Canandaigua Lake Watershed Association (CLWA) has reviewed scores of scientific studies on neonicotinoid insecticides, with a focus on understanding the benefits and costs of these compounds to the economy and to the environment. We are convinced that the excessive and largely unnecessary use of neonicotinoid insecticides, particularly as a prophylactic seed coating for corn, soybean and wheat, threatens those resources. Our watershed must be protected, not only for ourselves but for future generations as well. After careful consideration, the CLWA Board of Directors has decided to support passage of the proposed Birds and Bees Protection Act (S1856), and we urge you to do so as well. Please see the addendum for our detailed examination of the issues and the scientific information that informed our decision.
We are mindful of the difficulties this legislation might impose on some farmers, and we know that you share our concerns. Many family farms already operate on thin profit margins, and they can ill afford to lose some percentage of their crops to insect pests. We recognize that passing this legislation will impose a big shift in the way the agricultural community farms their land, so we ask that you use your influence in the legislature to secure the resources farmers will need as they transition to using uncoated seeds and to employing alternative, environmentally sustainable, practices. Using insecticides as a prophylactic insurance policy is both an economically and environmentally unsound strategy, and we are convinced by the scientific evidence that it must cease, and be replaced by integrated pest management strategies.
You have always been a true champion for this region, and we are grateful for your tireless efforts in protecting the environmental as well as the economic resources of our state. Thank you for considering our opinion on the Birds and Bees Protection Act. We urge you to vote in favor of this important amendment to the New York Environmental Conservation Law. We will be calling your office soon, and hope to find a time to meet with you in person to discuss our position.
Respectfully,
Lynn Klotz
President, Board of Directors
CLWA Board of Directors:
Neil Atkins, Katrina Busch, Susan Carpenter, Dee Crofton, Linda Dworaczyk, Rob Gray, Susan Martenson, Douglas Merrill, Sally Napolitano, Joel Pasternack, Ellen Polimeni, Shaynee Rainbolt, Wade Sarkis
The Argument for Banning Select Neonicotinoids in New York
At the time of their development in the 1990s and early 2000s, neonicotinoids were viewed as a welcome replacement for the much more toxic and environmentally dangerous organophosphates, carbamates, and organochloride insecticides. Neonicotinoids have recognizable and irresistible benefits. They are systemic toxins, which means they are transported into all plant tissues and provide protection against a wide array of insect pests, a fact which can lead to a reduction in the number of insecticide applications in fields facing intense pest pressure. At reasonable concentrations, they target mainly insects and related taxa, and they are largely safe for many other species, including humans. Had they been used judiciously as one component of an integrated pest management (IPM) strategy, there would be no need to ban their use except under conditions where there are no other options readily available.
Instead, neonicotinoid-coated seeds were sold to farmers as an insurance policy against the possibility that their crops might become infested, even if that possibility was remote. Several national and international studies, including a very comprehensive report published in 2020 by a team of scientists at Cornell University, demonstrate that the economic benefits of corn and soybean seed coats are minimal at best, and are often beneficial only when a field endures high pressure from several pest species.1,2 That is not typical of New York farm fields. While they may protect a farm against an unanticipated insect attack, their benefits as an insurance policy against these relatively rare occurrences are grossly outweighed by the clear and unrelenting damage they inflict on the environment. There are occasions when neonicotinoid insecticides are the only course of action against invasive pests, like the spotted lantern fly and the hemlock wooly adelgid, which attack fruit and forest trees. This bill will not prohibit the use of these insecticides under emergency circumstances.
Point 1: Prophylactic seed and turf/ornamental plant treatments with neonicotinoid insecticides in the absence of an integrated pest management strategy is an economically and environmentally unsound practice
There are significant negative outcomes from the use of neonicotinoids in insect control. One is that non-target species (not insect pests) are adversely affected. Harmless insects, including our economically-vital pollinators, as well as useful insects that serve as biological controls of insect pests, are being lost in large and economically-unsustainable numbers.3 The numbers of birds and bird diversity are likewise threatened.4 The US EPA determined in 2022 that between 1,225 and 1,445 endangered plant and animal species (67-79%) are likely adversely affected by neonicotinoids.5
Since 90-95% of the insecticide applied to the seed coat remains in the soil instead of in the plant, it alters soil health, infiltrates nearby non-crop plants, and eventually washes into groundwater and surface water. Neonicotinoids degrade slowly, and they are persistent, so repeated use year after year creates toxic landscapes and waterscapes. One study shows that U.S. farmlands are now 48 times more toxic to all insect species than they were in the 1990s.6 Conservative estimates are that more than 90 tons of these insecticides accumulate in New York farmlands, green spaces, and bodies of water each year.1
Point 2: The New York landscape has become toxic to harmless and economically-beneficial species of insects, including pollinators that contribute $400 million to the NY economy
Because of their persistence and high-level water solubility, neonicotinoids are now prevalent in dangerously high concentrations in most lakes and streams in the U.S. and worldwide.7,8 The presence of these toxins is causing a loss of vital invertebrate species that form the foundation of the entire freshwater aquatic ecosystem, adversely affecting macroinvertebrates, fish, amphibians, birds and mammals.9,10 Furthermore, neonicotinoids have been detected worldwide in well water as well as raw and finished municipal drinking water. Recent studies show that most routine drinking water treatments remove only a fraction of neonicotinoids, and that significant removal requires advanced granular activated carbon filtration not available to many small and rural municipalities.11,12 There is some evidence to suggest that chlorinating certain neonicotinoid formulations may create more toxic end-products. Canandaigua Lake alone serves 78,000 residents with drinking water and supports millions of dollars in tax and tourist revenues. This resource is at risk.
Point 3: Neonicotinoid insecticides have entered the aquatic environment in high enough concentrations to threaten entire aquatic ecosystems as well as drinking water supplies
There is one additional argument for banning these products. A recent study showed that nearly 50% of human subjects tested, including children as young as three years of age, had urine samples that contained neonicotinoids.13 Earlier generations of insecticides were topical, and could be washed off the surfaces of fruits and vegetables. Systemic neonicotinoids infiltrate the plant tissues and are consumed when eaten. Studies of these compounds on experimental mammals suggest several potential health problems, including risks to human reproduction and the development of the brain, particularly in fetuses and children.14,15,16
Point 4: Due to their pervasiveness and high concentrations in food and water, neonicotinoids now pose a risk to human health
Neonicotinoids are banned in many European countries and in Canada, and there is little evidence at this time for adverse economic impacts.17 The NYSDEC has prohibited their use in some downstate counties due to water table concerns. The agency has banned one neonicotinoid formulation, chlothianidin, from being applied anywhere in NYS as a spray for agricultural, commercial and homeowner use because of concerns about groundwater contamination and risks to fish and wildlife. However, the agency is unable to restrict its use as a seed coat. The USEPA has chosen to provide all neonicotinoid seed coats with a FIFRA exemption as “treated articles or substances.” This means that nearly 70 tons (of the 90 ton
total) of neonicotinoid insecticides that enter NY soil and water each year from coated seeds cannot be regulated, or even monitored, as pesticides.18 The Birds and Bees Protection Act will close this loophole.
A ban on the use of neonicotinoid insecticides as defined by the Birds and Bees Protection Act will impose some hardships on some farmers and turf growers who believe they have few if any alternatives available to them. However, incorporating Integrated Pest Management (IPM) strategies have been proven to produce better crop yields than seed application while also significantly improving the welfare of pollinators, the quality of food, and the preservation of aquatic and terrestrial environments.19,20 The core feature of Integrated Pest Management is to use insecticides as a last resort, and only after the pests have been identified and it has been determined that they pose an undue economic penalty. Insecticides are then employed in a targeted, economically-feasible, and environmentally-sensitive fashion.21
Point 5: Alternatives to the unnecessary use of neonicotinoids do exist, and they need to be employed to protect the ecology and the economy of the Canandaigua Lake watershed
Weighing the largely insignificant economic benefits to New York farmers against the considerable environmental detriments, there is simply no good reason for farmers to continue to use neonicotinoid-treated corn, soybean and wheat seeds. A similar argument can be made for their use on turf and ornamental plants, unless environmental emergencies dictate their usage. The bill provides this safety measure.
References
1 Grout, T.A., et al., Neonicotinoid Insecticides in New York State: Economic Benefits and Risk to Pollinators. 2020. Cornell University.
2 Mourtzinis, S., et al., Neonicotinoid Seed Treatments of Soybean Provide Negligible Benefits to US Farmers. Nature Scientific Reports. 2019. 9:11207. https://www.nature.com/articles/s41598-019-47442-8.
3 Sanchez-Bayo, F., The Trouble with Neonicotinoids: Chronic Exposure to Widely Used Insecticides Kills Bees and Many Other Invertebrates. Science 14 November 2014. Vol, 346, No. 6211. Pp. 806-807. https://www.jstor.org/stable/24745155.
4 Eng, M., et al., A Neonicotinoid Insecticide Reduces Fueling and Delays Migration in Songbirds. Science. 13 September 2019. Vol. 365, 6458, pp.1177-1180. DOI: 10.1126/science.aaw9419.
5 United Stated Environmental Protection Agency Report: EPA Finalizes Biological Evaluations Assessing Potential Effects of Three Neonicotinoid Pesticides on Endangered Species. 2022. https://www.epa.gov/pesticides/epa-finalizes-biological-evaluations-assessing-potential-effects-three-neonicotinoid.
6 DiBartolomeis, M et al., An assessment of acute insecticide toxicity loading (AITL) of chemical pesticides used on agricultural land in the United States. PLoS One. 2019 Aug 6;14(8):e0220029. doi: 10.1371/journal.pone.0220029. PMID: 31386666; PMCID: PMC6684040.
7 Borsuah, J.F. et al., Literature Review: Global Neonicotinoid Insecticide Occurrence in Aquatic Environments. Water. 2020 12(12), 3388; https://doi.org/10.3390/w12123388.
8 Hladik, M.L., Kolpin, D.W., Kuivila, K.M., Widespread occurrence of neonicotinoid insecticides in streams in a high corn and soybean producing region, USA. Environ. Pollut. 2014, 193, 189–196.
9 Barmentlo, S. H. et al., Experimental Evidence for Neonicotinoid Driven Decline in Aquatic Emerging Insects. Proceedings of the National Academy of Sciences. October 25, 2021. https://doi.org/10.1073/pnas.2105692118.
10 Yamamuro, M., et al., Neonicotinoids Disrupt Aquatic Food webs and Decrease Fishery Yields. Science. 1 November 2019, Vol. 366, 6465. Pp. 620-623. DOI: 10.1126/science.aax3442.
11 Klarich, K.L., et al., Occurrence of Neonicotinoid Insecticides in Finished Drinking Water and Fate during Drinking Water Treatment. Environmental Science & Technology Letters. 2017, 4, 168-173. DOI: 10.1021/acs.estlett.7b00081.
12 Kim, J., et al., Concentrations and Distributions of Neonicotinoids in Drinking Water Treatment Plants in South Korea. Environmental Pollution. November 2021, Vol. 288. https://doi.org/10.1016/j.envpol.2021.117767.
13 Ospina, M., et al., Exposure to Neonicotinoid Insecticides in the U.S. General Population: Data from the 2015- https://doi.org/10.1016/j.envres.2019.108555.
14 Gu. U.H. et al., Reproductive Effects of Two Neonicotinoid Insecticides on Mouse Sperm Function and Early Embryonic development In Vitro. PLoS One. 2013 Jul 29; 8(7):e70112. doi: 10.1371/journal.pone.0070112. PMID: 23922925; PMCID: PMC3726447.
15 Cimino A.M. et al., Effects of Neonicotinoid Pesticide Exposure on Human Health: A Systematic Review. Environmental Health Perspectives. 2017, 125 (2). https://doi.org/10.1289/EHP515.
16 Zhao, G-P., et al., Toxicities of Neonicotinoid-Containing Pesticide Mixtures on Nontarget Organisms. Environmental Toxicology and Chemistry. 2020, 39 (10) pp. 1884-1893. DOI: 10.1002/etc.4842.
17 Kathage J. et al., The Impact of Restrictions on Neonicotinoid and Fipronil Insecticides on Pest Management in Maize, Oilseed rape and Sunflower in Eight European Union Regions. Pest Management Science. 2018 Jan;74(1):88-99. doi: 10.1002/ps.4715. Epub 2017 Oct 13. PMID: 28842940; PMCID: PMC5765491.
18 Jactel, H. et al., Alternatives to Neonicotinoids. Environment International. 2019. Vol. 129, pp. 423-429. https://doi.org/10.1016/j.envint.2019.04.045.
19 United States Environmental Protection Agency Report: EPA Response to the April 2017 Petition from Center for Food Safety and Others Relating to EPA Regulation of Pesticide-Treated Seed. 2022. https://www.regulations.gov/document/EPA-HQ-OPP-2018-0805-0104.
20 Pecenka, J.R., et al., IPM Reduces Insecticide Applications by 95% While Maintaining or Enhancing Crop Yields Through Wild Pollinator Conservation. Proceedings of the National Academy of Sciences. 2021. Vol. 118. https://doi.org/10.1073/pnas.2108429118.
21 U.S. Environmental Protection Agency Report: Integrated Pest Management (IPM) Principles. https://www.epa.gov/safepestcontrol/integrated-pest-management-ipm-principles.