July 22, 2014
Ann Prichard, Pesticide Registration Branch Chief
Department of Pesticide Regulation
State of California
Dear Ms. Prichard,
I am writing to you as a concerned citizen of California about neonicotinoid
pesticides. I earned a BA in biology from UC Riverside and an MA in biology
from CSU Fresno in the 1960-s and -70’s. I was a biological research tech
for about fifteen years, then I switched gears and graduated from University
of Oregon with a second bachelor’s degree in landscape architecture. I have
been a CA registered landscape architect since 1989 in private practice.
I am writing to ask you to take action to terminate the studies that have
been dragging on for five years about California’s use of neonicotinoid
pesticides and their impact on honeybees. Please require very speedy
publication of its findings. If the study is unbiased and comprehensive, I
expect the Department of Pesticide Regulation to conclude that these
pesticides should be restricted greatly or outright banned. The following
explains why I think that should be the outcome.
I have been following the honeybee colony collapse syndrome issue since it
surfaced around 2007. Most recently, studies published in 2014 have now
found conclusive correlations between bird population declines where
neonicotinoid pesticides have built up in watersheds. The relationship is
caused by the pesticides having persisted long enough to kill many species
of insects. The destruction of insects harms all species of birds (even
fruit and seed-eating birds) because terrestrial bird nestlings require the
protein found in insects (or other sources) to reach maturity.
I know that other factors are involved in honeybee colony mortality: poor
feeding of hives over winter, as well as starvation in the very agricultural
fields where they are brought to pollinate crops, when there are too many
bees for the crop to feed, and there are no supplemental flowering plants in
fallow land thatthey could feed on, due to excessive use of glyphosate and
other herbicides. I know about a couple of diseases that are almost epidemic
in some areas, and parasites, especially the Varroa mite.
Neonicotinoid manufacturers misdirect our attention to Australia where the
Varroa mite is not found, where neonicotinoids are in use, and where colony
collapse disorder has not been found. However, I have not seen this as a
serious scientific paper. I wonder, are Australian bees treated the same as
US bees (transported long distances to pollinate thousands of acres of a
single species of plant, with no other sources of nectar or pollen, for
instance)? Are hedgerows or wildlands left for supplemental pollen sources
to carry hives over when crops aren’t flowering sufficiently? Have
neonicotinoids been used as long there as in Europe and the US with the
subsequent buildup in the environment? Are Australian crops also treated
with glyphosate as extensively as American crops? Is it possible that some
plants in Australia give honeybees more resistance to stress and they can
recover from nerve damage caused by neonics? What is the level of homeowner
use of neonics? In short, is Australia’s apiculture and neonicotinoid
exposure really comparable to the US and Europe to the extent that the
Varroa mite is truly the only factor in their better survival?
Leaving those questions aside, I think evidence is available to conclude
that neonicotinoids are a key factor in bee declines in the US, and in
California in particular.
1. Research has proven that neonicotinoid pesticides are killing large
numbers of many other species of insects including bumblebees, insects that
are NOT infested by Varroa mites.
2. Studies found that colonies of honeybees that had Varroa mite infestation
had much greater mortality if the bees also tested positive for
neonicotinoid exposure, far below the agency threshold listed for acute
3. Please also consider this. I may not remember this correctly, but if I
did, it is significant. In 2007 when I initially started to study this, I
read the 1980’s era lab studies conducted for Bayer’s product (the original
neonicotinoid) on bee mortality. Every research cycle for acute exposure,
they reduced the exposure level to test, and at each lower level, bees died,
not 50% for the LD50, but enough to count. These were lab studies, not where
bees are working as part of a hive with all those stresses. I recall that
the studies did not reach a point where mortality didn’t occur. Researchers
never found a level at which bees were not harmed. They just stopped
studying it, and the product was approved and in use by around 1990.
I recommended Bayer’s product imidacloprid in the 1990’s when the lerp
psyllid was swarming and harming Syzygium (= Eugenia) hedges in San Diego. I
recommended it in part because the label said it was not harmful to bees,
vs. Sevin and some other potent insecticides that were known bee killers.
Now I am sad and angry because I am pretty damn sure that I was responsible
for killing a lot of bees, and wild birds, as well as other insects that are
critical to the functioning of the entire California natural ecosystem, and
for pollinating our crops.
I strongly urge you to complete the long delayed study of neonicotinoids
being conducted by your Department. In the process I hope the Department
will conclude it is time to severely reduce their use, so by reducing their
harm, honeybees and other insect pollinators stand a better chance of
surviving and performing all their ecosystem services, while we devise a way
to protect them from Varroa mites.
The corporations that sell these pesticides have made a lot of money, so
they will undoubtedly protest, using all their wealth as a weapon against
this. Farmers whose crops have been protected by use of neonicotinoids may
have lower yields, and that may translate into higher prices, so consumers
may be affected. Big tobacco corporations which have provided the feedstock
for neonicotinoids will lose money. But just as people finally reduced
tobacco consumption in cigarettes because tobacco was killing people, we
need to stop killing Earth’s other creatures – and hurting ourselves in the
process – even if we have to pay some more to make it happen.
Maybe there is a silver lining: abandoned tobacco cropland could make great
restoration sites for the wide variety of plants that would help restore
insects and birds.
I hope for a reply from your office.
This is a wonderful effort on Kay’s part and you, too, can write something similar, using the information above. Her business email address, if you want the full text from her or wish to comment or ask questions is email@example.com