This came in today with a request to forward to as many US beekeepers as possible. The deadline for comment is only a few days away, and in the holiday season to boot. One can only wonder why the comment period ends a few sort weeks before the US national bee meetings. Coincidence? There were some additional documents attached, but, seeing as BEE-L does not support attachments, I have posted the rest of the docs at http://www.honeybeeworld.com/misc/carbaryl/ --- My name is Jeff Anderson, I operate a commercial bee operation California Minnesota Honey Farms based in Eagle Bend Minnesota and Oakdale California. I have had significant problems with the spraying of carbaryl (Sevin) both to hybrid poplar plantations in Minnesota, and thin spraying apples in California. EPA is re registering old chemicals, carbaryl is currently opened for public comment until December 27th. I have co written a comment to the Carbaryl IRED to which I am requesting beekeeper or bee organization sign ons. The boiled down request is that EPA loose the "if bees are foraging in the treatment area" from the bee caution. If this were to occur, the bee caution would simply say, "Do not apply or allow to drift to blooming crops or weeds. It is my opinion that this would be hugely easier for spray applicators to assess rather than the presence of pollinators. Also it should be more enforceable. In Minnesota we run into Minnesota Department of Ag's logic, that just because bees are foraging today, is no sign they were here last Thursday when the spray application took place. It should be a given that when there is bloom, there are pollinators. I have established some connections in the environmental community. Beyond Pesticides became interested that someone from the bee community was interested in responsible pesticide use, and offer to co write my comments. ALL the information in my comment letter is MY information. Beyond pesticides formatted it and worded it in a manner which they thought would make the most impact at EPA. ...I am hopeful that you could spread this around and hopefully generate some sign ons or direct comments to this issue. Last spring I was invited to DC by the Executive Board of ABF, one of the requests of EPA was a written definition of the 'bee caution'. EPA declined to do that , I have been told by 3 of the 6 EPA persons present that EPA is not going to make any public statement about the bee caution until after the Carbaryl issue is settled. Evidently it is EPA's opinion that bee kills are minor regional events, and that the Minnesota problem if ignored will simply fade away. Pesticides are every beekeepers problem, and we need to re draw the line back where pollinators have protection. I babbled about enough. I am hopeful that you can facilitate this effort. Beyond Pesticides is compiling the sign on information. Contact Shawnee Hoover at [log in to unmask] or phone 202-343-5450. Because of the Christmas Holiday Beyond Pesticide is going to submit comments by tomorrow afternoon December 22nd. Official EPA closing date is December 27th. Thanks for your attention in this matter. Sincerely Jeff Anderson California Minnesota Honey Farms 7342 River Road Oakdale CA 95361 209-847-4731 cell 209-345-2045 721 Wells Street Eagle Bend MN.56446 PS PLEASE FEEL FREE TO CONTACT ME IF YOU NEED ADDITIONAL INFORMATION :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: -- Visit www.honeybeeworld.com/BEE-L for rules, FAQ and other info --- ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::