The EPA is requesting public comment on a biological evaluation of three seed treatment pesticides, called neonicotinoids. Neonicotinoids were created in the 1990s to require less mass spraying and possible damage to the environment. They are seed treatments, so they protect plants when they are most vulnerable to pests and that means less strain on the environment with spraying.

The sounds great, but so does limiting them when you read "each of these chemicals is likely to adversely affect certain listed species or their designated critical habitats" because that reads authoritative.

Well, yes and no. Though groups who monetize their opposition to science will make a big deal out of the term Biological Evaluation, it is mostly a legal process. EPA is ostensibly independent, but they must use a process mandated by Congress. (1) And groups like Center for Biological Diversity manipulate the process so they can 'suggest' risk even though science does not show it. 

Here are iimportant things to know.

The reason they are examining three neonics pesticides and not all seven is because of a court case, not science-based concern about the environment or belief that nitro-based pesticides are more harmful than cyano-based.

It is worth your time. Because this is about pesticides, you can guess there will be about 400,000 comments. While most of the comments will be collusion by anti-science activists, EPA really only considers 'all pesticides should be banned, EPA is controlled by Big Science' type stuff as one comment, even if there are 399,000 of them. 

So your comment will not be diluted by garbage manufactured at attorney-run activist groups like Center for Biological Diversity. They not only read constructive comments, they act on them.(1) 

This is a long process. In 2021, Melathion was the first compound to be evaluated using Marine Fisheries and US Fish and Wildlife Services. The process began in 2016. So it proceeded during two Democratic administrations and a Republican one. Yes, Democrats are perceived as more ban happy, and it is true that 70 percent of all Endangered Species listings happened in just two administrations, but those were not determined by science the way pesticides are, and by taking a long time the interference by politicians in both parties is modulated.

The Endangered Species Act is a legal blunt instrument that has little science and it is the reason these products are required by law to get a new look, even if no government scientist believes they are a problem. EPA is required to look at 'hazard' regardless of risk, so if even one creature is impacted every 15 years, EPA is going to examine it.

Real world data does not matter, but it should. EPA does not get involved in risk so real world data is not used. However, one benefit to the Services getting involved is that they will look at population level real world data. Farmers know that no one is using neonics at the levels that studies EPA is required by law to include in their evaluation have claimed can cause harm. In the real world, no bee flies around in a cloud of pesticides for over 12 hours but if you want to create provocative claim and get media attention, you do just that and assume science journalists will just rewrite the press release.

Hawaii is the reason that the Endangered Species Act is such a mess in the US - and their arbitrary reason for declaring an endangered species impacts everything and erodes confidence in the system.

Pandas are not endangered but they would be if they lived in Hawaii. Hawaii declares everything and anything at risk of extinction if there are less than 2,400 of them and there are only 2,000 pandas. Due to a number they picked out of the air, Hawaii now has so many plants it calls endangered that their number to de-list has become the national standard.

Averages are dumb in science - men have less than two testicles on average - and Hawaii has polluted trust in science by exploiting the poor wording in Endangered Species law to game the system for the lawyers opposed to science that dominate Hawaiian culture.

In the real world, 75 percent of species have never needed 2,400 to be viable, some have never had that number in their history. Only 19 percent of species have needed more than 2,400 to be sustained. Yet that has become a legal number despite it being irrelevant 81 percent of the time.


(1) Case in point: a few months ago, for another biological evaluation comment, I noted that they were considering a species at risk from the pesticide but that one those species, the southern acornshell, has been extinct for almost 50 years.  During that time, the EPA had done two registrations and two SAPs and that species was never mentioned. It seems like a sloppy mistake to suddenly make in 2021, but it isn't really the fault of EPA. They got a list handed to them, again by law, and have to use it. Still, after my comment they went through the process of getting it removed. 

 They listened. Then they fixed it. That means it is worth your time.