It occurs to me that there is about to be a rush to return as much as
possible to the States under the guise of "states'" rights.  Among other
things, Federal expenses are cut leading to tax cuts, etc.  However, even
though in the past beekeepers stayed put and arguably didn't engage in
interstate commerce, that is no longer true.  Pollination requires
interstate commerce which is one trigger for Federal intervention.

It is in the interest of the pesticide (of any kind) producers to move
responsibility to the States, fragmenting the responsibility for all kinds
of labeling, use, and enforcement which can be brought to bear against
them.

In addition, even if we ignore interstate/international marketing of honey
which it can be argued is normally done by a distribution level at least
one step removed from beekeeping, and which is, in relative terms a minor
market, the same can't be said of crop production reliant on bees as
reliable and manageable pollinators.

Therefore, while the State programs are important, for the purposes of
holding the line or even beefing up the insect (bee) protection mechanisms
including the pesticide use labels, the harm about to be done directly to
the bee industry and secondarily to the crop production industry depends
on making the argument that both, because of their interstate nature, are
properly the responsibility of the Federal Government.

In addition, since not all States maintain the same level of bee
protection programs, some, evidently not controlling bees at all, it seems
to me an argument can be made to the States and the Federal Government,
that States having weak programs may find themselves ignored by the
pollination industry.  Beekeepers may conclude that it is not worth
endangering their assets to move them into areas with weak or no
regulation.

[The usual disclaimer: not qualified to make a legal argument but have, on
occasion, read the Constitution.]

On Thu, 11 Jan 2001, Matthew Shepherd wrote:

> I am currently reviewing the EPA's draft Pesticide Registration Notice on=
>  Bee Precautionary Labeling. Her at the Xerces Society, we want to get a=
>  response to the EPA by the Jan 22nd deadline.
>
> The draft notice talks of state approved bee protection programs. Can=
>  anyone point me towards some information on these?

---------------
Richard Yarnell, SHAMBLES WORKSHOPS | No gimmick we try, no "scientific"
Beavercreek, OR. Makers of fine     | fix we attempt, will save our planet
Wooden Canoes, The Stack(R) urban   | until we reduce the population. Let's
composter, Raw Honey                | leave our kids a decent place to live.