EPA were appointed to co-chair the
President's task force. As both agencies were completely caught
off guard by this announcement, each expressed frustration with
the lack of communication. We would reasonably expect, in light
of this surprise announcement by an agency within the
Department of the Interior, the USDA and EPA would double down
on their efforts to enhance Federal coordination and
communication. Unfortunately, just 2 months later, EPA released
a study of the benefits of neonic seed treatment on soybeans
with little to no input from the USDA.
USDA's Chief Economist sent a letter to the EPA disagreeing
with the assessment, referring to it as incomplete, premature,
and unnecessarily burdensome to the task before farmers and
ranchers to produce food, feed, and fiber, for a strong and
healthy America. That letter is in Members' folders and will be
made part of today's hearing record.
[The information referred to is located on p. 31.]
The Chairman. Examples like this are why we fought so hard
in the farm bill to give ag a seat at the table when EPA is
considering rules and regulations that would impact farmers. I
expect EPA's Science Advisory Board to follow Congressional
intent and give farmers that voice so better policy can be
made. Today, USDA and EPA both have a seat at the table, and I
look forward to your testimony.
[The prepared statement of Mr. Davis follows:]
Prepared Statement of Hon. Rodney Davis, a Representative in Congress
from Illinois
Good afternoon,
I would like to welcome everyone to this hearing in which we will
continue to examine aspects of pollinator health.
As many of you are aware, the Agriculture Committee has had a long
interest in examining and promoting pollinator health. In both the 2008
and 2014 Farm Bills, provisions were included to authorize pollinator
research and extension programs, improve capacity and infrastructure
within USDA to promote long-term pollinator health, and to authorize
expanded surveillance of pests and diseases affecting pollinators.
Following passage of the 2014 Farm Bill, this Subcommittee
commenced an oversight process focusing on specific threats to
pollinator health. In a hearing held just over a year ago, we heard
from public and private sector scientists. While there were many
factors discussed contributing to pollinator health, one factor leading
most lists was the threat associated with a parasitic mite known as
Varroa destructor.
The lead bee researcher at USDA, Dr. Jeff Pettis referred to this
mite as a ``modern honey bee plague'' and suggested that it has been
responsible for the deaths of massive numbers of colonies both within
the United States and worldwide.
Nevertheless, despite the overwhelming consensus within the
scientific community regarding the relative importance of the various
factors contributing to overall pollinator health, the factor near the
bottom of the scientific community's list seems to be the factor
highest on the list of activist groups.
Pesticides, and in particular a new family of pesticides known as
Neonics seem to be attracting the lion share of media and public
interest attention.
Neonics can be applied to the plant or used as a seed treatment.
They are highly effective and have seen a very rapid adoption rate
among producers because of the significant benefits they offer. It is
frustrating that efforts to innovate and employ new, proven
technologies to enhance our ability to produce food, feed, and fiber
are constantly under attack.
Shortly after our hearing last year, the President issued an
Executive Memorandum establishing a White House Task force to review
pollinator health. The main focus of the work was to be on expanding
habitat for pollinators. I should note that the Task Force findings
were supposed to be released at the end of 2014, but unfortunately, 5
months later we are still waiting for this report.
The Order also directed the various Departments and agencies
assigned to the task force to work together to develop a National
Pollinator Health Strategy. While coordination and communication were
understood to be a central tenant of this Executive Order, only days
after receiving the Order, the National Wildlife Refuge System
announced a ban on neonics and biotech plants without a single effort
to communicate with either USDA or EPA their intentions or
justification. I would note that the Secretary of Agriculture and
Administrator of the EPA were appointed to co-chair the President's
task force. As both agencies were completely caught off guard by this
announcement, each expressed frustration with the lack of
communication.
We would reasonably expect that in light of this surprise
announcement by an agency within the Department of the Interior, the
USDA and EPA would double down on their efforts to enhance Federal
coordination and communication. Unfortunately, just 2 months later, EPA
released a study on the benefits of neonic seed treatment on soybeans
with little to no input from USDA. USDA's Chief Economist sent a letter
to EPA disagreeing with the assessment referring to it as incomplete,
premature, and unnecessarily burdensome to the task before farmers and
ranchers to produce food, feed, and fiber for a strong and healthy
America. That letter is in Members' folders and will be made part of
today's hearing record
Examples like this are why we fought so hard in the farm bill to
give agriculture a seat at the table when EPA is considering rules and
regulations that would impact farmers. I expect EPA's Science Advisory
Board to follow Congressional intent and give farmers that voice so
better policy can be made.
Today, USDA and EPA both have a seat at the table.
I look forward to your testimony.
The Chairman. And I would like to now recognize the Ranking
Member, Ms. DelBene, for her opening statement.
OPENING STATEMENT OF HON. SUZAN K. DelBENE, A REPRESENTATIVE IN
CONGRESS FROM WASHINGTON
Ms. DelBene. Thank you, Mr. Chairman. Thanks for calling
this hearing. And I want to thank our witnesses for being here
with us this afternoon. As the Subcommittee undertakes our
responsibility to examine pollinator health, it will be
important to understand as fully as possible the role that the
seed treatments and other crop protectants play in growers'
overall pest management decisions. In my view, there is no
simple answer to the question of their value. Some growers may
be justified in using the seed treatments, while others may
find little or no need to do so. I do want to caution, though,
about any of us reaching any conclusions from a single hearing.
This issue is far too complex for talking points. And this
issue demands our thoughtful and methodical attention. And I
hope that we will hold future hearings to further explore this
complex issue.
I hope that we will get the opportunity to hear from
beekeepers, fruit and vegetable growers, economic
entomologists, and other experts. In light of all the recent
press focusing on the use of neonic seed treatments, I have to
wonder why today's hearing did not include these parties but,
instead, is centered on what seems to be more of an insular
issue between two Federal agencies. And while I respect our
witnesses' expertise, I believe Members of the Subcommittee
would have been better served by first hearing from those on
the ground and in the field, those who must make on an
individual basis thoughtful decisions on the use of crop
protection chemistries.
By focusing on the perception of a disagreement between
agencies during an open and transparent public comment process,
we reduce our oversight role to refereeing. The testimony
provided by constituent witnesses, the beekeepers and growers
who we represent, can help inform the policy decisions we make
with administrative agencies. My goal is to ensure that
individual growers have the tools needed to make the best pest
management decisions given their individual circumstances of
crop, climate, and ecological sensitivity.
Mr. Chairman, I look forward to hearing from our witnesses
today. And I encourage future hearings on this important issue.
And I yield back.
The Chairman. Thank you, Ms. DelBene.
The chair would request that other Members submit their
opening statements for the record so the witnesses may begin
their testimony and to ensure that there is ample time for
questions.
The chair would like to remind Members that they will be
recognized for questioning in order of seniority for Members
who were present at the start of the hearing. After that,
Members will be recognized in order of their arrival. I
appreciate Members' understanding.
Witnesses are reminded to limit their oral presentations to
5 minutes. And just like Chairman Conaway has been a stickler
for that, we will be here too. All written statements will be
included in the record.
I would like to welcome our witnesses to the table. First
off, Dr. Robert Johansson. He is the Acting Chief Economist
with the USDA here in Washington, D.C. And Mr. Jim Jones, the
Assistant Administrator, Office of Chemical Safety and
Pollution Prevention, part of the EPA. Dr. Johansson, please
begin your testimony when ready.
STATEMENT OF ROBERT JOHANSSON, Ph.D., ACTING CHIEF ECONOMIST,
U.S. DEPARTMENT OF AGRICULTURE,
WASHINGTON, D.C.
Dr. Johansson. Chairman Davis, Ranking Member DelBene, and
other Members of the Subcommittee, thank you for the
opportunity to be at today's hearing on the Federal
coordination and response regarding pollinator health. With
more than 75 percent of flowering plants relying on
pollinators, their health is important to USDA and to all of us
consumers. The value of honey production in the U.S. has
increased in volume and value terms by about 20 percent in 2014
relative to 2013. And that is from the USDA honey report that
NASS does each year. That has been rising to 178.2 million
pounds produced and $38.5 million respectively. The estimated
value earned by honey producers in 2014 is more than double
that of 1994, even adjusting for inflation. However, production
volume is lower by about 18 percent relative to that year.
The current average price of about $2.16 a pound is a
record high, indicating the increasing value that U.S.
consumers place on honey. U.S. imports of honey have also
reached historic highs, doubling in volume between 2004 and
2013 to about 154,000 metric tons. U.S. honey producers are
responding to those higher honey prices. The number of
producing colonies and average production per colony grew from
2.6 million colonies producing 57 pounds per year in 2013, to
2.7 million colonies at 65 pounds per colony of production in
2014. Although there is still plenty of room for growth, in
1993 there were more than 3 million colonies producing at 73
pounds of production per colony. Furthermore, the rental fees
that producers charge for pollination services continue to rise
due to increasing demand for those services.
The average rental rate per hive doubled between 2005 and
2009 to more than $150. Indeed in 2012, the fees charged for
honey bee pollination services exceeded $650 million. However,
annual losses of colonies remains high, making it difficult to
meet that rising demand for pollination services. Although the
national trend data we currently have is limited, we know that
beekeepers lost roughly 34 percent of their colonies during
2013-2014, down from 45 percent the year before, but still very
high. And, of course, this morning's report on preliminary
numbers for 2014-2015 from the Bee Informed Partnership, shows
that losses of managed honey bee colonies were 23.1 percent for
the 2014-2015 winter, down 6.6 percent from the previous year.
However, for the first time, summer losses exceeded winter
losses, making annual losses for the year a very high 42.1
percent.
To promote the health of honey bees and other pollinators,
President Obama issued his June 20, 2014 Memorandum, as you had
mentioned, Mr. Chairman, charging Federal departments and
agencies with taking steps to help restore pollinator
populations. The Federal Government is poised to lead in this
effort, given its broad, national perspective and ability to
identify and prioritize goals and programs that extend beyond
state and national borders. Understanding the Federal
Government cannot act alone in promoting pollinator protection,
the President also identified the need for public-private
partnerships, as well as increasing citizen engagement. To
accomplish that effort, the President created the Pollinator
Health Task Force, co-chaired by, as you noted, the Secretary
of the USDA and the Administrator of EPA.
USDA has a rich history in partnering with other Federal
agencies and numerous stakeholders in recognizing that the
collaborative effort is much more effective in achieving
success. And USDA agencies are providing important
contributions to the protection of pollinators. Our research
agencies, including ARS, NIFA, ERS, and NASS, conduct and
support that research. The Office of Pest Management Policy
coordinates our pest management work across the department with
EPA. And APHIS conducts a national survey of honey bee pests
and diseases and collaborates with others on ways to manage,
suppress, and eradicate pests and diseases.
Our conservation programs, including those managed by the
FSA and NRCS, support pollinator habitat across the country.
And the U.S. Forest Service supports outreach, technology
transfer, and pollinator habitat. The Office of the Chief
Economist will typically be asked to review and analyze issues
that may fall under the purview of those activities. Such
review and analysis may occur as a normal part of the operation
of my office. As such, I will describe some of our
responsibilities, providing some examples of how we interact
with EPA and their activities.
The main mission of my office is to advise the Secretary of
Agriculture on the economic prospects of ag markets and on the
economic implications of policies and programs affecting U.S.
food and fiber production in rural areas, to ensure the public
has consistent, objective, and reliable agricultural forecasts,
and to promote effective and efficient rules governing USDA
programs.
Areas of major analyses include international trade
agreements, risk-sharing institutions, crop insurance,
commodity programs, developments in commodity markets,
sustainable development, and ag labor. I see that I am running
out of time, so I am going to note just a couple areas of
coordination with EPA. And, certainly, my testimony is
submitted for the record for those Members that wish to review
that.
USDA collaborates with EPA on a number of key issues, such
as the Federal Pollinator Health Task Force. Many offices
within USDA have established working relationships with EPA
that date back to the Agency's founding. My office, in
particular, coordinates review of USDA and other agencies'
significant rulemakings and has a long history of collaboration
with EPA on those issues.
An example is the work that we did on the Ag Worker
Protection Standard last year. We provided input into that
process. As part of the Federal Insecticide, Fungicide, and
Rodenticide Act, FIFRA, EPA must provide the Secretary of
Agriculture a copy of the rule and give USDA the opportunity to
review and comment. I will also note that we also work with EPA
on a number of issues, including the Clean Water Act, and the
Clean Air Act.
And with that, I will conclude, just to note that I thank
you for inviting me to provide some perspective on pollinator
issues, as well as the role of the Office of the Chief
Economist. Thank you very much.
[The prepared statement of Dr. Johansson follows:]
Prepared Statement of Robert Johansson, Ph.D., Acting Chief Economist,
U.S. Department of Agriculture, Washington, D.C.
Chairman Davis, Ranking Member DelBene, and other Members of the
Subcommittee, thank you for the opportunity to be at today's hearing on
the Federal coordination and response regarding pollinator health. With
more than 75 percent of flowering plants relying on pollinators, their
health is important to the U.S. Department of Agriculture (USDA) and to
all of us as consumers.
The value of honey production in the United States increased in
volume and value terms by about 20 percent in 2014 relative to 2013
(USDA-NASS Honey Report; 2015, 1995) rising to 178.2 million pounds
produced and $385.2 million, respectively. The estimated value earned
by honey producers in 2014 is more than double that of 1994 adjusting
for inflation. However, production volume is lower by about 18 percent
relative to 1994.\1\ The current average price of $2.16 per pound is a
record high indicating the increasing value that U.S. consumers place
on honey (average of retail, private, and co-op pricing). U.S. imports
of honey have also reached historic highs, nearly doubling in volume
between 2004 and 2013 to 154 thousand metric tons (USDA-ERS 2014).\2\
---------------------------------------------------------------------------
\1\ http://usda.mannlib.cornell.edu/MannUsda/
viewDocumentInfo.do?documentID=1191.
\2\ http://www.ers.usda.gov/publications/sssm-sugar-and-sweeteners-
outlook/sssm-314.aspx.
---------------------------------------------------------------------------
U.S. honey producers are responding to higher honey prices; the
number of producing colonies and average production per colony grew
from 2.6 million colonies producing 57 pounds per year in 2013 to 2.7
million colonies at 65 pounds per colony of production in 2014. There
is still plenty of room for growth; in 1993, there were more than three
million colonies at 73 pounds of production per colony.\3\ Furthermore
the rental fees that producers charge for pollination services
continues to rise due to increasing demand. The average rental rate per
hive doubled between 2005 and 2009 to more than $150. In 2012 the fees
charged for honeybee pollination services exceeded $650 million (USDA-
ERS 2014).\4\ However, annual loss of colonies remains high, making it
difficult to meet rising demand for pollination services. Although the
national trend data we currently have is limited, we know that
beekeepers lost 34 percent of their colonies during 2013-14, down from
45 percent the year before, but still very high.\5\
---------------------------------------------------------------------------
\3\ http://usda.mannlib.cornell.edu/MannUsda/
viewDocumentInfo.do?documentID=1191.
\4\ http://www.ers.usda.gov/media/1679173/special-article-
september_-pollinator-service-market-4-.pdf.
\5\ Lee, et al. (2015) ``A national survey of managed honey bee
2013-2014 annual colony losses in the USA,'' Apidologie 46(3), pp. 292-
305.
---------------------------------------------------------------------------
To promote the health of honeybees and other pollinators, President
Obama issued his June 20, 2014 Presidential Memorandum charging Federal
departments and agencies with taking steps to help restore pollinator
populations. The Federal Government is poised to lead this effort,
given its broad national perspective and ability to identify and
prioritize goals and programs that extend beyond state and national
borders. Understanding that the Federal Government cannot act alone in
promoting pollinator protection, the President also identified the need
for public-private partnerships as well as increased citizen
engagement. To accomplish this effort, the President created the
Pollinator Health Task Force, co-chaired by the Secretary of the USDA
and the Administrator of the Environmental Protection Agency (EPA).
USDA has a rich history in partnering with other Federal agencies
and numerous stakeholders in recognizing that the collaborative effort
is much more effective in achieving success. USDA agencies are
providing important contributions to the protection of pollinators. Our
research agencies, including the Agricultural Research Service (ARS),
National Institute of Food and Agriculture (NIFA), Economic Research
Service (ERS), and National Agricultural Statistics Service (NASS)
conduct and support research. As a recent example of this scientific
collaboration, NASS has initiated a series of national colony loss
surveys, which will provide the statistical foundation for several
other Federal agencies conducting scientific work in this area. The
Office of Pest Management Policy (OPMP) coordinates pest management
work across the Department and with the Environmental Protection
Agency. The Animal and Plant Health Inspection Service (APHIS) conducts
a national survey of honey bee pests and diseases and collaborates with
others on ways to manage, suppress, and eradicate pests and diseases.
We are exploring ways to further leverage this work with our colony
loss survey program, so that detailed results regarding honey bee
health can be generalized to the nation as a whole. Our conservation
programs, including those managed by the Farm Service Agency (FSA) and
the Natural Resources Conservation Service (NRCS), support pollinator
habitat across the country. And, the Forest Service (USFS) supports
outreach, technology transfer, and pollinator habitat.
The Office of the Chief Economist (OCE) will typically be asked to
review and analyze various issues that may fall under the purview of
those activities. Such, review and analysis may occur as part of the
normal operation of my office. As such, I will describe some of our
responsibilities and provide some examples of how we interact with EPA
and their activities.
The Office of the Chief Economist
The main mission of the Office of the Chief Economist is to advise
the Secretary of Agriculture on the economic prospects in agricultural
markets and on the economic implications of policies and programs
affecting the U.S. food and fiber system and rural areas; ensure the
public has consistent, objective and reliable agricultural forecasts;
and to promote effective and efficient rules governing USDA programs.
Areas of major analyses include international trade agreements, risk-
sharing institutions, crop insurance, commodity programs, developments
in commodity markets, sustainable development, and agricultural labor.
OCE serves as the focal point for the nation's economic
intelligence, analysis, and review related to domestic and
international food and agriculture. The World Agricultural Outlook
Board (or the World Board) is housed within OCE and coordinates and
oversees clearance of all commodity and aggregate agricultural data
used to develop USDA outlook and situation information. The World Board
publishes the monthly World Agricultural Supply and Demand Estimates
report, which shows U.S. farmers, policymakers, and traders what's
going on in the world of farm commodity forecasts at a single moment in
time. The World Board also publishes the Weekly Weather and Crop
Bulletin, an international summary of crop-related weather
developments.
Four other offices are located within the Office of the Chief
Economist.
The Climate Change Program Office functions as the
Department-wide coordinator of agriculture, rural and forestry-
related global change program and policy issues facing USDA.
The Office ensures that USDA is a source of objective,
analytical assessments of the effects of climate change and
proposed response strategies.
The Office of Environmental Markets supports the Secretary
in the development of emerging markets for water quality,
carbon sequestration, wetlands, biodiversity, and other
ecosystem services.
The Office of Energy Policy and New Uses advises the
Secretary of Agriculture in developing and coordinating USDA
energy policy, programs, and strategies related to energy and
biobased products, and coordinates USDA activities related to
energy and biobased products within and outside the USDA.
The Office of Risk Assessment and Cost-Benefit Analysis
ensures that major USDA regulations affecting the environment,
human health or human safety are based on sound scientific and
economic analysis. The Office reviews and provides guidance to
agencies on risk assessments and cost-benefit analyses.
Coordination with EPA
The Department of Agriculture collaborates with the EPA on a number
of key issues, such as on the Federal Pollinator Health Task Force.
Many offices within the USDA have established working relationships
with the EPA that date back to the Agency's founding.
As you know, the USDA works to support the American agricultural
economy to strengthen rural communities; to protect and conserve our
natural resources; to increase agricultural production and export; and
to provide a safe, sufficient, and nutritious food supply for the
American people. The USDA encourages sufficient and efficient
production of food, fiber and forest products for the public welfare
and manages and conserves many of the nation's natural resources. The
EPA administers and enforces Federal laws designed to protect the
nation's land, water, and air systems so that they may support life.
The laws administered by EPA address air and water pollution, solid and
hazardous waste management, pesticides and toxic substances and
radiation protection. Many of EPA's actions--pesticide regulation,
point and non-point source pollution control, solid waste management,
air regulation, renewable fuel feedstock regulation--affect rural and
agricultural communities. Through cooperation on environmental issues
affecting agriculture and rural communities, the EPA and the USDA have
developed strong working relationships.
My office, in particular, coordinates review of USDA and other
agencies' significant rulemakings and has a long history of
collaboration with the EPA. An example of how USDA and EPA have worked
together is the Agricultural Worker Protection Standard. In July 2013,
EPA notified USDA that the proposed rule and economic analysis were
ready for review. Under the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA), EPA must provide the Secretary of Agriculture
a copy of a rule and give USDA the opportunity to review and comment.
The Office of Pest Management Policy was created in 1997 to coordinate
the USDA's role in the pesticide regulatory process. USDA's Office of
Pest Management Policy invited EPA to brief USDA to provide an overview
of the proposed rule and shortly after that briefing, the proposed rule
arrived. In reviewing the economic analysis OCE helped enhance some
assumptions that EPA had developed. The early deliberations resulted in
improvements to some components in the draft proposed rule prior to the
delivery of to the Office of Management and Budget (OMB) for
interagency review and then for public comment.
The Office of the Chief Economist also works with EPA on non-
regulatory matters. For example, the Office of the Chief Economist
through its Office of Environmental Markets has been working closely
with EPA to develop and expand market-based approaches to conservation
in the Chesapeake Bay watershed. Market approaches can lower costs for
those complying with water quality requirements and create new revenue
streams for farmers. In 2013, USDA and EPA entered into a Department-
level partnership agreement on water quality trading. Through this
agreement USDA and EPA are collaborating on new tools and information
to help the states in the region reduce costs in program design and
implementation, improve environmental performance, and foster
consistency. Under the agreement, OCE and EPA have jointly developed a
web-based information support tool that links policy guidance from EPA
with examples and materials from existing trading programs. That
partnership has allowed USDA and EPA to better meet the needs of the
states and should create new opportunities for farmers in the region
while lowering the costs of improving water quality in the Chesapeake
Bay.
We also work with EPA on a variety of Clean Air Act issues, such as
our public comments to EPA's Science Advisory Board on the accounting
framework for biogenic greenhouse gas emissions. As another example, my
office and EPA cooperate on efforts to quantify and report national
greenhouse gas emissions and sinks. USDA provides estimates of forest
carbon stocks and sequestration and works closely with EPA to estimate
greenhouse gas emissions and sinks from the agricultural sector. EPA
includes that information in the annual U.S. Greenhouse Gas Inventory.
Conclusion
Thank you for inviting me to provide some perspective on pollinator
issues as well as the role of the Office of the Chief Economist.
The Chairman. Thank you, Dr. Johansson.
Mr. Jones, feel free to give your opening testimony.
STATEMENT OF HON. JIM JONES, ASSISTANT
ADMINISTRATOR, OFFICE OF SAFETY AND POLLUTION
PREVENTION, ENVIRONMENTAL PROTECTION AGENCY, WASHINGTON, D.C.
Mr. Jones. Thank you, Chairman Davis, Ranking Member
DelBene, and Members of the Subcommittee. My name is Jim Jones,
and I serve as the Assistant Administrator for the
Environmental Protection Agency's Office of Chemical Safety and
Pollution Prevention, which is the office that is responsible
for Federal pesticide regulation in the United States.
Pollinator protection is an extremely high priority for the
EPA. Over the past several years, we have taken many steps to
develop scientifically sound analytical techniques for
assessing the potential impacts of pesticides on pollinators
and have acted, based on this science, to reduce those
exposures determined to be of most significant risk. As the
science continues to advance through the registration review
programs, the Agency will continue to work with stakeholders to
put in place any additional mitigation strategies to continue
to protect pollinators. As you well know, pollinators are
responsible for nearly one in every three bites of food you
eat. In addition, they contribute nearly $15 billion to the
nation's economy. Loss of our pollinator populations have the
potential to not only threaten agricultural production but to
also threaten natural plant communities and important services
provided by ecosystems.
Researchers studying pollinator health have been unable to
identify a single cause for pollinator declines and have
concluded that losses of honey bee colonies are likely the
result of a complex interaction of a number of stressors. In
May 2013, the U.S. Department of Agriculture and the EPA
released a comprehensive scientific report on honey bee health.
This report synthesized the current state of knowledge
regarding the primary factors that scientists believe have the
greatest impact on managed bee health. These factors include
exposures to pests and pathogens, poor nutrition due to
decreased availability of high-quality forage, exposure to
pesticides, and bee biological genetics and breeding. Each play
a role in impacting managed bee health and likely also impact
the health of native pollinators. It is because of these many
factors and in light of the emerging science that in June 2014,
President Obama established the Pollinator Health Task Force,
co-chaired by USDA and EPA.
In the very near future, the strategy developed by the task
force will be released and is the result of a strong
interagency collaboration with a focus on improving pollinator
health and increasing pollinator habitat. Of all the stressors
impacting pollinators, the EPA has a role to play in two areas.
First, ensuring that new and existing products do not cause
unreasonable adverse effects to pollinators. And, second,
registering new products for beekeepers to use in controlling
hive pests such as Varroa mites. Pesticides play a critical
role in agricultural production and the health of our society.
Pesticides can also lead to adverse ecological and human health
consequences.
Congress has entrusted the EPA to balance the risks and
benefits of pesticide use. Mitigating the effects of pesticides
on bees, many of which are intended to kill insects, is a
difficult task but is also a priority for the Federal
Government, as both bee pollination and insect control are
essential to the success of agriculture. The EPA is working to
reduce bees' exposure to pesticides without losing the ability
to control pests in agriculture. Certain pesticides are also
important pest management tools for beekeepers to control the
Varroa mite or hive beetles. This is an inherently difficult
goal to achieve since the pesticide, such as those intended to
control Varroa mites on bees, essentially seek to control the
mite while not harming the bee colony.
To achieve these goals, EPA has focused its pollinator
efforts in three primary areas. Advancing the science and
understanding of the potential impact of pesticides on
pollinators. Second, taking appropriate risk management actions
based upon the available science. And, third, collaborating
with domestic and international partners to advance pollinator
protections. In the near future, as part of the rollout of the
pollinator health strategy, the EPA will soon announce
additional initiatives for continuing to improve pollinator
health. We will take those actions based upon the best
available science and utilizing our longstanding principles of
public engagement and transparency.
The EPA will also continue to work with USDA and other
Federal and state agencies to protect pollinators, while
ensuring that growers can meet their pest control needs in
order to maintain a diverse ecosystem and provide for a healthy
and abundant United States food supply. I am happy to answer
any questions from the Subcommittee.
[The prepared statement of Mr. Jones follows:]
Prepared Statement of Hon. Jim Jones, Assistant Administrator, Office
of Safety and Pollution Prevention, Environmental Protection Agency,
Washington, D.C.
Thank you Mr. Chairman.
My name is Jim Jones and I serve as the Assistant Administrator for
the Environmental Protection Agency's Office of Chemical Safety and
Pollution Prevention. Pollinator protection is an extremely high
priority for the EPA. Over the past several years we have taken many
steps to develop scientifically sound analytical techniques for
assessing the potential impacts of pesticides on pollinators and have
acted, based upon this science, to reduce those exposures determined to
be of most significant risk. As the science continues to advance,
through the registration and registration review programs, the agency
will continue to work with stakeholders to put in place any additional
mitigation strategies to continue to protect pollinators.
As you well know, pollinators are responsible for nearly one in
every three bites of food you eat. In addition, they contribute nearly
$15 billion to the nation's economy. Losses of our pollinator
populations have the potential to not only threaten agricultural
production, but to also threaten natural plant communities and
important services provided by ecosystems.
Researchers studying pollinator health have been unable to identify
a single cause for pollinator declines and have concluded that losses
of honey bee colonies are likely the result of a complex interaction of
a number of stressors. In May 2013, the U.S. Department of Agriculture
(USDA) and the EPA released a comprehensive scientific report on honey
bee health. This report synthesized the current state of knowledge
regarding the primary factors that scientists believe have the greatest
impact on managed bee health. These factors include: exposures to pests
and pathogens; poor nutrition due to decreased availability of high
quality forage; exposure to pesticides; and bee biological genetics and
breeding. Each play a role in impacting managed bee health and likely
also impact the health of native pollinators. It is because of these
many factors, and in light of the emerging science, that in June 2014,
President Obama established the Pollinator Health Task Force, co-
chaired by the USDA and the EPA. In the very near future, the strategy
developed by the task force will be released and is the result of a
strong interagency collaboration with a focus of improving pollinator
health and increasing pollinator habitat.
Of all of stressors impacting pollinators, the EPA has a role to
play in two areas: first, ensuring that the new and existing products
do not cause unreasonable adverse effects to pollinators; and second,
registering new products for beekeepers to use in controlling hive
pests such as Varroa mites. Pesticides play a critical role in
agricultural production and the health of our society. If misused or
overused, however, pesticides can also lead to adverse ecological and
human health consequences. Congress has entrusted the EPA to balance
the risks and benefits of pesticide use. Mitigating the effects of
pesticides on bees, many of which are intended to kill insects, is a
difficult task but is also a priority for the Federal Government, as
both bee pollination and insect control are essential to the success of
agriculture. The EPA is working to reduce bees' exposure to pesticides
without losing the ability to control pests in agriculture. Certain
pesticides are also important pest management tools for beekeepers to
control the Varroa mite or hive beetles. This is an inherently
difficult goal to achieve since the pesticide, such as those intended
to control Varroa mites on bees, essentially seek to control the mite
while not harming the bee colony.
To achieve these goals, the EPA has focused its pollinator efforts
in three primary areas: (1) advancing the science and understanding of
the potential impact of pesticides on pollinators; (2) taking
appropriate risk management actions, based upon the available science;
and (3) collaborating with domestic and international partners to
advance pollinator protection.
Addressing potential risks associated with pollinator exposure to
pesticides necessitates that a robust and scientifically supported
assessment framework be in place. In January 2011, the EPA convened a
workshop through the Society of Environmental Toxicology and Chemistry
to explore the current state of the science on pesticide risk
assessment for pollinators. Working with a cross-section of
stakeholders and scientists from around the world, the outcomes from
this workshop provided the scientific foundations for a new pollinator
risk assessment framework. Through collaboration with our regulatory
partners in Canada and the state of California, the EPA submitted these
new scientific techniques to the FIFRA Scientific Advisory Panel in
September 2012. Through this new framework, the EPA has identified the
types of data, both hazard and exposure, that are needed to properly
assess the potential impacts of pesticides on pollinators. The
framework:
relies on a tiered process;
focuses on the major routes of exposure, including contact
and dietary exposure; and
distinguishes different types of pesticide treatments, such
as compounds applied to plant leaves or seed/soil-applied
(systemic) compounds.
Working through the Organization for Economic Cooperation and
Development, the EPA serves as the co-chair of the Pesticide Effects on
Insect Pollinators Expert Group. Working in collaboration with the
International Commission on Plant Pollinator Relationships, this group
is developing harmonized guidelines for conducting the studies used in
the EPA's risk assessment framework. In addition, we have begun to
apply this new risk assessment framework in our regulatory decision
making processes, both for new registrations as well as the re-
evaluation of existing registrations via the registration review
program.
Taking risk management action, as supported by the science, is also
a critical step in protecting pollinators. One such example is the
initiative that the EPA announced in August 2013 to require new
pesticide labels that prohibit the use of neonicotinoid products when
bees are present. Earlier that year, the EPA had determined, based on
potential effects of these compounds on honeybees and other
pollinators, as well as bee kill incidents in Oregon and Canada, that
when used as previously labeled, these products posed a concern for
potential adverse effects on pollinators. Products bearing these new
required labeling statements began to appear in the marketplace in
2014. Since then, the agency has required similar types of labeling for
other products for which risks to bees have also been identified.
In addition, the EPA accelerated the re-evaluation of the
neonicotinoids as part of the registration review process. Working with
our regulatory partners in Canada and California, we sped up the re-
evaluation schedule for this group of pesticides. The EPA also required
the registrants for these compounds to develop the necessary pollinator
data, consistent with our new risk assessment framework. We plan to
announce, in the near future and consistent with the directive from
President Obama in his June 2014 Memorandum, a further acceleration of
this re-evaluation. Additionally, in early April 2015, the agency sent
letters to registrants of neonicotinoid pesticides with outdoor uses
informing them that the EPA will generally not be in a position to
approve these applications for new uses of these compounds until new
pollinator data have been submitted and more technically robust
pollinator risk assessments are complete.
In October 2014, the EPA announced the public availability of a
benefit analysis conducted as part of the ongoing registration review
of the neonicotinoid pesticides. The agency's analysis of the benefits
of neonicotinoid seed treatments for insect control in soybeans
concluded that there is little or no increase in soybean yields using
neonicotinoid seed treatments when compared to using no pest control at
all. Consistent with the EPA's longstanding policies on public
participation and transparency, we sought public input of this
analysis. In addition, I personally traveled to the Mississippi Delta
to meet with soybean growers to better understand their pest control
needs and the role of these products in their pest management programs.
We are currently in the process of reviewing the over 40,000 comments
we received on our analysis. The revised analysis will be incorporated
into the risk/benefit determination that we will make for these
products as part of the ongoing registration review of the
neonicotinoids. Additional benefits analyses for the neonicotinoid
pesticides may be conducted, as needed, as part of this ongoing re-
evaluation.
In March 2015, the EPA registered a new miticide, oxalic acid, to
combat the devastating effects of the Varroa mite on honey bee
colonies. Oxalic acid was already registered for this use in Canada and
Europe. Recognizing beekeepers' need for additional registered tools to
combat the Varroa mite in U.S. honey bee colonies, the EPA collaborated
with the USDA on the registration. The EPA was able to expedite its
evaluation in part due to a ``work share'' which allowed Health
Canada's Pest Management Regulatory Agency (PMRA) to share their data
reviews with the EPA risk assessors and risk managers. The EPA used the
existing data and information from PMRA, including updated reviews of
toxicity, dietary exposure, environmental fate and transport, and
product chemistry data. After a thorough and priority evaluation of all
the data, the EPA concurred with the conclusions and registration
decision made by our Canadian colleagues and approved the registration
in less than \1/4\ of the time it usually takes.
Finally, collaboration with domestic and international partners to
advance pollinator protection is critical. Over the past three years,
the EPA has co-hosted pollinator summits on several topics, including
seed treatments, honey bee health, Varroa mites, and forage and
nutrition. In addition, through the EPA's Pesticide Program Dialogue
Committee, the EPA sought advice on how to improve pesticide labeling,
increase methods for reporting bee kill incidents, expand the
availability of best management practices for reducing pollinator
exposure to pesticides, and develop a consistent approach for
investigating bee kill incidents. In response to the advice received,
the EPA has greatly improved pesticide labels for the neonicotinoids
and has imposed similar labeling requirements for other pesticides that
are acutely toxic to bees. We have expanded the various methods that
bee kill incidents can be reported, both via the EPA's website and
other mechanisms, and we worked with states to develop a more
consistent approach and guidance for investigating bee kill incidents.
We also worked collaboratively with stakeholders and land-grant
universities to make more publicly available information on best
management practices for reducing pesticide exposures to bees. The
President's Fiscal Year 2016 budget request includes additional funding
for the EPA's pollinator protection efforts, including $1.5 million to
further the study of acute toxicity amongst honey bee populations and
to explore additional risk management options, and $500,000 to augment
the work of states and tribes to develop pollinator protection plans.
And, as mentioned earlier, we are working with our international
partners to continue to advance the science and understanding of the
potential impacts of pesticides on pollinators.
In the near future, as part of the roll out of the Pollinator
Health Strategy, the EPA will soon announce additional initiatives for
continuing to improve pollinator health. We will take those actions
based upon the best available science and utilizing our longstanding
principles of public engagement and transparency. The EPA we will also
continue to work with the USDA and other Federal and state agencies to
protect pollinators while also ensuring that growers can meet their
pest control needs in order to maintain a diverse ecosystem and provide
for a healthy and abundant United States food supply.
The Chairman. Thank you, Mr. Jones.
In light of the fact that they are about ready to call a
vote, it looks like it will be one vote, when it happens, I
will make sure that we stand in recess. And we will come back
here and continue the line of questioning. But I know one of
our Members actually has to go to a markup immediately
following the vote. So I am going to yield my first 5 minutes
to my colleague, Mr. Moolenaar from Michigan, to ask questions.
Mr. Moolenaar. Thank you, Mr. Chairman. Dr. Johansson and
Mr. Jones, I appreciate you being here testifying today and for
your focus. I just wanted to ask, first, when you talk about
releasing a strategy, do you have a timeline for that?
Mr. Jones. Yes. We are talking about something within the
next several weeks. So it will not be much longer.
Mr. Moolenaar. Okay. Thank you. And as part of the process,
I am assuming that there would be a communication strategy of
broadly communicating that. Will that be part of that strategy?
Mr. Jones. That is correct.
Mr. Moolenaar. Okay. If I could, I would also ask your role
is regarding chemical safety and pollution prevention. And we
are talking about pesticides but also herbicides. Would that be
part of your area?
Mr. Jones. Yes. My office is responsible for pesticide
regulation at the Federal level of the United States. And
pesticides are defined under the law as herbicides,
insecticides, fungicides, rodenticides, basically anything
designed to kill a pest.
Mr. Moolenaar. Okay. Got you. One of the things I wanted to
ask your input on, recently the International Agency on the
Review of Cancer, which is part of the World Health
Organization, announced a classification of glyphosate as a 2A
category probable carcinogen. Are you familiar with that
conclusion?
Mr. Jones. Yes, sir.
Mr. Moolenaar. Okay. It seems that that conclusion
contradicts other parts of the World Health Organization which
have reviewed glyphosate and found no evidence of it being a
carcinogen. And then other regulatory bodies around the world
have reviewed this also. And I understand that the EPA prepared
a desk statement and found in 2014 after reviewing 55
epidemiological studies on the possible cancer and non-cancer
effects of glyphosate, that it does not warrant any changes in
the EPA's cancer classification. And I guess the reason I bring
this up is, first, do you still, given the report that they
had, are they in communication with you on this, recognizing
your conclusions with the EPA?
Mr. Jones. IARC operates independent of the United States
Government, and of any other government in the world. We are
making sure that we are looking at everything that they looked
at before we finalize, well it is not finalized--put a draft
assessment, which we are going to do in the July timeframe. But
we collaborated with our colleagues in Canada in the
development of our assessment.
So we are making sure that we are looking at everything
that they looked at. I can say, as a matter of fact, that the
body of information that was in front of us is much larger than
the body of information that was in front of the IARC.
Mr. Moolenaar. So you would stand by your conclusions in
spite of what they have concluded and based on a broader
assessment?
Mr. Jones. Our conclusions, which will be released in the
July timeframe, we will definitely be standing behind.
Mr. Moolenaar. Okay. Thank you. And in the next few weeks,
you expect to release your strategy. And it would be based on
the sound-science approach that you are using in other areas?
Mr. Jones. That is correct.
Mr. Moolenaar. Thank you. Thank you, Mr. Chairman.
The Chairman. Thank you. I would like to advise Members
that a series of votes has been called. I anticipate the series
of votes to last as long as it takes to get you to the floor
and back. So it should be a very quick series of votes. And as
long as we get back here, we will call the hearing back in
order. I would ask that you return quickly so that we can get
it going again. This hearing will stand in recess subject to
the call of the chair.
[Recess.]
The Chairman. This hearing of the Subcommittee on
Biotechnology, Horticulture, and Research will come to order.
As we left off, again, welcome, Dr. Johansson, Mr. Jones.
We will give folks a couple seconds to sit down since I don't
think anybody thought we would start the hearing again with
only two Members. But we like to be timely. And, ironically,
the next questioner is sitting in her chair. So I would like to
recognize the Ranking Member, Ms. DelBene, for her round of
questions.
Ms. DelBene. Thank you, Mr. Chairman. And, again, thank you
to our witnesses for being with us today.
Mr. Jones, can you describe for the Committee the benefits
of moving EPA's pesticide risk assessment process for bees and
for other insect pollinators from a qualitative to a
quantitative risk assessment process?
Mr. Jones. Thanks, Congresswoman. So one of the issues that
came up as we began to observe the attention being paid to the
neonicotinoids, was that our assessment wasn't capturing the
kinds of exposures the honey bee, in particular, could get from
neonicotinoid exposures because the chemicals are, they behave
in the environment significantly differently than many of the
alternatives. And so we developed a way to allow us to
quantitatively assess the risk associated with this class of
chemistry to honey bees through the design of a particular
study. So it will allow us to speak with greater confidence and
less uncertainty as it relates to the impact of these compounds
on honey bees.
Ms. DelBene. And it is my understanding that the EPA has
begun to employ the new risk assessment framework for bees as
part of its regulatory decision-making process for all
pesticide chemistries, and is that correct?
Mr. Jones. That is correct. We deploy the framework for all
chemistries. Many chemistries, however, will not trigger the
higher-tiered studies because of their properties. But we will
at least think about how those other chemicals--whether, the
relevance of this new framework is to other pesticides. So it
won't just be neonicotinoids.
Ms. DelBene. Dr. Johansson's letter characterizes EPA's
October 2014 analysis as that of an incomplete risk assessment.
Now, it seems that EPA simply conducted a literature review
whose data could inform the risk assessment process. Would that
be a correct characterization of what you did?
Mr. Jones. Well, it was a benefits analysis, we were
looking at the benefits of the chemical, as opposed to what
risk it poses. So we weren't at all attempting to characterize
the risks of the compound. We were attempting to characterize
the benefits. And we got a fair amount of comment from USDA and
from many others about what they saw that was right about it or
was wrong about it.
Ms. DelBene. And so what happens now with all that comment?
Where do you go from there?
Mr. Jones. So we will give consideration to all the
comments that we received, which included field visits. I
personally went to the Delta at the request of soybean growers
there to look at their experiences. We will incorporate all of
that into our final assessment. And then we will bring that
together with a risk assessment for purposes of risk
management.
Ms. DelBene. And you talked about this a little bit in your
testimony, can you put into perspective in real-world terms how
important pollinators are to our food supply? My district is a
specialty crop district. We have lots of fruits and vegetables
and red raspberries in particular, highest producer per capita.
So what in real terms would the continued decline and loss
of pollinators mean for our food supply and for our ecosystems?
Mr. Jones. That may be a question better answered by Dr.
Johansson.
Ms. DelBene. Absolutely.
Mr. Jones. But they are of critical importance to
agriculture and to American consumers.
Ms. DelBene. Dr. Johansson, are you----
Dr. Johansson. Certainly we know that pollinators are
important for a good number of crops. For example, as you
mentioned, specialty crops in particular. A lot of tree crops
in California, for example, rely 100 percent on pollinator
services. There has been a range of valuations on the actual
dollar amount that those contribute to U.S. agriculture as a
value-added component.
I mentioned earlier in my testimony that the service fees
alone were roughly $650 million in 2012. Jim had mentioned that
some valuations had gone up to upwards of $50 billion.
Certainly, I have seen estimates anywhere in the range of $15
to $20 billion per year in terms of the value of the crops that
are pollinated by pollinators.
And so putting an actual value on, or how you go about
estimating the economic value, you would need to look into a
variety of factors such as alternatives to pollination and that
kind of thing and sort of net that out. But just from the
ballpark standpoint, we would say that certainly pollinators
are providing large value-added to the U.S. ag economy.
Ms. DelBene. Thank you. Thank you, Mr. Chairman. I yield
back.
The Chairman. Thank you, Ms. DelBene. I would like to now
recognize Mr. Scott from Georgia, for 5 minutes.
Mr. Austin Scott of Georgia. Thank you, Mr. Chairman. I
have a couple of comments before I get into the questions. And
while I certainly don't blame each of you individually, but it
shouldn't take a Congressional Committee or a presidential
directive for the USDA and the EPA to work on an issue of this
magnitude. There was a lot of talk as we were getting started
in the testimonies about honey. But the fact of the matter is
pollination is the real issue for our food supply. I like
honey. And bees are known for honey. But it is really the
pollination issue that is of importance to our food supply.
So I would hope that in the future it wouldn't take
Congress or the President to get the agencies to work together
on these issues. And the second thing I would ask or suggest is
that honey bees and pesticides, those aren't mutually exclusive
issues. I have concerns, if you will, when we talk about the
neonicotinoids and other things, that they are becoming
somewhat the whipping boy here when the pesticides really
aren't, that is not the primary issue that is the problem.
The Varroa mite is, in my opinion, one of the biggest
problems. And my question for you, Mr. Jones, what is the EPA
doing to make sure that we have the tools to combat that pest
that has been so devastating to our bee colonies?
Mr. Jones. Thank you, Congressman. So our role here is to
make sure that when we get an application for a Varroa mite
control product, that we expedite our review of it. And we
actually have a really good example of that in the last 9
months, where researchers at the Department of Agriculture
determined that a chemical that had been used for other things,
oxalic acid, has the potential to control Varroa mite in honey
beehives and not harm the bee. And so we worked with them on
developing an application that they then submitted to us. And
within several months, we had licensed it. So that oxalic acid
is on the market today. It was a rather short period of time
from discovery of its potential as a Varroa mite control and
licensing.
Mr. Austin Scott of Georgia. All right. So, I appreciate
that expedited approval. But what we call a discovery, the fact
of the matter is that was already being used in Canada I
believe for this very issue, wasn't it?
Mr. Jones. It was, yes.
Mr. Austin Scott of Georgia. So it is not really a
discovery. It is the fact that other countries were already
using this. And if I remember correctly, we actually used the
research from Canada on that particular pesticide or whatever
we want to call it that attacks the Varroa mite to approve it.
And I would just hope that we would be able to continue to
expedite those things.
What is the current estimate of the bee population, the
cultivated bee populations and the wild bee populations?
Mr. Jones. I happen to know for managed bees that the
number, the Department of Agriculture number is about 2.7
million managed bee colonies in the United States. I don't
believe any of us know the wild populations. I don't know that
they are surveyed.
Mr. Austin Scott of Georgia. Yes. It would be hard to count
them, wouldn't it? That doesn't mean that certain agencies
don't try to count other things and make up some numbers from
time to time. How does it in the managed area compare to recent
historic levels?
Mr. Jones. My understanding is that the managed colony
numbers, they are actually up a little bit over the last 5
years, from 2.5 million to 2.7 million. But that in the 1940s,
they were as high as six million managed bee colonies. And as
recently as the early 1980s, it was around three million. So
overall, the trend is they are down. They seem to have
stabilized and there is a small uptick.
Mr. Austin Scott of Georgia. All right. Thank you. Dr.
Johansson, do you have anything to add to those?
Dr. Johansson. No. Those are the numbers that you could see
from looking at the NASS honey reports, you can pull out of
there the number of colonies. Right now, as Jim had mentioned,
the most recent report documents 2.7 million colonies. Last
year, there was 2.6, so a slight increase. But certainly in
previous years, it was much higher than that. We would expect
that as the valuation, as you mentioned, of pollination
services goes up, over time you would expect producers to
respond by trying to increase that number.
Mr. Austin Scott of Georgia. Does the USDA keep any
estimates of wild bee populations?
Dr. Johansson. We could certainly get back to you on that.
I have seen some in some of the preparation I did. But I don't
have the number on the top of my head. And I would hesitate to
try to dig through these papers to try to find it for you.
Mr. Austin Scott of Georgia. I would be interested in the
estimates and what they have done historically.
Thank you, Mr. Chairman. And I apologize, I used 40 seconds
of your time.
The Chairman. I will get them back at the next subcommittee
hearing that you are chairing.
Mr. Austin Scott of Georgia. That is fine.
The Chairman. I would like to now recognize my colleague
from Florida, Mr. Yoho, for 5 minutes.
Mr. Yoho. Thank you, Mr. Chairman. Gentlemen, I appreciate
you being here.
What I would like to bring out in this hearing is
clarification and the purity of science and the purpose of
science and not have agendas driven by one side or the other.
That your decisions in the EPA and USDA are based factually on
science. Because if we don't have that in your agency, what we
have is mob rule or we have the media hysteria that goes on
that drives things that will affect, say, one of the large box
retail stores because of media hype in the respect that they
think that neonics are bad or insecticides are bad. But, yet,
when you look at all the benefits that we have gotten over the
years, it outweighs the bad.
And you guys are obviously there to protect us and the
environment and things within the environment. But it has to be
based on pure science. And what I read here is disturbing in
that the EPA is moving to rule before the studies are done. And
what I want to ask you is do we have assessed values of neonics
in the nectar of a flower that is toxic to a bee? What level is
that, Mr. Jones?
Mr. Jones. Thanks, Congressman. We have not finished the
risk assessment process for neonics and their essential risks
in bees. A part of doing that is understanding exposure. And a
part of evaluating that exposure is to get good estimates
around the amounts of neonic in honey, in nectar, I am sorry,
in pollen and in nectar because that is one of the ways a bee
can be exposed.
Mr. Yoho. Well, coming from the State of Florida, we have
the University of Florida there with IFAS which does a
fantastic job in research. What they are finding out is--and I
am sure you are aware of what is going on in Florida with our
citrus trees, we have about 90 to 95 percent of the citrus
trees in Florida are infected with the huanglongbing bacteria.
And it has decimated our population of citrus trees. And
without the use of neonics, we will have no citrus in Florida.
And Florida without citrus trees is like Wal without Mart. It
just doesn't work.
And the neonics have been proven that if you give them 3
weeks prior to the blooming stage of the plant, that they are
very effective at stopping citrus greening. And, yet, the
levels of the neonics in the nectar measured, is less than 20
parts per million, which is what is deemed toxic for the bee.
It is well below that. So a strategic spraying and application
of a product is what is beneficial for the citrus tree, as it
is for other crops. And when I look at the honey bee population
in the world, I have a study right here in front of me, if you
look from 1960 to 2010, the millions, the amount of beehives,
they have gone from 50 million beehives to now they are right
at 80 million beehives worldwide. And when you look at when
neonics were introduced, there was a decline in that era but it
was before neonics were introduced into the environment. And
our populations have gone up.
And then when we look at the stress that are on the bees,
when you look at California that has to import a lot of their
bees, they have to transport them long ways or other parts of
the country, the stress factor along with the mites and the
viruses seem to play more of a relationship when you look at
the correlation of stress on the hives, management of the
hives, and the contamination when you bring in outside
population of bees, it is like children and horses, when you
move them together, they are going to pick up exogenous strains
of viruses that affect them.
We need to put more emphasis on that and that research.
Because if we look at just Canada, they have roughly 16 million
acres of canola. And they don't have a decline in bee
population. Of course, they don't have the Varroa mites. But
they have been using neonics steadily for the last 20 years.
What are your thoughts on that?
Mr. Jones. Well, a couple of things. First, I would like to
recognize that we authorized the use of the neonics in Florida
citrus because of the exact scenario that you described. So we
are very familiar with the issues they are having. We are
committed to using sound science in making the regulatory
decisions that we do around neonics. Most of the grief that we
get is because we haven't canceled the neonics, not because we
are not following a science-based process. I think that you are
referring to Australia as opposed to Canada. Canada is
suffering some of the same bee issues that we are. Australia,
from the accounts that I have gotten, has not, and Australia
does not have the Varroa mite at least as of yet.
Mr. Yoho. The reports I have right now is that Canada with
their canola fields, roughly 16 million acres, their bee
population is doing well. And their honey production is doing
fine. It hasn't seen a dip. Unless I am wrong on that.
Mr. Jones. Actually, I am sorry, eastern Canada has had bee
population issues that are similar to the United States. And
western Canada has not.
Mr. Yoho. All right. And I will reserve my questions for
the second go-around, Mr. Chairman.
The Chairman. Thank you, Mr. Yoho. I now would like to
recognize my colleague from Washington, Mr. Newhouse, for 5
minutes.
Mr. Newhouse. Thank you, Mr. Chairman. I appreciate that.
Welcome, gentlemen. Thank you for being here about this
important subject. I am a fruit producer. So I understand fully
the importance of honey bees to our way of life and to our
ability to produce food, but also a user of some of these
classes of chemicals. And I might add that they have been very
successful in allowing us to control very problem pests very
economically and have gone a long ways to actually reducing the
amount of sprays that we apply. We can find a balance here at
some point.
But I have just a couple of questions. I will ask Mr. Jones
first, if I might. As I am a producer, I am interested in this
subject. Would you say that there are any investigations or
statistics about negative impacts on bee health that are
correlated to the misuse of pesticides contrary to label
requirements and recommendations?
Mr. Jones. There certainly, Congressman, have been a number
of incidents associated with the misuse of pesticides. One that
has gotten a lot of the attention from the state just south of
yours in Oregon. And they are easily predicted, if you misuse
an insecticide, that you may kill insects that you were not
intending to kill. And that is something that we have seen
where, in the case in Oregon, neonicotinoids, but, it frankly,
could have been any insecticide, were applied to linden trees
while tens of thousands of bumblebees were in that tree. The
label said it shouldn't be used that way. But it was used that
way. And yep, big surprise, all the bumblebees in that tree or
most of them died. We have a lot of evidence that if you misuse
an insecticide in a way where insects are present that you
didn't want to inadvertently kill, you will see deaths, in that
case, bee deaths.
Mr. Newhouse. I guess where I would like to probe a little
further, how much are we working on enforcing those existing
rules, those existing label restrictions versus coming up with
new rules? Shouldn't we be doing the former before the latter?
Mr. Jones. As a former commissioner of an ag department, I
would expect you would know that pesticide use in the United
States is enforced by state ag departments with the exception
of a couple of states where it is done by the Environmental
Agency which is California and New York. So I would turn to my
state NASDA colleagues to answer that question.
Mr. Newhouse. I appreciate that. And I do understand. A
growing number of municipalities and even several states around
the country are banning the use of this class of chemicals. I
understand the EPA's regulatory decisions are based on analysis
from numerous, hundreds of staff reviewing available data. In
your estimation, do these states and cities have the expertise
and staff resources to be making these kind of decisions?
Mr. Jones. I wouldn't speculate on the capacity of states
or local governments to make some of the choices that are being
made. I think that one of the reasons people are frustrated
with our time schedule is that we have not finished our review,
which is why we are expediting the review of the neonicotinoids
so that municipalities, states, and others can have the benefit
of EPA's risk assessment.
Mr. Newhouse. So a follow-up to that, similarly, when
retailers may have questions about a product and how or why it
may be approved, do you explain that approval process and the
requirements that you impose on those companies?
Mr. Jones. When we are asked it is usually by a
municipality. That is the entity that most often asks can we
come and explain to them how we do our work. We always provide
that kind of technical assistance. I am not aware of, it
doesn't mean it hasn't happened, but I am just not aware of a
retailer having asked for our views on a pesticide regulatory
issue.
Mr. Newhouse. Okay. Thank you very much. I will yield back
my time, Mr. Chairman.
The Chairman. You just yielded back the 40 seconds Chairman
Scott took. So thank you.
Mr. Newhouse. We are even.
The Chairman. Yes. I will let him know that. I would like
to now recognize my colleague from Pennsylvania, Mr. Thompson,
for 5 minutes.
Mr. Thompson. Mr. Chairman, thank you. Thank you for this
hearing, an incredibly, incredibly important topic in the world
of agriculture and, quite frankly, everyone that likes food.
Scientific research really is the key to protecting and
sustaining pollinator health. And there is already so much
research occurring between the USDA, the EPA, and other land-
grant universities. I am a little concerned, though, to some
degree that this research is being done in silos and we haven't
maximized the full synergistic benefits through collaboration,
that maybe at times there is little to no coordination between
these various entities.
Institutions, such as my alma mater, Penn State, land-grant
university, which I know is doing a considerable amount of
pollinator research and with Federal resources would be a great
partner, especially given their existing work with extension
activities. So my question is do the two agencies that you both
represent, respectively represent, does USDA or EPA intend to
move forward with any kind of national pollinator institute to
help bridge these connections and better coordinate efforts
and, quite frankly, in a synergistic way get to some good
solutions sooner rather than later?
Mr. Jones. Thanks, Congressman. We are coordinating with
our colleagues at the Department of Agriculture on pollinator-
related issues very closely and with your alma mater, Penn
State, I am forgetting the name of the entomologist there who
has been very active in our collective collaboration, as well
as many other land-grant researchers. I am not aware of any, at
least on the EPA's part, of standing up a pollinator institute
of any nature. I will defer to Rob.
Dr. Johansson. Certainly we can follow up with you on this
question in terms of our work with the land-grants. I know that
we have certainly requested additional budget resources for
some of our research agencies which do collaborate pretty
strongly with institutions like Penn State. So, for example,
both NASS, ARS, and NIFA have, we have requested additional
funds specifically for pollinators. But I am not aware of that
being targeted towards a specific institute.
Mr. Thompson. I would be real curious to get both your
respective professional opinions, and how would you feel about
an initiative that would stand up such a national pollinator
institute?
Mr. Jones. I will defer to Dr. Johansson, as I think that
the broader issues of pollinators are more in USDA's bailiwick
as opposed to just the pesticide.
Dr. Johansson. Well, it is a great question. I would like
to hypothetically think about that and get back to you on that.
Certainly, there has been pollinator research stations that we
have had in the past that have been part of the extension
service and collaborating at places such as LSU. And I know
that some of those have had budgetary issues in the past that
we are trying to boost now. And that would go a long way
towards answering your question. But I need to get specifics
from our Office of Budget and Policy Analysis on that.
Mr. Thompson. That would be great. And I would welcome
input from both agencies.
I think we are all very aware of the potential risk with
any kind of impairment to pollinators. And I would love to talk
with you and your agencies more about--I recognize that,
obviously, we are doing some isolated, some targeted
collaboration. But this really, the potential risk here
warrants perhaps a little broader collaboration.
I wanted to just quickly, I know that the chief of the
National Wildlife Refuge issued a unilateral moratorium on
January 26 prohibiting agriculture practices on Refuge property
that employ the use of biotechnology and neonic pesticides.
There were no independent reviews conducted documenting
specific health risks to humans or wildlife, nor was any
discussions held between the Refuge System and the agencies
responsible for review and regulation of these technologies. My
question, Mr. Jones, is with the July 17, where the Fish and
Wildlife Service announced it was banning the use of
neonicotinoids on U.S.--how did I do, Chairman, with the
pronunciation of that? Pretty good.
The Chairman. Terrible.
Mr. Thompson. Okay. Everything I learned I learned from
him--was EPA consulted by the Fish and Wildlife Service
regarding this decision? And what guidance did the EPA offer if
it did?
Mr. Jones. We were not consulted on that decision.
Mr. Thompson. Okay. Thank you, Chairman.
The Chairman. Thank you, Mr. Thompson. Since everyone here
has gone through a round of questioning, now the witnesses are
stuck with my round of questioning. But, first, being the
Chairman of the Subcommittee, I always enjoy hearing about
other land-grant universities and the positive research that is
being done there. But none can compare to the land-grant
university, the University of Illinois. And I see we have fans
in the back. Thank you.
The University of Illinois has been at the center of
pollinator research. Dr. May Berenbaum was awarded the National
Science Award for her research in pollinator issues. And I am
proud that what we see here today is a collaboration on
research that is very important to this issue happening at many
of our land-grant universities, which is why I am so proud of
the Subcommittee and the Members that are on the Subcommittee
because we have issues that affect the agriculture communities
as a whole. And we have research being done at our facilities
within our districts. And we are able here today to talk about
how that research is being utilized by the Federal agencies
who, at this point, are partners in releasing a report that, as
I said in my opening statement, is 5 months behind. I will
start with that question. Does anybody have an idea at the
table, Dr. Johansson, as to when this may come out? Maybe next
week?
Dr. Johansson. Well, Jim had mentioned that they were
expecting that to come out in the next couple weeks. I have
heard spring. And, obviously, spring is, in D.C., is a loosely
defined term. I think we may already be past spring in D.C.
Certainly, we are expecting that to come out sooner rather than
later. And I will let Mr. Jones fill in the blanks on more
specifics.
Mr. Jones. We are a couple of weeks away and the report
will be publicly released.
The Chairman. Great. I will hold you to it. All right. The
first question I have is for Dr. Johansson. I am sure you have
read recent media reports regarding allegations of scientific
suppression within the USDA. Have you ever felt pressured to
modify your conclusions or to keep them from the public?
Dr. Johansson. Speaking personally, no, I have not. I have
certainly, as a young researcher, felt that the peer-review
process was maybe sometimes a little slow for my desires,
wanting to get publications out into journals and what have
you. But for the most part, speaking from an economics
perspective, all the peer review that we put in place is
intended just to make sure that the research that is being done
is of sufficient quality and rigor for publication in
scientific and academic journals or for presentations at
professional meetings.
And so based on that experience, I have not ever felt that
any kind of research findings of mine or anybody in my office
have been adversely impacted by this review process that we
typically try and put in place just to ensure that the research
that is getting put out is of high enough quality for use to
the public.
The Chairman. And for this Committee, can you briefly
outline the process that you use for USDA scientists' work and
the peer-review process that it goes through before
publication?
Dr. Johansson. Sure. I think each office in USDA approaches
this differently depending on the kind of science that is being
done. And so I certainly don't want to speak for those other
agencies that have developed their processes and protocols that
are specific to the type of research that they are undertaking.
For our process, I can speak to a couple aspects of that.
Our office provides advice to the Secretary and that is
generally, typically just for internal consumption. And so we
often have to put that together relatively quickly and get that
up to his office. And he relies on our professional experience
to provide the best available information available to him at
that time. So that doesn't necessarily have any sort of
rigorous protocol that we have to go through to get that up to
him.
But, on the other hand, as part of my office, we have the
World Agriculture Outlook Board that coordinates all of our
estimates for the World Agricultural Supply and Demand that we
put out each month. That process is very tightly determined by
protocols that we put in place specifically to keep those
analysts protected from any kind of what may even be perceived
as outside interference from any political or questioning or
alterations of their findings.
And so I would just point out that at least the protocols
that are in our office are intended, essentially, to make sure
that our analysts are able to put out to the public the best,
most accurate information available.
The Chairman. So the reports that there has been
suppression due to political motives, they are wrong?
Dr. Johansson. I am not really familiar with those reports.
I haven't been involved with that issue. I know we do have a,
we have developed a scientific integrity policy at the
Department that is intended to provide guidance and discuss
these issues. We can certainly get that information to you. But
I haven't been involved with any reports of any kind of
suppression of USDA science results.
The Chairman. Okay. So do you equate the need to follow set
protocols with this allegation of political suppression that
you say doesn't exist?
Dr. Johansson. It certainly doesn't exist in my office or
with the work that we have been doing. I certainly can't
comment, like I said, on other agencies.
The Chairman. All right. Well thank you very much. I am
going to yield 5 minutes to my colleague from Florida, Mr.
Yoho.
Mr. Yoho. Thank you again, Mr. Chairman. I would like you
to continue on the working together as the EPA and USDA so that
we do come out with sound science. Mr. Jones, you were talking
in your testimony, there were three areas that you tried to
achieve these goals.
The EPA has focused it's pollinator efforts in three
primary areas advancing the science and understanding of the
potential impacts of pesticides on pollinators, taking
appropriate risk management actions based on that available
science, and collaborating with domestic and international
partners to advance pollinator protection. And we all agree how
important bees are in the pollination process in the production
of our fruits and vegetables.
To have that sound science working with the USDA, I have
also here the National Wildlife Refuge System bans neonics and
biotechs without justifying or communicating with the USDA or
the EPA, and on October 2014, EPA releases a study on neonics
talking about the treatments--I am sure you are aware of the
soybean seeds, that there was little or no overall benefits to
production, and the USDA comes out and disagrees with that
assessment and calls that risk assessment incomplete.
How do we get you guys on the same page working for a
common goal instead of fighting against each other, not
communicating with each other?
Dr. Johansson, what is your thoughts on that? What would it
take to get it where you are working together on that?
Dr. Johansson. Well, I certainly would agree that Jim and I
are certainly open to working together collaboratively,
certainly on economic analysis that his office is undertaking
to discuss the benefits or the economics behind a lot of these
treatments, and I am sure we will have an opportunity to follow
up with his office on those, moving forward. And, just to point
out, we do a lot of collaborating on a lot of issues. And
sometimes we just wanted to--in this case wanted to make sure
that we did provide comments on this, and we took the
opportunity to put those in the public record. I wouldn't
necessarily call it squabbling or anything like that. It was
just that we wanted to make sure that our comments were heard.
Mr. Yoho. Mr. Jones, what is your thoughts on working with
the USDA? I mean, how can we help facilitate you guys working
closer together so that when we do come out with a policy it
has the stamp and approval of the USDA, the EPA, the United
States Government, and it is factual, not based on an agenda,
and it is not being politically motivated or outside groups
motivated. What can we do to get beyond that and just on pure
science?
Mr. Jones. We are committed to basing our decisions on
science and following the rule of law, and we collaborate
extensively with the Department of Agriculture. As a matter of
fact, in the mid 1990s, when there was concern that we might be
running amuck in pesticide regulation, the Department set up an
Office of Pest Management Policy, which is our point of contact
on any issue, pesticide, regulatory, or science. And that is
our point of entry into the Department, and we coordinate and
collaborate on virtually every move we make that is of
significant note.
But we can always do better, and we are committed to doing
better and making sure that we are as coordinated as we can be.
If we were to issue certain regulations which the benefits
assessment was not, we actually have a statutory responsibility
to consult with the Secretary, and we do that. We have done
that on the worker protection standard, the current
certification and training standard, but that was not a
regulation. But we still went through the Office of Pest
Management Policy, and would be committed to doing that, going
forward.
Mr. Yoho. All right. I would encourage you guys to get the
results of that report out at soon as we can so we can bring
some stability to the market so that we don't have the big box
stores not using a neonic because they say the public
perception is these are bad.
And it brings me back to the trade deal coming up that we
are looking at with the European Union, and what the European
Union did banning the use of the neonics, or a 2 year
moratorium on it, and now it has spilled over to Canada, and it
was, let's see, after the European Commission voted to ban
neonics, anti-GMO, green and farm groups turned their focus on
Canada, pressuring Ottawa to follow suit. The responsible
agency, Health Canada's Pest Management Regulatory, aware that
the evidence fingering neonics was spotty vacillated issuing an
ambiguous assessment of the reported bees deaths in Ottawa, and
we don't want that driving our policies. Because now if we are
using those products here, we are going to be banned from
trading with Europe on that, and it is not based on science. It
is based on a political agenda. And if it is truth behind that,
I don't have a problem. But if it is not based on science, and
that is why we rely on you guys, and I know you guys are going
to do a great job because you have the USDA working right hand
in hand with you, and it will make American farmers stronger
with our bees. Thank you.
The Chairman. The gentleman's time has expired. Thank you.
Actually, let me jump in real quick and follow up a little
bit on the discussion that was just had.
Part of the reason why both of you are sitting here is
because we have a concern that there isn't the communication
between the two agencies within the same Administration co-
chairing the Pollinator Task Force, and the evidence is clear
in the letter that we have submitted for the record.
Dr. Johansson, were you surprised at the EPA's action here?
And can you actually elaborate a little bit more on your letter
and the USDA's disagreement with EPA and how to better
coordinate as co-chairs of this task force?
Dr. Johansson. Certainly, on your latter question that with
the task force there is great communication and great
collaboration between the two agencies and moving forward on
that. I am not really involved with the task force. We do, as I
mentioned earlier, review certain pieces of research or
analysis that may come out of that task force at some later
date for its economic content.
In the case of the study that EPA conducted on the benefits
of seed treatments for soybean producers, I wouldn't classify
it as a huge disagreement. EPA acknowledged that there were
some open questions that they needed to get more data on. They
wanted to get public comment on that. We agreed with that and
emphasized places that we thought that the public could provide
good data, particularly with respect to acknowledging the sort
of heterogeneity that you get in ag production across the
United States. Different regions have different growing
practices, different challenges, and certainly the economics of
the situation may be different in any given year.
Certainly we would also point out, which didn't come into
play in this particular analysis, there are benefits to
different types of producers, different crops, as has been
pointed out by Congressman Yoho and Congressman Newhouse. Those
weren't addressed in this analysis, and certainly moving
forward, we would expect that looking at the benefits of seed
treatments will be--or the use of this type of chemical,
pesticide, would be different by region, by crop, by time of
year, and that is essentially the point we were trying to make
in those comments.
The Chairman. Well, thank you. I appreciate that. And keep
in mind, now the Ranking Member DelBene talked about why
couldn't we have more stakeholders in the pollinator issue and
the colony collapse disorder issue sitting at the table with
you. Well, we don't have a task force report. It is 5 months
late. Otherwise, we would have had those stakeholders sitting
at the table, but what we see as an oversight institution is,
is we see a disagreement between agencies that are supposed to
be working together. This is what frustrates us, and this is
the reason why both of you are here. Because, hopefully, your
presence, you could take our messages back to your superiors at
your respective agencies and let them know that we want to see
that communication. We want to work with you. We want to
address these issues based upon clear science. And we have so
many examples that have come up today of institutions that are
willing and doing the work in pollinator research to help you
with. But let's make sure that we have that communication
within our own agencies.
And, again, I would like to take this opportunity to ask
you, Mr. Jones, to take a message back to Administrator
McCarthy that I talked to her about, let's get a member of the
ag community on your EPA Science Advisory Board. And let me be
clear on the Congressional intent of that, since I wrote the
provision. I don't want somebody that just has a scientific ag
research--a scientific background. Let's get somebody who is
actually out in the fields on that Science Advisory Board so
that we can put a seat at the table that has real agricultural
experience. I am not saying what type. I mean, obviously
central Illinois is home to corn and soybeans. I call them the
special crops, not the specialty crops, but we have so many
opportunities to work together, and the reason you are here
today is I hope you take that message back.
So with that I am going to recognize my colleague from
Washington for 5 more minutes.
Mr. Newhouse. Well, thank you, Mr. Chairman. And coming
from a state that raises some of those specialty crops, the
State of Washington, if I could in a related line of
questioning, Mr. Jones, let me relate some frustrations from
some of the stakeholders in my district as it relates to
registering pesticides with the EPA. I would like your response
to some of their concerns.
They reported to me that despite submitting ample
independent evidence concerning the impacts of their products,
that sometimes the agency will pick fewer independent stand-
alone studies. Sometimes that lack raw data to formulate their
decisions, and then make registration tolerance decisions based
on that instead. And just so you know, I have heard this more
than one time.
Could you respond to these concerns and describe to us what
the registration process looks like and is it uniform.
Mr. Jones. Thank you, Congressman.
So the registration process involves manufacturers
generating a standardized set of data. It is standardized but
the amount of data we will ask for to register a pesticide on a
food use is a higher amount of data then, for example, to
register a nonfood use like a rodenticide product. But within
that category, it is standard, the data that we want. They are
required to generate that data.
For registration of a chemical, most of the review we do
involves the data that is generated. When we are looking at
existing chemicals, it often involves not only the information
generated by the manufacturer but information that may have
been generated by all sorts of entities. Information from the
literature, peer-reviewed information from sources other than
the manufacturer. For new chemicals, though, likely the only
data you are going to have is what the manufacturer generated.
So the process that we use in doing risk assessment
involves looking at all available information. As I said, most
of that is going to be manufacturer generated, but not
exclusively, and then making judgments about how to apply the
standards we have for robust science to that data to perform
risk assessments.
Mr. Newhouse. Okay. All right. I appreciate that response,
and just wanted to make sure you were aware of some of those
concerns in the process. Certainly as a specialty crop
producer, sometimes we feel like we are overshadowed by the row
crops, and that focus of attention certainly is important to
us, and would appreciate expediting as much as possible the
process.
Mr. Jones. One of the very good collaborations we have is
with the Department of Agriculture and their IR-4 program which
is designed to basically provide the residue data if necessary
to support minor use registrations which we give a very high
priority to.
Mr. Newhouse. Good. Good. Thank you. And thank you, Mr.
Chairman.
The Chairman. The gentleman yields back the balance of his
time. And thank you for recognizing specialty crops once again.
I want to thank both of you again. I have just got a couple
more questions that, because I am here the entire time, I
usually wait rather than make my colleagues have to wait around
for us to get through a line of questioning, and then we can
actually get a few ends tied up and we will get you out of
here.
Mr. Jones and Dr. Johansson, there is actually legislation
that has been introduced that would suspend the registration of
neonics and establish a new standard for pesticide
registration.
Mr. Jones, can you tell us what impact you think this would
have on farmers' yields and, more importantly, global food
security?
Mr. Jones. We have not evaluated what would happen in the
event of a removal of neonicotinoids as a class of pesticides.
So I really can't speak with any degree of authority on that
question.
The Chairman. And, Dr. Johansson, can you?
Dr. Johansson. Well, certainly we would see producers
switch to other classes of pesticides in that case, and so we
would need to evaluate relative effectiveness and cost of those
other types of treatments. But certainly we would expect that
producers would find an alternative. It is just a question of
how costly that would be. We would need to evaluate that, but I
wouldn't suspect that we would see--other than the case of
potentially places where there aren't alternatives, or aren't
as effective alternatives, a huge decrease in production. Just
probably an increase in cost.
The Chairman. Okay. And, Dr. Johansson, your testimony
discusses the need for public-private partnerships and
increased citizen engagement to promote pollinator health. And
I have promoted public-private partnerships in other issues,
including water infrastructure on another committee that I
serve on, and I am interested in what the task force is
actually developing here. Can you provide a preview of what you
are working on with public-private partnerships, or keep this
Committee updated on the particular issue? Even though I would
rather that last statement not be an out for you not to have to
answer.
Dr. Johansson. Yes. I have to follow up with you on that.
The Chairman. You took the out.
Dr. Johansson. Yes. We will make sure to get you that
information.
The Chairman. In a couple weeks?
Dr. Johansson. In a couple weeks definitely.
The Chairman. How about a week?
Dr. Johansson. Well, I will see what I can shake loose when
I get back to 1400 Independence.
The Chairman. Thank you. Thank you.
Well, I am going to go ahead and go into the closing
statement, and before we adjourn, do you have any other
questions, Mr. Newhouse?
Well, again, thank you to both of you for being here today
at this hearing. I was able to get a lot of questions asked on
very important issues. Again, we have a concern at this
Subcommittee over the lack of communication between your
agencies and between other agencies within the same
Administration.
Now, Dr. Johansson, you were being very kind in many of
your comments in regards to decisions made, specifically on the
issue relating to the EPA's decision on soybeans, but you do
say specifically in your letter that the USDA disagrees with
the EPA's decision.
I think that disagreement could have been avoided with a
little bit of communication. And we are going to continue to
have hearings like this to talk about a lack of communication
if we don't feel that this task force is coming together and
continuing to work.
So take this message back and let your superiors know we
really appreciate you spending the time here to answer our
questions. You get to be on the front lines of getting our
frustration sometimes, and both of you, I truly do appreciate
the time that you spent in front of this Subcommittee.
And under the rules of the Committee, the record of today's
hearing will remain open for 10 calendar days to receive
additional material and supplementary written responses from
the witnesses to any questions posed by a Member.
This Subcommittee on Biotechnology, Horticulture, and
Research is now adjourned.
[Whereupon, at 3:03 p.m., the Subcommittee was adjourned.]
[Material submitted for inclusion in the record follows:]
Submitted Letter by Hon. Rodney Davis, a Representative in Congress
from Illinois
April 6, 2015
Richard Keigwin,
Director, Pesticide Re-evaluation Division,
Environmental Protection Agency,
Washington, D.C.
Re: USDA Public Comments on the EPA's Benefits of Neonicotinoid Seed
Treatments to Soybean Production document published in the
October 22, 2014 Federal Register; EPA docket
identification (ID) number EPA-HQ-OPP-2014-0737.
Dear Mr. Keigwin:
America's farmers face numerous challenges as they work to produce
the food, feed, and fiber for a strong and healthy America. On October
22, 2014, EPA added an additional and unnecessary burden by publishing
a portion of an incomplete risk assessment titled ``Benefits of
Neonicotinoid Seed Treatments to Soybean Production'' which again puts
growers in the position of defending their pest management decisions.
USDA staff had specifically requested EPA to complete the full risk
assessment that would more robustly describe the benefits of
neonicotinoid seed treatment for all crops. Instead, EPA released the
report regarding soybean seed treatment without additional
consideration of other crops or to USDA cautions about releasing a
premature assessment of the costs and benefits of such seed treatments.
EPA's release of the incomplete report has resulted in a plethora of
articles which cast doubt on the value of seed treatment and
neonicotinoids for agricultural production and the choices made by
farmers. EPA's report indicates that most neonicotinoid seed treatments
were prophylactic in nature and that there are available alternative
foliar insecticide treatments that would be as effective at similar
cost to neonicotinoid seed treatments. EPA concludes that there ``. . .
are no clear or consistent economic benefits of neonicotinoid seed
treatments in soybeans.''
As a whole, USDA disagrees with that assessment. We believe that
pest management strategies are made in consideration of pest pressures,
climate, landscape, and numerous other factors.
Growers should have the ability to use the best tools available to
manage pests that include choices in seed treatment and pest management
tactics. Each knows best what works for his or her individual
situation.
Again, thank you for the opportunity to review. Our comments are
below.
Sincerely,
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Robert Johansson, Ph.D.,
Acting Chief Economist,
U.S. Department of Agriculture.
attachment
USDA Public Comments on the EPA Document
``Benefits of Neonicotinoid Seed Treatments to Soybean Production''
Background
It is clear that the soybean crop is of significant size and
importance to overall U.S. production. In 2013, U.S. farmers harvested
3.36 billion bushels of soybeans on 76.25 million acres, which was
valued at $41.84 billion. Average soybean yield was 44 bushels per
acre. In 2013, soybean price at the farm averaged $14.30 per bushel.
It is also clear that expenditures on neonicotinoid seed treatment
for soybeans are substantial and not insignificant. In 2013
neonicotinoid seed treatment sales exceeded $1 billion and more than
$400 million for soybean seed treatments, or roughly nine percent of
seed costs. There are at least 36 different EPA registered
neonicotinoid-based products for seed treatments in soybean. Many of
those products are also registered in 40 or more states in addition to
the Federal registration.
The agricultural sector, including the soybean sector, is typically
viewed as competitive. As such it is unlikely that most farmers would
be purchasing seed treatments if there was no value to them. For
example, extension agents at the University of Mississippi point out
that adoption of neonicotinoid seed treatments for soybeans in MS has
risen from two percent in 2007 to 90 percent today. That pace is more
rapid than adoption of herbicide resistant soybeans \1\ and has been
driven by the value MS soybean producers place on the protections
afforded by neonicotinoid seed treatments.\2\
---------------------------------------------------------------------------
\1\ See discussion at http://www.ers.usda.gov/data-products/
adoption-of-genetically-engineered-crops-in-the-us/recent-trends-in-ge-
adoption.aspx.
\2\ See http://www.mississippi-crops.com/2014/10/31/do-
neonicotinoid-seed-treatments-have-value-regionally-in-soybeans/.
---------------------------------------------------------------------------
EPA Findings
EPA argues that it would be equally cost-effective for producers to
substitute protections afforded by neonicotinoid seed treatments with
other foliar applications of pesticides. The report makes the broad
generalization that ``. . . At most, the benefits to soybean growers
from using neonicotinoid treated seeds are estimated to be 1.7% of net
operating revenue in comparison to soybean growers using foliar
insecticide . . .''
To come to that conclusion, EPA has had to make several broad
generalizations and to rely on scarce and limited data that are not
public. For example, EPA assumes that foliar spraying of pesticides is
done by all producers who are purchasing seed treatments, that such
spraying does not incur additional costs in management or equipment
purchases, and that such spraying can address the same pests over the
same time window as seed treatments. EPA did not consider any potential
environmental consequences of foliar spraying such as compaction issues
with farm fields if additional treatments are required, increased risk
of exceeding food tolerance residue levels when compared to seed
treatments, effects of increased foliar sprays to farm workers,
pollinators, other beneficial arthropods or integrated pest management
systems, nor regulatory barriers to spraying created by other
environmental regulations. The EPA analysis assumes that foliar
spraying is environmentally preferable to using seed treatments.
EPA notes some additional limitations in their report, which they
indicate may affect their conclusions:
EPA acknowledges that there may be risk management benefits
to using neonicotinoid seed treatments, but that they lack
information to quantify those benefits.
EPA acknowledges that neonicotinoid seed treatments may be
more or less valuable to soybean producers in conjunction with
other crop management technologies, such as IPM or crop residue
management. EPA has not included any of those cross effects in
their analysis.
EPA acknowledges that the use of neonicotinoid seed
treatment may help soybean producers manage pesticide
resistance. The efficacy of alternatives to neonicotinoid seed
treatments are not adjusted for such resistance issues.
EPA also acknowledges that other costs of soybean production
not accounted for in this analysis may influence the extent
that uncertainty in EPA's analysis would affect the
conclusions.
Conclusion
USDA disagrees with the general assertion by EPA that there are
``no clear'' economic benefits to seed treatments in soybeans. In 2013
neonicotinoid seed treatment sales exceeded $1 billion and more than
$400 million for soybean seed treatments. In general, USDA would
suggest that farmers are efficient and would not use management
practices that did not generate expected benefits that were at least as
great as the cost of that management practice. Farmers will generally
employ such practices to the point when the marginal benefit of that
practice is equal to the marginal cost of that practice. In this case,
employing a menu of pesticide practices that includes seed treatments
is balanced against the costs of using those practices.
Because, those decisions are based on expected crop prices and
expectation that in some years pest management will be more or less
necessary based on environmental conditions it may be that in any given
year costs of pest management exceed the benefit provided in that year.
However in other years such investments are repaid and would cover
previous year's use of those practices. Similarly, pest management in
one region may protect crops from certain pests at a different rate
than in other regions. Given the pace of adoption of neonicotinoid seed
treatments particularly in some regions of the country, it is clear
that there are economic benefits to using those seed treatments.
Unfortunately, EPA's conclusions are not supported by complete data
nor analysis. EPA's analysis does not include potential labor and
management savings afforded by seed treatments. Moreover, it does not
consider cases when timely foliar applications are not possible or as
effective due to general field and weather conditions. Applications of
pesticides are required to mitigate the adverse effect of those pests
on a newly emergent crop. EPA's calculation does not include
consideration of control for soil pests that would not be affected by
foliar applications. EPA's calculation does not include any additional
regulatory expenditure by landowners, such as costs to revise pesticide
permit applications, or costs to submit new applications for foliar
spraying. EPA does not consider the benefits of seed treatments when
soybeans are grown in rotation with other crops, such as corn, which
may be higher than consideration of benefits on a year by year and crop
by crop basis. Under a reasonable sensitivity analysis it can be shown
that EPA's calculations could be understated by more than a factor of
ten for soybean producers in certain regions.
USDA is disappointed that EPA published this report in such a
preliminary format without offering USDA an opportunity to help EPA
reframe their analysis and correct the misrepresentation of economic
costs and benefits that underlie this report. Farming is different from
running a dry cleaning enterprise or an electrical utility. It is the
nature of farming that production conditions are uncertain and
variable. Producers have to employ a variety of processes and
technologies that are best suited to a particular farm, farm family,
and environmental condition. As such it is inappropriate to draw
conclusions about the entirety of soybean production across regions of
the United States under different environmental conditions by simply
looking at national averages over several years.
Seed treatments are a preventative measure that guard against yield
losses due to certain pests in certain years in certain places. Because
farmers have shown rapid adoption of that management technology in some
states it is clear that there is value to those treatments. Seed
treatments are just one of the tools a producer has to manage pests on
the farm. USDA agrees that in some situations different pesticide
methods may be equally effective as seed treatments in a given year.
And it is likely that in some soybean growing regions, there are more
cost-effective pest management treatments. However, in other situations
or regions, environmental conditions would likely favor the efficacy of
seed treatments over those afforded by foliar spraying.
For many regions, it is generally agreed in the soybean IPM
research community that use of neonicotinoid insecticides may not be
useful in enhancing yield in soybean, especially for aphid control
since it does not persist to the period when aphids are most damaging
to yield. However, yield enhancement is not the only consideration for
using neonicotinoids in crop production, including in soybeans. Those
insecticides may have benefits in soybeans to help produce seed without
mottling by reducing virus transmission by beetles, especially around
edges of fields. Seed producers get ``docked'' for mottled seed.
Environmental or ecological consequences of neonicotinoids may not
be as great as other traditional insecticidal insect control,
especially with regard to unintended mortality of beneficial insects
since, in soybeans, it does not persist to the period when most
beneficial insects are most active.
Based on the above points, soybean is not a good model for judging
the value of neonicotinoids to yield enhancements. Pesticides are
considered in production systems as a whole and all crops in that
system are generally included. The soybean belt has rotations with corn
and soybeans included and neonicotinoids are used in corn as well.
Soybeans are now a big part of the production systems in the cotton
belt where neonicotinoids have been found to be effective in enhancing
cotton yields. Integrated systems rely on every tool available and
assessments of any component in the system should include all other
possible components.
Because of the many limitations and uncertainties acknowledged by
EPA, USDA suggests that EPA revise their study to evaluate the full
costs and benefits of neonicotinoid seed treatments in all crops and
regions. Furthermore, because EPA has relied on data currently
unavailable to the public, USDA requests that EPA include more survey
results from the recently released reports that indicate that farmers
are using neonicotinoid seed treatments for a variety of reasons.\3\
---------------------------------------------------------------------------
\3\ See recent studies on this topic published by AgInformatics
(http://growingmatters.org/studies/).
---------------------------------------------------------------------------
Specific Comments
1. USDA suggests EPA reframe their analysis to consider the full costs
or benefits of neonicotinoid seed treatments as it would
typically do under its FIFRA requirements.
When considering pesticide uses under the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA), EPA provides a benefit
assessment in conjunction with a risk assessment and other materials
that inform the determination of whether the use of a pesticide results
in unreasonable adverse effects on the environment. Consideration of
benefits is required during EPA's decision-making process. During
registration, registration review or when considering cancellation of a
pesticide, USDA and the public receive the entire set of documents
relevant to the Administrator's determination of unreasonable adverse
effects on the environment.
In cases where the Administrator proposes cancellation of a product
or proposes a regulatory action, the Secretary is provided the relevant
documents prior to the interagency review with the option to provide
formal comments to be included in the Federal Register notice when the
regulatory action is published in the Federal Register. All of the
neonicotinoid pesticides are currently undergoing registration review
with data generation projected to be completed by 2015 for
imidacloprid; 2016 for thiomethoxam, clothianidin, and dinotefuran; and
2017 for acetamiprid and thiocloprid. Risk management decisions are to
follow in 2016 to 2019. Normally the benefits assessment for specific
uses would not be released to the public prior to the interim risk
management decision. For example, the interim decision and benefits
assessment for flutolanil was released in September while the pesticide
was in the last stages of registration review and a full 6 months
following the release of its human health risk assessment in March. In
the case of neonicotinoid seed treatments, USDA and the public will see
only the soybean neonicotinoid seed treatment benefits assessment
without a risk assessment or notice of the decision under
consideration. Soybean seed treatment is singled out among all of the
neonicotinoid seed treatments, without explanation, creating
uncertainty among growers and seed providers over the future of this
tool.
2. The potential change in use for neonicotinoid seed treatments
assumed in EPA's analysis is economically significant.
Because the value of these treatments are in excess of $1 billion
in sales for the U.S., any analysis of the costs and benefits of using
neonicotinoid seed treatments would be considered economically
significant and would undergo full notice and comment by OMB and USDA
before public comments were solicited.
Even when limiting the scope to soybean seed treatments, the sales
of neonicotinoid treatments exceeded $400 million in 2013, likely
making any economic analysis of restricting the use of those treatments
economically significant. If EPA recommended cancellation of soybean
seed treatments, the Secretary would be asked to comment on EPA's
analysis of the impacts on the agricultural economy. As such, USDA
suggests that EPA consider the costs and benefits of neonicotinoid seed
treatments per the guidance provided by OMB Circular A-4 and the OMB
Information Quality Guidelines. Such analysis would explore the many
limitations noted in this study and would also examine the efficient
use of pest management systems across crop species and regions while
considering potential resistance issues.
3. The report does not consider the environmental benefits of
neonicotinoid seed treatments for soybeans.
In general, EPA analysis would consider both the costs and benefits
of a particular use of a pesticide in question. Despite the title of
this report, EPA does not consider any environmental benefits in this
analysis. Using seed treatments minimizes the exposure of non-target
insect populations to active ingredients included in foliar sprays.
Such potential benefits to those insect populations have not been
included in this analysis.
Several reports recently have noted the positive environmental
benefits associated with seed treatments. For example, the
AgInformatics Value Report (2014) indicates that soybean producers that
choose to use neonicotinoid seed treatments say that family and worker
safety (70%), protecting water quality (57.5%), and protecting
beneficial insects (43.8%) are `very important' considerations when
selecting pest management strategies. And extension agents at the
University of Mississippi note, ``. . . Neonicotinoids are a class of
chemistry that are highly efficacious against insect pests and very
safe to mammals. This has led to increased use in many crops grown in
the Mid-South region . . .''
4. Preventative seed treatments are likely to be more or less effective
under certain conditions and regions.
Most management techniques for growing crops work better in some
years than others. For example, during a period of low precipitation it
is more useful to irrigate your crop. In other periods, the investment
in irrigation technology may not show an economic return. That is also
the case with seed treatments. In some years in some regions,
neonicotinoid seed treatment may prevent significant yield losses;
whereas in others it may not be as beneficial. In some of those
instances, the producers may not be able to effectively use foliar
sprays as an alternative. That could be due to a number of reasons,
such as lack of appropriate conditions for spraying foliar sprays. In
addition, common pests are found in both corn-bean rotations.
Controlling pests during the soybean rotation may provide benefits for
the corn rotation. It does not appear that EPA has considered those
potential benefits.
Some foliar pests cannot be effectively controlled with foliar
sprays for a period at the beginning of the plant cycle; e.g.,
germination. Extension agents at the University of Tennessee indicate
that seed treatments are most effective in the 3-4 weeks at the
beginning of crop growth, which is the critical period for protecting
seedlings when they are most vulnerable to pests. Early in the season,
it is often the case that fields are wet and therefore difficult for
producers to get out into the fields for foliar pesticide applications.
In addition, some pests may be below ground and therefore not
controlled by foliar sprays.
EPA does not consider protection from the wide range of pests that
are controlled by neonicotinoid seed treatments, but simply focuses on
three. Other pests often do not cause significant damage to seedlings,
but some may: weevils, trochanter mealybug, grape colaspis, wireworms,
three-cornered alfalfa hopper, bean leaf beetle, thrips, white-fringed
beetles, etc. Indeed, EPA notes that ``. . . In instances where seed
treatments may provide some insurance benefit against unpredictable
outbreaks of sporadic pests, such as seed maggots or three cornered
alfalfa hoppers, BEAD cannot quantify benefits with currently available
information. However, this insurance benefit may exist for some
growers, particularly those in the Southern U.S. Given currently
available information, BEAD projects that any such benefits are not
likely to be large or widespread, given the negligible historical
pesticide usage targeting these pests in soybeans . . . .''
5. Seed treatments minimize the management and labor investment
required for scouting and foliar spraying.
It does not appear that EPA has considered the time and labor
savings afforded producers by use of seed treatments. EPA assumes that
all producers are already applying foliar sprays and so the addition of
active ingredients to address the same pest spectrum does not come at
any cost other than the actual ingredients. However, not all soybean
producers apply foliar sprays and those that do may not be applying
them at the same time as covered by the seed treatment window of pest
control.\4\
---------------------------------------------------------------------------
\4\ See discussion at https://www.pioneer.com/home/site/us/
template.CONTENT/agronomy/crop-management/high-yield-management/
soybean-aphids/guid.069BE58A-CCEA-CE6C-A77D-3E5B02A320EB and http://
www.farmdoc.illinois.edu/manage/newsletters/fefo04_04/fefo04_04.pdf.
---------------------------------------------------------------------------
6. EPA's use of limited data to support their analysis is unfortunate,
when they were aware that several other studies on this topic
would be released at roughly the same time. Those additional
data could have been used to augment the limited data cited by
EPA in their report.
EPA's use of unpublished and sparse data to make overly broad
conclusions about the efficacy and economic value of neonicotinoid seed
treatments does not comport with OMB's Information Quality Guidelines
or EPA's Guidelines for Ensuring and Maximizing the Quality,
Objectivity, Utility, and Integrity of Information Disseminated by the
Environmental Protection Agency. As an example, EPA states ``when asked
when growers should use neonicotinoid seed treatments, 11 of 20
respondents indicated that they should be used under specific
conditions--for example, when planting soybean in an area experiencing
high infestation rates, or in double cropping scenarios or when
planting early season soybeans.'' Compare that to the AgInformatics
Value Report that shows soybean farmers select insecticidal treatments
(seed versus foliar) based on cost, consistency of yield and duration
of protective effects. The AgInformatics Value Report included 622
soybean farmers from 14 states.
7. EPA's Table 4 should show sensitivity analysis as is standard
practice for cost-benefit analysis.
EPA derives their conclusion that neonicotinoid seed treatments do
not provide any significant benefits from their calculations in Table
4. EPA describes that table as providing conservative results. USDA
would disagree. EPA has not considered many things that would affect
those calculations. Indeed, it seems that EPA agrees and acknowledges
many of those limitations,
EPA acknowledges that there may be risk management benefits
to using neonicotinoid seed treatments, but that they lack
information to quantify those benefits.
EPA acknowledges that neonicotinoid seed treatments may be
more or less valuable to soybean producers in conjunction with
other crop management technologies, such as IPM or crop residue
management. EPA has not included any of those cross effects in
their analysis.
EPA acknowledges that the use of neonicotinoid seed
treatment may help soybean producers manage pesticide
resistance. The efficacy of alternatives to neonicotinoid seed
treatments are not adjusted for such resistance issues.
EPA also acknowledges that other costs of soybean production
are not accounted for in this analysis may influence the extent
that uncertainty in EPA's analysis would affect the
conclusions. For example, foliar applications of pesticides
often require landowners to apply for pesticide application
permits and to undertake more burdensome pesticide applications
precautions. Such additional regulatory costs are costly to
producers and have not been included in this analysis.
Those limitations further calls into question the overly broad
conclusions EPA has published. By considering some reasonable
alternatives to EPA's limited comparison, USDA notes that seed
treatments could be very beneficial to producers under certain
conditions that are unknown to a producer at planting time (see table
below).
----------------------------------------------------------------------------------------------------------------
EPA Assumptions Sensitivity Analysis
Revenue and Cost Units ----------------------------------------------------------------------
Seed Treatment Alt. 1 Alt. 2 Alt. 3 Alt. 4
----------------------------------------------------------------------------------------------------------------
Yield (bu/ac) 45 45 45 45 38
Other pests (bu/ac) ^1 ^1
Price ($/bu) $12.03 $12.03 $12.03 $12.03 $9.59
Gross revenue ($/ac) $536 $536 $536 $529 $355
Insecticide costs ($/ac)
Seed treatment ($/ac) $8
Foliar spray ($/ac) $14 $14 $14 $14
Labor & Mgmt ($/ac) $0 $7 $7 $7
Other variable costs ($/ac) $173 $173 $173 $173 $173
Total variable costs ($/ac) $180 $186 $194 $194 $194
Net operating revenue ($/ac) $356 $350 $343 $336 $161
----------------------------------------------------------------------------------------------------------------
Percent difference (%) 1.69% 3.79% 4.05% 41.76%
----------------------------------------------------------------------------------------------------------------
Alternative 1: EPA assumptions: yield protection of foliar
sprays is equal to seed treatment; no additional costs of
pesticide treatments for labor and management or scouting.
Assumes flubendiamide is the active ingredient in foliar spray.
Requires 2 gallons of water per acre for aerial application and
10 gallons per acre for ground application. A recent California
study of various emusifiable concentrations estimated the per
acre cost of aerially applying flubendiamide at 2.0 fl. oz at
$22.10 per acre. Flubendiamide is used in soybeans at 2-3 fl.
oz per acre.
Alternative 2: Includes a cost of applying foliar pesticides
range from $6 to $25 based on prices quoted in Soybean
Business, a magazine for Minnesota growers. See also Johnson,
K.D., et al. (2009) ``Probability of Cost-Effective Management
of Soybean Aphid (Hemiptera: Aphididae) in North America,''
Journal of Economic Entomology 102(6): 2101-2108.
Alternative 3: Considers the case that foliar sprays do not
control for potential soil pests or that the optimal time to
apply pesticides are not available due to field or
environmental conditions. As such, the yield benefits afforded
by foliar sprays are assumed to be 1 bu/ac less than those
provided by seed treatments.
Alternative 4: Same as alternative 3, but in a region where
the yields are lower than the national average (e.g.,
Mississippi soybean yield in 2009 was 38 bu/ac and the national
yield was 44 bu/ac) in a year with low prices (e.g., average
price received by farmers in 2009 for soybeans was $9.59 per
bu).
[all]