July 24, 2017
Office of Pesticide Programs
Regulatory Public Docket (7502P)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW Washington, DC 20460
RE: Docket ID Number EPA-HQ-OPP-2011-0581 & EPA-HQ-OPP-2011-0865, Thiamethoxam Registration Review and Clothianidin Registration Review
The National Cotton Council (NCC) appreciates the opportunity to comment on the Environmental Protection Agency’s (EPA) “Preliminary Bee Risk Assessment to Support the Registration Review of Clothianidin and Thiamethoxam”. The NCC does not agree with several assumptions used by the EPA, and is strongly concerned the EPA has not recognized the important benefits these products provide to the cotton industry resulting in societal and environmental benefits due to less reliance on older chemistries.
The NCC is the central organization of the United States cotton industry. Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from California to Virginia. U.S. cotton producers cultivate between 9 and 12 million acres of cotton with production averaging 12 to 18 million 480-lb bales annually. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 125,000 workers and produce direct business revenue of more than $21 billion. Annual cotton production is valued at more than $5.5 billion at the farm gate, the point at which the producer markets the crop. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 280,000 workers with economic activity of almost $100 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.
Unexpected Introduction of New Methodology
The NCC believes the EPA should not have introduced a “new methodology to assess exposure from pollen in bee bread” by simultaneously incorporating it into a risk assessment released for public review. The introduction of a new methodology should be reviewed prior to its incorporation into risk assessments. The NCC notes the EPA has recently taken this approach with incorporation of epidemiology studies as well. The NCC strongly objects to EPA’s approach to introducing new methodologies by imbedding them into the release of risk assessments. Any new methodology should be vetted to all stakeholders prior to being implemented into practice.
The NCC is deeply concerned with the proposed methodology and believes it to be flawed. First, it appears the agency assumes collection from one crop that has been treated. The pollen collection for bee bread will incorporate multiple sources of pollen. Second, the NCC is concerned that the assumption force feeds bees with pollen they would not normally collect and may represent mostly nutritional deficiencies. Third, the methodology does not represent real world activity of bees blending multiple sources for nutritional aspects. Such deficiencies can result in health consequences that are inappropriately being assigned to test chemistries. The NCC urges EPA to revisit the use of this methodology.
The EPA has claims of calculating a Risk Quotient. Upon examination, the EPA has used two different hazard points for the calculation, and no exposure points. Risk has always been a function of hazard and exposure, and the EPA is utilizing two hazards which assumes 100% exposure. The NCC does not agree with the EPA’s assumption and urges the agency to revise the risk to represent exposure. Whether calculated from BeeREX or empirical field residue toxicity data, the data points used do not represent bee exposure to the pesticide use.
Multiple Uses of Pollen and Nectar Food
The risk assessment speaks multiple times of pollen and nectar bee bread. The NCC would like clarification that all references to pollen were removed for cotton assessments. The NCC has provided EPA multiple scientific papers denoting the unattractiveness of cotton pollen to bees, as well as the questionable attractiveness of cotton itself. The assessment spans many crops, and the methodologies seem to most often include pollen and nectar. It is stated on page 273 that, “Cotton is noted to have both floral and extra-floral nectaries that is attractive to bees while pollen is not considered attractive to honey bees.” However, it is not clear that cotton pollen was removed from the calculation of the risk assessment, meaning another pollen source would have made up the beebread.
Benefits of Neonic Uses
The NCC understands EPA has received a presentation from Dr. Jeff Gore, Research Entomologist at Mississippi State University, studying the insect control with and without neonics, and that the study reflects the fact that removing the neonics from the production system resulted in more foliar applications of older chemistries, an overall increase in pesticide use, and a net loss of profit to the producer.
The importance of the neonic chemistries to the cotton industry cannot be overstated. The cotton industry, once plagued with boll weevil and tobacco budworm as major pests, has undertaken many measures to reduce pesticide use, but those changes have shifted the pest complex toward piercing/sucking insects such as thrips, aphids, whiteflies, stinkbugs, and plant bugs. The neonic chemistries provide control of these pests with fewer applications, but producers must also include rotations of mode of action for overall pest control and resistance management strategies, meaning that other chemistries are to be considered necessary, not alternatives.
The NCC conducted a recent survey of state extension entomologists regarding the cotton production use of the neonic chemistries. Approximately 82 percent of cotton production utilizes treated seed, and this adoption is predominantly driven by the need to control thrips. Thrips have historically been recognized as a major pest of cotton plants emerging from the soil until the plants grow three to four nodes. Losses to thrips often vary because the effect extends beyond plant injury. Thrips injury often includes delaying growth and development, thereby extending the growing season, subjecting the crop to more pest pressure, and delaying harvest which often subjects the crop to adverse weather causing yield and quality losses. In some states with very high historical thrips pressure (eg. VA, GA, SC, NC), there has been a growing adoption of in-furrow neonic treatments, but at a national level the percentage is around 11 percent. At a national level, pre-bloom foliar applications are made to less than 46 percent of the cotton acreage, but equals the post bloom applications. The foliar uses vary tremendously between states due to certain pest pressures such as plant bugs in the Mid-south. Georgia and South Carolina report less than 5 percent foliar applications while Texas reports less than 20 percent use of foliar applications. Removing seed treatment considerations, the question was asked of the state entomologists to rate the importance (0=low, 3=critical) of in-furrow, foliar pre-bloom, and foliar during bloom. The national average was 2.18, 1.81, and 1.94 respectively. These entomologists quickly point out that tank mix applications with other modes of action are common in order to comply with resistance management strategies.
The consensus expressed among the entomologists is there are no acceptable alternatives to replace the use of neonics in the IPM and resistance management strategies for their states. The loss of neonics will result in additional reliance on older chemistries, multiple applications, and risks to flare up other pest populations resulting in additional control measures.
The NCC urges EPA to refine the risk assessment with real exposure rather than a substitute hazard value and to develop a tier III study which they will accept. The NCC urges EPA to remove any cotton pollen, including bee bread, from the assessment for cotton and to negate the new methodology until further vetted with stakeholders before being released in an assessment. The NCC urges EPA to carefully evaluate the importance and benefits of the neonic chemistries. Lastly, recognized products under registration review certainly should not be identified as alternatives to the product under review.
The NCC thanks EPA for the opportunity to provide comments on this registration review.
Senior Scientist, Regulatory and Environmental Issues
National Cotton Council