Leveraging Agency Resources to Advance Varroa Research

November 14, 2014

The following is the Center for Regulatory Effectiveness’ statement before the Presidential Pollinator Health Task Force on November 12th. A pdf of CRE’s testimony is attached here.

Introduction

We applaud the EPA for initiating the public participation phase of the Task Force’s work in protecting pollinators by holding these public meetings. In doing so, EPA is helping fulfil two Presidential directives, one promoting honey bee health and other being the President’s transparency directive.

I am Bruce Levinson[1] with the Center for Regulatory Effectiveness, a regulatory watchdog located in Washington, DC.

We have been analyzing bee health studies in great detail focusing on the studies, research reports and syntheses of data on honey bee health from national regulatory and science agencies around the world including in agencies in the US, the UK, Australia, and New Zealand. There is a consensus among regulators around the world that it is varroa destructor, not seed treated with neonicotinoids, which is the overwhelming menace to honeys bees. The following examples are illustrative:

  • From Australia’s national science agency (CSIRO), “The Varroa mite is considered the most serious global threat to beekeeping and is without question the most serious threat to the viability of the Australian honey bee industry.
  • From the UK’s Department of Environment, Food and Rural Affairs (Defra), “The blood-sucking Varroa is the biggest killer of honey bees world-wide, having developed resistance to beekeepers’ medication.
  • Also from Defra, “While this assessment cannot exclude rare effects of neonicotinoids on bees in the field, it suggests that effects on bees do not occur under normal circumstances. This assessment also suggests that laboratory based studies demonstrating sub-lethal effects on bees from neonicotinoids did not replicate realistic conditions, but extreme scenarios. Consequently, it supports the view that the risk to bee populations from neonicotinoids, as they are currently used, is low.”
  • From the New Zealand parliament’s Primary Production Committee, “There is currently no evidence of the [colony collapse] disorder in New Zealand, although these [neonicotinoid] pesticides are commonly used here as a seed dressing and as foliar sprays.
  • From the Australian Pesticides and Veterinary Medicines Authority, “…the introduction of the neonicotinoids has led to an overall reduction in the risks to the agricultural environment from the application of insecticides.

This Task Force can only achieve its Presidentially-assigned goal of reversing “pollinator losses and help[ing] restore populations to healthy levels” by developing research, education and public-private partnership plans counter the threat from varroa destructor and the diseases is spreads.

There are two major challenges in developing a varroa strategy. The first challenge is to have research funds to allocate and second of which is to have an effective vetting process for deciding how to allocate funds among competing projects. EPA’s innovative and long-established yet underappreciated P3 program is an opportunity for the agency to leverage existing programs to advance honey bee protection.

EPA’s People, Prosperity and the Planet (P3) program, http://www.epa.gov/p3/ evaluates environmental research proposals by college students and puts them through a multi-tier screening process that is operated by the American Association for the Advancement of Science (AAAS).

The P3 program provides financial support to best proposals with EPA making all award decisions. Criteria used in the first tier of proposal evaluations include “problem definition; innovation and technical merit; connections to sustainability in terms of people, prosperity and the planet; measurable results, evaluation method, implementation strategy; and integration of the P3 Award competition as an educational tool.”[2]

EPA awards up to $15,000 to each of 42 student teams that win the first round of the competition. EPA also provides a grant of up to $75,000 to “further the project design, implement it in the field, and move it to the marketplace.”

The P3 program has three important attributes that Task Force could recommend be leveraged for varroa research,

  1. Focused on Scalable Sustainable Solutions. The P3 program is focused on assessing and supporting research projects by “college students can benefit people, promote prosperity and protect the planet by designing solutions that move us towards a sustainable future.”
  2. Project Evaluation. The P3 program used a tested and trusted, multi-tiered research proposal vetting process, and
  3. Established funding. The P3 competition is now in its 12th year.

EPA would be able to further leverage the P3 program for countering pestilence and disease by developing public-private partnerships with researchers in industry and academia.

CRE recommends that the Task Force advise EPA to

  1. Leverage the P3 program by directing it to prioritize varroa research proposals, and
  2. Make pollinator protection decisions based only on the best available science.


[1] Bruce Levinson is Senior Vice President—Regulatory Intervention and Editor of OIRA Watch.

[2] http://www.epa.gov/p3/fact_sheet.html.

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