As in other parts of North America, beekeepers in New York have been experiencing unsustainable losses of honeybee colonies. In 2014-15, annual colony losses in New York reached 54 per cent, according to the Bee Informed Partnership survey. And though losses were lower in preceding years, they consistently exceeded the economic threshold of 15 percent loss. At great expense, beekeepers have been able to recoup their winter and summer losses, but for declining native bee species the prospects are even less rosy. For example, the rusty-patched bumblebee (Bombus affinis), once common in New York and the Northeastern US, is now a candidate for the endangered species act.
An impressive worldwide body of scientific evidence implicates neonicotinoids as a major contributor to the decline of honeybee and wild bee populations (e.g. Lu et al., 2014). This is due to a combination of their acute toxicity, sub-lethal, intergenerational, neurotoxic, and immune system effects, their systemic behavior in plants and their persistence in soil and water [See the IUCN's Worldwide Integrated Assessment of the Impacts of Systemic Pesticides on Biodiversity and Ecosystems, 2015 (1)]. This relatively new family of insecticides is now believed to be the most commonly used global pesticide.
Unlike Europe and Ontario, Canada, the US has not acted to restrict the use of neonicotinoids. However, the federal government has specifically urged states to create pollinator protection plans. Some states are working on them and a few have completed them (2).
But at the first meeting of the New York State's Pollinator Task Force (Aug 6 2015), commercial beekeeper Jim Doan was flabbergasted to learn that state officials had appointed two representatives of the national pesticide industry to the 12-member panel. "It's very difficult for a beekeeper to think he can get a fair shake," he commented.
Consequently, I decided to see for myself. I attended the September 11 and October 1 Task Force meetings and listened to the recording of the August 6 meeting.
The New York State Pollinator Task Force
The NY state Task Force was set in motion by Governor Andrew Cuomo.
"Pollinators are crucial to the health of New York's environment, as well as the strength of our agricultural economy," Cuomo said in his announcement. "By developing a statewide action plan, we are expanding our efforts to protect these species and our unparalleled natural resources, and making an important step forward in our commitment to New York's ecological and economic future."
Thus, on April 23, 2015 Cuomo directed the state departments of agriculture and markets (NYSDAM) and environmental conservation (NYSDEC) to develop a state pollinator protection plan, involving stakeholders and research institutions in the process.
By July stakeholders were receiving invitations to serve on the state Pollinator Task Force, which was constituted with 12 "advisors" from the private and NGO sectors. Officials from NYSDAM and DEC serve as co-chairs. In addition, Cornell IPM program director Jennifer Grant sat with Task Force members and played an advisory role, though not as a Task Force member.
Task Force Membership
In terms of its personnel, three groups represent pesticide interests on the Task Force: CropLife America and Responsible Industry Supporting the Environment (RISE) are the pesticide industry's agricultural and non-agricultural trade groups respectively. Both are headquartered at the same Washington DC office. The NYS Agribusiness Association is the third agrochemical group. Dan Digiacomandrea, a technical sales specialist at Bayer CropScience, one of two makers of neonicotinoids, attended one Task Force meeting as that group's alternate.
Agriculture also got three seats, with appointees from the state farm bureau, state vegetable growers association and the fruit sector. The state vegetable growers consistently sent an alternate, Rick Zimmerman. His resume includes many years as a Farm Bureau lobbyist followed by a career as NYSDAM deputy commissioner. Today he heads up the Northeast Agribusiness and Feed Alliance. The state turf and landscape association has a seat, too.
Three NGOs were appointed to the Task Force: The Nature Conservancy, Audubon New York and the Natural Resources Defense Council. Member Erin Crotty, who is executive director at Audubon NY, previously served as DEC commissioner under Republican Governor Pataki. NRDC, which has sued EPA on neonicotinoids, was represented by one of two alternating attorneys at each meeting. Like the aforementioned industry representatives, no one from these organizations appeared to have any specific expertise on pollinators. The first two NGOs proposed ways to increase pollinator habitat but did not indicate concerns about pesticides.
Finally, beekeepers were apportioned two seats. With 12 hives, hobby beekeeper Stephen Wilson has chaired the Apiary Industry Advisory Committee for over 15 years. The other representative is Empire State Honey Producers Association president Mark Berninghausen, a small commercial migratory beekeeper from St. Lawrence County. This group has about 100 members out of the 3,000 or 4,000 beekeepers in the state.
The state has also been accepting public comments (though this was apparently not publicized and no deadline has been announced). These comments must be submitted to the governor's office, not to the Task Force directly (initially NYSDAM was accepting them). As of this writing, these comments have not been shared with task force members.
Given the make-up of New York's Pollinator Task Force - one-quarter pesticide industry plus one-third agriculture and turf care industries - and the allegiances of the two convening agencies, the complex issue of pesticides was therefore always likely to be handled with kid gloves.
The Timeline and the Content
At the kickoff meeting task force advisors had a chance to lay out their positions on what the state should do to protect bees. The second meeting focused on research needs and the third dealt with habitat enhancement and best management practices (BMPs).
Presentations took up much of the second and third meetings. For example, a series of managers from six state agencies described their land management practices and initiatives to provide habitat in respect to bees.
A highpoint was the talk by Cornell's new honeybee extension entomologist Emma Mullen. A Canadian who just moved to the US, she had been part of the team of scientists that worked on Ontario's Pollinator Health Protection Plan. Particularly illuminating was her explanation of the province's new program to decrease the corn and soybean acreage planted with neonicotinoid-treated seeds by 80% by 2017. She also outlined current Cornell research on bees.
NYSDAM commissioner Richard Ball, a vegetable grower, chaired the meetings and NYSDEC deputy commissioner Eugene Leff played a supporting role. Leff, whose portfolio includes pesticide regulation, previously presided over another stakeholder task force charged with dealing with an equally polarizing issue: preventing pesticide pollution of Long Island's groundwater. As with the pollinator task force, pesticide and agricultural interests were well represented on Long Island. (The 126-page strategy document that came out of that task force's work indicates that these interest groups succeeded in delaying any restrictions on suspect pesticides.)
To frame the initial Pollinator Task Force discussion, Commissioner Ball reiterated what has come to seem like the official US dogma on bee decline - there is no single cause and we must consider multiple areas of concern. While the list of pollinator threats varies, USDA, EPA and institutions like Cornell cite factors such as habitat loss, pests and pathogens, pesticides, genetics and/or climate change when they state that view.
Indeed, the most notable feature of the meetings was the overall reluctance to delve into the problem of pesticides except in so far as they induce immediate bee kills. Only two members of the 12-member task force (beekeeper Stephen Wilson and a Natural Resources Defense Council attorney) urged any limitations on the use of neonicotinoids.
Meetings Without Minutes or Structure
A number of additional aspects of these meetings support the idea that the Task Force exists primarily for appearance's sake. First, no one appeared to be taking official notes and no minutes were made available, despite advisor Stephen Wilson's request for minutes at the second meeting. (Recordings are posted on NYSDAM's website.) Second, no one wrote down ideas on a whiteboard or easel to capture them as they came up. Third, Task Force discussions were freewheeling, unstructured and all over the map.
The state's short timeline also challenges the notion of a deliberative process informed by science. The whole process, from the first of three Task Force meetings to the submission of priority recommendations to the governor, is scheduled to take only three months (3).
Yet the meeting agendas presume that in an hour or two of meetings these advisors will contribute content to the pollinator plan, generate a meaningful research agenda, and cobble together BMPs to protect bees. For all this to happen fails to pass the laugh test.
Thus, in the final portion of the third meeting, Task Force advisors were asked to consider a series of BMPs listed on a handout prepared in advance (presumably by NYSDAM or DEC) but not distributed until the actual meeting. Task Force members had not gotten through the first item on the list when time ran out (4).
Perhaps there was no real need to carefully craft a plan because the conclusions appeared to have been pre-ordained. In his closing comments at the third meeting, DEC deputy commissioner Leff referred back to the governor's blueprint for the state pollinator plan. In particular, Leff highlighted the BMPs designed to reduce pesticide exposure to managed pollinators through better communication among beekeepers and farmers. Leff stressed the need for landowners and pesticide applicators to know where hives are located and how to contact beekeepers before they spray. Beekeepers would have to be ready to move their hive, he said (5).
If his recommendations go into effect the onus of protecting bees from pesticides would fall on beekeepers. This is at odds with the historical assignment of such responsibility to pesticide applicators. In fact, pesticide labels carry legal weight in prohibiting pesticides considered acutely toxic to bees from being applied when flowers are in bloom or bees are present.
Leff's proposal to shift responsibility is radical, but it is not new; the essential elements of Leff's proposal are contained in the Guidance for State Pollinator Protection Plans, a June 2015 document produced by the State FIFRA Issues Research and Evaluation Group (6). (SFIREG is a committee of the Association of American Pesticide Control Officials. SFIREG used to have the document on its website, but has since removed it.) Among the six "critical elements" it identified for pollinator plans are methods for growers to know if managed pollinators are located near where pesticides are used and for contacting beekeepers prior to applying pesticides.
Thus it seems that pesticides are sometimes acknowledged to be causing at least part of the decline in pollinators, but the approach proposed by Leff and SFIREG ignores much of what is known-that systemic insecticides like neonicotinoids can harm bees months after application, for example via the planting of treated seeds (Lu et al., 2014), and that insecticides are not the only agrichemicals that harm bees. For example, a new study has found that exposure to low levels of glyphosate impairs honeybee navigation (Balbuena et al., 2015). And of course, warning beekeepers of impending pesticide applications does nothing to protect native pollinators, though ostensibly these plans are intended to protect them, too.
As the meeting was ending, I was able to pose a practical question. How easy is it for beekeepers to move their hives when they get a call that pesticides will be applied? Roberta Glatz, an older woman who serves on the state Apiary Industry Advisory Committee, replied from the audience.
She said that beekeepers aren't necessarily where their bees are. "They may be in North Carolina raising queens." She outlined other concerns as well. There are limited places where you can put your bees, and it takes a lot of negotiation to put in a bee yard. Logistics also come into play. Mud can impede access. Hives are heavy and usually have to be moved in the middle of the night when the bees are home. (And beekeepers often have day jobs, another beekeeper told me once the meeting ended.)
So while even the beekeepers of New York are having a hard time getting a fair shake in a protection plan for their own bees, in terms of pesticides it seems that Bombus affinis and other native bees should expect even less of one.
(1) Worldwide Integrated Assessment of the Impacts of Systemic Pesticides on Biodiversity and Ecosystems 2015 (IUCN's Task Force on Systemic Pesticides)
(2) The Pollinator Stewardship Council is the best clearinghouse of state government pollinator protection activities around the country. Another resource is a May 2015 white paper from the National Association of State Departments of Agriculture. It claims to provide links to the MP3s ("managed pollinator protection plans") of North Dakota, California, Mississippi, Florida and Colorado, but of these states only North Dakota seems to have developed an actual plan.
(3) The timeline called for the state to circulate the NYS Pollinator Protection Action Plan Recommendations to task force members on October 19. In turn, they would have 7 days to comment. As of October 28, a beekeeper on the Task Force reported that he hadn't received anything from the state yet.
(4) Discussion of specific BMPs was overshadowed by the contentious issue of whether beekeepers should be required to register all honeybee hives with the state and disclose their locations. BMPs listed on the handout pertained to such things as beekeepers' care for their colonies and control of mites and other parasites/diseases, landowners and state agencies enhancing pollinator habitat and forage, the correct and judicious use of pesticides and of Integrated Pest Management, and the roles of beekeepers, landowners and pesticide applicators in protecting honeybees from pesticides.
Balbuena, M. S., Tison, L., Hahn, M. L., Greggers, U., Menzel, R., & Farina, W. M. (2015). Effects of sub-lethal doses of glyphosate on honeybee navigation. The Journal of Experimental Biology, 10 July 2015. doi: 10.1242/ dev.117291
Lu C, Warchol KM, Callahan RA (2014) Sub-lethal exposure to neonicotinoids impaired honey bees winterization before proceeding to colony collapse disorder. Bull Insectol 67:125-130.