>  They [EPA] did not to reply to me,

Any reply to "public comment" from EPA comes only in the form of a summary of all public comment received, and only as an appendix to a "final rule".

> and the ABF and AHPA declined my request for them to sign on.  

Hey, I've seen that play before - "Here's an award, now sit down and shut up".  The status quo is thereby made that much easier to preserve, all one must do is start by sweeping standards down the well-know drain.

>  Our interface representative at the USDA also was unable to get an answer for me.

Not sure how USDA would be able to get anything out of EPA on this, but USDA ARS certainly has the last word on things like efficacy vs toxicity.  What does the stack of "acceptable science" look like to the disease/pest subject matter experts at ARS Beltsville?

>  Instead, the EPA scheduled a Zoom meeting with the leaders of the organizations (excluding me from this meeting).

The leaders are volunteers with many other better things to do, so they cannot be blamed for accepting the "invitation" on EPA's terms, but they do owe the dues-paying constituency they claim to represent a summary of who said what about what to who.  Where is this report?  Without it, the membership cannot advise the leadership of the needs of the membership.

>  A rep of the EPA told me that "we are looking to the industry associations to consolidate any questions/feedback they are hearing from the industry and provide input on any potential next steps."

Translation: We've classified certain parties as "activists" and "advocates", so we will ignore them entirely, discredit them as "too militant" when we speak with the current crop of self-appointed Industry Leaders, and leave the "activists" to lobby and attempt to overcome int inertia of these same organizations, so that we can limit our engagement to those who we identify as easier to intimidate/manipulate/harangue. 

Pro-Tip: The astute practitioner would counter this tactic by playing the congresscritter card.  The card is only effective when played by a large state beekeeping organization.  Or three, so that the combined membership outnumbers the membership of the claimed "national" organization.

Congresscritters have aides to turn the details into one-pagers, and they love calling large agencies on the carpet for ignoring the needs of their constituents, moreso in election years. 

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