We as citizens indeed have every right to petition or sue the EPA if they
are derelict in their duty.  And we have the opportunity to comment on
their proposals (as I do regularly).  But to think that for an agency to
defend itself from lawsuits is not a drain on its resources defies
rationality. Those of us in business  can easily imagine, for an entity on
a fixed budget, how costly and distracting it would be to defend itself
from continual lawsuits.

If, in one's fantasy world, one chooses to question the actual words that I
posted from the EPA senior (who of course put in the disclaimer that his
honest view did not reflect official government policy), that's your
choice.  Others on the List  however, may be interested in the actual
reality of the mindsets of, and interactions between our regulatory agency,
the Congress that funds it, and those advocacy groups that challenge its
decisions.

I maintain frequent communication (by email, phone, and in person) with
certain employees of the EPA involved in pesticide registration with regard
to honey bees.  I'm openly critical of some aspects of the current
evaluation and registration process, but feel that EPA is on the right
track.  The testing and registration of pesticides is slowly but
continually improving.  Pressure from advocacy groups is important.  But
that doesn't mean that such pressure may not extract a cost from the agency
that is in charge of protecting our bees.

There is more than one stakeholder involved.  As evidenced by the recent
comment to EPA by the Calif State Beekeepers Association regarding the
EPA's proposal to restrict certain pesticide applications to crops under
contract for pollination, there are plenty of beekeepers who are willing to
work with the agricultural stakeholders, and recognize their right to
protect their crops.  Many of us commercial beekeepers (who work with
growers on a daily basis) feel that some advocacy groups may go too far in
their zeal.

As with any pesticide registration (similar to the approval of a new
medicine), the final tier of testing occurs in the real world once it
starts being used.  If the label restrictions do not prevent unreasonable
adverse effects (as evidenced by adverse effects reports from beekeepers),
then the EPA can quickly (especially in the case of "conditionally
registered" pesticides) rewrite the label, or revoke the registration
entirely.

-- 
Randy Oliver
Grass Valley, CA
www.ScientificBeekeeping.com

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