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December 10, 2020

Michael Moore, Chair Pesticide Board Subcommittee Department of Public Health 305 South Street
Jamaica Plain, MA 02130

John Lebeaux, Commissioner Department of Agricultural Resources 251 Causeway Street
Boston, MA 02114

Re: Scientific Review of the Impacts of Neonicotinoid Pesticides on Pollinators

Dear Pesticide Subcommittee Chair Moore and Commissioner Lebeaux,

We write today to offer testimony on the Scientific Review of neonicotinoid pesticides and their impacts on pollinators and the environment as required by the legislature. Bee colony loss and pollinator declines have been a persistent threat for over a decade, with Massachusetts experiencing a dramatic 50% colony loss as recently as 2018, the most recent data reported by MDAR. We appreciate the diligent work that went into the Review and wish to especially thank Secretary Theoharides for her partnership in ensuring its completion.

As you are aware, under Chapter 41 of the Acts of 2019, the Legislature directed and provided funding to MDAR to complete a scientific review of the impacts of neonicotinoid pesticides on pollinators. The review was completed exactly one year ago, with clear and unambiguous findings, stating that “comprehensive reviews point to a large body of evidence documenting the ability of neonicotinoids to adversely affect pollinators” and that “it is clear that such compounds can adversely affect a range of pollinator species important to the Commonwealth of Massachusetts.” This comprehensive and well-documented review includes a thorough analysis of peer-reviewed scientific research and U.S. EPA product reviews, concluding that 42 of 43 documents studying effects of these pesticides identified an adverse effect associated with neonicotinoid exposure.

These conclusions, now 12 months old, clearly support decisive action by the Subcommittee and the Department to regulate these pesticides, consistent with the provisions of H.763, An Act to protect Massachusetts pollinators. Specifically, the review provides the scientific basis for restricting use of these pesticides to only licensed pesticide applicators.

At this time, we also offer comment on the process which has brought us to this point. We are troubled at the lack of urgency shown by the Subcommittee in completing this public hearing and finalizing recommendations by the statutory deadline of December 31, 2019. While we recognize that COVID-19 has impacted schedules across state government, the vast majority of agencies and the Legislature have continued to hold hearings by virtual means since last spring. The fact that it has taken the Department and the Subcommittee nine months to reschedule a public hearing required by legislative directive is extremely concerning.

Further, this delay continues a pattern of unresponsiveness by the Department and the Subcommittee with respect to these pesticides. The responsibilities of the Pesticide Subcommittee, as spelled out in 333 CMR 8.03, include “The subcommittee shall individually review for registration and classification those pesticides with an active ingredient or use pattern which the Subcommittee determines may cause unreasonable adverse effect(s) on the environment when used in accordance with label directions.” Despite concerns about neonicotinoids being brought to the Department’s attention repeatedly by the Attorney General’s office, legislators and others since 2014, the Subcommittee failed to initiate an independent review or take any consequential action until 2019, when legislatively required to do so. This inability or unwillingness to respond to concerns that clearly fall within its purview raises concerns about whether the Subcommittee is able to fulfill its charge under the law to regulate pesticides.

Limits on neonicotinoid use are supported by a broad range of stakeholders, including the Massachusetts Beekeepers Association and 11 county beekeepers’ associations across the Commonwealth; the Northeast Organic Farming Association; MassPIRG; Environment Massachusetts, Friends of the Earth, and Conservation Law Foundation; among others. Attorney General Maura Healey also supports limits on neonicotinoids, co-authoring H.763 as well as imposing a $75,000 settlement on Bayer Crop Science for misleading consumers about risks to pollinators. Additionally, retailers have been compelled to act, with Home Depot, Lowe’s, Walmart, and BJ’s Wholesale Club announcing replacement of these products on their shelves with less harmful alternatives.

More than any stakeholder, the agricultural community faces the risks of inaction, given that the $475 million Massachusetts agricultural sector is dependent on a healthy pollinator population. Limits on neonicotinoids are supported by Massachusetts Nursery and Landscape Association as well as the Massachusetts Flower Growers Association.

Other states, including Maryland, Vermont, and Connecticut, have already implemented similar restrictions, while Massachusetts, long a trailblazer in environmental protection, has yet to take action. With the review now complete and the scientific basis for limiting these pesticides now clearly established, we call on the Department and the Subcommittee to complete its process and implement restrictions without delay.

In conclusion, we strongly support the results of the scientific review and its unambiguous findings that limits on neonicotinoid pesticides are necessary. We urge the Subcommittee to act quickly in accordance with its authority and its legislative mandate to limit these products due to the threat they pose to pollinators and the environment. The science is clear and we ask the Subcommittee and the Department to fulfill their responsibilities to the public and take immediate action.

Sincerely,

Carolyn C. Dykema
State Representative 8th Middlesex District

James Arciero
State Representative 2nd Middlesex District

Brian M. Ashe
State Representative 2nd Hampden District

Ruth B. Balser
State Representative 12th Middlesex District

John Barrett, III
State Representative 1st Berkshire District

Linda Dean Campbell
State Representative 15th Essex District

Tackey Chan
State Representative 2nd Norfolk District

Michelle L. Ciccolo
State Representative 15th Middesex District

Mike Connolly
State Representative 26th Middlesex Districct

William L. Crocker, Jr.
State Representative 2nd Barnstable District

Claire D. Cronin
State Representative 11th Plymouth District

Angelo L. D’Emilia
State Representative 8th Plymouth District

David F. DeCoste
State Representative 5th Plymouth District

Carol A. Doherty
State Representative 3rd Bristol District

Mindy Domb
State Representative 3rd Hampshire District

Paul J. Donato
State Representative 35th Middlesex District

William J. Driscoll, Jr.
State Representative 7th Norfolk District

Lori A. Ehrlich
State Representative 8th Essex District

Kimberly N. Ferguson
State Representative 1st Worcester District

Dylan A. Fernandes
State Representative Barnstable, Dukes & Nantucket District

Ann-Margaret Ferrante
State Representative 5th Essex District

Sean Garballey
State Representative 23rd Middlesex District

Denise C. Garlick
State Representative 13th Norfolk District

Colleen M. Garry
State Representative 36th Middlesex District

Carmine L. Gentile
State Representative 13th Middlesex District

Thomas A. Golden, Jr.
State Representative 16th Middlesex District

Danielle W. Gregoire
State Representative 4th Middlesex District

Tami L. Gouveia
State Representative 14th Middlesex District

James K. Hawkins
State Representative 2nd Bristol District

Stephan Hay
State Representative 3rd Worcester District

Jonathan Hecht
State Representative 29th Middlesex District

Natalie M. Higgins
State Representative 4th Worcester District

Kevin G. Honan
State Representative 17th Suffolk District

Bradley H. Jones, Jr.
State Representative 20th Middlesex District

Patrick J. Kearney
State Representative 4th Plymouth District

Mary S. Keefe
State Representative 15th Worcester District

Kay Khan
State Representative 11th Middlesex District

Kathleen P. LaNatra
State Representative 12th Plymouth District

John J. Lawn
State Representative 10th Middlesex District

David H. A. LeBoeuf
State Representative 17th Worcester District

Jack P. Lewis
State Representative 7th Middlesex District

David P. Linsky
State Representative 5th Middlesex District

Kate Lipper-Garabedian
State Representative 32nd Middlesex District

Jay Livingstone
State Representative 8th Suffolk District

Marc T. Lombardo
State Representative 22nd Middlesex District

Adrian C. Madaro
State Representative 1st Suffolk District

Liz A. Malia
State Representative 11th Suffolk District

Paul W. Mark
State Representative 2nd Berkshire District

Joan Meschino
State Representative 3rd Plymouth District

Christina A. Minicucci
State Representative 14th Essex District

Liz Miranda
State Representative 5th Suffolk District

Frank A. Moran
State Representative 17th Essex District

David K. Muradian, Jr.
State Representative 9th Worcester District

Brian W. Murray
State Representative 10th Worcester District

Tram T. Nguyen
State Representative 18th Essex District

W. Smitty Pignatelli
State Representative 4th Berkshire District

Angelo J. Puppolo, Jr.
State Representative 12th Hampden District

David M. Rogers
State Representative 24th Middlesex District

Jeffrey N. Roy
State Representative 10th Norfolk District

Lindsay N. Sabadosa
State Representative 1st Hamphire District

Paul A. Schmid, III
State Representative 8th Bristol District

Danillo A. Sena
State Representative 37th Middlesex District

Alan Silvia
State Representative 7th Bristol District

Thomas M. Stanley
State Representative 9th Middlesex District

Paul F. Tucker
State Representative 7th Suffolk District

Steven Ultrino
State Representative 33rd Middlesex District

Aaron Vega
State Representative 5th Hampden District

Tommy Vitolo
State Representative 15th Norfolk District

Susannah M. Whipps
State Representative 2nd Franklin District

Joanne M. Comerford
State Senator Hampshire, Franklin, & Worcester District

Brendan P. Crighton
State Senator 3rd Essex District

Cynthia S. Creem
State Senator 1st Middlesex & Norfolk District

Julian Cyr
State Senator Cape and Islands District

James B. Eldridge
State Senator Middlesex & Worcester District

Ryan C. Fattman
State Senator Worcester & Norfolk District

Patricia D. Jehlen
State Senator 2nd Middlesex District

Jason M. Lewis
State Senator 5th Middlesex District

Joan B. Lovely
State Senator2nd Essex District

Michael O. Moore
State Senator 2nd Worcester District

Susan Moran
State Senator Plymouth & Barnstable District

Patrick M. O’Connor
State Senator Plymouth and Norfolk District

Rebecca L. Rausch
State Senator Norfolk, Bristol, and Middlesex District

Michael F. Rush
State Senator Norfolk and Suffolk District

Walter F. Timilty
State Senator Norfolk, Bristol, and Plymouth District

CC:
Governor Charlie Baker
Attorney General Maura Healey
Secretary Kathleen Theoharides, EOEEA
Chair Smitty Pignatelli, House Chair, Committee on Environment, Natural Resources and Agriculture
Chair Anne Gobi, Senate Chair, Committee on Environment, Natural Resources and Agriculture Commissioner Monica Bharel, Department of Public Health
Chris Eicher, Office of Speaker Robert A. DeLeo
The Massachusetts Dept. of Agricultural Resources Pesticide Board Subcommittee