American Scientist

A growing number of Americans are now keeping honeybees at their homes, observing the foraging worker bees and enjoying delicious honey harvests. The Obama family is no exception. The White House installed a beehive in 2010 on the South Lawn near the kitchen garden. Recently though, President Obama has looked far beyond his yard. After establishing the interagency Pollinator Health Task Force last year, co-led by the U.S. Department of Agriculture and the U.S. Environmental Protection Agency, the White House released its Pollinator Research Action Plan in May of this year. An interview with entomologist May Berenbaum, who was involved with the plan, was posted on American Scientist’s blog in June. As a former federal biologist and member of the U.S. Environmental Protection Agency’s Pollinator Protection team in the Office of Pesticide Programs, I am pleased to see pollinators getting attention beyond the EPA and at the highest levels of government. However, I am disappointed with the strategy.

While it is laudable to have focused and measurable goals for such a far-reaching federal strategy, in terms of lands and agencies implicated, the three goals of the White House pollinator plan are surprisingly limited in scope. They specifically target: reducing honeybee deaths, increasing monarch butterfly populations, and managing federal lands to benefit pollinators.

The last goal is certainly the most ambitious, including the simultaneous release of science-based best management practice guidelines for land management. More importantly, it includes the goal of creating what is being billed as a “monarch highway,” stretching from northern Minnesota to southern Texas in the right-of-ways along existing highway Interstate-35. While no one can be sure that monarchs will directly follow I-35, creating this “safe” migration corridor, consistent with monarchs’ normal northward-southward journey, may provide some support to dwindling populations. Highway rights-of-way are often managed with broad-spectrum herbicides, indiscriminant mowing, and practices that vary widely by state—but are generally designed to promote road safety rather than biodiversity. This new initiative to manage the roadside to protect monarchs will thus likely result in habitat protection that benefits many additional species, both pollinators and otherwise.

The first two goals are less impressive, as they are solely focused on promoting two charismatic pollinators that already receive a lot of public attention and research funding. I agree with fellow entomologist and University of Hawaii professor Daniel Rubinoff, who wrote an op-ed lamenting the oversize amount of resources that monarchs are receiving. As I mentioned in my previous post, there are literally thousands of other animal pollinators in need of conservation efforts and competing for a finite amount of notice and money.

I am not the only one unhappy with the details of the federal pollinator plan. However, other people aren’t happy with the federal strategy for a very different reason: They hoped it would call for an outright ban on neonicotinoid pesticides, similar to the one that is in place in the European Union. But that’s not how pesticide regulation works in the United States, the majority of which is done by the EPA. The laws that govern which pesticides are allowed and how they can be used are different here than in Europe. In order to understand how the EU and USA end up with differentregulatory outcomes, it’s critical to understand the scope of the two main federal statutes that give the EPA authority to regulate pesticides: FIFRA and FQPA.

FIFRA stands for the Federal Insecticide, Fungicide, and Rodenticide Act, which was first passed in 1947 and spells out how pesticides are distributed, sold, and used. Meanwhile, FQPA stands for the Food Quality Protection Act, which was made law in 1996 and included an important provision for improving regulations to protect infants and children from exposure to pesticide residues in food. FQPA is considered landmark legislation, as it resulted in a major reexamination of pesticide residues, with EPA assessing 99 percent of pesticide tolerances over the next decade.

How a pesticide is approved can look highly bureaucratic from the outside. It likely would have remained unintelligible to me, if I had not gone to work for the Office of Pesticides. But with that experience, I can say that the process is actually fairly straightforward. How the EPA assesses pesticide safety can be broken down into three major components. The first is performance: the pesticide needs to successfully control the target pests as proposed. The second is effects on human health: examining how much pesticide remains as residue in each of the food or animal products on which it is used. The third is environmental impacts: modeling the nontarget effects the pesticide might have on wildlife or in soil and water. Effects on pollinators would be included in this last category of testing and evaluation. Although I am oversimplifying for brevity, if you are interested to learn more, the University of Florida’s Pesticide Information Office has a great website introduction to pesticide labeling and a general overview of the testing process.

How pesticides are banned may look similarly obscure. However, it is also straightforward: In order to initiate cancellation (which is in and of itself a long, multistep process), the EPA must show that there is “unreasonable adverse effect.” Pollinator advocates argue that this threshold has been reached with regard to nontarget effects of neonicotinoid pesticides on honeybees and other organisms. Others dispute this conclusion. The debate lies around what constitutes unreasonable. Which species and how many need to be affected before action should be taken? These are hard questions that deserve continuous reexamination. One unquestionably positive aspect of the U.S. system of regulation is the opportunity and rightto public participation in the process, which has recently been expanded and is not a given in most other countries.

As a scientist who studies pollinators and pesticides, I would go one step further and say that participating in policy formation and review is the best way to support pollinators. The goals set by the White House reflect common failures in science policy formation: a shortage of applicable research to guide the process and a lack of participation from a diverse group of qualified scientists and engaged citizens. I would advocate three paths to bringingexpertise and energy directly to the federal pollinator task force on this issue. The first is that scientists can serve on the EPA Scientific Advisory Panel; scientists may nominate themselves or colleagues using this link. The second is to understand the study criteria that the agency can include in their data evaluations, so that one’s research is applicable to policy decisions, not just topically relevant. The third, which citizen scientists can also do, is to submit comments on policies under review.