Letter to the EPA: Take action on “Devil’s bargain” pesticides

An Open Letter to: Michael Regan, Administrator; Michal Freedhoff, Assistant Administrator, Office of Chemical Safety and Pollution Prevention; and Ed Messina, Office of Pesticide Programs Director, Environmental Protection Agency

The environment needs protection from neonicotinoid-coated pesticidal seeds, which are by far the greatest single insecticide application across the country, covering more than 100 million acres. Fundamental ecosystem integrity, plus the welfare of millions of birds and other animals where the coated seeds are planted, are at risk. You can be the difference makers if you seize the opportunity.

You know, as we NGO-types have recited to you in the past through broadly-supported letters and petitions, that a major body of evidence now shows neonic-coated seeds are the Devil’s bargain. While there may be some effective uses, they are mostly used prophylactically with no assessment of need. And yet they do great harm to essential pollinators, beneficial insects, and farmland birds, while contaminating the environment with their toxins.

In Ontario, Canada, when farmers were compelled to prove they needed to use neonic-coated seeds before being allowed by the provincial government, their use declined by a huge margin with no adverse economic effect.

Neonics have largely been banned in Europe since 2015. But, in the US, their excess production as a result of your agency’s leniency is a waste that resulted in the ongoing tragedy in Mead, Nebraska, where AltEn gathered about 80,000 tons of unwanted neonic-coated seeds in order to distill them for ethanol but instead ending up contaminating the environment to the tune of roughly $100 million in total damages. EPA’s uncritical approval of these seeds enabled the Mead disaster.

Of all the environmental threats in the United States, pesticides are conceptually the easiest to prevent because all the approved products out there resulted from registrations by your agency. But I am not asking you to cancel registrations, I am just asking you to take a closer look at EPA’s interpretation and regulatory issues that have allowed the harms of neonic-coated seeds to spin out of control.