ODA rule-making to prohibit 4 neonics on linden trees

Please join us to offer public comment on Oregon’s new proposal to ban the application of four neonicotinoid insecticides on linden trees.

Our Recommendation
Yes, it is necessary to ban the application of neonicotinoid insecticides.

Background
While it is true that the seven bee kills in Oregon were caused by neonics being applied to linden trees, these were “acute” and very visible poisonings. What we need are regulations that address chronic, sub-lethal exposures of these poisons. Research proves that neonics cause devastating sub-lethal effects, including disruption of mating, foraging, digestion and care of young. Nor does the proposed rule address their biological longevity. Neonics, which are extremely persistent in surface water and soils, are killing aquatic insects that are necessary to the survival of many species of birds and fish. Consequently, the present emphasis on acute toxicity of individual pesticides on individual trees must be expanded to account for chronic and sub-lethal toxicity. To Save Oregon’s Bees and other wildlife, it is necessary to permanently ban all neonics.

Take Action
Please send your comments to the Oregon Department of Agriculture by January 21 or plan to attend the public hearing…

WHAT: Oregon Department of Agriculture RULEMAKING PUBLIC HEARING on this proposed change in rules:
Prohibit the application of four neonicotinoid insecticides, regardless of application method, on linden trees.

WHEN: Jan. 21, 2015 – 2PM

WHERE: Department of Agriculture, 635 Capitol St. NE, Salem, OR 97301
at the Department of Agriculture Hearings Room (google map)

If you cannot attend the hearing in person, please send your comments to Susan Gooch via email: Susan.C.Gooch@state.or.us.

Facts that you can raise with the Department of Agriculture in your testimony:

1. The seven bee kills in Oregon were caused by neonics being applied to linden trees. The pesticide applications involved four types of neonicotinoids applied using a variety of application methods, including: spraying directly on leaves, tree injection, soil drench and a basal bark treatment. That proves there are not safe ways to use these insecticides. However, the proposed rule seems very narrowly based on these “acute” and very visible poisonings. Bees are also impacted by the use of neonicotinoids on any flowering plant because the poison gets taken up through the plant or tree and expressed through the pollen and nectar.

2. What we need are regulations that address chronic, sub-lethal exposures of these poisons by various environmental pathways. Research proves that neonics cause devastating sub-lethal effects, including disruption of mating, foraging, digestion and care of young.

3. Nor does the proposed rule address their biological longevity. Neonics, which are extremely persistent in surface water and soils, are killing aquatic insects that are necessary to the survival of many species of birds and fish.

4. The present emphasis on acute toxicity of individual pesticides on individual trees must be expanded to account for chronic and sub-lethal toxicity in soil, surface water and other plant species. To protect pollinators and other wildlife, it is necessary to permanently ban all neonics.

What the Science Shows: see this page for more scientific research (Beyond Pesticides)

Reference Documents from the state of Oregon

1) Secretary of State: STATEMENT OF NEED AND FISCAL IMPACT (PDF)

2) NOTICE OF PROPOSED RULEMAKING HEARING (PDF)

3) Proposed Oregon Administrative Rule (OAR 603) – Oregon Department of Agriculture (PDF)

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