Endangered Species Act:
CLA’s member companies help develop the crop protection products that allow farmers to advance agriculture. When combined with careful stewardship and resource management, crop protection products also contribute to biodiversity conservation and reduce the need to farm additional land. The government protects the nation’s threatened plants, animals and their habitats through enforcement of the Endangered Species Act (ESA) by the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS), collectively called “the Services.” The federal government and general public are required to consider the impacts of their activities on endangered species and consult with the Services regarding those activities if there is a potential to affect an endangered species.
With respect to pesticide registration actions, the consultation process between EPA and the Services is dysfunctional. The current lack of a functional process results in duplicative work conducted by all three agencies which adds an unnecessary financial burden to the government and U.S. citizens. In late 2013, CLA commissioned a report that found that under the current ESA consultation process, the scheduled review of 744 pesticide registration dockets by fiscal year 2023 would cost taxpayers $474 million above current budgetary levels as well as major increases in the current budgets and staffing of NMFS and FWS.
CLA has worked to show EPA and the Services how to resolve their differences in the development of a streamlined common approach that meets the requirements of FIFRA and ESA and makes better use of the resources available to them through the U.S. Department of Agriculture (USDA). In addition, CLA and its members continue to defend member product registrations against ESA-related litigation. In 2013, the National Academy of Sciences (NAS) issued recommendations for improving ESA consultations among federal regulatory agencies and determined that the NMFS and FWS should work more closely with EPA and use a common approach to evaluate potential pesticide risks to threatened and endangered species. The report advocates for a more streamlined process that minimizes independent risk assessments by the Services that unnecessarily duplicate EPA’s efforts.
Nearly one year after NAS issued its recommendations, EPA’s Office of Pesticide Programs, USDA and the Services held a one-day workshop to provide a forum for stakeholders to offer scientific and technical feedback on the interim approaches that were issued in November 2013 by EPA, USDA, and the Services in response to NAS’s report. Scientists from CLA and several member companies participated in the workshop, coordinating stakeholder presentations to include non-governmental organization perspectives. CLA has commissioned a guidance document for development in 2015 for interagency evaluation of crop protection products per FIFRA and ESA to help the agencies move toward a uniform process to evaluate the potential impacts of pesticides on endangered species.
Pollinators are a major driver of a healthy agricultural system; approximately one-third of the crops used to produce foods and beverages are dependent on bees, birds, butterflies and other beneficial insects. Since 2006, U.S. beekeepers have reported average overwintering losses of honey bee colonies ranging up to 35 percent. The 2014 annual survey conducted by USDA, however, reports that overwintering losses dropped to 23.2 percent from 30.5 percent the winter before. This news is encouraging, and CLA’s science and regulatory, legal, government relations and communications teams are working with regulators, beekeepers and farmers to develop common sense solutions to pollinator health.
In February 2014, EPA and USDA collaborated on a Varroa mite summit, continuing efforts of academic, government and industry scientists to explore the state of science and prospects for control and management of this most harmful parasitic pest of honey bees. Several of CLA’s Pollinator Issue Management Team (PIMT) members represented CLA at the summit and spoke to attendees about our industry’s efforts to protect bees from the harmful effects of Varroa mites. In July 2014, the PIMT partnered with the Minor Crop Farmer Alliance, American Farm Bureau Federation and National Cotton Council to hold a pollinator/labeling workshop. More than 40 industry and commodity representatives were briefed on concerns related to pesticide label language required by EPA to protect pollinators, which may impinge on agricultural productivity.
On June 20, President Barack Obama released a Presidential Memorandum, “Creating a Federal Strategy to Promote the Health of Honey Bees and Other Pollinators,” which seeks to foster collaboration across the federal government and with private industry and organizations to support pollinator health. The President’s memorandum presents a comprehensive strategy, calls for broad participation from a number of federal agencies, and echoes comments submitted to the White House from CLA regarding research, stewardship programs and public-private partnerships. CLA is hopeful that this level of federal cooperation along with targeted congressional action will help generate practical, science-based solutions for improving pollinator health.
Collaboration has been a key factor in working toward a solution to pollinator health, and CLA’s commitment to partnership is evident in our bee-focused initiatives. CLA and the crop protection industry worked together in 2013 to find a common understanding of new EPA requirements for neonicotinoid product labels and hosted meetings with leaders of EPA and USDA for a presentation of industry-commissioned information on the socio-economic benefits of these insecticides. CLA also participates on the EPA Pesticide Program Dialogue Committee’s Pollinator Protection Work Group, including sub-groups on education, labeling, and stewardship; contributes actively on CLI’s Global Pollinator Health Strategy Team; and works closely with European Crop Protection Association and CropLife Canada on pollinator issues.
From posters to news releases to letters-to-the-editor, CLA continues to provide a reasonable and consistent voice in the pollinator health debate. In December 2013, CropLife Foundation released “The Role of Seed Treatment in Modern U.S. Crop Production,” an in-depth report detailing the uses of seed treatments, primarily fungicides and insecticides, and the resulting benefits for growers, consumers and the environment. Seed treatments are an important agricultural tool to reduce potential environmental and pollinator exposure through an increasingly precise application method. CLA also works continuously with the American Seed Trade Association to update the Seed Treatment Stewardship Guide, an inclusive guide for farmers and pesticide applicators with instructions on the proper handling and management of treated seeds.
CropLife Foundation’s StewardshipFirst™ initiative defines crop protection stewardship as the ethical management of a pesticide’s life cycle, from the product’s creation to its distribution and sale and the regulated disposal of the container. CropLife StewardshipFirst™ actively promotes the sensible use of pesticides through container management, agricultural warehouse accreditation and responsible use programs and practices. Ultimately, the goal of CropLife StewardshipFirst™ is to maximize crop protection benefits and minimize potential risks from using crop protection products.
CLA and StewardshipFirst™ advocate for strong legislative regulations and standards to protect public health while providing farmers with the tools they need to perform crop diagnostics. In order to accomplish this goal, CLA has developed cooperative relationships with other national trade associations, grower groups, consumer advocacy organizations and regulatory bodies on the federal, state and local levels to advance modern agricultural solutions. CLA works with industry leaders to help ensure that product innovations meet farmer needs; collaborates with scientists to ensure that pesticides are safe; and provides outreach to policymakers on Capitol Hill to shape key policy decisions that benefit farmers and consumers.