Tues – 11/13: Bees need you to write some stinging comments in their defense. Today. By 11:59pm EST.

Today, we need comments on two almost identical rules regarding some our smallest, yet most essential agricultural benefactors. It will take you about 5 minutes to read this and another 5 minutes to write something.

(These “Rules” are where legislators, who should be packing up their desks, together with their pet lobbyists, push through legislation that is too shady, dangerous and/or un-American to withstand the scrutiny and cameras they would encounter on the floor of Congress. This is where lawmaking, money and influence meet, hoping we don’t notice.)

Action #1/#2 – Just say “NO” to sulfoxaflor  – Dow’s newest invention to accidentally kill off bees. – 2 identical comments – DUE TODAY BY 11:59 pm EST

Dow AgroSciences has applied for a large expansion of the use of sulfoxaflor, a pesticide shown to highly toxic to bees and  which was already banned once by the US 9th Circuit Court of Appeals. It was re-registered in 2016, with the prohibition from the EPA that applicators keep it away from bee-attracting plants. Recently Dow submitted an application to the U.S. Environmental Protection Agency to allow for it’s use on rice, avocados, residential ornamentals and at tree farms and greenhouses. Sulfoxaflor, which attacks the central nervous system of insects, is designed in part to replace “neonicotinoid” pesticides, which multiple studies have linked to bee colony collapse. Dow, you can do better. Let’s help you by not allowing this to happen.

There are two proposals open for comment until Nov. 13th. You can install your nifty new comment into BOTH of them. Use your own voice when you can. Comments do not have to be long or filled with scientific jargon.

Comment #1 (This only has 6 comments!) 

Comment on “Application for New Uses”  at this link. (Check out other comments for inspiration here.)

Comment #2 (This only has 5 comments!)

Comment on “Pesticide Product Registration: Applications for new uses” at this link. (Check out other comments for inspiration here.)

Samples:

• It’s simple–without bees we are doomed. No hype, no exaggeration. Our environment and our agriculture depend on them. Humanity can’t afford use of bee-killing pesticedes.
• Sulfoxaflor, which attacks the central nervous system of insects, is designed in part to replace “neonicotinoid” pesticides, which multiple studies have linked to bee colony collapse.
• Replacing bee-harming neonicotinoids with an equally toxic pesticide is not helping anyone except, Dow AgroSciences.
• A recent study published in Nature found that sulfoxaflor exposure at low doses had severe consequences for bumblebee reproductive success. The authors cautioned against EPAs current trajectory of replacing neonicotinoids with nearly identical pesticides like sulfoxaflor.
• In response to a legal challenge by beekeepers, the 9th Circuit Court of Appeals vacated the EPAs original registration of sulfoxaflor in 2015, finding that it was too dangerous for bees. The EPAs new 2016 registration for sulfoxaflor purportedly designed to ensure no exposure to bees excluded crops that are attractive to bees and have indeterminate flowering patterns.
• This proposed change would expand the use of the bee-killing pesticide sulfoxaflor to rice, avocados, greenhouses, tree farms and residential ornamental plants sold at retail outlets, which counters the protection of limiting the application to crops that are not attractive to bees and have indeterminate flowering.
• Sulfoxaflor also has been used on an estimated 17.5 million acres of farmland under “emergency exemptions” granted by the EPA over the past couple years. This practice of granting emergency exemptions for pesticide use was recently criticized in a U.S. Environmental Protection Agency’s Office of the Inspector General report:
  “We found that the [EPA’s Office of Pesticide Programs] does not have outcome measures in place to determine whether the emergency exemption process protects human health and the environment”.
• There’s a great poem as a comment here.