It has come to my attention the EPA plans to confirm an extension in the use of four neonicotinoid insecticides; imidacloprid, thiamethoxam, clothianidin and dinotefuran, on US farmland, for the next 15 years, despite the fact the agency has noted "ecological risks of concern, particularly to pollinators and aquatic invertebrates".

Neonicotinoids are chemicals widely used on crops to treat them for pests. However, neonicotinoids cause devastation among non-target insects, such as bees, butterflies, beetles, earthworms, amphibian, and the wildlife that depend on them for their own substance, including various species of endangered birds and bats. In other words, Neocotinoids are a POISON to our wildlife.

The chemicals assault receptors in an insect's nerve synapses, causing uncontrollable shaking, paralysis, and death.

In the case of honeybees, and wild populations of bees, those deliberately exposed to even tiny amounts of the neonicotinoid pesticide imidacloprid, were, on average, three times more likely to become infected by the parasite nosema, as findings by Dr Jeffrey Pettis, of the US Department of Agriculture's Bee Research Laboratory, have shown. The nosema parasite is decimating bee populations at an alarming speed already, and neonicotinoids only contribute to making the problem worse.

Because these chemicals are water-soluble, they easily leach out of plants and into the soil, streams and aquifers, causing an extreme, irreversible, and direct, harm to wildlife. For this reason, Canada has restricted their use while the EU has completely banned the outdoor deployment of clothianidin, imidacloprid, and thiamethoxam.

150 million acres of American cropland, a surface approximately the size of Texas, are 48 times more toxic now than they were 25 years ago, due to the use of neonicotinoids.

Our ecosystems are already collapsing under the ever-increasing pressures of climate disarray, and the accumulated impact of various pollutants, from microplastics to heavy metals such as mercury, and lead. That the US government is willing to bend, one more time, to the lobbying by farming groups and pesticide makers to perpetuate the use of neonicotinoids nationally, is unacceptable.

Furthermore, science and experience has shown that neonicotinoids don't really increase agricultural yield in the long run.

As per Nathan Donley, Environmental Health Science director at the Center for Biological Diversity "WE DO NOT HAVE ANOTHER 15 YEARS TO WASTE. (…) as we have been seeing enormous crashes in insect numbers".

I feel outraged that the EPA is going down this path, which is contrary to its mission of protecting the American environment, the health of soils, air and aquifers, and with them, our precious wildlife. The Biden's Administration made environmental sensitivity and responsibility an important point in the campaign trail, and this is a betrayal to those voters who elected him believing he would implement the policy and actions necessary to protect our environment.

I encourage you to FOLLOW THE SCIENCE and the rest of the world in this. The cost of appeasing the chemical industry will be enormous and irreversible, and the consequences of using these poisons will reach far beyond the insects and invertebrates in question. They are only the first step on a complex food chain and pollination system, and as such, they are also vital in a sustainable food supply for human life.

No "mitigation rules" will ever suffice to curb the negative effects of neonicotinoids in our landscapes and wildlife.

Please, I urge you to COMPLETELY BAN the use of all, and any, neonicotinoid, particularly, the use of imidacloprid, thiamethoxam, clothianidin and dinotefuran. This is a big deal. Too much depends upon it.

Thanks for your consideration.


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