The National Cotton Council of America (NCC) appreciates the Rep. John Conyers Jr.’s concern for the relationship between honeybee colony health and U.S. economic and food security (Why Congress Should Care About the Beepocalypse, Roll Call, April 7, 2014). While cotton is one of many crops that does not require the assistance of bees for pollination, the NCC, along with many other agricultural organizations, industries and non-government organizations, continue to seek scientific causes of the decline in honeybee health. Leading scientists, including Dr. Jeff Pettis to whom the congressman referred, have conducted many studies seeking the cause of the honey bee decline and have reported in many open forums that pesticides are only one of many possible factors contributing to the decline in honeybee health. In USDA’s Report on the National Stakeholders Conference on Honeybee Health (October 15–17, 2012), Pettis reported, “No single silver bullet will solve the problems affecting honeybees and other pollinators.” Similar information was provided in an earlier Congressional Report identifying the multiple factors contributing to the decline in honeybee health.

The NCC appreciates that the Environmental Protection Agency has reviewed many scientific studies in the context of legal use rates and application restrictions. The EPA has improved pollinator protection label language and has increased use restrictions where needed. The EPA continues to rely on sound science that provides agriculture the ability to protect crops from damaging insect pests that would reduce yield with minimal disruption to the agroecosystem.

While it is true that the European Commission passed a two-year ban on neonicotinoids, the NCC respectfully notes the decision was not based on science demonstrating a causal relationship. The uncertainty of the decision is reflected in the fact that it is a limited restriction (2 years) rather than an outright ban of the pesticide group. The NCC additionally notes a more recent scientific review of the same group of pesticides published by the Australian Veterinary and Medicine Authority (Neonicotinoids and the Health of Honeybees in Australia, February 2014). The Executive Summary stated, “On the basis of information available to it, the APVMA is currently of the view that the introduction of the neonicotinoids has led to an overall reduction in the risks to the agricultural environment from the application of insecticides. This view is also balanced with the advice that Australian honeybee populations are not in decline, despite the increased use of this group of insecticides in agriculture and horticulture since the mid-1990s.”

The NCC encourages others to recognize pesticides are not the cause of honeybee health decline. Policies directed solely at pesticides will not provide the solution but may have broad unexpected economic impacts on agricultural production.

Don Parker is the manager of integrated pest management at the Memphis-based National Cotton Council of America.