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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 

( 

Printed for the use of the Committee on Agriculture 

agriculture.house.gov 

COMMITTEE ON AGRICULTURE 

K. MICHAEL CONAWAY, Texas, Chairman 

RANDY NEUGEBAUER, Texas, 

Vice Chairman 

BOB GOODLATTE, Virginia 

FRANK D. LUCAS, Oklahoma 

STEVE KING, Iowa 

MIKE ROGERS, Alabama 

GLENN THOMPSON, Pennsylvania 

BOB GIBBS, Ohio 

AUSTIN SCOTT, Georgia 

ERIC A. ‘‘RICK’’ CRAWFORD, Arkansas 

SCOTT DESJARLAIS, Tennessee 

CHRISTOPHER P. GIBSON, New York 

VICKY HARTZLER, Missouri 

DAN BENISHEK, Michigan 

JEFF DENHAM, California 

DOUG LAMALFA, California 

RODNEY DAVIS, Illinois 

TED S. YOHO, Florida 

JACKIE WALORSKI, Indiana 

RICK W. ALLEN, Georgia 

MIKE BOST, Illinois 

DAVID ROUZER, North Carolina 

RALPH LEE ABRAHAM, Louisiana 

TOM EMMER, Minnesota 

JOHN R. MOOLENAAR, Michigan 

DAN NEWHOUSE, Washington 

COLLIN C. PETERSON, Minnesota, Ranking 

Minority Member 

DAVID SCOTT, Georgia 

JIM COSTA, California 

TIMOTHY J. WALZ, Minnesota 

MARCIA L. FUDGE, Ohio 

JAMES P. MCGOVERN, Massachusetts 

SUZAN K. DELBENE, Washington 

FILEMON VELA, Texas 

MICHELLE LUJAN GRISHAM, New Mexico 

ANN M. KUSTER, New Hampshire 

RICHARD M. NOLAN, Minnesota 

CHERI BUSTOS, Illinois 

SEAN PATRICK MALONEY, New York 

ANN KIRKPATRICK, Arizona 

PETE AGUILAR, California 

STACEY E. PLASKETT, Virgin Islands 

ALMA S. ADAMS, North Carolina 

GWEN GRAHAM, Florida 

BRAD ASHFORD, Nebraska 

SCOTT C. GRAVES, Staff Director 

ROBERT L. LAREW, Minority Staff Director 

SUBCOMMITTEE ON BIOTECHNOLOGY, HORTICULTURE, AND RESEARCH

RODNEY DAVIS, Illinois, Chairman 

GLENN THOMPSON, Pennsylvania 

AUSTIN SCOTT, Georgia 

CHRISTOPHER P. GIBSON, New York 

JEFF DENHAM, California 

TED S. YOHO, Florida 

JOHN R. MOOLENAAR, Michigan 

DAN NEWHOUSE, Washington 

SUZAN K. DELBENE, Washington, Ranking 

Minority Member 

MARCIA L. FUDGE, Ohio 

JAMES P. MCGOVERN, Massachusetts 

ANN M. KUSTER, New Hampshire 

GWEN GRAHAM, Florida 

(II) 

(III) 

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 

(1) 

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 

2 

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. 

3 

[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. 

4 

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 

5 

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 

6 

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 

7 

1http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1191. 2http://www.ers.usda.gov/publications/sssm-sugar-and-sweeteners-outlook/sssm-314.aspx. 3http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1191. 4http://www.ers.usda.gov/media/1679173/special-article-september_-pollinator-service-market-4-.pdf. 5Lee, et al. (2015) ‘‘A national survey of managed honey bee 2013–2014 annual colony losses 

in the USA,’’ Apidologie 46(3), pp. 292–305. 

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

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

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 

8 

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. 

9 

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 marketbased 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 

10 

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 

11 

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 pesVerDate Mar 15 2010 10:11 Jun 30, 2015 Jkt 041481 PO 00000 Frm 00015 Fmt 6633 Sfmt 6621 P:\DOCS\114-14\94750.TXT BRIAN
12 

ticides 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 reevaluation. 

13 

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. 

14 

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.] 

15 

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 assessVerDate Mar 15 2010 10:11 Jun 30, 2015 Jkt 041481 PO 00000 Frm 00019 Fmt 6633 Sfmt 6601 P:\DOCS\114-14\94750.TXT BRIAN
16 

ment. 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 valueadded 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. 

17 

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. 

18 

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 straVerDate Mar 15 2010 10:11 Jun 30, 2015 Jkt 041481 PO 00000 Frm 00022 Fmt 6633 Sfmt 6601 P:\DOCS\114-14\94750.TXT BRIAN
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tegic 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 sciencebased 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 

20 

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 hapVerDate Mar 15 2010 10:11 Jun 30, 2015 Jkt 041481 PO 00000 Frm 00024 Fmt 6633 Sfmt 6601 P:\DOCS\114-14\94750.TXT BRIAN
21 

pened, 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 landgrant 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 

22 

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? 

23 

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 peerreview 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. 

24 

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. 

25 

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 PolliVerDate Mar 15 2010 10:11 Jun 30, 2015 Jkt 041481 PO 00000 Frm 00029 Fmt 6633 Sfmt 6601 P:\DOCS\114-14\94750.TXT BRIAN
26 

nator 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 

27 

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. 

28 

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 

29 

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:] 

31 

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, 

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 soyVerDate Mar 15 2010 10:11 Jun 30, 2015 Jkt 041481 PO 00000 Frm 00035 Fmt 6621 Sfmt 6621 P:\DOCS\114-14\94750.TXT BRIAN

11414001.eps
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1See discussion at http://www.ers.usda.gov/data-products/adoption-of-genetically-engineeredcrops-in-the-us/recent-trends-in-ge-adoption.aspx. 2See http://www.mississippi-crops.com/2014/10/31/do-neonicotinoid-seed-treatments-havevalue-regionally-in-soybeans/. 

beans 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

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 afVerDate Mar 15 2010 10:11 Jun 30, 2015 Jkt 041481 PO 00000 Frm 00036 Fmt 6621 Sfmt 6621 P:\DOCS\114-14\94750.TXT BRIAN
33 

3See recent studies on this topic published by AgInformatics (http://growingmatters.org/studies/). 

forded 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

34 

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 . . .’’ 

35 

4See discussion at https://www.pioneer.com/home/site/us/template.CONTENT/agronomy/ 

crop-management/high-yield-management/soybean-aphids/guid.069BE58A-CCEA-CE6C-A77D3E5B02A320EB and http://www.farmdoc.illinois.edu/manage/newsletters/fefo04_04/ 

fefo04_04.pdf. 

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

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. 

36 

7. EPA’s Table 4 should show sensitivity analysis as is standard practice for costbenefit 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). 

Revenue and Cost Units 

EPA 

Assumptions 

Sensitivity Analysis

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. 

37 

• 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). 

Æ