Hi all
I have made friends with many of the Xerces people, and have tried to keep an open conversation with them. We agree about the need for the protection of pollinators, pollinator habitat, and so on. However, they have taken some extreme positions over the years. They have supported the banning of honey bees in natural preserves on the assumption that they are non-native and invasive in some of these habitats. Their report on neonics was heavily biased in favor of a guilty until proven innocent approach. (Is it a coincidence that it is dated April 1, 2012?) 

They write:
> Without clear evidence that they are not causing long-term harm to non-target species such as pollinators, the use of neonicotinoids should be restricted to applications that will not affect these vital insects.

This is circular logic: how can you say which applications "will not affect" bees, when you are "without clear evidence" that they do or don't?  Earlier in 2012, a much more scientific and far ranging assessment came and went with very little fanfare:

> Based on our evaluation, we conclude that trace dietary neonicotinoids are not implicated in population declines of honey bees. Our evaluation is provisional, however, because important gaps remain in current knowledge. We therefore identify avenues for further investigations to resolve this longstanding uncertainty.

They outline the following import questions:

> First, experimental investigations of the effects of dietary neonicotinoids on the vital demographic rates of colonies and individuals are needed. 
> Second, a quantitative demographic model for honey bee population dynamics is essential in order to evaluate the condition of sufficient harm
> Third, epidemiological analyses of the association between the rates of neonicotinoid application and colony loss will be incisive.
> Fourth, it is necessary to determine whether trace dietary neonicotinoids are synergists of co-acting stressors.

SOURCE:

"Dietary traces of neonicotinoid pesticides as a cause of population declines in honey bees: an evaluation by Hill’s epidemiological criteria" James E. Cresswell, Nicolas Desneux, and Dennis vanEngelsdorp 

What it boils down to is whether we act of what we know or what we fear. We know that neonics have been used widely for decades now. We know (even Xerces acknowledges this) that they cannot be blamed as a direct cause for pollinator decline. We also know that these substances and this method of application is far safer for bees and other organisms that previous generations of pesticides. Pesticides must be applied to produce reasonable returns, that is plain. They have to be safe for the environment, and the EPA is charge with seeing that they are. But to ban a class of insecticide based on fear and innuendo is not scientific, is not democratic, and is not justified given the current state of knowledge.

Xerxes writes:
> The bee safety of currently approved products containing neonicotinoid insecticides should be reassessed and all conditional registrations reexamined and/or suspended until we understand how to manage the risk to bees.

Is this fair? Or is it raising the bar impossibly high?

PLB

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