EPA Opens Up On Neonics

Agency Explains Purpose of Report, Prepares for Final Review

Emily Unglesbee
By  Emily Unglesbee , DTN Staff Reporter
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The future of neonicotinoid soybean seed treatments will be decided by 2016, after the EPA finalizes its registration review of the chemicals. (DTN photo by Bob Elbert)

ST. LOUIS (DTN) -- The Dec. 22 deadline for the public comment period is drawing near for EPA's controversial October report on the use of neonicotinoids in soybean seed treatments.

As dozens of comments pile up on the agency's website, EPA representatives, including the scientists who wrote the study, agreed to a long-sought interview with DTN on the report. They clarified the methodology and purpose of the report and explained the logic behind some of its most disputed claims.

The 18-page report has drawn scrutiny and criticism from the agricultural community for its firm stance that neonicotinoids in soybean seed treatments provide no tangible yield benefits to farmers and are used mostly as an unnecessary insurance policy by Midwestern growers.

Since the report was released on Oct. 16, a data technology company called Ag Informatics has begun releasing a series of studies on the benefits of neonicotinoids in agriculture, commissioned by three major neonic manufacturers, Bayer Crop Science, Syngenta and Valent USA. Preliminary results from their studies suggest a yield advantage of 3% for neonicotinoid-treated soybean seed versus untreated seed, the researchers have announced.

The EPA received the Ag Informatics studies and the data sets behind them, said Bill Jordan, deputy office director for programs for the EPA's Office of Pesticide Programs. The agency is evaluating that data, along with public comments, and will complete a risk assessment for the pesticides before any final decisions are made on the re-registration of neonicotinoids in soybeans.

"We are on track to make a regulatory decision in 2015 or 2016," he told DTN.

THE PROMPTING

The lone release of the EPA's analysis of the benefits of neonics in soybeans surprised many in the agricultural community. The report is part of a re-registration review of three neonicotinoids chemicals, imidacloprid, thiamethoxam and clothianidin.

Re-registration reviews are required by law once every 15 years for all pesticides on the market, Jordan explained. However, the neonic review was put on the fast track by the agency, because of the suspected role of neonics in issues of pollinator health in the U.S.

"There's been... a lot of concern and controversy about this group of pesticides, so we moved them up in terms of priority for re-evaluation in the review process," Jordan said.

Registration reviews require both a benefits assessment and a risk assessment for the chemicals in question.

A brief, preliminary review of the benefits of neonics in the major row crops prompted the agency to zero in on their use in soybeans, Jordan said.

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"In the case of the neonics, there were a number of claims made that the products really didn't provide any meaningful benefits and for that reason, EPA should get rid of them," he explained. "We did a very quick review and were able to satisfy ourselves that the neonicotinoid insecticides did provide benefits on some level -- we didn't go through any cost analysis -- in most crops, but when we looked at soybeans, the data didn't convince us that there were clear benefits."

THE SCIENTISTS BEHIND THE REPORT

Entomologist Clayton Myers and economist Elizabeth Hill, from the EPA's Biological and Economic Analysis Division, were tapped to lead an in-depth assessment of the benefits of neonics in soybeans.

Although he specializes in Integrated Pest Management (IPM), Myers' primary area of study has been tree fruit pests, not row crops, he told DTN. Hill holds a master's degree in environmental economics.

Jordan maintained that the scientists and their team were well equipped to take on the benefit assessment, despite the lack of anyone specializing in row crops or neonicotinoids. He pointed to Myers' IPM background, information the agency received from the North Central IPM Center and the expertise of the researchers' whose work the assessment evaluated.

"The reason we put it out for public comment is if there are additional sources of information or other ways of looking at the available information that would give us an improved basis for conclusion," he added.

THE REPORT'S METHOD

Myers and Hill scanned the Entomological Society of America's Arthropod Management Tests (AMT), an editor-reviewed journal that publishes yield and efficacy data for pest management methods in the U.S. They searched for any data on neonicotinoids in use against soybean pests such as the bean leaf beetle and soybean aphid, Myers explained.

The scientists also examined the peer-reviewed scientific literature and tapped into some questionnaire data from the North Central IPM Center. Finally, they also reached out to Canada's Pest Management Regulatory Agency (PMRA).

Unlike the EPA, the PMRA requires companies provide efficacy and product performance data in order to register their pesticides in Canada. The EPA scientists requested this data on neonicotinoids from PMRA, but discovered it "wasn't immediately germane to the analysis" because "most of the information that they had does not carry product performance all the way to yield," Myers explained.

They did not seek any efficacy or yield performance data from the companies that manufacture and sell neonicotinoid seed treatments, he confirmed.

THE REPORT'S CONCLUSIONS

Agricultural company representatives, farmers, and the Ag Informatics researchers have criticized the EPA neonic assessment for using data sets that were not large-scale enough to make a national assessment.

"EPA is not aware of any publically available information that looks at comparative soybean yield protection (neonicotinoid seed treatments or alternatives) on a systematic area-wide basis, which would provide numbers to cross check against the data used in the assessment," Jordan told DTN in an email. "We will evaluate such data if it is submitted as part of the public comment period."

Critics have also voiced concerns that the report underestimates the cost and limitations of alternative foliar insecticides, which the EPA scientists recommended for controlling soybean pests targeted by seed treatments.

Specifically, the EPA scientists pointed to the availability of foliar sprays such as organophosphates, pyrethroids, neonicotinoids and sulfoxaflor for alternative pest control.

However, they downplayed the cost of scouting and additional field passes to spray these insecticides, which the Ag Informatics researchers estimated would add around $3.30 an acre for farmers currently using neonic seed treatments.

The EPA report maintains that additional field passes would be largely unnecessary given farmers' ability to tank-mix the insecticides with other pre-existing spray routines, such as herbicide applications. Myers pointed specifically to glyphosate applications, which he said "would likely be going on at the same time of the year" as foliar sprays to control early season pests targeted by neonic seed treatments.

In defense of their decision not to include the cost of scouting in their analysis of the cost of spraying alternative insecticides, Myers pointed to the fact that seed treatments are only active in a soybean plant for the first three to four weeks of growth.

"These seed treatments are not going to provide season-long protection from all the pests, so growers are still going to have to scout soybeans regardless of whether or not they choose to use a neonicotinoid seed treatment," he said.

Some have noted that the removal of neonicotinoid seed treatments would leave farmers with little recourse for seedling pests such as the seed corn maggot or wireworm, which the Ag Informatics researchers estimate prompt one-third of neonicotinoid seed treatments. The EPA scientists did not give this concern much weight in the report, instead concluding that "soil pests such as seed maggot and wireworms have not historically driven pesticide usage in soybeans."

You can read the EPA assessment of the benefits of neonicotinoids here: http://goo.gl/…, and view or make a comment in the public comment section here: http://goo.gl/….

You can find the Ag Informatics studies on neonics here: http://growingmatters.org.

Emily Unglesbee can be reached at emily.unglesbee@dtn.com

Follow Emily Unglesbee on Twitter @Emily_Unglesbee

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Emily Unglesbee