The overwhelming majority of federally threatened and endangered species are likely to be “adversely affected” by three commonly used neonicotinoid insecticides, the Environmental Protection Agency said in draft assessments that were met with immediate criticism from grower groups Thursday.

The draft biological evaluations are the first step in the interagency consultation process with federal wildlife agencies required by the Endangered Species Act, which is likely to result in newly proposed mitigation measures when the final evaluations are released.

EPA issued proposed interim registration decisions last year that contained some mitigation measures for five neonics, including the three that are the subject of the evaluations.

The American Farm Bureau Federation, American Soybean Association, National Cotton Council and Minor Crop Farmer Alliance said the analyses fail to consider “real world” use of imidacloprid, clothianidin and thiamethoxam.

Conservation groups, meanwhile, said they show the damaging effects on the substances on wildlife and are more evidence that the substances shold be banned.

The farm groups said the application rates used by EPA in its analyses are well above the actual rates applied.

The draft evaluation for imidacloprid, for example, assumes U.S. soybean farmers use a half-pound per acre, the maximum rate allowed. “However, USDA Agricultural Resource Management Survey (ARMS) data indicates that, in 2018, soybean growers applied an annual average of only 0.054 pounds per acre – less than one-ninth the draft BE’s assumed rate,” the groups said.

ASA President Kevin Scott said the agency did not use the “best scientific and commercial data available,” as required by the Endangered Species Act in overestimating the amount of neonics used.

The overwhelming amount of neonics are used to coat seeds that are planted well before pollinators appear, he said.

EPA said a “likely to adversely affect” (LAA) determination “means that EPA reasonably expects that at least one individual animal or plant, among a variety of listed species, may be exposed to the pesticide at a sufficient level to have an [adverse] effect. The LAA threshold for a BE is very sensitive because the likely ‘take’ of even one individual of a species, which includes unintentional harm or death, triggers an LAA determination.”

Use of that threshold “often results in a high number of LAA determinations,” the agency said in the evaluations.

Bayer, which sells both imidacloprid and clothianidin, two of the neonics assessed, said it “remains convinced of the safety of its neonicotinoid insecticides when used according to label instructions” and also called the BE’s “only one part of the complex, in-depth US registration review; as such, it is important to view these conclusions within the broader context of the regulatory process.”

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Syngenta Group said it would be at least a week before it has finished reviewing EPA's evaluation of its product, thiamethoxam.

In the case of imidacloprid, EPA made LAA determinations for 1,445 species of 1,821 the agency looked at, or 79.3%. For thiamethoxam, the number of LAA determinations was 1,396, or about 77%, while for clothianidin, the number was 1,225 species likely to be adversely affected, or about 67%.

Conservation groups assert, and some research has shown, that neonics harm bees. All three BE’s concluded that they do.

“Imidacloprid is characterized as highly toxic to bees, highly toxic to birds and moderately toxic to mammals on an acute exposure basis,” its BE says. “In terrestrial organisms, thiamethoxam and clothianidin are characterized as highly toxic to bees on an acute exposure basis.”

For all three, EPA said, “Available data suggest potential effects to honey bee and bumble bee colonies that manifest as impacts to numbers of adults and decreases in brood.”

George Kimbrell, legal director of the Center for Food Safety, which sued to force the agency to consider the impacts of the chemicals on endangered species, said the evaluations showed the neonics “are causing drastic ecological harm, both the collapse of bee populations as well as putting literally hundreds of endangered species at extinction risk across the country. The Biden administration needs to complete its process with all due speed in order to start protecting these iconic species.”

And Lori Ann Burd, environmental health director and a senior attorney at the Center for Biological Diversity, said “EPA doesn’t need any more proof. It should ban neonicotinoids right now.” She pointed in particular to declining population of pollinators.

“The American bumble bee, once the most common bumble bee species in the U.S., has declined by an estimated 89% in just the past 20 years. There are more Starbucks locations than monarch butterflies in California. What will it take for the EPA to act on this information and ban these deadly chemicals?”

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