### National Honey Bee Advisory Board 

### American Beekeeping Federation American Honey Producers Association

Beyond Pesticides Pesticide ActIon Network North America Center for Biological Diversity

December 8, 2010



### The Honorable lisa P. Jackson 

### Administrator U.s. Environmental Protecton Agency 

### ArIel Rios Building, MC 110lA 1200 Pennsylvania Avenue NW 

### Washington DC 200

Dear Administrator Jackson: In light of new revelations by your agency in a November 2, 2010 memorandum that a core registration study for the insecticide clothianìdin has been downgraded to

unacceptable for purpses of registration, we are writing to request that you take 

### urgent action to stop the use of this toxic chemicaL. Clothianidin is a widely used pesticide linked to

a

### severe and dangerous decline in pollnator populations. As we are sure you appreciate, the failure of the agency to provide adequate protection for pollinators under ìts pesticide registration program creates an emergency with imminent hazards: Food production, public health and the environment are all seriously threatened, and the collapse of the commerCÎal honeybee-keeping industry would result In economic harm of the highest magnitude for U.S. agriculture. 

### The debate on clothlanidin and the neonlcotlnoid pesticides is not new to the agency, but the recognition of the past failure of the Office of Pesticide Program's (OPP) 

### 2007 scientific review, now acknowledged, requires immediate action to stop use whHe new studies are conducted. We refer you to the memorandum entitled "Clothianidin Registration of Prosper T400 Seed Treatment on Mustard Seed and PonchoNotivo Seed 

### Treatment on Cotton," November i, 2010 (see pp. 2, 4), The science that the agency has, and the independent lierature find that clothianidin-contaminated pollen and nectar 

### presents an imminent haiard. Because the hazards to honeybee health are present within 

### registered use parameters, it is dear that label chnges alone will not offer adequate protection. The issue is not one of application error, in other words. We therefore urge the 

### agency to issue a stop use order immediately. Our nation cannot afford, and the

environment cannot tolerate another growing 

### season of dothianindin use.The Honorable Usa Jackson

PAGE TWO 

### December 8, 2010 

### In additIon, because this problem reflec an overuse of the conditional registration program in OPP, we urge you to set an Immediate moratorium on the use of such 

### registrations unti the program is fully evaluated for compliance with its underlying statutory responsibilties.. The conditonal registration of cJothlanidin in 2003 with 

### outstanding data critical to its safety assessment represents a failure that could and should 

### have been avoided. Clearly, the impacts on pollnators were not adequately evaluated prior

to the issuance of the conditional registration, despite knowledge of ffchronic toxic risk to hone bee larvae and the eventual instabilty of the hive." This Is the case wJth poUinator 

### protecion and a host of other issues that have direct bearing on environmental protection and pubUchealth.

In redoing the dothianidinstudy and evaluating the causes of Colony Collapse 

### Disorder and the larger issue of the pollnator decline crisis, we urge you to establish protocol that fully assesses the compleidtiesthat come together to threaten the honeybees. To be futly protective of bees, reviews must consider multiple chemical and cumulative expsures, persistence. and sYnergistic effects. We can no longer rely on studies of 

### indivdual chemicals in isolatIon. Thank you for your attention to the pollnator crisis and efforts to stem the tide of contamination and poîsoning. We look forward to your reply. 

### Sincerelyi



### National Ho.neyBee Advisry Board Steve Ells. 

### Secretary 

### American Beekeeping Federation David Mendes 

### President American Honey Producers Association Kenneth Haft 

### President Beyond Pesticides
Jay 

### feldman Executive Director 

### Pesticide Action Network North America Heather PilatIc 

### Co-Directr Center for Biological Diversity 

### Justin Augustin Staff Attorney

cc Steve Owens, Assistant Administrator, Office of Chemical Safety and Pollution Prevention

### Steven Bradbury; Director, Office of Pesticide ProgramsMessage Information

Dat 1210812010 09:49 AM From Jay Feldman -ejfeklman@beyondpeticides.org;: To UsaP Jackson/DC/USEPNUS@EPA 

### cc Subject Request Letter 

### Mesge Body
Full text of request letterfrcrn National Honey Bee Advisory Board, k'lerican Beekeeping Federation, American Haney Producers Association, Beyond Pesticides, Pesticide Action Network North America, and Center for Biological Diversity is attached. Dear Administrator Jackson: In light of new revelations by your agency in a No\rêmber 2, 2010 memorandum that a core registration study for the insecticide clothianidin has been downgraded to unacceptable for purposes of registration, we are writing to request that you take urgent action to stop the use of this toxic chemical. 

## Clothianidin is a widely used pesticide linked to a severe and dagerous decline in pollinator populations. As we are sure you appre.ciate. the failure of the agency to provide adequate protection for pollinators under ita pesticide registrat:ion program creates an emergency with imminent hazards: Food productioni public health and the environment are all seriously threatened, and the collapse of the commercial honeybee-keeping industry would result in economic harm of the highest magnitude for U. S. 

## agriculture. 8est regards. Jay Feld'ln

EPA!1200 o 

### pd Jay Feldman I 

### .:mail to: j feldman@beyondpesticides. org::j feldman@beyondpesticides . org Executive Director Beyond Pesticides 701 B Street SE Washington DC 20003 

## .:http://ww .beyondpesticides. org/~http://ww .beyondpesticides. org (202.) 543-5450 , fax (202) 543-4791

OEX Procìng Information Proced DatEr 

### proc By PO 0fMesag6 Count