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

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