Another good target for EPA reform

Europe gives Trump Administration excellent tutorials on how not to regulate pesticides

Guest essay by Paul Driessen

With reform-minded folks in charge of the Executive and Legislative Branches, unelected, unaccountable, un-removable bureaucrats may soon be exerting far less power over our policies, regulations, lives and livelihoods. Energy and climate are high on the fix-it list. Another important topic is insecticides.

The European Union and Canada have provided object lessons in how not to regulate these important chemicals. Scott Pruitt and his new team over at EPA will certainly want to avoid their malpractice.

For nearly a decade, manufactured controversies have raged around a relatively new class of pesticides called neonicotinoids. These advanced systemic crop protectors are absorbed into the plant itself and thus target only pests that suck or chew on crops, particularly during the plants’ early growth phases.

That minimizes impacts on beneficial insects – like crop-pollinating bees. domesticated and wild bees are barely exposed and thus unlikely to be harmed when neonic seed or soil treatments are used, in contrast to what can happen when manmade or “organic” chemicals are sprayed on crops. But despite this minimal risk, anti-pesticide activists have tried for years to blame neonics for recent honeybee health problems.

In 2013, their well-funded advocacy campaigns played a major role in causing the EU’s decision-making European Commission to impose a “two-year” ban on using neonicotinoids with bee-attractive crops.

Not surprisingly, almost four years later, there is no sign that the Commission will reconsider its position, despite accumulating evidence that managed bee populations are not now and never were in any danger of collapse or extinction. As my longer article on explains, that evidence includes the EU’s own 2014 and 2015/16 studies, and nearly a dozen large-scale field studies around the world.

Going even further, the European Food Safety Authority now says bees are at grave risk from neonics used on European crops that do not attract bees, such as winter cereals, beets, potatoes, leafy vegetables, maize (corn) and sorghum – whether the neonics are seed treatments, foliar sprays or soil applications. There may be no actual evidence of harm, the EFSA says, but a risk to bees “cannot be excluded.”

Just as crazy, the agency’s 2013 Bee Guidance Reference Document lets bureaucrats decide which studies and data can be accepted and deemed relevant – and which can be ignored. It also means chemicals that can control crop pests may never be approved; and only ineffective chemicals will be approved (along with chemicals that are or could be dangerous for bees, but are deemed to be “natural” or “organic”).

That explains why EU member nation governments for three years have refused to approve the BGRD. However, in the wacky world of EU regulations, the mere fact that member governments have refused to approve a guidance document doesn’t prevent unelected Eurocrats from using it to advance their agendas.

The BGRD specifies a three-tier scheme for evaluating potential impacts on bees. At Tier 1, extremely low laboratory test thresholds pretty much automatically force evaluations under more complex, costly and time-consuming second and third tiers. At the highest tier – full field testing – the guidance specifies wide spatial separation requirements between test fields and control fields, where beehives are located.

To ensure experimental integrity, the BGRD requires that neonic test areas must be free of other pesticide-treated, bee-attractive crops, and far enough away from such areas that tests are not affected. But that means scientists need areas four times larger than Paris, France. That’s virtually impossible in densely populated Europe. Catch 22!

To pass the “no risk” test, evaluators must then prove the pesticide being tested doesn’t produce more than a 7% fluctuation in a beehive’s populations. But natural fluctuations can easily reach 15% from frigid cold snaps, infestations by Varroa destructor mites, or even beekeepers applying chemicals to hives to control mites or other pests and diseases. So it’s impossible to show that population changes greater than 7% were not due to neonic use on crops. Catch-22 again! But it gets even worse.

Euro regulators even ignored some of the best available data: large-scale field studies done under Good Laboratory Practices. Nearly a dozen such studies consistently demonstrate that no observable adverse effects on honeybees result from field-realistic exposures to properly applied neonic pesticides.

But instead of accepting these studies, EU bureaucrats rely on laboratory studies that other researchers have shown consistently overdose bees with pesticides. That lets regulators focus on adverse neonic impacts that can justify bans, but under conditions that bees would never encounter in the real world.

In another case, five carefully conducted, inter-related studies published in the journal Ecotoxicology covered a large-scale 2013-14 northern Germany field study of honey bees, bumble bees and solitary red mason bees that forage in oilseed rape (akin to canola) fields treated with the neonic Clothianidin.

The elaborate, sophisticated studies assessed neonic residues from bees and hives under actual field conditions. They found that the residues were well below levels that can adversely affect bees – and that neonics “did not cause any detrimental effects on the development or reproduction” any of the three species. Enter Joseph Heller, yet again.

The studies were paid for by Bayer CropLife, because EU agencies generally don’t fund such studies (though they do give millions a year to environmentalist groups). Voila! Anti-pesticide activists can challenge and dismiss the well-documented experimental results – and the EFSA can ignore the results in reaching its latest conclusions on risks to bees that are not attracted to neonic-protected crops. All because of a guidance document that EU member states never approved!

Unfortunately, bad science and regulatory policy are not confined only to the other side of the Atlantic. HealthCanada recently imposed a phased-in ban on another relatively new neonic pesticide. It did so using an EU-like Catch-22 approach, despite any actual evidence of real-world harm – and without considering insect infestations, crop losses, the absence of safe alternative pesticides, or the fact that other insecticides actually are harmful to bees and/or aquatic life.

All this suggests there is ample reason to worry about the U.S. Environmental Protection Agency’s own inbred inclinations. A late 2014 EPA study/memorandum contends that neonic pesticides were ineffective in controlling soy crop pests. It was refuted by scientists who had better data and repudiated by the US Department of Agriculture. But EPA did not withdraw or cancel the 2014 soy efficacy memo.

A 2015 preliminary EPA assessment essentially exonerated neonic seed treatments, as posing virtually no risk to bees. But another one said neonics on citrus trees are potentially dangerous, even though neonics as the only solution for “citrus greening” disease that is decimating lemon, orange and grapefruit trees.

These EU, Canadian and EPA actions offer important lessons for Trump-Pruitt pesticide regulators.

* Stick to risk-based standards embedded in U.S. legislation, and avoid any drift toward the “precautionary principle,” which looks only at alleged or inflated risks from using chemicals – never at the risks of not using them, and never at risks that could be reduced or eliminated by using the chemicals.

* Focus on replicable, evidence-based, field-tested science. Don’t let agenda-driven activists pressure EPA (or the Agriculture Department) into excluding the best and most relevant available data.

* Revise or eliminate standards, policies and regulations that were based on less than defensible, real-world data and analyses; that do not fully consider the costs and benefits of using (or not using) available chemicals; or that fail to balance demonstrated agricultural, consumer and environmental considerations.

EPA policies on neonics and other issues would be a perfect place to begin changing the way Washington works.

Paul Driessen is senior policy analyst for the Committee For A Constructive Tomorrow (, and author of Eco-Imperialism: Green power – Black death and other books on the environment.


91 thoughts on “Another good target for EPA reform

  1. but a risk to bees “cannot be excluded.”…..

    sigh…about the same risk as bees being eaten by whales…but that can’t be excluded either

    Someone raised these idiots.

      • I presume that as soon as the Chief Justice of the SCOTUS declares Donald Trump to be the POTUS; he (the Pres) will issue an executive order sending the US Marshalls to the State Department, and the EPA and escorting every person with an employee badge out to the parking lot and removing their credentials from them.
        The janitorial service, can then load potted plants, and dog pictures and such paraphernalia not the property of the USA, in to boxes to be placed outside in the parking lot for the ex employees to tke away with them.

        The Donald, can then send them a Presidential tweet telling them to not ask for a reference.


    • Piece of propaganda from the Sierra Club this week begs recipients to sign a petition to have this class of pesticides banned, with context-free jeremiad claiming the pesticides are solely responsible for the “endangered” status of bees. And begging for funds, of course. I’ll keep the nifty package of wildflower seeds they enclosed . . .

    • They are lawyers who don’t understand science, or even reality, trained as they are in black and white issues.

    • You mean “Too late” I suppose. [snip . . . try and be polite. Snark doesn’t add a thing to the debate . . . mod]

  2. There is a lot to be done. But I’d concentrate on the stupidity of demonizing the badness of CO2; that’s the priority. Don’t lose sight of that and get distracted by side issues. Not yet. First and most important is to grab the brass ring from the climate alarmists. Nothing comes close to being as important as that.

    • I disagree. If the brass ring is too close to being grabbed, the environmentalists will begin using a new demon. They have introduced many ideas about bad chemicals, how wonderful nature is, etc. They always have a backup plan. Failure to recognize that leaves people who oppose their actions at a huge disadvantage playing catch-up.

  3. Well if they cannot be fired, they can be repurposed.
    Environmental protection Agency, such possibilities.
    Saving Desert Sand, but counting it first.
    Protecting polar bears.. from starvation.
    Searching for GlobalWarming in summer (think mosquito)
    Reducing taxpayer funded harm to the social environment, by voluntary early retirement.
    Just having most of these “civil servants” write a description of their own jobs, then publicizing these job descriptions would be fascinating.

    Here in Canada, our last PM, a conservative, repurposed a criminally useless group of “civil servants”.
    From staffing a firearm registry to administering federal payrolls.
    Our “public servants” are having hysterics as their payroll is now getting the same standard of care and competence that law abiding gun owners used to.
    For some reason they are most unhappy.
    So the possible repurposing of EPA employees has potential for great things.
    Suppressing forest fires?

    • “Searching for GlobalWarming in summer (think mosquito)”

      It’s my understanding Alaskan mosquitos are issued FAA tail numbers.

      • I guess only the big ones can feed on the furry fauna, but there’s few that won’t breed when it’s above freezing and stagnant water. Doesn’t have to be in Alaska, either.

      • “It’s my understanding Alaskan mosquitos are issued FAA tail numbers.”

        And run the length of the bed to get airborne.

      • Not really, but the smaller ones will just eat you on the spot, because they are afraid the big ones will just take you away from them if they carry you back to the swamp.


    • “Protecting polar bears.. from starvation.” are you suggesting our excessive government workers go out to commune with the polar bears like that idiot did in Alaska with the brown bears, I don’t feel sorry for him when the bear ate him but it is too bad he brought his girlfriend with him to enhance the bears protein intake. Yes Darwin awards often are well earned, and a lot of our bureaucrats could be in the running, but sending them out to do a polar bear census and to personally poll, the bears is a bit much, even though I think a good number of our bureaucrats might volunteer for such a job. Maybe just outright firing them may seem a bit cruel but at least it not directly feed them to the bears.

  4. I have actually researched this in some depth because of interest in the wild honey bee colonies on my farm, and the many cultured bee colonies nearby. (alfalfa and crabapple honeys).. Bees have problems including invasive parasites like varroa mite, hive stessors like insufficient diversity of nutrition (a probable cause of CCD during almond grove flowering), and overuse of indiscrimanent insecticides. Seed coat neonictotimides are absolutely not among them, for reasons in the guest post. And most crops sprayed with insecticides are NOT bee friendly in the first place. Have to agree that ‘green’ assults on newer, environmentally more friendly insecticides are mostly just an assult on well grounded science. Ditto the ‘carcinogen’ assult on glyphosate, one of the safest herbicides ever invented. Extensively tested. Extensive epidemiology. None of that true science matters to green GMO objectors spreading their ‘false news’.

    • Rud, when I hear the lawyers’ radio ads to sue Monsanto if you ever used glyphosate and have cancer I can’t help but think of the same type of correlation vs. causation uncertainty that exists with CO2 and global temps. Very shaky science, but very determined lawyers.

      • Correlation vs. causation? Y’mean like living in a wood frame house is “associated” with cancer, hypertension, old age, low sex drive, alcoholism, obesity and schizophrenia? ;-)

      • Pop—Agreed. Lawyers are very seriously damaging science by suing for everything imaginable. They don’t need evidence, just a jury that will buy the line they are selling.

    • Really the only problem with Glyphosate is that nature is rather quickly developing GMOs of its own which are resistant. Are we actually speeding up evolution?

      • PP, totally agree. Is already a >10 million acre farm disaster, more than ten weeds. Wrote about it already in 2012 in Gaia’s Limits. We do everything possible on my farm to slow that evolution. Crop rotation, herbicide rotstion, limited GMO contour planting….We will still eventually succumb. Simply too close to genetic ‘ground zero’,

      • It still makes more sense than than grass and broadleaf selective herbicides with soil carry-over potential. Besides, without what Monsanto has developed, the world would not be at all as well off. Same thing with the fossil fuel “fad”.

      • Just helping evolution along a bit. Bugs and weeds can evolve very fast and when they evolve faster than the chemists can keep up we’ll see some real farm crises. In my career I’ve heard too many times that “This is the solution.” It was originally claimed that pheromones were a permanent solution to many pests because we “are stopping them from breeding, so they can’t evolve resistance.” They forgot to tell the bugs which just changed their stink slightly and kept on breeding. Then it was the Chlordimeform ovicides that could never breed resistance because “…it kills their eggs.” So the bugs just laid stronger eggs and kept breeding. When I started in ag work 1/4 pound/acre of a popular carbamate insecticide would virtually sterilize a field. By the time I retired a full pound/acre gave mixed results. Same with the synthetic Pyrethroids that once were devastating to insects but now many species can practically swim in it. Time was when a light application of 24D would take out every weed in my yard. Now it takes the max rate plus a synergistic agent and ideal conditions.

        Even if the neonics are deregulated in 10-15 years we will need something else — or have to go hungry.

      • I believe propane works a treat, heat sterilising tends to avoid the genetic problems and in combo with glyphosate can slow down the immunity factor – Fact is that immunity isn’t always what it seems. Glyphosate susceptibility varies among weeds, there are certain species of weeds that are not particularly susceptible, when you spray glyphosate you remove the competition to the less susceptible species and whala, the species mix obviously skews toward less susceptible species. If every now and again you take to the susceptible species with burning propane before they can seed then they too can be controlled.

    • So sayith: ristvan – December 26, 2016 at 6:09 pm

      I have actually researched this in some depth because of interest in the wild honey bee colonies on my farm, and the many cultured bee colonies nearby. (alfalfa and crabapple honeys).. Bees have problems including invasive parasites like varroa mite, hive stessors like insufficient diversity of nutrition (a probable cause of CCD during almond grove flowering), and overuse of indiscrimanent insecticides.

      Ristvan, I have also been pondering, studying and researching the per se CCD problem for the past 20+- years, …… ever since it became the “buzzword” of the lefty liberal “We Hate American Capitalism” crowd.

      And being a learned Biologist it has always utterly AMAZED me as to why in hell anyone would actually “label” the problem associated with the “care n’ keeping” of hives of Eastern European Honey Bees as being “Colony Collapse Disorder” (CCD) …… and then claim its “cause” is directly attributable to insecticides and/or Honey Bee parasites or diseases.

      “DUH”, labeling the problem “Colony Collapse Disorder” sounds like something a Certified PhD Psychiatrist dun thunked up to appease the gullible.

      Ristvan, they called it Colony Collapse Disorder because that is exactly what happens. The bee colony in the hive “collapses” (meaning slowly decreases in numbers) because the Honey Bees fly away from the hive and NEVER RETURN. There is NEVER any dead bees in or around the hives to be collected and studied to determine what killed them.

      If the assumed death of said Honey Bees was the fault of insecticides or parasites then there should be plenty of “dead bees” inside or around the bee hives, ….. BUT THERE IS NONE.

      So the question is, ……. why didn’t those bees RETURN to their hives? And the logical answer is, ….. something “screwed-up” their biological GPS navigation system and thus their “return” GPS coordinates were wrong and they simply flew off into the “wild blue yonder”.

      Iffen you want to solve the CCD problem, ….. then do your “testing” inside of a large “enclosed” sports stadium where the Honey Bees can’t get away from you ……when they get away from their hives.

      Cheers, Sam C, ….. the ole Biologist who actually learned the science of the natural world around him.

      • Sam C says:

        the logical answer is, ….. something “screwed-up” their biological GPS navigation system

        Any idea what might cause that? (From someone who tended a hive many yrs ago)

      • Sam: I agree though we do not have large cereal or fruit cultivation in our area. Extremes of temperature fluctuation kills our bees more frequently than anything else. We live in northern Vermont and every year we experience significant fluctuations in temperatures we lose a hive. Second in loss rate like this year is when a hive has an old queen and weakens and the hive is overrun by neighboring wild or domesticated bees.


      • Colony Collapse Disorder was a known “thing” as early as 1865, and was a “problem” in the early 1900’s.
        But “sometimes this happens and no one knows why” doesn’t fill the checkbooks of dot-org’s.

      • @ beng135

        “Any idea what might cause that?

        Beng, after a Honey Bee returns to its hive after finding a “new” food/pollen source, it performs a per se “dance” to instruct the other bees as to the exact direction (and maybe flying time and distance) to where that food/pollen is located.

        It’s a given fact that the bee “marks” the per se GPS location of its hive before it goes searching for food. The proof of this is the so called “beeline” which gets it name from the ole timers who went looking for a hive of wild honeybees to steal their honey.

        Anyway, the HB uses the Sun’s solar irradiance, ….. and its “angle of incidence”, ….. to somehow triangulate its physical location and the direction (and maybe flying time and distance) to and/or from its hive or food source.

        And it’s probably a SPECIFIC frequency in said solar irradiance that it uses. And IF SO, …. then any change in that solar frequency …… OR ……. iffen there is a new cosmic or man-made source of that solar frequency that the HB uses, ….. then that would surely screw up the flight path of the hive-bound or pollen-bound Honey Bee and it would continue to fly n’ fly until it fell out of the air and dead on the ground. Thus, resulting in CCD.

        And it is my learned opinion that that is exactly why a “closed environment” (sports stadium) is prerequisite to solving the CCD problem.

        Hopes the above helps, Sam C

  5. “…unaccountable, un-removable bureaucrats…” Let’s hope both these conditions are overturned, with those accountable for the fake science and capture of their agencies by environmentalists being fired or even jailed, and that the unholy grip of the SEIU on our federal employees broken and replaced with a well-managed meritocratic system.

  6. unaccountable, un-removable bureaucrats

    Want to have some fun with recalcitrant federal employees?
    Historically, federal employees were not allowed to form unions. That was changed in 1962 when president Kennedy signed Executive Order 10988.

    As we have found out, executive orders can be rescinded by a new executive. Surely, such an idea must be tempting for the new president-elect.

    Let the games begin!

    • Just an opinion, but I think it should be either civil service OR union, not both.

      I’m still crusading to have the EPA hq moved to the Heartland. Lenexa, Kansas would be my first preference.

  7. “Clothianidin is an alternative to organophosphate, carbamate, and pyrethroid pesticides. It poses lower risks to mammals, including humans, when compared to organophosphates and carbamates. It has helped prevent insect pests build up resistance to organophosphate and pyrethroid pesticides.”

    It is important to notice that Clothianidin is being marketed as an alternative to these other pesticides. One can appreciate the newer neonicotinoids but would you evaluate it the same way if you knew that other effective competitor pesticides are being outlawed at the same time? That is the question.

    And they are being banned. Not only the EU and the EPA, but also the Department of Agriculture is attempting to incrementally move all countries to phase out conventional agriculture. The DoA has even signed five-year agreements with China to phase out conventional growing and ranching methods. Tell that. to the incoming Trump Administration.

    Organophosphates, in particular, are an inexpensive and effective control for the maggots that attack cabbage, broccoli, cauliflower and brussel sprouts, as well as the highly destructive olive fruit fly — just to name two uses. Organophosphates have been safely used for decades. You have to look at the whole picture.

  8. I am going to have to disagree with everyone here on the neonuc threat to honeybees.

    Our undrstanding of colony collapse disorder to be sure is incomplete. But what we do know is that the forager bees leave and never return.

    The world is a big place when you are only a few grams in weight but you can fly up to 20 mph. And the wind can be blowing even harder than that to fly against to return and shifting, and foraging up to a kilometer from the hive is not uncommon. Yet they go out, and return dozens of times a day, everyday.Bees have obviously evolved complex navigation and homing skills we do not understand. The impact of even the smallest amounts of neonuc seem to confuse whatever this complex but precise navigation skill entails. Sure it take may take considerable higher dose to affect reproduction or outward development. But there is evidence for impacts to navigation-homing from neonics.

    And neonics sprayed on to corn then turned into corn syrup, which is then used as a energy source by bee keepers to feed their hives while in transport seems to be another way in which neonics can poison the bees. Overspray between adjacent crop fields may be another way neinics can enter the honeybees. Further the dosage effects may be cumulative in their impacts to homing and navigation. Absence of evidence is not absence of effect. And in the case of honeybees, something clearly is killing them and neonics stills sits pretty high on the list of suspects.

    • Varroa mite which is a relatively new parasite is far more likely to be the cause of colony collapse.

      Also, the intensification of agriculture so that the bees only have crops that all come into season in a very short period is another strong candidate.

      However, by far the strongest candidate, given that most of the work is being done by female workers whilst the male bees just sit on their arses waiting to mate, is the pernicious effects of feminism and “sex-equality”.

    • joelobryan. I am a beekeeper and it would be nice if you were right and it were that simple, but it is not. All the beekeepers I know who have bees near or abutting neonic treated fields have no problems with them. The only issues are when they are used not in accordance with label directions which is true for all pesticides.In fact, their bees have never been better because of the difference between the neonics and what was used before.

      The comment about neonics in HFCS was shown to be false. Bees foraging behavior is influenced by large doses of neonics, from which they recover (bad drunk), but the same effect has been noted with several pesticides.

      Most of what you talked about came from lab studies where the bees were fed unrealistic amounts of the neonics. In the real world, for the past more than ten years, about 17 million acres of canola in Canada has been treated with Imidacloprid (the most common neonic) and pollinated by bees and no issues have been reported by the beekeepers. That puts the lie to most all the propaganda which is what it is.

      We are losing our bees mostly because of the Varroa mite and viruses. But I appreciate the attention to bees, even if the reasons are completely wrong, because of the good research that has been promoted to “save the bees”. Even though, if you do any homework, you will find that the number of managed colonies in the US has been increasing, not decreasing.

      The parallel narratives and “science” between the neonics (which are less harmful to farmers and the environment than the alternatives) and climate change (where CO2 is actually beneficial as is a warmer climate) fit perfectly and they are driven by the same suspects.

      • I’ve also read that genetic homogeneity among colonies of commerically-bred bees, and the fact that they are trucked around the country with the same population exposed to and stressed by MANY different pesticides many play a significant role.

    • joel I agree with you too, as someone who assists a beekeeper of some 40+yrs experience
      i find this:
      For nearly a decade, manufactured controversies have raged around a relatively new class of pesticides called neonicotinoids. These advanced systemic crop protectors are absorbed into the plant itself and thus target only pests that suck or chew on crops, particularly during the plants’ early growth phases.

      the entire plant INCLUDING the NECTAR and Pollen is also contaminated BY the neonics
      and bees sample many flowers many times a day!
      they dont carry a nectar drop back they ingest it, thereby absorbing it and contaminants with it.
      Bayer had to admit that it WAS a problem and swapped advice to use it INground rather than sprayed
      even dust from in soil applications was an issue.
      the admitted it killed small mammals and pollinators.

      I used to run a soils lab
      looking at soil treated with glyphosate and other chem
      the biota was almost non existent
      compared to untreated/ nutrient poor soil thats had no chemicals in 30yrs that were massively alive and active.
      what I saw had my jaw dropping and dismayed me as to the health of what we eat from those soils.
      and the residue containing the systemics then goes into soils..
      and research showed trees a distance away had absorbed the neonics from groundwater as well
      so its NOT exactly a nice product
      to the person thinking organophosphates are ok?
      ask the medicos treating people with neuro toxic issues from using those chemicals how they see them.
      long term bioaccumulators.

      • ozspeakup: I fully believe your criteria for concern will lead to the conclusion we should simply oft ourselves because everything we do is damaging unless we just give up, turn to hunter/gatherer and let evolution remove the weak. That’s a very depressing view of what human beings are worth, but not uncommon. Sadly.

      • Effects of glyphosate on soil microbial communities and its mineralization in a Mississippi soilhere.

        Conclusion: “These results indicate that glyphosate has only small and transient effects on the soil microbial community, even when applied at greater than field rates.

        Full abstract: “Transgenic glyphosate-resistant (GR) soybean [Glycine max (L.) Merr.] has enabled highly effective and economical weed control. The concomitant increased application of glyphosate could lead to shifts in the soil microbial community. The objective of these experiments was to evaluate the effects of glyphosate on soil microbial community structure, function and activity. Field assessments on soil microbial communities were conducted on a silt loam soil near Stoneville, MS, USA. Surface soil was collected at time of planting, before initial glyphosate application and 14 days after two post-emergence glyphosate applications. Microbial community fatty acid methyl esters (FAMEs) were analyzed from these soil samples and soybean rhizospheres. Principal component analysis of the total FAME profile revealed no differentiation between field treatments, although the relative abundance of several individual fatty acids differed significantly. There was no significant herbicide effect in bulk soil or rhizosphere soils. Collectively, these findings indicate that glyphosate caused no meaningful whole microbial community shifts in this time period, even when applied at greater than label rates. Laboratory experiments, including up to threefold label rates of glyphosate, resulted in up to a 19% reduction in soil hydrolytic activity and small, brief (<7 days) changes in the soil microbial community. After incubation for 42 days, 32–37% of the applied glyphosate was mineralized when applied at threefold field rates, with about 9% forming bound residues. These results indicate that glyphosate has only small and transient effects on the soil microbial community, even when applied at greater than field rates.

    • I notice you laid out a bunch of “what if’s” with no substantiation. This post specifically mentions using fact based science and not just the precautionary principle.

    • @ joelobryan
      December 26, 2016 at 11:00 pm: I am sorry, Joel, but what you just wrote is just another meaningless ramble of vague hippy suppositions. We expect better here, except from trolls. My fellow Plant Scientists/Pathologists/Entomologists have been looking hard for years, and cannot substantiate what you seem to be inferring. Neonics are safe, and we will be the first to say otherwise if proven so. The time to respect real scientific endeavour is returning.
      CCD is something we old hands understand. But patsies who falsely imagine the weather conditions which favour it have been banished by CO2 magic, are akin to their fellows who think other drugs can expand their minds, or make them fly. Enough of that foolishness, please. The times of wild jet stream weather are also back.

  9. “Absence of evidence is not absence of effect.” Does that mean that presence of evidence is not presence of effect?

    • You have to examine the population, or individuals within it, to discern effect. There may be evidence of application all over the place, but if the population doesn’t change, you have no detectable effect.

  10. Almost everything the EU does can be explained by commercial profit. In other words, is there a big corporation in the EU who is pocketing money either by rules outlawing the old (and usually far cheaper) alternative, or rules banning a new highly beneficial alternative that undercuts the entrenched EU interests.

    • There is the A. Ltd. that wants to sell a new, highly profitable product. There is B. Inc. that successfully sells a well established product that generates their income since quite a long time. Now A. and B. are doing every trickery they can possibly conceive to kick the competitor out of the market. As it is with the A. Larmists, the fearmongers have done better, for quite a while, although they are supposedly wrong. So it’s the company that fearmongers best that will be the first behind the post, not necessarily the one with the least harmful ‘poison’.

      • A good comment I think. The reality is that our whole world is overrun with information, much if not most of which is hurled at us by various special interest groups. Most of these seem to have no regard for limiting their point of view to the truth or what is provable or balancing their narrative with a perspective contrary to what they see as their interest. We try to discern the truth and what path to follow from thousands of false signposts set for us by communication experts, lawyers, unions, corporations, governments and special interest groups; none of which have any interest in being truthful. Then they wonder why we rebel and vote against our institutions. THEY DO NOT SERVE OUR INTERESTS!

    • @ Scottish Sceptic
      December 27, 2016 at 1:01 am: You are right of course Jock who questions. , Such victims of crony capitalism and also neomarxism, have no longterm future as competitive economic or social units. A tragedy in the making.

  11. I farm about 800 acres of heavy arable land in central southern England, and one of my immediate neighbours is a professional beekeeper. He doesn’t just farm bees – he does research into hive design and a hundred and one other aspects of his trade. When the neonic ban came in here, I carefully raised the topic. expecting a great cheer from him, equal in volume to the groan that we oilseed rape growers had let out when this oh-so-vital insecticide was withdrawn. I was somewhat surprised when it turned out that he, too, was furious at the ban. He despaired that we farmers would now be driving through the crop several times with our cropsprayers during the first couple of weeks of the OSR growing season, applying pyrethroids in a blanket application, rather than the nice targeted technique that seed treated with neonics was. How on earth, he asked, can that be better for the wildlife – big and small?

  12. I would like to see reform at a deeper level. At the core. Instead of debating the merits of any particular regulation, a debate on the government’s authority to regulate at all.

  13. This is off topic, but why is the full stop always omitted in the introduction to any discussion. See the current five articles and they all omit a full stop after ‘ A guest … by ….. but the next sentence starts with a capital letter.
    Why the incorrect punctuation ?

  14. What is the point having the EPA involved in what is clearly a responsibility of the USDA. As we can see from the comments in this forum, farmers are the ones who know about farming. Drain the swamp.

  15. If the Animal Kingdom could talk, would the bees and the polar bears be having a good laugh down at the bar about pulling another one over on the humans…?

  16. The incredible knowledge base, from physics to bee’s, of persons speaking rationally on this site just reaffirms why I visit every day. The comments on bee’s and farming have been enlightening. As the old saying goes, you learn something new every day. Thank-you all.

    • Rachel Carson did not kill more people—bureaucrats using her book did. Don’t blame the author of the book. She didn’t ban DDT, the government and the Greens did. It is their doing.

      • @ Sheri
        December 27, 2016 at 6:43 am: Oh come on. Sheri, it was her (totally false) idea! She need not have lied, and now you may or may not know what lies do – they kill.

      • Brett exactly and sometimes the liar know that very fact! In Rachel case I not giving her the benefit of doubt.

  17. EU institutions are far from perfect. Western arguments are often refreshing, but now I don’t know where to start:

    How can EPA be a good reform target because of something EU, Canada etc have done, particularly for pesticides? How about US commitments in the UN Rotterdam convention and Stockholm protocol? DDT anyone? Or why limit it there? Pick any

    Now let’s analyse the EU: EFSA remit is limited to food and feed in accordance with the Regulation (EC) No 178/2002. Was EFSA giving an opinion on bee feed?

    Never mind the points above, the following puzzles me the most personally: thanks to Lisbon agreement, directly and democratically elected EU parliament – with the final say in the bureaucracy management nominations – obtained right wing majority in May 2014. The first time in the history. Why are fingers pointing from the Atlantic now? /rant

    • @jaakkokateenkorva December 27, 2016 at 6:46 am

      EU Parliament ?

      A Parliament that can NOT initiate laws (that privilege belongs to the unelected EU Commissioners)
      A Parliament that may only debate such EU Commission Proposals as the EU Commission see fit to allow ?
      A Parliament that has no authority to change ANY EU Commission directive ?
      A Parliament that has no right to stop an EU Commission directive coming into force ?

      That ‘democratically elected Parliament’ ? The one with zero powers; zero authority and a mandate to spend EU taxpayers money debating what exactly ?

      Isn’t it great; we can elect a Member of the European Parliament; to do what exactly ? Nothing that is recognisable as any form of Parliament that some one from a Common Law Nation would recognise as a sovereign law making body; that is for sure.There was/is more honesty in the CCP;PRC electoral process (or even Idi Amin’s One Man; One Vote; Once; the One Man being Idi Amin [or to be a bit more current – Robert Mugabe fits the bill as well]) and the European Parliament is about as democratic as the Democratic Republic of Korea.

      • If this is discussion about pesticide legislation in the US, they would originate from UN recommendations. That was my point.

        What comes to EU parliament, who wishes to extend their power to further e.g. to overlap national parliaments?

        But don’t take me wrong. Fancy your Nigel Farage sitcom. On democracy. About Mugabe in Zimbabwe. The notorious Commonwealth member until 2002. Perhaps Mugabe only wanted Zimbit from Commonwealth. Heading his system locally himself. Instead of un-democratic relics. Like the prospect of Charles and the House of Lords – heritable power closer to the arrangements in the Democratic People’s Republic of Korea than anywhere else in the western world.

  18. Paul, this appears to be yet another example of giving credence to the use of the precautionary principle in science. Sounds warm and fuzzy to the lay folks and ignorant politicians, but it absolutely has no place in either economics or real science if you consider that those of us living in the real world routinely apply risk to almost everything we do–and often pay the price if we rush to judgment and fail to consider it. But Risk involves a pragmatic application of 3 factors: Probability of Occurrence, Severity of Potential Impact, and actual Exposure potential. If we know that some catastrophic event only occurs on Jupiter, the probability of it occurring on Earth must be considered to be almost negligible since realistic exposure potential is so low. If the impact, given that the even occurs, is high, one must reconsider the likely exposure and the actual probability of occurrence. A catastrophic consequence requires additional investigation to ensure the actual probability and exposure assessments are realistic–neither overblown or underestimated. However, if the most likely impacts are small, different people can come to different conclusions as to the level of risk one is willing to accept. However, the precautionary principal essentially does away with all the rational analysis and adopts a “Guilty Until Proven Innocent” decision matrix.

    Climate alarmists routinely skip the scientific labor of observation, synthesis of an hypothesis, testing, reproducibility of predicted results by coworkers and skeptics alike, before graduating to a supportable theory–where there is no Settled Science that 97% of any population agrees with. You won’t find 97% of real scientists who consider Einstein’s gravitational theory “settled science” although we all accept it as a well supported working theory that may very well be absolutely true. But the moment we take it as gospel, we stop being scientists who must be willing to follow the data wherever they it lead us.

    Bottom line: the impact of a direct hit by a meteor is catastrophic but the chances are infinitesimally small. Under the precautionary principle, none of us should bother reproducing! The impact of automobile accidents is huge–and occurs on a daily basis–but the relative risk to individuals is moderate at most. By the precautionary principle, automobiles should be banned and we’d all have to walk to work. NGOs and environmental alarmist groups love the precautionary principal because they can demand that any activity they personally disagree with be shut down by bureaucratic regulators and Big Government without ever bothering with risk or cost benefit analyses to determine whether the recommended approach will actually change the parameters of risk at all. All they have to do is speculate that the consequences might be bad–and Voila! So when do we start holding them to the economic consequences of their judgments when their calamities never occur?

  19. EPA Mistake

    The EPA erroneously asserts Global Warming Potential (GWP) is a measure of “effects on the Earth’s warming” with “Two key ways in which these [ghg] gases differ from each other are their ability to absorb energy (their “radiative efficiency”), and how long they stay in the atmosphere (also known as their “lifetime”).”

    The EPA calculation of the GWP of a ghg erroneously overlooks the fact that any effect the ghg might have on temperature is also integrated over the “lifetime” of the gas in the atmosphere so the duration in the atmosphere ‘cancels out’. Therefore GWP, as calculated by the EPA, egregiously miscalculates the influence on average global temperature of greenhouse gases. The influence (forcing) of a ghg cannot be more than determined by its concentration.

    The influence on average global temperature of a ghg molecule depends on how many different wavelengths of EMR the molecule can absorb/emit. Water vapor molecules can each absorb/emit at least 170 different wavelengths in the wavelength range of terrestrial radiation (p 499 of….87..497E/0000499.000.html ) compared to only one for CO2. There are about 30 times more WV molecules in the sea level atmosphere so it is at least 170 x 30 = 5100 times more likely that EMR absorbed by CO2 and thermalized will be reverse-thermalized to water vapor.

    Thermalization of all absorbed radiation and the complete dominance of water vapor in reverse-thermalization explain why CO2 has no significant effect on climate. Terrestrial EMR absorbed by CO2 is effectively rerouted to space via water vapor with the result that CO2 has no significant effect on climate.

    • It looks more and more as the science comes in the effect of doubling CO2 is moot, the effect if any is not important. Yet the pro-AGW crowd will not give it up, after all, in the end, the reality was not science but people control.

    • Dan:
      “The influence on average global temperature of a ghg molecule depends on how many different wavelengths of EMR the molecule can absorb/emit”

      No it doesn’t.
      It depends on it’s relative concentration (CO2:H2O) through the depth of the atmosphere.
      IE: Drier regions/altitudes have most effect (colder aloft and so eventual emission to space is weaker)

      “Water vapor molecules can each absorb/emit at least 170 different wavelengths in the wavelength range of terrestrial radiation ”

      That CO2 absorbs more strongly than H2O at the Earth’s peak LWIR emmision, namely 15microns
      and also picks up a window that H2O has at 4 microns destroys that specious argument……

      “Thermalization of all absorbed radiation and the complete dominance of water vapor in reverse-thermalization explain why CO2 has no significant effect on climate. Terrestrial EMR absorbed by CO2 is effectively rerouted to space via water vapor with the result that CO2 has no significant effect on climate.”

      As I’ve told you belore – that’s just Sky-dragon slaying physics, and of which I shall not debate – by virtue of hand-waving my friend.

      There is NO “re-routing” of LWIR through H2O around all CO2 molecules.
      WV/H2O re-emits via molecular vibration/back-radiation and if there is a CO2 molecule in the way it will absorb that energy. And that is ignoring the wavelengths that H2O misses it.

      • Toneb – That is a start. Here is the rest of the story:

        The average amount of time that passes between when a molecule of CO2 in the atmosphere absorbs the energy and momentum of a photon until it emits one (the relaxation time) is about 6 µsec (values from 6 to 10 µsec are reported) . Heat is conducted in the atmosphere by elastic collisions between molecules. The average time between collisions of molecules in the atmosphere at sea level conditions is less than 0.0002 µsec

        Thus, for a CO2 molecule at sea level conditions, it is at least 30,000 times more likely that a collision will occur (thermal conduction) than a photon will be emitted. The process of a molecule absorbing the energy in a photon and conducting the energy to other molecules is thermalization. There are thousands more absorption ‘opportunities’ for water vapor compared to CO2. Thermalized energy warms the air and causes convection. It carries no identity of the molecule that absorbed it.

        Reverse thermalization, where the warmed jostling molecules excite some molecules to emit a photon is almost entirely to water vapor molecules at sea level conditions over most of the planet.

  20. “EPA policies on neonics and other issues would be a perfect place to begin changing the way Washington works.” Put some teeth in the Data Quality Act.

Comments are closed.