Draft Biological Evaluation for Neonicotinoids (PFB)

October 25, 2021

Environmental Protection Agency
1200 Pennsylvania Avenue N.W.
Washington, D.C. 20460

RE: Docket ID Number EPA-HQ-OPP-2021-0575, National Level Threatened and Endangered Species Biological Evaluations for Clothianidin, Imidacloprid and Thiamethoxam

Dear Administrator Regan:

On behalf of Pennsylvania Farm Bureau (PFB), the state’s largest general farm organization, I am writing to submit comments related to Docket ID Number EPA-HQ-OPP-2021-0575, National Level Threatened and Endangered Species Biological Evaluations for Clothianidin, Imidacloprid and Thiamethoxam. These neonicotinoids are important for agricultural production,

Pennsylvania Farm Bureau supports the comments submitted by the American Farm Bureau Federation (AFBF) dated October 25, 2021 and ask that this support be noted as part of the comment record.

Just like AFBF, PFB has members who use neonicotinoid pesticides in their farming operations, including operations growing horticultural and ornamental plants, as well as row crops. Additionally, growers often use neonicotinoids as part of integrated pest management (IPM) programs. This class of pesticides offers farmers selective control over pests to maintain beneficial insects, while keeping potential pest away. Without neonicotinoids, farmers would need to use old chemistries that do not offer the same selective benefits, impacting yields, application amounts, and the progress made using existing IPM and resistance management programs. Additionally, use of neonicotinoid-treated seed has reduced non-target exposure and environmental runoff.

Due to the clear importance of neonicotinoids for a wide variety of farm operations, any measures that seek to restrict the use of neonicotinoids would adversely impact farmers, their farm operations, and the environment as well. As EPA continues to explore potential mitigations and limitations on uses of neonicotinoids, it is important than any alternative products suggested have equal or better efficacy than existing products, and be fully available for producers. For example, the EPA-suggested alternatives like pyrethroids and organophosphates are also under review and may be subjected to new limitations on their uses.

It is also important that EPA utilize the most accurate data available for draft biological evaluations, including for Clothianidin, Imidacloprid and Thiamethoxam. Like AFBF, we are concerned that the methodology used to conduct the biological evaluation for these neonicotinoids might lead to limitations on registered uses and compromise the viability of these products.

We appreciate the opportunity to provide comment on this docket. We ask as EPA continues to review the impact of neonicotinoids on species and habitats, that the Agency consider the benefits of neonicotinoids and how they enable farmers to produce more food, fuel and fiber, while also taking good care of the land. The Agency should also ensure that they utilize data and usage patterns reflective of actual product use instead of assumed product use. Finally, we urge EPA to ensure any potential mitigations or limits on these products as a result of this biological evaluation comes from the best available science and data.

Thank you for your consideration. I’m happy to answer any questions you may have.

Rick Ebert