Bee Health: USDA and EPA Should Take Additional Actions to Address Threats to Bee Populations
Published: 2016-02-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Honey bees and other managed and wild, native bees provide valuable pollination services to agriculture worth billions of dollars to farmers. Government and university researchers have documented declines in some populations of bee species, with an average of about 29 percent of honey bee colonies dying each winter since 2006. A June 2014 presidential memorandum on pollinators established the White House Pollinator Health Task Force, comprising more than a dozen federal agencies, including USDA and EPA.
GAO was asked to review efforts to protect bee health. This report examines (1) selected USDA agencies' bee-related monitoring, research and outreach, as well as conservation efforts, and (2) EPA's efforts to protect bees through its regulation of pesticides. GAO reviewed the White House Task Force's national strategy and research action plan, analyzed data on USDA research funding for fiscal years 2008 through 2015, reviewed EPA's guidance for assessing pesticides' risks to bees, and interviewed agency officials and stakeholders from various groups including beekeepers and pesticide manufacturing companies.
section_title: What GAO Found
paragraphs: The U.S. Department of Agriculture (USDA) conducts monitoring, research and outreach, and conservation that help protect bees, but limitations in those efforts hamper the department's ability to protect bee health. For example, USDA has increased monitoring of honey bee colonies managed by beekeepers to better estimate losses nationwide but does not have a mechanism in place to coordinate the monitoring of wild, native bees that the White House Pollinator Health Task Force's May 2015 strategy directs USDA and other federal agencies to conduct. Wild, native bees, which also pollinate crops, are not managed by beekeepers and are not as well studied. USDA officials said they had not coordinated with other agencies to develop a plan for monitoring wild, native bees because they were focused on other priorities. Previous GAO work has identified key practices that can enhance collaboration among agencies, such as clearly defining roles and responsibilities. By developing a mechanism, such as a monitoring plan for wild, native bees that establishes agencies' roles and responsibilities, there is better assurance that federal efforts to monitor bee populations will be coordinated and effective. Senior USDA officials agreed that increased collaboration would improve federal monitoring efforts.
USDA also conducts and funds research and outreach on the health of different categories of bee species, including honey bees and, to a lesser extent, other managed bees and wild, native bees. Consistent with the task force strategy and the 2008 Farm Bill, USDA has increased its conservation efforts on private lands to restore and enhance habitat for bees but has conducted limited evaluations of the effectiveness of those efforts. For example, a USDA-contracted 2014 evaluation found that agency staff needed additional expertise on how to implement effective habitat conservation practices, but USDA has not defined those needs through additional evaluation. By evaluating gaps in expertise, USDA could better ensure the effectiveness of its efforts to restore and enhance bee habitat plantings across the nation. USDA officials said that increased evaluation would be helpful in identifying where gaps in expertise occur.
The Environmental Protection Agency (EPA) has taken steps to protect honey bees and other bees from risks posed by pesticides, including revising the label requirements for certain pesticides, encouraging beekeepers and others to report bee deaths potentially associated with pesticides, and urging state and tribal governments to voluntarily develop plans to work with farmers and beekeepers to protect bees. EPA also issued guidance in 2014 that expanded the agency's approach to assessing the risk that new and existing pesticides pose to bees. The task force strategy also calls for EPA to develop tools to assess the risks posed by mixtures of pesticide products. EPA officials agreed that such mixtures may pose risks to bees but said that EPA does not have data on commonly used mixtures and does not know how it would identify them. According to stakeholders GAO interviewed, sources for data on commonly used or recommended mixtures are available and could be collected from farmers, pesticide manufacturers, and others. By identifying the pesticide mixtures that farmers most commonly use on crops, EPA would have greater assurance that it could assess those mixtures to determine whether they pose greater risks than the sum of the risks posed by individual pesticides.
section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that USDA coordinate with other agencies to develop a plan to monitor wild, native bees, and evaluate gaps in staff expertise in conservation practices, and that EPA identify the most common mixtures of pesticides used on crops. USDA and EPA generally agreed with the recommendations.

section_title: Letter
paragraphs: Bees play a vital role in agriculture by pollinating crops that are worth  billions of dollars to farmers, while also providing environmental value to  other landowners and natural ecosystems by pollinating flowering plants.  The health of bee populations, therefore, is important to the nation’s well- being. In recent years, beekeepers, farmers, scientists, and others have  been increasingly concerned about the health of European honey bees  that are commercially managed for honey production and pollination  services; other managed bees; and wild, native bees. Annual surveys of  U.S. beekeepers since 2006 indicate that, on average, about 29 percent  of honey bee colonies have been dying over the winter. Government and  academic researchers have documented long-term declines for some  populations of other bee species, including bumble bees, but little is  known about trends for populations of the estimated 4,000 or more  species of wild, native bees in the United States.
A June 2014 presidential memorandum on pollinators established the  White House Pollinator Health Task Force, comprised of more than a  dozen federal agencies and co-chaired by the Secretary of Agriculture  and the Administrator of the Environmental Protection Agency (EPA). In  response to direction in the memorandum, the task force issued a May  2015 national strategy for protecting bees and other pollinators from a  range of possible threats, including pests and pathogens, reduced  habitat, lack of nutritional resources, and exposure to pesticides. The  task force’s strategy contains three overarching goals, two of which relate  to bees: (1) reducing honey bee colony losses during winter to no more  than 15 percent within 10 years; (2) increasing the Eastern population of  the monarch butterfly to 225 million butterflies occupying an area of  approximately 15 acres in the overwintering grounds in Mexico, through  domestic and international actions and public-private partnerships, by  2020; and (3) restoring or enhancing 7 million acres of land for pollinators  over the next 5 years through federal actions and public-private  partnerships. The White House Task Force also issued the Pollinator  Research Action Plan in May 2015, which it described as a road map for  federally-supported pollinator health research, contingent upon available  funding.
The U.S. Department of Agriculture (USDA) and EPA have several  programs that contribute to protecting bee health. USDA’s National  Agricultural Statistics Service (NASS) surveys beekeepers to document  the number of active managed colonies of honey bees and honey  production levels. USDA’s programs for research and outreach are  primarily conducted or funded by its two largest research agencies, the  Agricultural Research Service (ARS) and the National Institute of Food  and Agriculture (NIFA). USDA’s Farm Service Agency (FSA) and Natural  Resources Conservation Service (NRCS), which oversee conservation  programs for private lands, provide financial and technical support to  landowners to encourage habitat conservation, including conservation  intended to provide bees and other pollinators with forage and nesting  areas. EPA plays a role in protecting bees as part of its regulation of  pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act  (FIFRA). EPA makes regulatory decisions that affect pesticides used by  farmers and other landowners, as well as pesticides used by beekeepers  to combat pests that infest bee hives. In particular, EPA determines  whether pesticides may cause unreasonable adverse effects to the  environment, including bees and other organisms, when used in  accordance with widespread and commonly recognized practice.
In this context, you asked us to review specific USDA and EPA efforts to  protect bee health. Our objectives were to evaluate (1) the bee-related  monitoring, research and outreach, and conservation efforts of selected  USDA agencies; and (2) EPA’s efforts to protect bees through its  regulation of pesticides.
To examine USDA’s monitoring, research and outreach, and conservation  efforts with respect to bees, we selected five USDA agencies: NASS,  ARS, NIFA, NRCS, and FSA, because they have been most involved in  addressing bee health issues. We reviewed the methodology of the NIFA- funded Bee Informed Partnership’s national survey of commercial  beekeepers on their honey bee colony losses, to assess the reliability of  the survey and determined that, while the data are not generalizable to  the nation, they illustrate the experiences of the respondents with respect  to colony losses. We analyzed the methodology that NASS used in a  2015 survey of beekeepers about honey bee colony losses and the  efforts within USDA to monitor wild, native bees. We also reviewed our  prior body of work on interagency collaboration, as agencies within USDA  carry out work related to bee monitoring in conjunction with other  agencies; from that work, we selected practices that were related to  challenges that we or agency officials identified and used the practices to  assess interagency collaboration at USDA concerning bee monitoring.
We analyzed funding data for ARS and NIFA from fiscal year 2008  through fiscal year 2015 and fiscal year 2008 through fiscal year 2014,  respectively, to document the agencies’ support for bee-related research  and outreach. We selected fiscal year 2008 as the starting point to reflect  2008 Farm Bill initiatives; data from fiscal years 2015 and 2014 were the  most recent data available for ARS and NIFA, respectively. We assessed  the reliability of ARS and NIFA funding data by comparing agency- provided data with data found in USDA’s Current Research Information  System (CRIS) and reviewing the agencies’ management controls and  determined that these data were sufficiently reliable for the purpose of  reporting on bee-related research projects. We reviewed how ARS and  NIFA categorize research data in USDA’s CRIS database and compared  the CRIS categories to those used in the task force strategy and research  action plan. We also reviewed an evaluation of NRCS’s technical  assistance efforts and examined the agency’s response to conclusions  about the level of bee habitat conservation expertise within the agency.  Further, we examined the data FSA and NRCS collect from their bee  habitat conservation efforts to determine the extent to which the data  could be used to evaluate the agencies’ progress in meeting the task  force strategy’s goal to restore and enhance pollinator habitat. To assess  the reliability of these data, we reviewed management controls over the  information systems that maintain the data and found them sufficiently  reliable for our reporting purposes. We interviewed USDA officials  regarding all of these activities.
To examine EPA’s efforts to protect bees, we gathered information on its  regulation of pesticides under FIFRA. Specifically, we reviewed the  agency’s 2011 interim and 2014 final guidance for assessing the risk that  pesticides posed to bees. We also reviewed a 2012 document  containing comments from EPA’s FIFRA Scientific Advisory Panel  regarding the agency’s risk assessment framework. We examined how  EPA has applied the new guidance to particular pesticides. We reviewed  data and interviewed agency officials about the status of EPA’s pesticide  registration and registration review programs. In particular, we gathered  information about pesticides that have been associated with bee kill  incidents, as indicated by EPA’s Ecological Incident Information System  (EIIS). To assess the reliability of the EIIS data, we discussed with EPA  officials the methods by which the agency collects and assesses the EIIS  data and determined that, while the data had limitations that are  discussed in the report, they were sufficiently reliable for the purpose of  identifying pesticides potentially associated with bee kills. We also  reviewed documents and interviewed agency officials regarding EPA’s  efforts to encourage states to develop voluntary managed pollinator  protection plans.
In addition, to address both objectives, we gathered stakeholders’ views  on what efforts, if any, USDA and EPA could make to protect bee  health. Specifically, we interviewed a nonprobability sample of  stakeholders from 35 of the following types of organizations, identified  through interviews with agency officials and other interested parties: farm  groups, including those generally representing conventional or organic  farming and commodity groups whose crops are largely pollinated by  managed bees, e.g., apple and almond growers; groups representing  commercial beekeepers; pesticide manufacturing companies; state  government; universities; and conservation and environmental  groups. USDA and EPA reviewed the stakeholder list and made  suggestions. We also obtained advice from a member of the National  Academy of Sciences with extensive experience on bee and pollinator  research about how to achieve a balanced list of stakeholders with varied  expertise and knowledge. We interviewed the stakeholders using a data  collection instrument and conducted a content analysis of the  stakeholders’ responses, whereby we organized their comments into  relevant categories. In particular, we asked stakeholders about their  familiarity with agency efforts to protect bee health, as well as their views  on any suggestions for efforts the agencies should make to further protect  bee health. Because we used a nonprobability sample of stakeholders,  their views cannot be generalized to all such stakeholder organizations  but can be illustrative. In addition, the views expressed by the  stakeholders do not represent the views of GAO. Further, we did not  assess the validity of the stakeholders’ views on what efforts USDA and  EPA should make to protect bee health. For more detail on our  objectives, scope, and methodology, see appendix I. We incorporated  relevant stakeholders’ views into our discussion of USDA and EPA efforts  to protect bees and present a more comprehensive summary of their  views in appendix II.
We conducted this performance audit from October 2014 to February  2016 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: This section provides information on the role and economic value of bees,  bee population trends, factors affecting bee health, effects of bee losses  on agriculture and ecosystems, and the roles and responsibilities that  USDA’s ARS, FSA, NASS, NIFA, and NRCS, and EPA have played with  respect to addressing bee health issues.
subsections: section_title: The Role and Economic Value of Bees
paragraphs: Pollinators—including honey bees, other managed bees, and wild, native  bees—are critical to our nation’s economy, food security, and  environmental health. Honey bees—nonnative insects introduced to the  United States in the 1620s by early settlers—are the most recognizable  pollinators of hundreds of ecologically and economically important crops  and plants in North America. In 2014, USDA reported that crops  pollinated by honey bees directly or indirectly account for up to one-third  of the U.S. diet. The most recent study on the value of pollinators to  U.S. food and agriculture was published in 2012 and estimated that, as of  2009, the total value of crops that were directly dependent on honey bee  pollination, including almonds, apples, and cherries, was almost $12  billion. The study estimated that, also as of 2009, the total value of  crops that were indirectly dependent on bees, such as hay, sugar beets,  asparagus, and broccoli, was more than $5 billion. In addition,  according to a 2015 USDA-NASS report, honey bees produced more  than $385 million worth of honey in 2014.
Approximately 1,500 to 2,500 commercial U.S. beekeepers manage  honey bee colonies, according to an estimate by the American  Beekeeping Federation. Many commercial beekeepers travel across the  country to provide pollination services for farmers’ crops and to support  honey production. According to the 2014 USDA report, in 2012, almonds,  sunflowers, canola seed, apples, cherries, and watermelons were among  the top crops that were sources of pollination service fee revenue for  beekeepers. About 1.6 million honey bee colonies—approximately 60 to  75 percent of all U.S. commercial honey bee colonies—provide pollination  services to California’s almond orchards early each spring. Figure 1  shows the estimated acreage of crops for which beekeepers provide  pollination services and the location of summer feeding grounds for  commercially managed bees.
In addition to honey bees, certain managed bees and wild, native bees  also provide valuable pollination services. Whereas honey bees comprise  an estimated 98 percent of managed bees in the United States, other  managed bee species—including bumble bees, alfalfa leafcutting bees,  and orchard mason bees—comprise the remaining 2 percent, according  to a representative of the Pollinator Stewardship Council. These other  managed bees pollinate alfalfa, almonds, apples, cherries, and tomatoes.  Wild, native bee species may also pollinate agricultural crops. In 2009,  crops directly and indirectly dependent on pollination by other managed  bees; wild, native bees; and other insects were valued at almost $10  billion according to the 2012 study of the value of pollinators to U.S. food  and agriculture. In addition, a 2007 National Research Council study  found that wild, native bees provide most of the pollination in natural plant  communities, which contributes to valuable ecosystem services, including  water filtration and erosion control.
section_title: Bee Population Trends
paragraphs: According to the White House Task Force’s 2015 Pollinator Research  Action Plan, in 2006, some beekeepers in the United States began to  notice unusually high mortality among their honey bee colonies over the  winter months. From 2006 to 2014, beekeepers who responded to the  Bee Informed Partnership’s nongeneralizable national survey of managed  honey bee colony losses reported that an average of about 29 percent of  their bee colonies died each winter. Those losses exceeded the  approximately 13 to 19 percent winter loss rate that beekeepers indicated  in the surveys were acceptable. Furthermore, when winter losses are  combined with losses at other times of the year, total annual losses can  be higher. For example, a preliminary report from the Bee Informed  Partnership indicated that beekeepers who responded reported total  annual losses of more than 40 percent of colonies from April 2014  through March 2015. Whereas nongeneralizable data on short-term  losses in honey bee colonies are available, the status of other managed  bees and most of the wild, native bee species in the United States is less  well-known.
section_title: Factors Affecting Bee Health
paragraphs: According to the White House Task Force’s strategy and research action  plan, intensive public and private research in the United States and  abroad over the past 8 years has shown that no single factor is  responsible for the general problems in pollinator health, including the  loss of honey bee colonies or declines in other bee populations. The task  force stated that bee health problems are likely caused by a combination  of stressors. Some of these stressors, in no particular order, include habitat loss, degradation, and fragmentation, including reduced  availability of sites for nesting and breeding; poor nutrition, due in part to decreased availability of high quality and pests (e.g., the mite Varroa destructor) and disease (e.g., viral,  bacterial, and fungal diseases); pesticides and other environmental toxins; and migratory stress from long-distance transport.
section_title: Effects of Bee Losses on Agriculture and Ecosystems
paragraphs: Continued losses of honey bees; other managed bees; and wild, native  bees threaten agricultural production and the maintenance of natural  plant communities. Commercial beekeepers are concerned that honey  bee colony losses could reach an unsustainable level for the industry.  According to a 2014 USDA report, the cost of honey bee almond  pollination services is believed to have risen in connection with the  increased cost of maintaining hives in the midst of industry-wide  overwintering losses. Officials we interviewed from a commercial  beekeeping organization said that, for beekeepers, meeting the growing  demand for pollination services in agricultural production has become  increasingly difficult, particularly as a result of bee colony losses.  Although the number of managed honey bee colonies has been relatively  consistent since 1996, ranging from about 2.4 to 2.7 million colonies, the  level of effort by the beekeeping industry to maintain colony numbers has  increased, according to the White House Pollinator Health Task Force’s  strategy. For example, beekeepers face increasing production costs,  which include sugar, protein, medications, and miticides (chemicals that  kill the mites that can infest bee hives). Furthermore, when winter colony  losses are high, beekeepers may compensate for these losses by splitting  one colony into two, supplying the second colony with a purchased queen  bee and supplemental food to build up colony strength. Using this  method, the commercial honey beekeeping industry has generally been  able to replenish colonies lost over the winter, but at a cost. These  increased maintenance costs can result in increased rental fees for  farmers renting the hives.
section_title: Specific Roles and Responsibilities of USDA and EPA in Addressing Bee Health Issues
paragraphs: Five USDA agencies within the scope of our review—NASS, ARS, NIFA,  FSA, and NRCS—as well as EPA have specific roles and responsibilities  with respect to addressing bee health issues.
USDA has surveyed beekeepers in the United States since the late 1930s  to determine the number of honey bee colonies and the amount of honey  produced. The survey, now conducted by NASS, is called the Bee and  Honey Inquiry. NASS maintains a list of beekeeping operations in the  nation and has been surveying beekeepers in all states except Alaska  since the 1970s to gather data on honey bee colonies, including the  number of colonies producing honey, total pounds of honey produced,  and total value of production by state for a production year.
ARS, USDA’s largest research agency, conducts research within several  of its laboratories that could protect bee health. NIFA, USDA’s primary  agency providing research grants to universities, provides competitive  grants to conduct research related to bee health and to disseminate the  results through the Cooperative Extension System. CRIS, which is  managed by NIFA, contains information on ARS and NIFA research and  outreach. CRIS provides documentation and reporting for agricultural,  food science, human nutrition, and forestry research, education and  extension activities for USDA, including those related to bee health.
FSA and NRCS oversee conservation programs that, among other things,  help provide habitat for bees. FSA administers the Conservation Reserve  Program (CRP), which implements long-term rental contracts with  farmers to voluntarily remove certain lands from agricultural production  and to plant species that will improve environmental health and quality,  such as improving forage plantings for bees and other pollinators. The  long-term goal of the program is to reestablish valuable land cover to help  improve water quality, prevent soil erosion, and reduce loss of wildlife  habitat. NRCS administers the Environmental Quality Improvement  Program (EQIP), which implements short- to long-term contracts with  farmers to voluntarily implement practices to conserve natural resources  and deliver environmental benefits, such as created wildlife habitat, which  may benefit bees. In addition, NRCS administers components of the  Agricultural Conservation Easement Program, in which plantings may  benefit bees or other pollinators. NRCS has primary responsibility for  providing to landowners the technical assistance needed to plant the  pollinator-friendly habitats. NRCS assists farmers through a network of  staff at headquarters, state, and county offices. In addition to supporting  overall pollinator habitat across the nation, FSA and NRCS are focusing  CRP and EQIP pollination resources on five upper Midwest states  (Michigan, Minnesota, North Dakota, South Dakota, and Wisconsin) that  are home to a significant percentage of honey bee colonies during the  summer months.
Under FIFRA, EPA is responsible for regulating pesticides, including  those used on crops and other plants and those used by beekeepers to  combat bee pests. As part of this responsibility, EPA reviews applications  from pesticide manufacturers seeking to obtain a registration for new  pesticides or new uses of existing pesticides. Under FIFRA, pesticide  registrants are required to report to EPA any information related to known  adverse effects to the environment caused by their registered  pesticides. In addition, the Food Quality Protection Act of 1996  amended FIFRA to require that EPA begin a review of the registrations of  all existing pesticide active ingredients. As further amended in 2007 by  the Pesticide Registration Improvement Renewal Act, FIFRA requires all  reviews be completed by October 2022. According to EPA’s website, the  FIFRA requirement applies to about 1,140 pesticides. EPA has chosen to  review the registration of all of these pesticides in about 740 “cases.” A  case may cover more than one pesticide active ingredient that are closely  related in chemical structure and toxicological profile. The Pesticide  Registration Improvement Act of 2003 (PRIA) amended FIFRA to require  that EPA issue annual reports containing a review of its progress in  carrying out its responsibilities for reviewing new and registered  pesticides.
Other agencies, including some within USDA, also have programs related  to bee health. For example, USDA’s Forest Service has conducted some  research and monitoring and conserves habitat to protect bee  populations. The U.S. Geological Survey (USGS) within the Department  of the Interior (Interior) has monitored wild, native bee populations.  Interior’s National Park Service and the National Science Foundation  have also funded research on bee health, and Interior’s Bureau of Land  Management is making changes to land-management programs by  incorporating native, pollinator-friendly plants in its management  practices.
section_title: Selected USDA Agencies Conduct Monitoring, Research and Outreach, and Conservation to Protect Bees, but Limitations Exist within Those Efforts
paragraphs: Five selected USDA agencies conduct monitoring, research and  outreach, and conservation to protect bees, but limitations within those  efforts hamper the agencies’ ability to protect bee health. In 2015, USDA  agencies increased honey bee colony monitoring to better estimate honey  bee colony losses nationwide, but as a co-chair of the White House  Pollinator Health Task Force with EPA, the department has not worked  with task force partners to coordinate a native bee monitoring plan. In  addition, USDA has conducted and funded research and outreach,  primarily by ARS and NIFA, on the health of different categories of bees,  including honey bees and, to a lesser extent, other managed and wild,  native bees, but CRIS, which tracks USDA-funded research and  outreach, is not currently designed to enable tracking or searching of  projects by bee category. Furthermore, USDA’s FSA and NRCS have  increased funding and taken other actions to promote bee habitat, but  neither agency has a method to count all of the acres that landowners  have restored or enhanced to benefit bees and other pollinators, and  limitations in their evaluation of those actions may hinder their  conservation efforts.
subsections: section_title: USDA Agencies Increased Honey Bee Colony Monitoring in 2015 but Have Not Worked with Federal Partners to Coordinate a Native Bee Monitoring Plan
paragraphs: USDA agencies have taken some actions to increase monitoring of honey  bees, other managed bees, and wild, native bees, but USDA, which co- chairs the White House Pollinator Health Task Force with EPA, has not  worked with its partners on the task force to coordinate a native bee  monitoring plan.
subsections: section_title: Monitoring Honey Bees
paragraphs: In April 2015, NASS, which conducts USDA bee surveys, initiated colony  loss surveys to provide quarterly estimates of honey bee colony losses in  the United States. NASS officials told us that the results of these surveys  will improve data on colony losses from prior USDA-funded surveys.  According to the task force’s strategy, federal agencies plan to use data  from these surveys to assess progress toward the strategy’s goal of  reducing winter honey bee colony losses to no more than 15 percent by  2025. USDA has conducted surveys of beekeepers in the United States  to track the number of honey bee colonies in the country since the late  1930s, but those surveys have not gathered beekeepers’ observations or  data about bee health problems.
Before NASS’s new surveys, NIFA provided most of the funding for the  Bee Informed Partnership to survey beekeepers about colony losses and  honey bee health from 2006 through 2015. The surveys showed that, on  average, about 29 percent of respondents’ honey bee colonies have been  dying over the winter, but the results cannot be generalized beyond the  survey respondents. The partnership has used a variety of methods to  reach out to all beekeepers in the country and in recent years received  responses from over 6,000 beekeepers. However, the partnership has  not calculated or estimated response rates to the surveys and has not  reported whether nonrespondents might differ from the respondents in  terms of survey answers. Because of this, the results cannot represent  beekeepers in general.
In a letter to the Office of Management and Budget (OMB) commenting  on the new NASS survey, the partnership stated that NASS is well- equipped to take over the honey bee colony loss surveys with its new  quarterly and annual surveys. According to NASS officials, improvements  will be possible in the new NASS surveys in part because NASS  maintains a comprehensive list of beekeepers from which it can select a  random sample. According to an agency document and official, the  quarterly survey will capture data from beekeeping operations with five or  more colonies, and operations with fewer than five colonies will receive  one annual survey in December. NASS officials said that their estimates  of U.S. colony losses during 2015 will be available in May 2016. NASS  has also added questions to the annual Bee and Honey Survey on the  costs associated with colony maintenance, which may include costs  associated with colony losses.
In addition, USDA’s Animal and Plant Health Inspection Service (APHIS)  has coordinated a national survey of honey bee pests and diseases  annually since 2009 with the University of Maryland and ARS. However,  that survey does not provide estimates of colony losses in the United  States.
section_title: Monitoring Other Managed Bees
paragraphs: According to NASS officials, NASS does not conduct surveys to estimate  populations or colony losses of other managed bees, such as bumble  bees, alfalfa leafcutting bees, and orchard mason bees, because NASS  does not consider them to be within the scope of their responsibilities for  farm livestock commodities. USDA’s ARS and NIFA conduct and fund  limited monitoring activities in agricultural settings to estimate populations  and health issues for these other types of managed bees. However, the  research action plan established as a priority engaging NASS in collecting  data on the commercial sales of nonhoney bee pollinators to understand  the economic value of alternative pollinators. To address this priority,  NASS included in a new survey on the cost of pollination—which largely  focuses on honey bees—questions on the cost to agricultural producers  for products such as wildflowers and pollination by other managed bees  and native bees. NASS began data collection for this new survey in  December 2015.
section_title: Monitoring Wild, Native Bees
paragraphs: USDA agencies, including ARS and NIFA, have conducted and supported  limited monitoring of wild, native bees, according to USDA documents  and officials. For example, one NIFA-funded project at Pennsylvania  State University begun in 2010 seeks to establish baseline biodiversity  and abundance data for native bees in and adjacent to Pennsylvania  orchards, determine which species are pollinators, and quantify their  relative significance and economic importance, according to the project  summary in CRIS. In addition, in 1997, ARS’s laboratory in Logan, Utah,  began monitoring wild, native bees in parks, forests, and other areas in  the United States as part of their efforts to develop alternative pollinators  for U.S. agriculture, according to ARS scientists. In one project, ARS has  annually conducted surveys of bumble bee populations for 5 to 8 years at  five sites in Nevada, Oregon, and Utah. The goal is to provide insight into  natural population dynamics of native bees in native habitat and identify  bumble bee population trends by species on the basis of 10 years of  surveys. According to the project description, bumble bee declines have  been documented over the last decade, but long-term studies of bumble  bee community dynamics are lacking, and such monitoring will help  determine whether a fluctuation in a bumble bee population is a natural  cycle or something unusual.
In its 2007 report on the status of pollinators, the National Research  Council stated that wild, native bees are arguably the most important and  least studied groups of pollinators. The report recommended  establishing a baseline for long-term monitoring, and a coordinated  federal approach with a network of long-term pollinator-monitoring  projects that use standardized protocols and joint data-gathering  interpretation. The report also stated that pollinator monitoring programs  in Europe have effectively documented declines in pollinator abundance,  but there is no comparable U.S. monitoring program. Stakeholders from  pesticide manufacturing, university research, and  conservation/environmental groups we interviewed said that USDA  should take additional actions to monitor wild, native bees because  current monitoring is insufficient and will not facilitate provision of trends  in these bee populations. Stakeholders from some groups suggested that  USDA and other agencies, such as USGS, should coordinate federal  monitoring efforts. A stakeholder from a university said that USDA should  develop a coordinated assessment policy for native bees to provide  information on their status because, without such a policy, agencies will  not know which species are declining, endangered, or extinct.
The 2014 presidential memorandum on pollinators called for the White  House Task Force to assess the status of native bees and other  pollinators. The subsequent White House Task Force strategy and  research action plan state that native bees are affected by habitat loss  and degradation, and that there is strong evidence, for some species, that  such factors have led to population declines. For example, the research  action plan states that collapses in bumble bee species have been  statistically documented, but little is known about trends for wild, native  bees, most of which are solitary, rather than social, bees. The research  action plan also states that (1) the scope of native bee monitoring is  limited by available funding, (2) assessments of native bees’ status rely  on disparate historical collection data and limited contemporary surveys,  and (3) a survey of bees in various ecosystems is needed to determine  the status of native pollinators.
The White House Task Force’s research action plan identified several  priority actions, with corresponding lead and support agencies  responsible for different aspects of the monitoring. For example, the  research action plan identifies ARS, USGS, and the Fish and Wildlife  Service as three of the lead agencies for the priority actions to develop  baseline status data and to assess trends in pollinator populations. And  the research action plan identifies NIFA, NASS, the National Science  Foundation, the Forest Service, and the National Park Service as primary  support agencies for these priority areas. Although the research action  plan identifies which agencies have responsibility for monitoring  pollinators, it does not identify the development of a mechanism, such as  a monitoring plan, to coordinate the efforts of those agencies related to  native bees. As of September 2015, USDA did not have plans to work  with task force members to coordinate development of such a mechanism  for wild, native bees. Some officials said that USDA has not coordinated  with other task force agencies to develop a wild, native bee monitoring  plan because they were developing the broader task force strategy. The  research action plan also does not define and articulate the common  outcome or identify specific roles and responsibilities for each lead or  support agency. Key practices for agency collaboration that we identified  in an October 2005 report call for agency staff to work together across  agency lines to define and articulate the common federal outcome or  purpose they are seeking to achieve that is consistent with their  respective agency goals and mission. Another key practice we identified  calls for collaborating agencies to work together to define and agree on  their respective roles and responsibilities, including how the collaborative  effort will be led.
In addition, we identified, in a February 2014 report, key practices for  agency collaboration that call for establishing shared outcomes and goals  that resonate with, and are agreed upon, by all participants and are  essential to achieving outcomes in interagency groups. Furthermore,  although the research action plan mentions stakeholders and  partnerships, it does not articulate how they will be included in addressing  priority actions related to monitoring native bees. In September 2012,  another key practice we identified calls for ensuring that the relevant  stakeholders have been included in the collaborative effort. This  collaboration can include other federal agencies, state and local entities,  and private and nonprofit organizations. By developing a mechanism,  such as a monitoring plan for wild, native bees that would (1) establish  roles and responsibilities of lead and support agencies and their shared  outcomes and goals and (2) obtain input from relevant stakeholders,  there is better assurance that a coordinated federal effort to monitor bee  populations will be effective. One senior USDA official stated that  coordinating with the other task force agencies to develop a wild, native  bee monitoring plan would be very important for gathering data to show  the status of wild, native bees in the future. Key USDA and USGS officials  with bee-related management responsibilities agreed that developing  such a monitoring plan would help them establish a consistent approach  across their agencies. The officials also said that USDA and other  agencies should establish a team of federal scientists to coordinate the  development of a federal monitoring plan for wild, native bees that would  establish monitoring goals and standard methods and involve state and  other stakeholders. Some USDA and USGS officials said that without a  team to coordinate a monitoring plan, individual agency efforts may be  ineffective in providing the needed information on trends in wild, native  bees in the United States.
section_title: USDA Bee Research and Outreach Have Focused Primarily on Honey Bee Health, but Limitations in Its Research Information System Hinder Efforts to Track Research Projects
paragraphs: USDA has conducted and funded research and outreach, primarily by  ARS and NIFA, on the health of different categories of bees, including  honey bees and, to a lesser extent, other managed and wild, native bees,  but CRIS, which tracks USDA-funded research and outreach, does not  currently facilitate tracking or searching of projects by bee category.  ARS’s honey bee projects have focused on projects for many health  concerns. For example, the ARS laboratory in Baton Rouge, Louisiana,  has focused for many years on breeding honey bees that are resistant to  Varroa mites. Also, ARS’s laboratory in Beltsville, Maryland, has  conducted research to develop management strategies for diagnosing  and mitigating disease, reducing the impacts of pesticides and other  environmental chemicals, and improving nutrition. ARS’s laboratory in  Logan, Utah, is identifying how farmers may use different pollinators,  including managed and wild, native bees. This research includes  developing methods for mass production, use, and disease control for a  selection of bees.
ARS scientists have regularly disseminated the results of their research at  national, regional, state, and local bee-related conferences and events.  ARS officials have also conducted outreach at meetings to provide  information to commodity growers, such as the Almond Board of  California. One ARS scientist noted that he had attended 27 state and  other types of beekeeper meetings over the past 5 years. Another ARS  scientist told us that he spends about 25 percent of his time conducting  outreach with beekeepers. In addition, ARS scientists have published  dozens of articles summarizing their research results in scientific journals.
From fiscal year 2008 through fiscal year 2015, ARS obligated $88.5  million for projects focused on bee health and $1.6 million for projects on  the effect of pollination by different types of bees on crop or plant  production. Of the $88.5 million obligated, our analysis determined that  $72.6 million was for projects primarily focused on honey bee health, an  additional $6.3 million was for projects with a combined focus on the  health of honey bees and other bees, and $9.6 million was for projects  focused only on other managed bees or wild, native bees. According to  ARS officials, all ARS funding for research on wild, native bees has been  for the purpose of developing new uses for managed bees in commercial  agriculture.
Unlike ARS, which itself conducts research, NIFA provides funds for  research through grants. For fiscal years 2008 through 2014, NIFA’s  competitive grants for research on bee health were largely focused on  honey bees, with some efforts focused on managed and wild, native  bees. For example, NIFA obligated funds for a 2012 grant to a team of  scientists and outreach specialists at Michigan State University, the  University of California-Davis, and other institutions that works with  growers to develop best practices for pollinator habitat enhancement and  farm management practices to bolster managed and wild, native bee  populations. The project is examining the performance, economics, and  farmer perceptions of different pollination strategies in various fruit and  vegetable crops, according to the project website. These strategies  include complete reliance on honey bees, farm habitat manipulation to  enhance suitability for native bees, and use of managed, native bees  alone or in combination with honey bees.
For fiscal years 2008 through 2014, NIFA obligated $29.9 million on  competitive grant projects focused primarily or partially on bee health, and  $11.6 million on projects focused on pollination effectiveness. Of the  $29.9 million, our analysis of individual grant project objectives and  descriptions determined that NIFA provided $16.7 million to projects on  honey bee health, $9.8 million to projects on the health of honey bees  and other bees, and $3.4 million to projects on the health of wild, native  bees.
In addition to funding competitive grants, NIFA provides support for bee  research at land-grant institutions through capacity grants to the states on  the basis of statutory formulas. From fiscal year 2008 through fiscal year  2014, these institutions expended $10.7 million in NIFA grants for  research related to bees. Furthermore, state institutions have used NIFA  capacity grants to support bee-related extension and education activities  through the Cooperative Extension System, such as teaching best  management practices to beekeepers, according to an agency budget  official. However, because NIFA and its partners do not track capacity  grant funding related to extension activities by subject, we were not able  to determine the amount of extension funding dedicated to bee-related  activities. In addition, according to estimates by the Economic Research  Service, overall research funding has declined in inflation-adjusted  dollars, from 1980 to 2014, which may have resulted in a reduction in the  number of cooperative extension bee specialists. According to NIFA  officials, about 28 bee specialists are currently supported by the  Cooperative Extension System in the United States and its territories.  That number has declined from an estimated 40 extension bee specialists  in 1986, largely due to funding reductions. In addition, according to NIFA  officials, the reduction in extension funding may have reduced expertise  in related areas, including Integrated Pest Management (IPM), which  focuses on long-term prevention of pests or their damage through a  combination of techniques, such as biological control, habitat  manipulation, modification of cultural practices, and use of resistant  varieties, paired with monitoring to reduce unnecessary pesticide  applications. IPM extension agents routinely advise farmers on  alternatives to pesticides and pesticide application methods that reduce  risk to bees and other pollinators.
USDA’s CRIS provides overall funding data and descriptions of bee- related research and outreach but does not facilitate tracking projects and  funding by the categories of bees addressed by the White House Task  Force’s strategy and research action plan. In addition, the research action  plan identifies key research needed to fill knowledge gaps for honey  bees; other managed bees; wild, native bees; and other pollinators.  However, the three categories for bees and other pollinators used in  CRIS to code USDA projects are “honey bees,” “bees, honey and other  pollinators,” and “other pollinators,” so that bee-related research projects  that could help fill the identified knowledge gaps may not be easily  identified in CRIS. For example, NIFA guidance on reviewing certain  competitive grant applications states that national program leaders must  check CRIS to determine if the proposed work has already been funded  by NIFA or ARS and to ensure that it is not unnecessarily repeating work  not yet published. In addition, ARS guidance directs the agency’s  scientists to search CRIS for potentially duplicative projects when  preparing project plans. Because projects may have multiple objectives, it  would be time-consuming to readily identify and track completed and  ongoing bee-related research by category of bee. Both the NIFA staff and  the researchers would have to search the codes for the up to three  different CRIS categories and then review the descriptions and the  multiple objectives for all projects with those codes.
By updating the categories of bees in CRIS to reflect the categories of  bees discussed in the White House Task Force’s strategy and research  action plan, USDA could increase the accessibility and availability of  information about USDA-funded research on bees. Senior USDA officials  said that CRIS would be more useful within the department and to others  seeking to identify bee-related research projects and project funding by  topic if USDA revised it to indicate the categories of pollinators that are  consistent with the research action plan. ARS and NIFA officials agree  improvements to CRIS could help managers track research spending  over time by the categories of bees identified in the research action plan.  One NIFA official estimated that revisions to CRIS could be done cost- effectively using minimal staff time.
section_title: FSA and NRCS Have Taken Actions That Promote Bee Habitat Conservation, but Limitations Could Hinder the Agencies’ Conservation Efforts
paragraphs: FSA and NRCS have taken many actions to promote bee habitat  conservation since 2008, but limitations in research, tracking of pollinator  habitat, and evaluation of the agencies’ conservation efforts could hinder  those efforts.
subsections: section_title: FSA and NRCS Have Taken Many Actions That Promote Bee Habitat Conservation
paragraphs: The Farm Bill of 2008 authorized USDA to encourage the use of  conservation practices that benefit native and managed pollinators and  required that USDA review conservation practice standards to ensure the  completeness and relevance of the standards to, among other things,  native and managed pollinators. In August 2008, and again in May 2015,  NRCS in partnership with the Xerces Society and San Francisco State  University published guidance identifying several conservation  programs, including CRP, EQIP, and NRCS’s Conservation  Stewardship Program (CSP) that could be used to promote pollinators  on working lands. This guidance identified 37 practices to create or  enhance pollinator habitat by providing more diverse sources of pollen  and nectar, and shelter and nesting sites, among other things.
According to FSA and NRCS officials, CRP and EQIP are the largest  USDA private land conservation programs benefiting pollinators.  Participants voluntarily sign up or enroll in FSA or NRCS conservation  programs and in specific practices within those programs. As of August  2015, FSA had over 132,000 acres enrolled in pollinator-specific CRP  practices, with a remaining allocation of 67,000 acres that could be  enrolled under these practices. In 2014, FSA announced an additional $8  million in incentives to enhance CRP cover crops to make them more  pollinator-friendly. FSA is offering incentives to CRP participants in the  five states that are home to most honey bee colonies during the  summer—Michigan, Minnesota, North Dakota, South Dakota, and  Wisconsin—to establish pollinator habitat. According to an FSA official,  because CRP participants began to implement habitat enhancements in  fiscal year 2015, FSA does not yet have information on the number of  acres of habitat established. Also, within CRP, the State Acres for Wildlife  (SAFE) initiative allows agricultural producers to voluntarily enroll acres in  CRP contracts for 10 to 15 years. In exchange, producers receive annual  CRP rental payments, incentives, and cost-share assistance to establish,  improve, connect, or create higher-quality habitat. As of November 2015,  the SAFE initiative was providing pollinator habitat in Michigan, Ohio, and  Washington. For example, the goal of the Michigan Native Pollinators  SAFE project is to enroll 2,500 acres of enhanced habitat over the next 5  years to benefit native pollinators.
In addition, in fiscal year 2014, NRCS provided more than $3.1 million in  technical and financial assistance to EQIP participants in the five states  that are home to most honey bee colonies during the summer to  implement conservation practices that would provide pollinator habitat.  This funding led to over 220 contracts with participants to establish about  26,800 acres of pollinator habitat, according to NRCS data. NRCS made  $4 million available in fiscal year 2015 through EQIP for honey bee  habitat. NRCS also funds other conservation programs that can benefit  bees and other pollinators. For example, the CSP provides financial and  technical assistance for participants whose operations benefit pollinators.  From 2012 through 2014, 17,500 acres were enrolled in one beneficial  CSP practice intended to improve habitat for pollinators and other  beneficial insects. Another CSP practice for grazing management may  benefit pollinators, but the acreage that benefits pollinators is unknown,  according to an NRCS official. In addition, NRCS offices in several states,  including Montana and South Dakota, seek to benefit pollinators with  upland habitat restoration funded by the Wetlands Reserve Program.
NRCS and FSA have taken steps to provide information to field offices,  agricultural producers, and others that is useful for pollinator habitat  conservation programs. For example, in collaboration with the Xerces  Society and academic partners, NRCS has revised and expanded lists of  plants that benefit bees and technical guidance for conserving pollinator  forage. The NRCS Conservation Innovation Grants program has  supported several projects across the country designed to demonstrate  the value of habitat for pollinators, as well as to expand and improve  NRCS’s capacity to establish and monitor high-quality bee forage sites.  The task force’s strategy notes that FSA is working collaboratively with  NRCS to promote the use of more affordable, pollinator-friendly seed  mixes on CRP land. Some NRCS Plant Materials Centers—which  evaluate plants for conservation traits and make them available to  commercial growers who provide plant materials to the public—have  pollinator forage demonstration field trials under way to determine and  demonstrate the effectiveness of forage planted for pollinators. In  addition, FSA, NRCS, and Interior’s USGS and Fish and Wildlife Service  have funded a website that provides information on plant-pollinator  interactions to help agencies improve pollinator seed mixes for programs  such as CRP and EQIP, according to a USGS official. USGS manages  this website, known as the Pollinator Library, to provide information on the  foraging habitat of pollinating insects with the goal of improving their  habitat. The Pollinator Library is to help users determine which flowers  that various insects, including native bees, prefer. The website includes a  search feature so users can determine, for example, what types of  pollinators have been found on different plant species, by state and land  type (such as CRP land). Knowing which flowers pollinators prefer is  useful to agencies creating seed mixes for CRP and EQIP habitat  enhancement efforts.
section_title: Limitations in Research, Tracking Acres of Pollinator Habitat, and Evaluation Could Hinder the Agencies’ Conservation Efforts
paragraphs: While USDA agencies have taken steps to improve bee habitat,  according to USDA officials and documents, limitations related to (1)  research on bee habitat and forage, (2) tracking acres of restored or  enhanced pollinator habitat, and (3) evaluating NRCS and FSA  conservation efforts, could hinder conservation efforts.
Research on Habitat and Forage  As part of the task force’s strategy and research action plan, federal  officials evaluated completed research and determined that additional  research on bee forage and habitat is needed to support NRCS, FSA,  and other entities’ conservation efforts. The task force’s research action  plan notes that there is much more to learn about the relationships  between plants and pollinators, including  identifying habitat with the greatest potential for pollinator benefits; developing locally-adapted plant mixes to provide resources for  pollinators throughout the year; designing a means for properly collecting, processing, storing, and  germinating sufficient seeds for restoration; and developing new concepts and techniques to understand how to  establish a broad mix of plants required for restoration based on  different factors—e.g., cost-effectiveness and site properties.
In addition, the research action plan identifies priority research actions for  federal agencies. For example, one priority action is developing a  science-based plant selection decision support tool to assist land  managers. According to the research action plan, this tool would help  land managers use the most effective and affordable plant materials  currently commercially available for pollinator habitat in wildland,  agricultural, or urban areas. The strategy for carrying out this action in 2  to 3 years, according to the research action plan, is to identify existing  science capacity to produce the decision-support tool. The research  action plan identifies ARS, NRCS, and USGS as able to provide  collaborative leadership for this action within the Plant Conservation  Alliance (PCA). Another priority action is developing a system for  monitoring the use of native plant materials. According to the research  action plan, the strategy for this action is within 2 years to develop an  interagency, online, searchable database to collect and analyze relevant  data efficiently (e.g., species, plant material type, location, acreage, year,  establishment, impacts on pollinators) to evaluate the use of native plant  materials. The research action plan identifies ARS and NRCS as sharing  collaborative leadership within the PCA for this action with the U.S. Forest  Service and Interior’s USGS and Bureau of Land Management.
Tracking Acres of Restored and Enhanced Pollinator Habitat  In response to the June 2014 presidential memorandum on pollinators,  the task force established an overarching goal on pollinator habitat  acreage of restoring and enhancing 7 million acres of land for pollinators  over the next 5 years through federal actions and public-private  partnerships. Under the task force’s strategy, USDA agencies, including  FSA and NRCS, are to contribute to this goal. FSA and NRCS are able to  track acres of pollinator habitat restored and enhanced under pollinator- specific initiatives and practices, according to agency officials. However,  they are unable to track acres on which landowners implement practices  for other conservation purposes, such as for erosion control, improved  water quality, or wildlife habitat, that may also have an additional benefit  for pollinators, according to agency officials. According to FSA and NRCS  officials, developing a method for tracking most acres with conservation  practices benefiting pollinators will be time-consuming and may require  some form of estimation. For example, according to FSA officials, the  agency may be able to estimate acres of pollinator habitat using  information it has on the types of plants landowners have planted.  Nevertheless, by developing an improved method, within available  resources, to track conservation program acres that benefit pollinators,  FSA and NRCS would be better able to measure their contribution to  restoring and enhancing the acres called for by the task force strategy’s  goal. Both agencies agreed that developing an improved method for  tracking acres on which pollinator habitat has been restored or enhanced  would provide valuable information. As of November 2015, the agencies  had begun to discuss and consider methods they might use to track acres  on which pollinator habitat has been restored or enhanced but had yet to  develop an improved method.
Evaluating FSA and NRCS Conservation Efforts  USDA has funded two evaluations of the effectiveness of FSA and NRCS  conservation efforts related to pollinator habitat. First, in 2013, FSA and  NRCS began jointly supporting a USGS study to evaluate the effect of  CRP and EQIP plantings on honey bee health and productivity in five  Midwestern states—Michigan, Minnesota, North Dakota, South Dakota,  and Wisconsin. According to a January 2015 USGS progress report, the  monitoring will quantify the effect USDA conservation lands have on  honey bee health and productivity. For example, USGS is comparing the  health of honey bee colonies in areas dominated by row crops with the  health of colonies located in areas with significant CRP and pasture  acreage. The evaluation has begun to show which weeks or months may  have a shortage of blooming forage. USGS plans to expand this  evaluation in 2016 to additional sites in Michigan and Wisconsin and add  a demonstration project to monitor the effect of CRP and EQIP plantings  on orchards, according to a USGS official. Information generated from  this USGS evaluation will be used to improve pollinator seed mixes for  CRP and EQIP, according to FSA and NRCS officials. Second, in 2014,  the Pollinator Partnership, under a cooperative agreement with NRCS,  issued an independent evaluation of how NRCS field offices were  promoting, implementing, monitoring, and documenting pollinator habitat  efforts in conservation programs in several states. This evaluation  concluded, among other things, that NRCS field offices were eager to  support pollinators, but agency staff needed additional expertise to advise  landowners how to implement effective conservation practices. However,  NRCS has not conducted an evaluation to show where there may be  gaps in expertise and how they might be filled; for example, whether the  gaps should be filled through additional formal training for staff or through  the informal learning that occurs when field staff, using technical  assistance funding, monitor the field work to determine which plants are  thriving and attracting bees.
According to NRCS officials, headquarters’ evaluations of pollinator  habitat have been limited, in part, because the agency has been focused  on implementing the plantings. The NRCS National Planning Procedures  Handbook directs an evaluation of the effectiveness of the implemented  plan to ensure it is achieving its objectives. The officials said that  increased evaluation would be helpful because, while each state office  has a biologist and other conservation experts, including partner  biologists from nonprofit organizations, there are gaps in technical  expertise on pollinator habitat available to some field offices. As a result,  some field offices have less ability to effectively plan and monitor  pollinator habitat. One university stakeholder suggested that NRCS  ensure that each of the approximately 30 states with a significant need for  pollinator habitat has a native bee expert. NRCS officials said an  evaluation of field office efforts to restore or enhance bee habitat could  help identify where expertise gaps occur. Another NRCS official said that  the agency could survey its staff to gather their views on the need for  additional training or expertise. In addition, one NRCS official said that  on-site evaluation of the success of the pollinator habitat is important to  understanding the effectiveness of the technical assistance.
NRCS officials also said that additional evaluation is needed to determine  if technical assistance funding is adequate to support conservation  planning efforts for different pollinator habitats across the country. NRCS  funding for technical assistance enables field staff to develop  conservation plans for landowners and to assess the implementation of  those plans. NRCS’s financial assistance funding to landowners helps  pay to implement conservation plans. If technical assistance funding is  too low, the effectiveness of conservation efforts may be compromised,  according to NRCS officials. As total funding for NRCS conservation  programs has increased, the percentage available for technical  assistance has decreased relative to financial assistance. In 2014,  funding for technical assistance was proportionally half of what it was in  2002, relative to the amount of financial assistance that it supported in  terms of conservation planning and monitoring. Specifically, according to  NRCS officials, for every dollar provided for financial assistance in 2002,  about $1.22 went to technical assistance. However, in 2014, for every  dollar provided for financial assistance, about 59 cents was provided for  technical assistance. According to USDA officials, the reduced  percentage of funding devoted to technical assistance has resulted in  NRCS field office staff having less time to plan for and ensure the quality  of conservation efforts, including pollinator habitat, because the staff must  spend more time in the office managing contracts and ensuring that all  financial assistance dollars are obligated. By increasing evaluation of its  habitat conservation efforts, including gaps in expertise and technical  assistance funding available to field offices, USDA could better ensure  the effectiveness of its efforts to restore and enhance bee habitat  plantings across the nation.
section_title: EPA Has Taken Some Steps to Address Pesticide Threats to Bees, but Potential Threats Remain
paragraphs: EPA has taken steps to address pesticide threats to bees, but potential  threats remain. Among other steps, in 2013, EPA revised the label  requirements for certain pesticides and in 2015, proposed revisions for  certain additional pesticides that are acutely toxic in an effort to reduce  bees’ exposure. Since at least 2009, EPA has encouraged beekeepers  and others to report bee kill incidents potentially associated with  pesticides, but agency officials and others point to challenges to accurate  reporting and data collection on these incidents. EPA has also  encouraged state and tribal governments to voluntarily develop plans to  work with farmers and beekeepers to protect bees from pesticides. EPA  has revised its guidance for assessing the risks new and existing  pesticides pose to bees, but there are limitations to the approach,  including a lack of data on pesticides’ risks to nonhoney bees and risks  that pesticide mixtures pose to bees. Changes to EPA’s risk assessment  approach will likely extend its schedules for reviewing the registrations of  some existing pesticides—including many that are known to be toxic to  bees—as the agency gathers and reviews additional data on risks to  bees. However, EPA has not revised the publicly available work  schedules for pesticides currently under review.
subsections: section_title: EPA Revised the Label Requirements for Certain Pesticides and Has Proposed Revisions to Label Requirements for Additional Pesticides Known to Be Acutely Toxic
paragraphs: In August 2013, EPA directed the registrants of four pesticides in a class  of chemicals known as neonicotinoids to submit an amendment to revise  the labels of products containing those pesticides that were registered for  outdoor use on plant foliage. Neonicotinoids are insecticides that affect  the central nervous system of insects, causing paralysis and death.  Pesticide labels contain directions for use and warnings designed to  reduce exposure to the pesticide for people and nontarget organisms,  including beneficial insects such as bees. It is unlawful to use any  pesticide in a manner inconsistent with its labeling. In proposing the label  changes, EPA cited the possible connection between acute exposure to  particular pesticides and bee deaths. EPA called for the labels to have a  pollinator protection box (also called a “bee advisory box”) and new  language outlining the directions for the products’ use, in addition to any  restrictive language that may already be on the product labels. The  agency directed the registrants to submit revisions to their product labels  with EPA’s prescribed language no later than September 30, 2013, and  told the registrants that it anticipated that the new product labels would be  in place in 2014.
The new language for the pollinator protection box warns of the threat the  pesticide poses to bees and other pollinators and instructs the user to  follow the new directions for use. The directions for use restrict the use of  the pesticide on crops and other plants at times when bees are foraging  on those plants. More specifically, the directions generally prohibit foliar  use, or use on leaves, until flowering is complete, and all petals have  fallen from the plants. However, the new directions for use allow for  exceptions to the prohibition under certain conditions, which vary,  depending on whether or not managed bees are on-site to provide  contract pollination services.
In November 2014, EPA staff told us the label changes to the four  neonicotinoids had led to confusion for pesticide users and resentment by  some stakeholder groups, but that the agency planned to address these  concerns through additional label changes for those and other pesticides  that are acutely toxic to bees. In particular, according to EPA officials,  pesticide users found that new label language, in some instances,  contradicted other parts of the label or was poorly defined. In May 2015,  EPA requested public comments on a proposal to make label changes  restricting the use of some products containing acutely toxic pesticides  on pollinator-attractive crops when managed bees are present for the  purpose of providing pollination services, saying that “clearer and more  consistent mandatory label restrictions could reduce the potential  exposure to bees from pesticides categorized as acutely toxic to bees.”  The deadline for public comments on EPA’s proposal was June 29, 2015.  Subsequently, that deadline was extended to August 28, 2015. According  to EPA officials, as of October 2015, the agency was in the process of  reviewing more than 100,000 comments on the label proposal; in part due  to the number of comments, the officials said they could not estimate  when the agency will finalize the proposal.
section_title: EPA Has Encouraged Beekeepers and Others to Report Bee Kill Incidents Potentially Associated with Pesticides
paragraphs: Since at least 2009, EPA has encouraged beekeepers and others to  voluntarily report bee kill incidents—that is, when bees in or near a hive  are killed by a suspected exposure to a pesticide, according to agency  officials. EPA records reports of bee kills that may have been associated  with pesticide use in its Ecological Incident Information System (EIIS)  database on adverse pesticide incidents. When EPA receives reports of  bee kill incidents, according to agency officials, it considers a range of  evidence to evaluate the probability that a specific pesticide was the  cause. The evidence could include information about pesticide use near  the incident, the known toxicity of the pesticides used in the area, and  physical or observational evidence associated with the affected bees.  After considering the evidence, EPA categorizes the likelihood that a  specific pesticide was associated with the bee kill as highly probable,  probable, possible, unlikely, or unrelated. In total, the EIIS data include  306 unique bee kill incidents occurring from 1974 through 2014 and  another 90 incidents with no associated year. Of this total of 396  incidents, EPA found sufficient evidence to categorize 201 as highly  probable or probable. The 201 incidents were associated with 42  pesticides. (The EIIS data show that 3 bee kill incidents were highly  probable or probable but name no specific pesticide.)
According to agency officials, EPA encourages the public to report  incidents to their state lead agency (typically the state’s department of  agriculture) so that such incidents can be properly investigated.  Recognizing that some members of the public may not feel comfortable  with reporting to their state officials, EPA’s website and the “bee advisory  boxes” added to certain pesticide labels identify additional options for the  public to voluntarily report bee kill incidents. These include reporting  through beekill@epa.gov, an e-mail address monitored by EPA’s Office of  Pesticide Programs or to report incidents to the National Pesticide  Information Center. In addition, EPA enters into cooperative agreements  with states. Through these agreements, EPA may delegate certain  authority to states to cooperate in enforcing FIFRA. One condition of the  cooperative agreement is that states must report information on all known  or suspected pesticide incidents involving pollinators to beekill@epa.gov  and send a copy to the relevant EPA regional office. EPA stores data on  incident reports from the public, the National Pesticide Information  Center, and the states in its EIIS database.
Several factors may contribute to underreporting of bee kill incidents,  according to EPA staff and others we interviewed. According to officials  from EPA and beekeeping and environmental organizations, beekeepers  may be reluctant to report bee kills to state agencies or to EPA for one or  more of three reasons. First, beekeepers may want to avoid conflicts with  farmers with whom they have an arrangement for providing pollination  services or for obtaining access to forage for honey production, even if  the farmer’s pesticide application practices may have contributed to the  incident. Second, beekeepers may want to avoid investigations that may  suggest the beekeeper’s hive management practices—specifically, the  use of miticides or other pesticides to combat hive pests—contributed to  the incident. Third, according to a senior EPA official in the Office of  Pesticide Programs, some beekeepers believe that submitting reports in  the past has not resulted in a positive response from regulatory  authorities and, therefore, is not worth the effort.
According to the senior EPA official, other challenges exist that may make  bee kill incident reports inaccurate. For example, beekeepers may not be  able to frequently monitor their colonies, so incidents may not be  discovered for several days; the passage of time may hamper a  conclusive investigation. Honey bees forage over an extensive range.  Therefore, it may be difficult to determine to which crops and pesticides  they have been exposed. Finally, according to the EPA official, the states  have increasingly limited budgets to support bee colony inspection  programs and pesticide incident inspection programs in general, and may  not be able to fully investigate reported incidents.
In addition to the voluntary incident reports from beekeepers and others,  FIFRA requires that pesticide registrants report factual information they  are aware of concerning adverse effects associated with their products— including the death of nontarget organisms such as bees. The  information reported by a registrant is known as a FIFRA 6(a)(2) Incident  Report. However, according to EPA staff, FIFRA 6(a)(2) reports are not  particularly useful in providing details on bee kills because FIFRA and its  implementing regulations do not require registrants to identify bees as the  species harmed by a pesticide. Instead, bees are recorded within a larger  category of “other nontarget” organisms. In addition, registrants do not  need to report individual incidents involving “other nontarget” organisms  when they occur. Instead, registrants can “aggregate” incidents that occur  over a 90-day period and report those aggregated data to EPA 60 days  after the end of the 90-day period. While these FIFRA reporting  requirements apply generally to pesticide registrants, as we noted earlier,  EPA modified its requirements for the registrants of four neonicotinoid  pesticides. In its July 22, 2013, letter notifying the registrants of its plans  to modify the pesticides’ labels to be more protective of bees, EPA also  instructed the registrants to report bee kill incidents within 10 days of  learning of the incident and that information on bee kills must not be  aggregated, regardless of the number of individual pollinators involved in  any incident.
section_title: EPA Has Encouraged State and Tribal Governments to Voluntarily Develop Plans to Protect Managed Bees from Pesticides
paragraphs: In response to a directive from the June 2014 presidential memorandum  on pollinators, EPA has encouraged state and tribal environmental,  agricultural, and wildlife agencies to voluntarily develop managed  pollinator protection plans (protection plans) that focus on improved  communication between farmers and beekeepers regarding the use of  pesticides and the proximity of managed bees. EPA is working with two  organizations to encourage states and tribes to implement the protection  plans: (1) the State-FIFRA Issues, Research, and Evaluation Group  (SFIREG) and (2) the Tribal Pesticide Program Council. In December  2014, SFIREG issued draft guidance for state lead agencies for the  development and implementation of state protection plans. According to  the guidance, the scope of the plans is limited to managed bees not  providing contracted pollination services at the site of application. As  such, the protection plans are intended to reduce pesticide exposure to  bees that are adjacent to, or near a pesticide treatment site where bees  can be exposed via drift or by flying to and foraging in the site of  application. According to SFIREG’s draft guidance, many of the strategies  to mitigate the risk of pesticide exposure to managed pollinators are also  expected to reduce the risk to native bees and other pollinators. The  voluntary protection plans would supplement EPA’s proposal to make  label changes restricting the use of acutely toxic pesticides, described  above, to protect managed bees that are under pollination contracts  between farmers and beekeepers. According to the task force’s strategy,  one of the key elements of the state protection plans are the metrics that  will be used to measure their effectiveness in reducing honey bee losses.  Those metrics, according to the strategy, may differ across states and  tribes.
Because the development of the protection plans is voluntary, EPA will  not approve or disapprove them, and measures of the plans’  effectiveness will be state- or tribe-specific, according to agency officials.  According to EPA officials, as of January 2016, seven states had  protection plans in place: Arkansas, California, Colorado, Florida, Iowa,  Mississippi, and North Dakota, while all but a few of the other states had  protection plans in some stage of development. In addition, EPA provided  funding for a November 2015 training program to address tribal pollinator  protection plans. Stakeholders we interviewed who commented on this  topic generally supported EPA’s efforts to encourage pollinator protection  plans. Stakeholders’ views on protection plans are summarized in  appendix II.
section_title: EPA Has Revised Its Guidance for Assessing Risks to Bees Posed by New and Existing Pesticides, but Limitations Remain
paragraphs: In June 2014, EPA issued guidance advising the agency’s staff to  consider requiring pesticide registrants to conduct additional studies on  the risks that new or existing pesticides may pose to bees and bee  colonies for pesticides going through the registration or registration review  processes. The 2014 guidance formalized interim guidance issued in  2011. EPA summarized the need for the risk assessment guidance in a  2012 White Paper to the FIFRA Scientific Advisory Panel that noted that  the lack of a clear, comprehensive and quantitative process for evaluating  pesticide exposure and subsequent risk to bees from different routes of  exposure was a major limitation. The guidance may result in registrants  conducting additional studies on the toxicity of new and existing  pesticides on honey bees. It also allows for several methods of  characterizing pesticide risk. However, EPA’s 2014 risk assessment  guidance relies largely on honey bees as a surrogate for other bee  species. In addition, the guidance does not call for EPA to assess the  risks that pesticide mixtures may pose to bees.
subsections: section_title: EPA’s Risk Assessment Guidance Potentially Calls for More Study of the Effects of New and Existing Pesticides on Honey Bees
paragraphs: EPA’s June 2014 guidance calls for agency staff to consider requiring  pesticide applicants or registrants to conduct additional studies on the  toxicity of their pesticides to honey bees. The guidance applies to EPA’s  review of new pesticide registration applications and its ongoing review of  existing registrations. EPA has used, and continues to use, a three-tiered  approach for assessing the risks that pesticides may pose to bees (and  other organisms). That is, the agency may require additional studies—in  Tiers II and III—from pesticide applicants or registrants, depending on the  results of any Tier I studies that it required. Therefore, under the June  2014 guidance, EPA staff are to consider a range of studies that examine  different life stages of honey bees (adult and larval), different types of  toxicity (acute and chronic), and different types of exposure to pesticides  (contact and oral). Studies may be conducted in laboratories on individual  bees (Tier I), as “semi-field” tests of small colonies (Tier II), or as field  tests of whole colonies (Tier III). EPA may also consider other lines of  evidence, including open scientific literature and incident reports.
Another aspect of assessing the risk of pesticides is deciding which  chemicals within a pesticide product are to be studied. EPA’s June 2014  guidance addresses this issue but leaves it to the discretion of agency  staff. Specifically, EPA’s June 2014 guidance states that toxicity data  using the end-use product may be needed if data suggest that a typical  end-use product is potentially more toxic than the active ingredient, and  bees may come directly in contact with the product. The guidance also  calls for agency staff to consider the effects that systemic pesticides  applied to seeds or in the soil may have on honey bees. Systemic  pesticides applied to plants and soil can move through the plant to other  plant tissues, potentially contributing to quantities of pesticide residues in  pollen and nectar.
EPA regulations identify three honey bee studies as required, or  conditionally required, and EPA’s 2014 guidance suggests additional bee  toxicity studies that agency staff might consider requiring. EPA staff we  interviewed acknowledged that additional steps are needed to establish  study guidelines, but said that the agency has the authority under FIFRA  to require and review any studies that it deems necessary to determine  whether a pesticide will have unreasonable adverse effects. In addition,  as of October 2015, EPA had not yet issued guidelines for the new types  of studies that registrants may be required to submit. However, in July  2015, EPA announced on its website that it was considering a proposal  within 12 months that would update and codify the data requirements  needed to characterize the potential risks of pesticides to bees and other  pollinators. In the meantime, registrants may conduct three of the  additional studies—acute adult oral toxicity, acute larval toxicity, and  semi-field testing with whole colonies—using guidelines developed by the  Organization for Economic Cooperation and Development (OECD).  EPA officials told us that, as of October 2015, formal guidelines did not  exist for chronic toxicity testing with adult bees and chronic toxicity testing  with bee larvae but said that EPA is contributing to international efforts to  develop formal guidelines, including draft guidelines on chronic toxicity  with bee larvae. In addition, the task force’s strategy stated that  standardized guidelines may not be developed for field studies (Tier III)  because “these studies are intended to address specific uncertainties  identified in lower tier tests.” Instead, according to agency officials, EPA  will have to agree on specific Tier III protocols proposed by the pesticide  applicant or registrant for particular pesticides.
section_title: EPA’s Risk Assessment Guidance Allows for Tiered Studies in Making Registration Decisions for New Pesticides and New Uses for Existing Pesticides
paragraphs: EPA’s June 2014 risk assessment guidance for honey bees allows the  agency to use tiered studies in reviewing registration applications for new  pesticides and new uses for existing pesticides. EPA’s review of  registration applications for four pesticides—cyantraniliprole, oxalic acid,  sulfoxaflor, and tolfenpyrad—provides examples of how the agency’s use  of its 2011 interim and 2014 final guidance and its call for bee-related  studies can vary. Because EPA’s risk assessment approach for this  guidance is a tiered one, the agency staff uses its discretion when  requiring registrants to conduct toxicity studies. For example, EPA  approved oxalic acid for a new use as a miticide to combat Varroa mites  in bee hives without requiring its own Tier II or Tier III studies. According  to EPA staff, the agency relied on existing data from Canada that shows  the pesticide has low acute toxicity and is effective at killing Varroa mites  without harming bee colonies. For the other three pesticides, which were  registered before the 2014 final guidance was issued, EPA reviewed  varying numbers and types of studies but did not require all of the types  of studies described in the new risk assessment guidance. However, EPA  decided, on the basis of the studies that were done, to place restrictions  on the pesticides’ use in order to reduce bees’ exposure. For example,  EPA did not require Tier III studies for sulfoxaflor but used the results of  Tier I and Tier II studies as the basis for reducing the amount of the  insecticide that was allowed to be applied per acre under the pesticide’s  2013 registration. In addition, cyantraniliprole and tolfenpyrad are  among the acutely toxic pesticides covered by EPA’s May 2015 proposal  to make label changes restricting the use of acutely toxic pesticides.
A finding from study results that a pesticide is toxic to bees (or other  organisms) does not necessarily mean that EPA will disapprove an  application for registration. Under FIFRA, throughout the tiered process,  EPA considers whether mitigation measures (e.g., changes to application  rates, the timing of applications, or the number of applications) are  sufficient to reduce exposure to a level at which risk estimates are below  levels for concern, while also taking the benefits from using the pesticide  into consideration.
section_title: EPA’s 2014 Risk Assessment Guidance Relies Largely on Honey Bees as a Surrogate for Other Bee Species
paragraphs: While EPA’s June 2014 pesticide risk assessment approach provides for  the inclusion of data on additional bee species where available, it relies  primarily upon data from honey bees as a surrogate for all bee species.  However, other bee species may be affected differently by pesticides.  EPA acknowledges in its guidance that there are limitations to using  honey bees as surrogates but maintains that honey bees can provide  information relevant to other species, and that adequate, standardized  tests are not yet available for other species. EPA is involved in  international efforts to develop standardized tests for other bee species  and has been directed by the task force’s strategy with researching risk  assessment tools for nonhoney bee species. However, EPA does not  have a schedule for expanding the risk assessment process to other bee  species. Stakeholders we interviewed from farming, commercial  beekeeping, university, and conservation/environmental groups said EPA  should expand its risk assessment process to include testing the effects  of pesticides on pollinators other than the honey bee, including other  commercial, or managed, and wild, native bees. Several of these  stakeholders specified that EPA should develop testing models and  guidelines for other types of bees, such as solitary and bumble bees.
EPA’s September 2012 White Paper attributed the agency’s focus on  honey bees to two factors: (1) honey bees are considered the most  important pollinator in North America from a commercial and ecological  perspective and (2) standardized tests on the effects of chemicals are  more developed for honey bees than for other managed bee species,  such as the alfalfa leafcutting and orchard mason bees. However, the  White Paper also noted that there are an estimated 4,000 species of wild,  native bees in North America and more than 20,000 worldwide. These  wild, native bees also provide important pollination services. Other  managed and wild, native bee species may be exposed to pesticides  through different routes, at different rates, or for different durations than  honey bees, all of which may influence the effects of pesticides. The  White Paper concluded that there was a clear need for a process to  assess risks to species other than honey bees, owing to potential  differences in sensitivity and exposure compared to honey bees. While  noting the importance of assessing risks to diverse bee species, the  White Paper also cited a 2012 European Food Safety Authority  conclusion that published laboratory, semi-field, and open field test  methods for other species (i.e., bumble bees, orchard mason bees,  leafcutting bees, and alkali bees) needed further development.
In its December 2012 review of EPA’s White Paper, the FIFRA Scientific  Advisory Panel recommended that EPA require testing on at least one  additional species to address the goal of protecting diversity. The FIFRA  panel stated that alfalfa leafcutting bee and orchard mason bees are the  easiest to include for Tier I testing, adding that these bees are  commercially available in large numbers and would be fairly easy to use  for higher-tiered tests. In addition, the panel noted that bumble bees are  also available commercially, and considerable research is available on  how to raise them, so they would be useful for Tier II tests, although with  limitations. EPA’s June 2014 risk assessment guidance stated that, as the  science evolves, methods and studies using other bee species may be  considered and incorporated into risk assessments.
The task force’s strategy stated that uncertainty is created by relying on  honey bees as a surrogate and stated the agency was working with  regulatory counterparts through the OECD to ensure the development of  standardized testing methods to address this uncertainty. In that regard,  the task force’s research action plan directs EPA to develop appropriate  assessment tools for sublethal effects of pesticides, adjuvants, and  combinations of pesticides on the fitness, development, and survival of  managed and wild pollinators (i.e., honey bees and other bees). The task  force’s strategy states that a metric for progress in meeting the strategy’s  directives will be the extent to which standardized guidelines are  developed and implemented for evaluating potential risks to bees other  than honey bees. According to the strategy, these studies will be critical  for determining the extent to which honey bees serve as reasonable  surrogates for other species of bees. However, the strategy and the  research action plan do not identify how or when EPA is to ensure that  adequate test protocols are incorporated into the risk assessment  process. According to EPA officials, it would not be reasonable for the  strategy to dictate a timeline or for EPA to commit to one given the  absence of appropriations to support the development of test guidelines.  Instead, these officials said that EPA is working with the OECD and other  international bodies to develop test guidelines for other species of bees.
According to OECD documents, progress has been made in developing  guidelines to assess the acute contact and oral toxicity of pesticides to  individual bumble bees. The documents state that the results of validation  testing for the guidelines (known as ring tests) are expected to be  reported by late 2015 or early 2016. However, it is not clear when EPA  could incorporate them into its risk assessment process, and guidelines  for other bee species would take additional time to develop. Regardless,  EPA has the authority under FIFRA to require pesticide registrants to  submit data on the toxicity of pesticides on other bee species using  methods that meet the agency’s approval. By developing a plan for  obtaining data from pesticide registrants on the effects of pesticides on  nonhoney bee species, including other managed or wild, native bees, into  its risk assessment process, EPA could increase its confidence that it is  reducing the risk of unreasonable harm to these important pollinators,  consistent with the task force’s strategy and research action plan.
section_title: EPA’s June 2014 Guidance Does Not Call for the Agency to Assess the Risks That Pesticide Mixtures May Pose to Bees
paragraphs: EPA’s June 2014 risk assessment guidance calls for the agency to  assess the risks that individual pesticides may pose to bees but not for  the assessment of the risks from combinations of pesticide products or  combinations of pesticide products with other chemicals. Farmers  sometimes mix pesticide products for a single application to reduce the  number of times they have to spray their fields. These combinations of  pesticide products are known as tank mixtures. Beekeepers have raised  concern that these mixtures of pesticide products may have synergistic  effects on bees, meaning that the effect of the combination is greater than  the sum of the effects of the individual pesticides. The Pollinator  Stewardship Council reported on its website in 2014 that beekeepers  attributed bee kill incidents to pesticides that acted in combination with  each other to increase their collective toxicity. In addition, farmers may  mix pesticide products with adjuvants, or chemicals to enhance the  pesticides’ effectiveness. University researchers have also reported that  combining certain pesticide products with other products can  synergistically increase the overall toxicity to bees. Stakeholders we  interviewed from commercial bee groups, universities, and conservation/  environmental groups suggested that EPA require companies to conduct  toxicity studies on pesticide tank mixtures as part of its risk assessment  process. According to agency officials, EPA has taken some steps to  expand the scope of its risk assessment to include mixtures of pesticides,  but challenges remain, as discussed below.
EPA registers an individual pesticide after assessing the risks the  pesticide poses to human health or the environment when used according  to its directions for use. EPA also assesses the risks posed by  combinations of pesticides that the applicant intends to be used as a  registered combination. Otherwise, EPA does not assess the risks of  tank mixtures of pesticides or combinations of pesticides and other  chemicals such as adjuvants that farmers or others may use. According  to EPA officials, the use restrictions that apply to tank mixtures of  pesticides are, instead, based on the most restrictive elements of the  individual pesticides’ labels.
In EPA’s September 2012 White Paper, the agency stated that “with  respect to mixtures, while multiple stressors and the interactive effects of  pesticides and/or other environmental stressors are important issues,  they will not be examined at this time.” However, the task force’s strategy  recognized the risks that pesticide mixtures may pose and called for EPA  to develop appropriate tools to assess the sublethal effects of pesticides,  adjuvants, and combinations of pesticides with other products on the  fitness, development, and survival of managed and wild pollinators.
Senior EPA officials told us in October 2015 that they agreed that tank  mixtures of registered pesticides pose potential risks to bees. However,  they said that there was no reliable process for assessing mixtures and  that, given the number of possible permutations that may occur in tank  mixing, it was difficult to imagine how EPA could reasonably commit to  such an effort. EPA officials also said that the use of tank mixes may  change over time and by location as farmers respond to different pest  outbreaks, and that the agency does not know how it would identify  commonly used mixtures. However, according to stakeholders we  interviewed, sources for data on commonly used or recommended  mixtures are available. These sources include the California Department  of Pesticide Regulation—which has an extensive data base on pesticide  use—the pesticide industry, farmers, pesticide application companies,  and extension agents.
At the same time, EPA officials noted that the agency is working with the  Fish and Wildlife Service and the National Marine Fisheries Service on  assessing the risks of pesticides to threatened and endangered species  such as salmon, including the risk posed by mixtures of pesticides. They  said the agencies’ effort could eventually be relevant to EPA’s guidance  for assessing pesticide risks to bees. EPA and the other agencies  subsequently developed joint interim scientific approaches for assessing  the risks of pesticides to threatened and endangered species. With  respect to pesticide mixtures, the agencies’ document on interim  approaches stated that risks associated with pesticide mixtures will  largely be considered qualitatively rather than quantitatively. A related  agency document states that long-term future work includes establishing  a quantitative approach for assessing risks of mixtures but provides no  time frames for doing so. We acknowledge that EPA’s work with other  agencies on pesticide risks to threatened and endangered species may  eventually contribute to its risk assessments for bees, but the effects of  that work remain to be seen. By identifying the pesticide mixtures that  farmers and pesticide applicators most commonly use on agricultural  crops, EPA would have greater assurance that it could assess those  mixtures to determine whether they pose greater risks than the sum of the  risks posed by the individual pesticides.
According to senior EPA officials, if the agency has information about  certain combinations being used regularly, it could require that pesticide  registrants provide testing data on those combinations. If an assessment  of commonly-used pesticide mixtures found synergistic effects on bees,  FIFRA authorizes EPA to take regulatory actions to reduce risks, such as  requiring label language warning of those effects.
section_title: Applying EPA’s New Risk Assessment Guidance Will Likely Extend the Agency’s Reviews of Registered Pesticides, and EPA Has Not Revised Review Schedules
paragraphs: Amendments to FIFRA require that EPA complete its reviews of all  pesticide active ingredients registered as of October 1, 2007, by October  2022. Applying EPA’s new risk assessment guidance to its review of  registered pesticides will add time to the posted review schedules for  some individual pesticides, and EPA has not revised these schedules.  As discussed, EPA’s revised risk assessment guidance for bees calls for  the agency to consider requiring registrants to conduct additional studies  on their pesticide’s effect on bees. According to EPA documents and  officials, the agency is now applying the new guidance to registered  pesticides that are in the review process, as well as to new pesticides.  Deciding what studies are needed, requesting the data from registrants,  waiting for the studies to be conducted, and analyzing the study data will  add time to EPA’s review of some pesticides’ risks to bees. The director  of EPA’s Pesticide Re-Evaluation Division and other senior officials told  us in April 2015, and confirmed in October 2015, that the agency was in  the process of deciding what additional bee studies, if any, will be needed  for specific individual pesticides. They could not estimate how long it will  take to make those decisions but said a large number of pesticides for  which EPA had begun a registration review prior to issuing its risk  assessment guidance in June 2014 could require data on bees. The  number of pesticides affected by the new risk assessment guidance is,  therefore, likely to be substantial, according to EPA officials. In its annual  PRIA implementation report, EPA reported to Congress in March 2015  that by September 30, 2014, it had begun the review process for 528  pesticide cases and prepared final work plans for 491 of those cases. The  final work plans identify the studies the agency is requiring the registrant  to conduct and show the agency’s estimated schedule for completing a  registration review. Of the 491 cases with final work plans, EPA had  issued registration review decisions for 105 cases by the end of fiscal  year 2014. According to EPA officials, as of September 30, 2015, the  agency had increased the number of reviews begun to 612 pesticide  cases, had prepared final work plans for 580 pesticides cases, and had  issued 155 interim and final registration review decisions.
According to the EPA division director, if EPA determines through  registration review that additional data are necessary to make the  necessary findings, the agency must obtain approval from the Office of  Management and Budget (OMB) to request the data from registrants that  use a particular active ingredient in their products. He added that, if EPA  decides that registrants need to do additional studies on bees, it will need  to obtain another approval from OMB for the new data. Once OMB  approves the request, the required risk assessment studies on bees may  take registrants from one to several years to conduct. The division  director said that EPA was concerned that the number of pesticides  needing new bee test data could overwhelm the supply of qualified testing  laboratories, which could delay the start and completion of those studies.  In its written comments on a draft of this report, EPA said that it had more  recently learned that laboratories are building capacity to conduct these  studies. However, the conduct of honey bee studies is confined to a  limited window within the year, typically from April through August.
The final work plans for most of the pesticide cases for which EPA had  begun registration review were developed and posted to the  www.Regulations.gov website before EPA adopted its revised risk  assessment guidance for bees in June 2014. According to EPA officials,  those work plans may therefore not reflect the types of studies that are  now called for by the new guidelines or the estimated schedules for  completing the registration reviews. Work plans that EPA posted after the  June 2014 risk assessment guidance, on the other hand, may better  reflect the types of studies that are called for by the new guidance.
To examine the effect that EPA’s revised risk assessment guidance has  had on its review of individual pesticide registrations, we selected eight  registered pesticides associated with bee kill incidents reported in EPA’s  EIIS database. The work plans for these pesticides (amitraz, carbaryl,  chlorpyrifos, coumaphos, malathion, and three neonicotinoid pesticides— clothianidin, imidacloprid, and thiamethoxam)—could provide information  on how EPA’s new risk assessment process will affect registration review,  although we found the full effect is not yet clear. The director of the  Pesticide Re-Evaluation Division explained that the work plans EPA has  posted at www.Regulations.gov for amitraz, carbaryl, chlorpyrifos,  coumaphos, and malathion are out of date because EPA has not yet  decided what additional data on the effects of the pesticides on bees the  agency will ask registrants to submit. However, EPA staff told us that the  work plans for the three neonicotinoid pesticides—which predate the June  2014 risk assessment guidance—more closely reflect the guidance and  call for additional studies on bees. EPA staff said that they were aware  of the need for more bee studies for those pesticides as the agency  developed its 2014 guidance.
While the new guidance is likely to affect many pesticide reviews, EPA  officials told us that the agency does not plan to revise the review  schedules in work plans that have already been posted. The officials said  that doing so would place a significant burden on agency staff and detract  from their ability to conduct registration reviews. Instead, EPA officials  said that the agency would annually announce for which pesticides it  expected to have preliminary risk assessments available for public review  in that year. In keeping with that plan, the May 2015 task force’s strategy  included a list of 58 registration review preliminary risk assessments that  EPA said would be open for public comments during 2015. Unlike the  posted work plans for pesticides undergoing registration review, the  announcement in the strategy did not estimate when the reviews of the 58  pesticides would be complete or identify what studies EPA has  determined will be required. We understand that it may be challenging for  agency staff to revise the review schedules in work plans that have  already been posted. However, given that EPA is working to determine  what studies will be required, it may soon be able to determine the  studies it would require of registrants. By disclosing in its annual PRIA  implementation reports which registration reviews have potentially  inaccurate schedules and when it expected those reviews to be  completed, EPA could provide Congress and the public with accurate  information about the schedules for completing the registration reviews,  thereby increasing understanding of EPA’s progress toward meeting the  October 2022 deadline for completing all registration reviews.
As required by FIFRA as amended by PRIA and subsequent legislation,  EPA’s PRIA implementation reports contain data on the number of cases  opened and closed in a particular fiscal year and cumulatively since the  start of registration review in 2007. EPA has reported on its website that it  expects to open 70 or more new registration review dockets annually  through fiscal year 2017. Although the reports do not estimate the number  of reviews EPA expects to close each year as it moves toward the 2022  deadline, the agency wrote in its fiscal year 2014 PRIA implementation  report that it continued to open dockets for new registration review cases  at the pace that must be maintained in order to finish reviews in 2022.  EPA has estimated that the average time it will take to complete a  registration review is about 6 years and that the agency has completed an  average of less than 20 per year. However, the new risk assessment  guidance for bees may increase the average time needed for reviews,  raising questions about EPA’s ability to complete its registration reviews  by 2022. EPA officials said that they are planning to assign additional  agency staff to work on these registration reviews.
section_title: Conclusions
paragraphs: USDA and EPA have taken numerous actions to protect the health of  honey bees and other species of bees, thereby supporting agriculture and  the environment. Even with these efforts, honey beekeepers continue to  report rates of colony losses that they say are not economically  sustainable. Although data on the size of nonhoney bee populations  (other managed bees and wild, native bees) are lacking, there is concern  that these bee species also need additional protection. Finding solutions  to address the wide range of factors that may affect bee health, including  pests, disease, reduced habitat and forage, and pesticide exposure, will  be a complex undertaking that may take many years and require  advances in science and changes in agricultural and land use practices.
Monitoring honey bees and other bee species is critical to understanding  their population status and threats to their health. The task force’s  research action plan on bees and other pollinators identified monitoring of  wild, native bees as a priority and directed agencies in USDA and the  Department of the Interior to take leading and supporting roles. However,  the research action plan did not establish a mechanism, such as a  monitoring plan, that would establish participating agencies’ roles and  responsibilities, establish common outcomes and goals, and obtain input  from states and other stakeholders on native bees. By working with other  key agency stakeholders, USDA can help agencies understand their  respective roles, focus on the same goals and outcomes, and better  solicit input from external stakeholders.
The task force’s strategy also includes a plan for extensive research on  issues important to honey bees; other managed bees; wild, native bees;  and other pollinators. USDA’s ARS and NIFA have funded and continue  to fund research on these three categories of bees. While the ability to  identify research projects by bee category is key to tracking projects  conducted to implement the task force’s research action plan, USDA’s  CRIS database does not currently reflect these categories. This limitation  hinders users’ ability to search for or track completed and ongoing bee  research. Updating the CRIS database to include the three bee  categories would increase the accessibility and availability of information  about USDA-funded research on all bees.
In addition, the task force’s strategy established a governmentwide goal  of restoring and enhancing 7 million acres of habitat for bees and other  pollinators. USDA’s NRCS and FSA are supporting efforts to improve  habitat to help meet the strategy’s goal. It is not yet clear, however, how  the agencies will determine which acres count toward this goal because  USDA cannot currently track all acres on which conservation practices  have restored or enhanced bee habitat as part of the effort to achieve the  strategy’s goal. Without an improved method, USDA cannot accurately  measure its contribution to the strategy’s goal. In addition, NRCS, which  provides technical assistance to landowners implementing conservation  practices, has conducted limited evaluation of the effectiveness of those  efforts. NRCS’s National Planning Procedures Handbook calls for the  agency to evaluate its conservation practices, including the technical  assistance provided to landowners. According to one evaluation, agency  staff need additional expertise to effectively advise landowners on how to  conserve pollinator habitat. However, NRCS has not evaluated which  locations have gaps or identified methods for filling the gaps. Such  methods could include providing additional training or time to conduct  technical assistance through which staff can learn which practices are  working and which are not. By increasing the evaluation of its habitat  conservation efforts to include identifying gaps in expertise and technical  assistance, USDA could better ensure the effectiveness of its efforts to  restore and enhance bee habitat plantings across the nation.
Moreover, EPA has expanded its assessment of pesticides for their risks  to honey bees. EPA generally uses data on pesticides’ risks to honey  bees as a surrogate for risks to nonhoney bee species but stated that  having data on those species would help meet the goal of protecting bee  diversity. The task force’s research action plan calls for EPA to develop  tools for assessing risks to a variety of bee species, including nonhoney  bee species, such as other managed or wild, native bees. EPA is  collaborating with international counterparts to develop standardized  guidelines for how to study the effects of pesticides on other bee species.  FIFRA authorizes EPA to require pesticide registrants to submit data from  tests on nonhoney bee species using methods that meet EPA’s approval.  By developing a plan for obtaining data from pesticide registrants on  pesticides’ effects on nonhoney bee species until the standardized  guidelines are developed, EPA could increase its confidence that it is  reducing the risk of unreasonable harm to these important pollinators.
Furthermore, EPA does not assess the risks that mixtures of pesticides  and other chemicals may pose to bees. Depending on the chemicals  involved, a mixture may pose a greater risk to bees than the sum of the  risks from exposure to individual pesticides. The task force’s research  action plan generally called for research on the effects mixtures of  pesticides can have on bees and, in particular, directed EPA to develop  appropriate assessment tools for sublethal effects of pesticides,  adjuvants, and combinations of pesticides with other products on the  health of managed and wild pollinators. However, EPA does not have  data on commonly used mixtures and does not know how it would identify  them. By identifying the mixtures that farmers and pesticide applicators  most commonly use on agricultural crops, EPA would have greater  assurance that it could assess those mixtures to determine whether they  pose greater risks than the sum of the risks posed by the individual  pesticides and, if appropriate, take regulatory action.
As directed by FIFRA, EPA began a review of all pesticide active  ingredients registered as of October 1, 2007, in fiscal year 2007 and is  required to complete it by October 2022. EPA’s review has been affected  by the changes to its risk assessment process that call for pesticide  registrants to submit additional bee-related data for some pesticides. As a  result, the agency’s posted schedules for reviewing the registration of  pesticides may be inaccurate because the schedules do not reflect  requests for additional data. However, EPA has not posted revised  schedules. Accurate information about the agency’s estimated schedule  would help Congress and the public better understand EPA’s progress  toward meeting the October 2022 deadline for completing all registration  reviews.
section_title: Recommendations for Executive Action
paragraphs: We are making four recommendations to the Secretary of Agriculture and  three recommendations to the Administrator of EPA.
To improve the effectiveness of federal efforts to monitor wild, native bee  populations, we recommend that the Secretary of Agriculture, as a co- chair of the White House Pollinator Health Task Force, coordinate with  other Task Force agencies that have monitoring responsibilities to  develop a mechanism, such as a federal monitoring plan, that would (1)  establish roles and responsibilities of lead and support agencies, (2)  establish shared outcomes and goals, and (3) obtain input from relevant  stakeholders, such as states.
To increase the accessibility and availability of information about USDA- funded research and outreach on bees, we recommend that the  Secretary of Agriculture update the categories of bees in the Current  Research Information System to reflect the categories of bees identified  in the White House Pollinator Health Task Force’s research action plan.
To measure their contribution to the White House Pollinator Health Task  Force strategy’s goal to restore and enhance 7 million acres of pollinator  habitat, we recommend that the Secretary of Agriculture direct the  Administrators of FSA and NRCS to develop an improved method, within  available resources, to track conservation program acres that contribute  to the goal.
To better ensure the effectiveness of USDA’s bee habitat conservation  efforts, we recommend that the Secretary of Agriculture direct the  Administrators of FSA and NRCS to, within available resources, increase  evaluation of the effectiveness of their efforts to restore and enhance bee  habitat plantings across the nation, including identifying gaps in expertise  and technical assistance funding available to field offices.
To better ensure that EPA is reducing the risk of unreasonable harm to  important pollinators, we recommend that the Administrator of EPA direct  the Office of Pesticide Programs to develop a plan for obtaining data from  pesticide registrants on the effects of pesticides on nonhoney bee  species, including other managed or wild, native bees.
To help comply with the directive in the White House Pollinator Health  Task Force’s strategy, we recommend that the Administrator of EPA  direct the Office of Pesticide Programs to identify the pesticide tank  mixtures that farmers and pesticide applicators most commonly use on  agricultural crops to help determine whether those mixtures pose greater  risks than the sum of the risks posed by the individual pesticides.
To provide Congress and the public with accurate information about the  schedules for completing the registration reviews for existing pesticides  required under FIFRA, we recommend that the Administrator of EPA  disclose in its PRIA implementation reports, or through another method of  its choosing, which registration reviews have potentially inaccurate  schedules and when it expects those reviews to be completed.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to USDA and EPA for review and  comment. USDA and EPA provided written comments on the draft, which  are presented in appendixes IV and V, respectively. In its written  comments, USDA said that it agreed, in large part, with the four  recommendations relevant to the department in the draft report and that  progress with regard to the recommendations would improve protection  for pollinators, especially bees. In its written comments, EPA said that it  agreed with the three recommendations relevant to the agency in the  draft report and that it has actions under way to implement the three  recommendations.
In its written comments, USDA described actions it has taken or could  take to implement our first recommendation that the Secretary of  Agriculture, as a co-chair of the White House Pollinator Health Task  Force, coordinate with other task force agencies that have monitoring  responsibilities to develop a mechanism, such as a federal monitoring  plan, that would (1) establish roles and responsibilities of lead and  support agencies, (2) establish shared outcomes and goals, and (3)  obtain input from relevant stakeholders, such as states. USDA noted that  while it would be impossible to monitor all of the approximately 4,000  species of bees in North America, it would be informative for agencies to  survey changes in the distributions of a common set of sentinel, or  indicator, bee species. The agency also described some of the monitoring  methods that it plans to use or that could be used by USDA, the  Department of the Interior, and other collaborators. In doing so, USDA  noted that identifying native bee species can be very difficult (even to  those trained in biology and museum curators) and that possible  remedies will be explored, including the development of a universal field  guide or apps that would facilitate bee identification efforts.
USDA also described steps that it plans to take to implement our second  recommendation that the Secretary of Agriculture update the categories  of bees in CRIS to reflect categories of bees identified in the White House  Task Force’s research action plan. USDA states that the discrepancy  between the government-wide effort and current classifications needs to  be reconciled to capture efforts of research, education, and extension  projects as they work to address threats to bee health. While USDA  states that the CRIS categories can be changed relatively quickly, it also  states that the efficacy of the changes varies, depending on whether they  are made for historical project data or for future project reports. USDA  describes the additional staff time needed to analyze and recode projects  manually in CRIS and that adding new classifications would affect current  projects and would require analysis to determine if changes will affect  trend reporting of the budget. USDA also states that a strategy will be  needed to increase awareness of the new classifications for project  directors and other scientists who may choose to change to the more  specific bee classifications for their projects. The agency then describes  the process by which changes are made to research classifications in  CRIS, saying that if the CRIS Classification Board approves changes to  CRIS when it meets in the spring of 2016, NIFA would address relevant  changes at that time.
USDA generally agreed with our third recommendation that the Secretary  of Agriculture direct the Administrators of FSA and NRCS to develop an  improved method, within available resources, to track conservation  program acres that contribute to the goal of restoring and enhancing  habitat for pollinators. USDA said that since November 2015, FSA has  had a method for estimating acres of pollinator habitat associated with  Conservation Reserve Program practices. In addition, according to  USDA, NRCS is exploring options to develop a method for tracking acres  on which conservation practices are planned and applied to benefit  pollinators.
USDA generally agreed with our fourth recommendation that the  Secretary of Agriculture direct the Administrators of FSA and NRCS to,  within available resources, increase evaluation of the effectiveness of  their efforts to restore and enhance bee habitat plantings across the  nation, including gaps in expertise and technical assistance funding  available to field offices. USDA said that it would expand and deepen its  studies on the impact of conservation cover on honey bee and other  pollinator health, diversity, and abundance as its budget allows.
EPA agreed with our first recommendation that the Office of Pesticide  Programs develop a plan for obtaining data from pesticide registrants on  the effects of pesticides on nonhoney bee species, including other  managed or wild, native bees. In addition, EPA described actions that it is  taking in collaboration with other parties to develop methods for testing  the effects of pesticides on nonhoney bee species. We also noted many  of these actions in the report.
EPA agreed with our second recommendation that the Office of Pesticide  Programs identify pesticide mixtures that farmers and pesticide  applicators most commonly use on agricultural crops to help determine  whether those mixtures pose greater risks than the sum of the risks  posed by the individual pesticides. EPA noted that there is opportunity to  identify some commonly used tank mixtures. At the same time, EPA  commented on our use of the term “unregistered mixtures.” In our draft  report, we intended for the term “unregistered mixtures” to mean  combinations of registered pesticides that EPA has not registered for use  in combination. However, we agree with EPA that the term “unregistered  mixtures” might cause confusion and revised the draft, replacing that term  with the term “tank mixtures.”
EPA agreed with our third recommendation that the agency provide  Congress and the public with accurate information about the schedules  for completing the registration reviews for existing pesticides required  under FIFRA. However, rather than agreeing to disclose this information  in its PRIA implementation reports, EPA committed to creating a public  website containing this information by April 2016. We agree that a public  website could be a suitable method for accomplishing the intent of our  recommendation.
USDA and EPA also provided technical comments, which we  incorporated as appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretary of Agriculture, the Administrator  of EPA, and other interested parties. In addition, the report will be  available at no charge on the GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or morriss@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix VI.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines (1) the bee-related monitoring, research and  information dissemination, and conservation efforts of selected U.S  Department of Agriculture (USDA) agencies and (2) the Environmental  Protection Agency’s (EPA) efforts to protect bees through its regulation of  pesticides.
To examine USDA’s monitoring, research and outreach, and conservation  efforts with respect to bees, we focused on the National Agricultural  Statistics Service (NASS), which surveys honey beekeepers; the  Agricultural Research Service (ARS) and National Institute of Food and  Agriculture (NIFA), which are the two largest USDA research agencies;  and the Natural Resources Conservation Service (NRCS) and Farm  Service Agency (FSA), which oversee conservation programs. To  examine bee monitoring activities, we analyzed the methodology that  NASS and the Bee Informed Partnership are using for their monitoring  efforts related to their surveys of honey bee colony losses. We also  reviewed the White House Task Force plans for wild, native bee  monitoring by a variety of federal agencies to determine whether a means  of federal coordination had been established. We also reviewed our prior  body of work on interagency collaboration, as agencies within USDA  carry out work related to bee monitoring in conjunction with other  agencies; from that work, we selected practices that were related to  challenges that we or agency officials identified and used the practices to  assess interagency collaboration at USDA concerning bee monitoring. In  addition, we reviewed ARS and NIFA documents related to monitoring  projects and interviewed ARS and U.S. Geological Survey officials and  university researchers participating in monitoring projects.
To examine bee-related research and outreach, we analyzed USDA  project funding data for ARS and NIFA for fiscal years 2008 through 2015  and for fiscal years 2008 through 2014, respectively, to identify the types  of bees addressed by the projects. We selected fiscal year 2008 as the  starting point to reflect 2008 Farm Bill initiatives; data from fiscal years  2015 and 2014 were the most recent data available for ARS and NIFA,  respectively. We evaluated the reliability of these data by comparing  agency-provided data with data found in USDA’s website for its Current  Research Information System (CRIS) and reviewing the agencies’  management controls to ensure the data’s reliability. We determined that  the data are sufficiently reliable for the purposes of this report. We also  reviewed how ARS and NIFA categorize research data in USDA’s CRIS  database and compared the CRIS categories to those used in the task  force strategy and research action plan. We interviewed ARS and NIFA  officials in headquarters and in three bee laboratories regarding research  and outreach projects being conducted and the usefulness of the CRIS  bee categories.
To examine bee-related activities in two key USDA agencies with  conservation programs, we collected data from NRCS and FSA on bee  habitat acres established in 2014 and 2015 for two honey bee initiatives  and associated agency funding. We evaluated the reliability of these data  by reviewing the agencies’ management controls for the systems  maintaining the data to ensure the data were sufficiently reliable for the  purposes of this report. We also reviewed NRCS and FSA guidance and  other documents on bee habitat, as well as evaluations of the NRCS  technical assistance efforts. In particular, we reviewed an evaluation by  the Pollinator Partnership of NRCS’s technical assistance efforts and  examined the agency’s response to conclusions about the level of bee  habitat conservation expertise within the agency. We interviewed FSA  and NRCS officials to discuss strengths and weaknesses of their  pollinator habitat efforts, particularly related to evaluation and technical  assistance.
To examine EPA’s efforts to protect bees, we gathered information on its  regulation of pesticides under the Federal Insecticide, Fungicide, and  Rodenticide Act (FIFRA). In particular, we obtained documents from, and  conducted interviews with, officials in EPA’s Office of Pesticide Programs  (OPP). OPP carries out EPA’s responsibilities for regulating the  manufacture and use of all pesticides (including insecticides, herbicides,  rodenticides, disinfectants, sanitizers, and more) in the United States.  Specifically, we reviewed EPA’s decisions in 2014 to modify the labels of  pesticide products containing neonicotinoid active ingredients. We also  reviewed EPA’s 2015 proposal to modify the labels of pesticides the  agency has determined to be acutely toxic to bees. We also gathered  information about pesticides that have been associated with bee kill  incidents from 1974 through 2014, as indicated by reports in EPA’s  Ecological Incident Information System (EIIS). To assess the reliability of  the EIIS data, we discussed with EPA officials the methods by which the  agency collects and assesses the EIIS data and determined that, while  they had limitations, they were sufficiently reliable for the purpose of  identifying pesticides potentially associated with bee kills. Furthermore,  we reviewed documents and interviewed agency officials regarding EPA’s  efforts to encourage states to develop voluntary “managed pollinator  protection plans.”
In addition, we reviewed the agency’s 2011 interim and 2014 final  guidance for assessing the risks that pesticides pose to bees and  examined how the agency has applied the new guidance to particular  pesticides. We also reviewed an EPA “White Paper” on risk assessment  the agency submitted to the FIFRA Scientific Advisory Panel for  comment, as well as the panel response. To learn more about how the  agency has used its 2014 risk assessment guidance when reviewing the  registration of existing pesticides, we selected 10 pesticides shown by  EPA’s EIIS database to be associated with bee kills. When EPA receives  reports of bee kill incidents, according to agency officials, it considers the  evidence provided and categorizes the likelihood that a specific pesticide  was associated with the bee kill as highly probable, probable, possible,  unlikely, or unrelated. We assigned to those certainties a score of 4, 3, 2,  1, or 0, respectively, and multiplied the number of incidents for each  pesticide by the certainty score. Using the product of those calculations,  we identified the 10 pesticides associated with the largest number of bee  kill incidents and weighted by EPA’s degree of certainty. The 10  pesticides, in alphabetical order, are amitraz, carbaryl, chlorpyrifos,  clothianidin, coumaphos, imidacloprid, malathion, methyl parathion,  parathion, and thiamethoxam. However, 2 of the pesticides, parathion  and methyl parathion, have been cancelled by their registrants and,  therefore, are no longer subject to EPA’s registration review process. For  the remaining 8 pesticides, we reviewed EPA’s final work plans and other  documents related to the agency’s registration review process and  interviewed agency officials to determine what effect the new risk  assessment guidance had on the registration review process.
We reviewed data and interviewed agency officials about the status of  EPA’s pesticide registration and registration review programs. The data  included the number of pesticide “cases” for which EPA had started the  registration review process from the beginning of fiscal year 2007 through  the end of fiscal year 2015, the number of cases with final work plans  completed, and the number of case reviews that EPA has completed. We  selected these time frames because EPA began the registration review  process required by FIFRA in fiscal year 2007, and the most recent data  available from the agency were through the end of fiscal year 2015. To  assess the reliability of the data on registration reviews provided directly  to us by EPA’s OPP, we compared them to data in EPA implementation  reports to Congress required by FIFRA and found them sufficiently  reliable for our reporting purposes.
To address both objectives, we gathered stakeholders’ views on what  efforts, if any, USDA and EPA could take to protect bee health.  Specifically, we interviewed stakeholders from the following types of  organizations or entities: general farming, including conventional and  organic farming; commodity farmers whose crops are pollinated by  managed bees; commercial beekeepers; pesticide manufacturers; state  governments; universities; and conservation/environmental protection.  We developed a list of candidate stakeholders by asking for suggestions  from knowledgeable federal officials and others knowledgeable about bee  health and through our review of relevant literature. USDA and EPA  officials reviewed our list of candidate stakeholders and made  suggestions. We also obtained advice from a member of the National  Academy of Sciences with extensive experience on bee and pollinator  research about how to achieve a balanced list of stakeholders with varied  expertise and knowledge. Appendix II presents a summary of  stakeholders’ views on USDA and EPA efforts to protect bees.
We conducted 35 interviews with stakeholders. A total of 50 individuals  participated in the interviews because, in some instances, more than one  person represented a stakeholder organization. See appendix III for the  names of the individuals we interviewed, their title, affiliation, and type of  stakeholder organization.
To ensure we asked consistent questions among all the identified  stakeholders, we developed an interview instrument that included  questions about the stakeholders’ expertise and experience regarding  bees, their knowledge of relevant USDA and EPA activities to protect bee  health, and their views on suggestions for efforts, if any, (1) USDA’s ARS,  NIFA, or NRCS should make with regard to bee-related research and  information dissemination; (2) other USDA agencies should make to  protect bee health; or (3) EPA should make to protect bee health. With  the exception of the university research scientists, the stakeholders  represented their organizations’ views. After completing the interviews,  we conducted a content analysis of the stakeholders’ responses, whereby  we organized their comments into relevant categories. Because we used  a nonprobability sample of stakeholders, their views cannot be  generalized to all such stakeholder organizations but can be illustrative. In  addition, the views expressed by the stakeholders do not represent the  views of GAO. Further, we did not assess the validity of the stakeholders’  views on what efforts USDA and EPA should make to protect bee health.
We conducted this performance audit from October 2014 to February  2016 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Stakeholders’ Views on Efforts USDA and EPA Should Make to Further Protect Bees
paragraphs: This appendix presents stakeholders’ views regarding suggested efforts  the U.S. Department of Agriculture (USDA) and Environmental Protection  Agency (EPA) should make to further protect bee health. Stakeholders  provided these views in interviews. Specifically, we interviewed a  nonprobability sample of stakeholders from 35 of the following types of  organizations or entities: general farming, including conventional and  organic farming; commodity farmers whose crops are pollinated by  managed bees; commercial beekeeping; pesticide manufacturing; state  government; university research; and conservation/environmental  protection.
In our interviews, we asked stakeholders for their familiarity with agency  efforts to protect bee health as well as for their views on suggestions for  any efforts the agencies should make to further protect bee health. The  information in table 1 provides a summary of stakeholders’ views on  commonly-cited topics and indicates the types of stakeholder groups that  expressed those views.
section_title: Appendix III: Bee Health Stakeholders We Interviewed
subsections: section_title: Name of stakeholder Laurie Davies Adams
paragraphs: The IPM Institute of North  America, Inc.
Assistant Extension/Research  Professor of Entomology   Commercial Director of Beeologics  Monsanto Company  Project Apis m.
section_title: Name of stakeholder Dudley Hoskins
paragraphs: Assistant Professor of Entomology  University of Maryland  Board Member and Past President  Western Alfalfa Seed Growers  Project Apis m.
section_title: Appendix IV: Comments from the Department of Agriculture
section_title: Appendix V: Comments from the Environmental Protection Agency
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Anne K. Johnson, (Assistant  Director), Kevin Bray, Ross Campbell, John Delicath, Ashley Hess,  Meredith Lilley, Beverly Peterson, and Leigh White made key  contributions to this report. Barbara El Osta, Karen Howard, Ying Long,  Perry Lusk, Jr, Anne Rhodes-Kline, Dan Royer, Kiki Theodoropoulos, and  Walter Vance also made important contributions to this report.