All
I apologize for the length of this post, but you should all see the call
for proposals from USDA for CCD research. Note: A Letter of Intent (LOI) is
required, and the due date for these is tomorrow.
I didn't like how the first big chunks of money were distributed for
pollinator protection/CCD studies, and I dislike this even more. I wonder if
any of you agree. If so feel free to contact USDA, your Congressional folks,
etc. If the U.S. wants to resolve issues like CCD - this is, in my mind,
NOT the way to do it. The full call for proposals follows my comments.
1) An LOI is required, by tomorrow. However, not all USDA programs
require LOI's, the agency wants a heads up in terms of reviewers to assemble, but
this is also a pre-filter - they can reject an idea months before the
Proposal due date with no review other than an in-house judgement.
For a problem like CCD, there should NOT be a required LOI. It is ok if
one has the information in hand to respond at this time, but lack of ability
to submit an LOI by tomorrow should not preclude submission of a proposal
on the due date June 10.
With fast breaking developments, one can easily imagine a break in the CCD
issue between now and the proposal submission date in June. Many agencies
recommend LOIs, but will accept proposals without - it just delays their
review schedule a bit.
2) Everyone, whether from a University, a small or large business, a
non-profit foundation, a citizens groups, even beekeepers SHOULD be able to
submit a proposal in response to this call for proposals and expect a fair and
objective review. If the real objective (GOAL) is to resolve CCD, there
should be an open application, and even a chance to put in an off-cycle
proposal, if a strong lead is suddenly discovered.
Also, If you've read the latest publication on CCD and the CAPS/Wide Area
studies, you will see language that mirrors the RFP about avoiding project
duplication, but then goes further by stating that the funding is directed
mainly toward the ag labs and AG SCHOOLS. In other words, they appear to
have favorites.
In this day and age, AG Schools don't have a lock on expertise and
technologies for investigating issues like these. For example, I'm from a liberal
arts college, and Joe DeRisi in San Francisco is on a campus heavily
involved with medical issues. And why shouldn't Bee-L, if a group of members
were so inclined, be able to submit a proposal and expect a fair review?
Certainly, there should be some small businesses that may have something like
the next step in varroa or Nosema control. Why should they have to take a
back seat to the Ag Schools?
3) USDA lab personnel can apply for these projects, even though the USDA
labs get their own operating budgets. USDA is the only federal agency that
I know that lets their own people, sometimes those who help write the RFPs,
apply for the same funds. Most other agencies have a set aside for their
own labs, don't ask everyone else to compete against their own
establishment. Also, when USDA personnel can both apply for funds and maybe even have
a say in reviewing proposals, that opens up a whole other set of issues.
4) You will note that this RFP not only calls for a required LOI, but USDA
a) discourages more than one letter of Intent - so if I were to propose a
Bee-L monitoring/CCD study as we've discussed on this list, I am
discouraged from also proposing a study of the twin pathogens that we think may be
the cause of CCD, and b) USDA wants a 'mother may I" letter from the
directors of the two programs that got the bulk of the previous funding ~$8M.
5) Look to the end of the RFP that appears below, it wants every applicant
to show that the proposed project builds upon and does not overlap the
goals of the two big, funded programs (USDA wide area, and CAPS). Since there
are lots of little projects and investigators under each of these, that
means just about everything will overlap, assuming the ultimate goal is
protection of pollinators, reduction of losses.
Any business with a solution to bee loss, is going to be forced to show
that there's no overlap, OR that the project builds on someone else's work,
which then brings up all kinds of issues about who owns/controls the
intellectual property.
This requirement especially works against small businesses, and it is just
as bad for non-profits like PAms and the Bee Associations, who should be
able to compete. For example, let's consider PAms. Since the
growers/beekeepers might be able to provide matching funds, they then should be able
have a word in specifying who owns the IP, whether its shared, or whether it
is going to be put in the public domain. They shouldn't have to build upon
someone pre-selected by USDA - maybe the work is great, but maybe its just
so so, or even bad, or maybe not even relevant.
So, the bottom line is that some of the original applicants who got the
original money are now in the position of having a say in pre-selecting
any/all new applicants - you are ENCOURAGED to provide a "Letter of support
from Project Directors in other funded projects" (i.e., Jeff and Keith).
That now means, that there will effectively be two levels of pre-selection
BEFORE any peer review - the in-house USDA program review based on the
LOI, AND the reviews of the two funded project's directors. None of this
involves formal proposal peer review - and it leaves open three ways to stop a
project dead in its tracks before even getting to the proposal stage.
In the worst case scenario, the LOI effectively hands potential
competitors for this round of funding the best ideas. Now, I want to be very clear,
I'm not saying that the Directors of these funded programs would violate
that trust, but it is unprecedented requirement, one that I would hope Jeff
and Keith would not want to have to do. Because regardless of the outcome,
one has to ask, will 'my idea' be rejected, then end up as part of one of
their programs next year? That's as awkward for them as it is for the
applicant.
Finally, from a perspective of full disclosure, I need to make it clear
that my University protested the objectivity of the previous CAPS proposal
and review process. USDA rejected our proposal to establish a Central
Clearing House to investigate cases of bee loss, setting up a stratified
sampling design, adding some mobil labs to take to problem areas as bees are
dying, and working with beekeepers, putting people in to the beeyards to find
out what was really going on. We were told that our 18 investigators with
almost 200 years of professional experience 'lacked' experience. We had
Army, DeRisi, etc. on our inexperienced team and we had the endorsement of
AHPA, since we put our emphasis on being out in the beeyards.
We were also told by USDA that beekeepers would never carry through on a
project that required beekeeper involvement. I know that is wrong, we've
hung in here on this issue because of beekeeper support, and in 1985 we
published a landscape level monitoring program with bees and volunteers - in
Science.
As per the complaint submitted to USDA by UM, we got a dismissive response
from USDA - they said they checked, everything was fine. UM stopped short
of filing a formal protest with GAO, because that would have stopped
everything. We felt at the time, better to see some funds aimed at solving the
bee problems, rather than stopping the whole proposal process.
I'm can retire (don't want to), but I'm concerned about younger, creative
folks like Randy Oliver, or Robert Cramer. They should be going after this
money. Robb was going to spin up his Nosema control work in a proposal
to this RFP, until he saw the requirements for the LOI. In our original
CAPS proposal, Robb proposed work on Nosema and an alternative to fumagillin
for treatment. His ideas were rejected with some rather impolite and
pre-judgemental comments from the USD reviewers about whether Nosema ceranae
warranted any concern.
Robb continued with his own university (MT State) funding and funds from CA
beekeepers and published a quick note on his findings in one of the trade
journals, and he reported his Nosema work at the next available bee
meetings. He wanted to get the word out quickly about his initial findings about
N. apis, N. ceranae, and potential treatments, with an emphasis on the
potential usefulness of a 10% bleach solution for controlling N. ceranae.
Now Robb's in the position of asking permission from CAPS to propose
continuing his own work and building on his own research. Obviously he's
overlapping a later funded CAPS project, that of a CAPS investigator who doesn't
even have the courtesy of acknowledging Robb's work at all, never mind that
his preceded theirs in timing, public dissemination, publication.
And the final insult, after having his proposed work rejected by the CAPS
reviewers, the press release for the funded CAPS proposal emphasized
essentially the same work as a highlight of their newly funded program.
Cramer has already more or less decided to abandon his line of work, since
it will overlap that of CAPS investigators. Whether its a different
approach, better, etc. is irrelevant. I am exceeding frustrated.
Also, I wanted to take a monitoring project with Bee-L members to the
table, and I wanted to look for funding to sequence the pathogen we think acts
with N. ceranae, as well as do the confirmatory dosing and field trials.
Both of these would have some overlap with the two funded programs (
there's a small monitoring program of volunteers, and there's Nosema work, with
some researchers beginning to look in to the area of pathogens where we've
been working for two years). We may have been there first, but if
someone else has USDA funds, we can't compete. And, we are expected to outline
our best ideas and proposals to USDA and to the other program Director's
and maybe even the investigators of these groups who will likely be our
competitors for the funds. I'm just not comfortable with that requirement.
Better to go to NSF, NIH, or some other agency - although they will always
ask, shouldn't/doesn't USDA fund bee work?
So, as per the LOI, my impression mirrors that the advice given to me a
few days ago by a federal program officer who has been watching this whole
CCD issue and the USDA RFP process from afar:
you cannot win, only enable your competition. The suggestion: Either
fight it, call for external review by GA0, or go elsewhere.
For all of you who want to know where your tax dollars are going to go and
how they are going to be distributed, here's the USDA RFP for 2010.
b.
Pest and Beneficial Insects in Plant Systems
Program Area Code – A1111
Letter of Intent Deadline – April 22, 2010 (5:00 p.m., ET); see Part IV, A
(page 29) for instructions
Application Deadline – June 10, 2010 (5:00 p.m., ET)
Total Program Funds – Approximately $6 million
Proposed Budgets exceeding $500,000 total (including indirect costs) for
project periods of up to 5 years will not be reviewed
National Program Leader – Dr. Mary Purcell-Miramontes (202-401-5168 or
[log in to unmask] (mailto:[log in to unmask]) )
Background
Insects in agricultural systems have a critical role in affecting food
security. Insects compete for agricultural crops and significantly reduce crop
yields. Insects also contaminate stored food and vector plant diseases,
which seriously damages crop quality. Conversely, insect pollinators are
vitally important to maintaining the world’s food supply. It is estimated that
one-third of the agricultural crops consumed depend on pollinators. Recent
studies indicate that pollinators are in serious decline world-wide.
Numerous factors have been implicated in this phenomenon; e.g., habitat
destruction, drought, global warming, loss of floral resources, poor nutrition,
invasive pests, diseases, and pesticide exposure. Other beneficial insects such
as parasitoids and predators are also important. In several systems,
insect pests are unable to establish or reach economically injurious levels due
to the action of these biological control agents. Similar factors that
threaten pollinator species can also adversely affect predators and
parasitoids. Fundamental and applied research is needed to enhance populations of
beneficial insects as well.
Agricultural chemicals are still the primary means to control insect
pests. Research has demonstrated adverse effects on public health, pollinators,
and biological control agents. Environmentally safer alternatives are
available in several systems. However, efficacy is often not optimal, and
fundamental knowledge is still lacking in biological processes which could lead to
better usage of these alternatives. In addition, the growing demand for
organically-grown plants has increased needs for biological approaches to
manage pests.
Program Area Priorities – Applicants must address one or more of the
following:
1.
Understand the environmental and biological processes that affect the
abundance and spread of agriculturally important insects. Organismal and
molecular approaches are appropriate. Research on Colony Collapse Disorder and
native or managed bee pollinators is included in this priority.
2.
Increase fundamental knowledge of plant-insect interactions affecting
abundance and behavior of insects. Studies on signaling mechanisms or
communication between insects or between insects and plants are encouraged.
3.
Elucidate genetic mechanisms used by insects to infest and develop in
plants and correspondingly how plants respond to insects.
Other Program Area Requirements:
•
All applications must adhere to the requirements beginning in Part IV
(page 29).
•
Applications from and collaborations with Minority Serving Institutions
are strongly encouraged.
•
This program is limited to the following plant systems: Horticultural and
field crops, forests and rangelands. Pest organisms are limited to insects
and mites. Beneficial species include insect biological control organisms
(e.g., predators and parasitic wasps) native bees and honey bees. The
following systems will not be supported in FY 2010: Livestock, transgenic crops,
ornamental plants, and turf grass. Organisms not supported include ticks,
nematodes, termites, ants, stored products pests, nuisance pests, and
insects that vector plant, animal and human diseases.
•
Projects that include an evaluation of management of pests are encouraged
to include an economic component (e.g., how crop yields affected are or a
cost-benefit analysis).
•
The application must include a section providing a justification for the
system studied, in terms of economic or societal benefits (either in the
short or long-term) to agriculture and/or rural communities. Studies of model
systems may be submitted to the program only if knowledge gained is applied
to systems of economic or societal importance within the duration of the
submitted project.
•
Applications pertaining to pollinator decline and Colony Collapse Disorder
must justify how the research either builds upon or does not overlap with
the goals of other funded research (Managed Bee CAP, area-wide project,
etc.). Letters of support from Project Directors in other funded projects are
strongly encouraged.
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