RE: Asian Longhorn Beetle Eradication Effort
I’m sending this
email out to individuals and organizations who might
have interest in the fall application of imidacloprid
by APHIS in Worcester County.
Today’s Boston Globe
article on the subject can be found here:
My wife and I are
beekeepers in Worcester County. Our colonies
are outside of the current treatment zone, but not far away. I wouldn’t be surprised if the zone extended
to some of our hives either in New Braintree or in Leominster.
I should also add
the disclaimer that I am not a beekeeper who believes that imidacloprid
is the cause of recent well publicized honeybee die offs. Imidacloprid does
kill bees in isolated incidents, some of these are well documented, and there
is no question that it is extremely toxic to bees if they encounter it. The issue with the ALB treatment is unique.
My wife and I
attended the initial public meeting in Worcester when the ALB was first
spotted. I participated in the forum,
and made important contacts at APHIS, notably, Bob Baca, whose job is
environmental compliance.
I made the first
suggestions, and did extensive follow up to have APHIS fund a monitoring
program for bees in and outside of the treated area. I put Bob Baca in touch with Ken Warchol, our county bee inspector who is working with Jeff
Pettis (of the USDA Beltsville Bee lab), a graduate student, and our state
apiarist, Al Carl, on this study (I believe they have setup 25 hives within the
treatment zone, and 25 outside). I maintain that if APHIS does what they plan
to do, that this study is imperative.
I don’t believe that
the Environmental Assessment done by APHIS is sufficient to justify any
treatments, because, as part of the assessment, they must determine if the bees
will encounter enough imidacloprid to cause
harm. The problem is, no one has data showing how much imidacloprid will end up in the pollen, nectar, and/or
plant resins (that bees collect for making propolis)
of the early blooming maple trees.
Certainly not with the dosages used, and not over a 3 year period (which
is the minimum treatment time being proposed by AHPIS).
Maple trees are an important
early source of pollen for bees in our area, usually in February, when they
need the protein to build up the colony, and there is little else
available. APHIS has no data to show what the levels of imidacloprid
will be in the maple pollen when they do the multi-year treatments at the level
they are proposing. Without this data,
any assessment from APHIS as to the impact on honeybees is impossible.
The current issue
before us is fall treatments scheduled to begin tomorrow, September 17, 2009.
I’ve tried to make
the case to APHIS that fall treatments violate the label requirements for imidacloprid. The
response from APHIS includes:
"The
imidacloprid treatments will continue to be conducted
in accordance with the label, which allows treatments to occur any time of the
year so long as bees are not visiting flowers while treatments are being
conducted."
Please read the
above, and consider the following.
1. Imidacloprid is a
systemic insecticide. It is designed to
spread to every part of the plant, and it does.
This includes the pollen and nectar.
2. The requirement that treatments not be
conducted while bees are visiting flowers is to protect bees from being
poisoned by this product. The
manufacturer feels that the product is toxic enough to require this in
application.
3. The timeline for fall treatment is that first
the trees are treated. The imidacloprid spreads to all tissue of the tree. The tree flowers in February. Bees forage and collect pollen and nectar
contaminated by imidacloprid (the levels are
unknown). Only after this, do the
beetles start to emerge, and either get poisoned while chewing their way out of
the tree, or when they try to chew their way in to lay eggs. This
is a violation of the intent of the requirements. One cannot claim that the time period between
when the pesticide is applied and when it is designed to be effective on the
target insect (ALB) is not “the time period the treatment is being conducted”. These treatments are illegal, probably deadly
to honeybees. To claim that the
requirement only requires that bees not be visiting flowers would allow
nighttime treatments, or treatments in the rain on any flower at any time. This interpretation is clearly not what Bayer
intended when drafting this requirement.
4. Tree or soil injections of imidacloprid are not applications of topical pesticides
that quickly break down. Imidacloprid is being used in the fall because it will keep the tree toxic through spring, past the time
bees will be foraging.
I also would like to
say that communication with APHIS (and Bob Baca specifically) has been easy and
productive. I greatly object to what
they are planning to do, and the justifications they use to do so, but nothing
seems to have been secretive or done behind anyone’s back. I couldn’t be more impressed in this regard.
I believe the fall
application to be illegal, and contrary to the label requirements. If you believe the same, please email the
following people at APHIS, as these are the folks I’ve been corresponding with.
Robert.M.Baca@aphis.usda.gov
Julie.S.Twardowski@aphis.usda.gov
Susan.J.O'Toole@aphis.usda.gov
Dean Stiglitz
BeeUntoOthers.com
dean@BeeUntoOthers.com