I would like to submit this testimony to the House Resources Committee, speaking in favor of HB 19.
I am a beekeeper in Alaska, and I am part of a group of dedicated beekeepers who are working to develop a strain of honeybees that are reliably hardy in Alaska. There are many challenges to keeping a colony of bees for multiple years. Our group is working to identify bees that are genetically superior in their ability to survive for multiple years. HB 19 is important to our efforts, as well as important to the health of all pollinators in Alaska, both wild and domesticated. Neonicotinid pesticides pose a threat to all honeybees, and likely interfere with a colony’s ability to survive the winter.
I strongly support the intent of this bill. However, the is a small but important flaw in the wording of the proposed legislation. In line 6 of the CS, I object to the words “in granular form”. This wording would allow all other potential applications of neonicotinid pesticides to the soil. This is an important loophole to close, because the most likely application of neonicotinids to the soil would be in the form of treated seed. While the statute would prohibit the treatment of seeds and plants in Alaska, the most likely source of treated seed would be outside of Alaska, where the treatment could be legally applied. Since the seed itself would not be the pesticide in granular form, but rather, a seed, the language as proposed would allow the use of treated seed.
I have suggested a number of alternative to Representative Drummond’s staff that would directly address treated seed as a prohibited method of application. However, it might be sufficient to simply strike the words “in granular form”. This would then prohibit any application to the soil outside of a greenhouse, including the application of treated seeds.
This language change is important because a likely source of neonicotinid pesticides in Alaska would be from commercial agriculture planting treated seed (for the purpose of this discussion, seed potatoes would be included as seeds, even though they are not seeds in a technical sense). On a smaller scale, consumers may purchase plants raised by greenhouses that come from seeds treated with neonicotinid pesticides. This same language would prevent the use of neonicotinid pesticides on treated seeds on garden plants intended to be planted outside.
Neonicotinids are systemic pesticides that are absorbed by plants and reside in the plant tissues. These insecticides make the plants themselves toxic to those insects that consume the plant tissues. In many cases, particularly in commercial agriculture, these pesticides are applied to seeds, with the effect of making the resultant plants resistant to insect pests throughout the life of the plant. Unfortunately, because of the systemic nature of these pesticides, the pesticide is expressed in small amounts in the nectar and pollen of flowering plants. Pollinators, including honeybees gather nectar and pollen, and are thus exposed to the pesticide. Some studies show that the level of pesticide present in nectar and pollen is not toxic to bees. However, because bees store and concentrate nectar and pollen, the pesticides tend to be sequestered in the honey and pollen stored by the bees, and because nectar is evaporated and concentrated to form honey, these pesticides tend to significantly increase in concentration in these stores.
The use of treated seeds and plants in commercial agriculture, even on non-flowering plants, has the additional risk that the pesticide residue present on the seeds and plants will drift out of agricultural fields and into adjacent fallow land, where it is absorbed by native plants, many of which are used by pollinators. Many producers of treated seed state in their literature that treated seed should not be applied when bees are foraging in adjacent areas, in order to prevent the exposure of bees to pesticide residue. Not only are honeybees exposed in this way, but native pollinators receive the same exposures, both from the treated crops themselves, and from adjacent areas where the pesticide has drifted from its original application.
In Alaska, the presence of neonicotind pesticides in the environment that are introduced into the forage range of honeybees (and other pollinators) presents additional problems. Because the pesticides are concentrated in the honey and pollen stores of bees, and overwintering bees are entirely reliant on resources that are gathered and stored during the summer, overwintering bees are exposed to an ongoing dose of pesticide at a time of year where they are challenged with the stress of surviving a winter. They cannot escape the contamination or find alternative food sources. Even if the level of pesticide is not immediately toxic to the bees, long-term, low level exposure has been shown to be harmful to colony health, and is likely to be a contributing factor to a number of other diseases and conditions.
Neonicotinids also have the potential to appear in consumer annual plants. Treated seeds and other applications of neonicotinids have been known to be used for annual flower plants. For retailers, there is an obvious benefit to using neonicotinids – their plants are resistant to insects. However, for many consumers, a primary motivation for planting flowers in and around their homes is to attract and support bees. Consumers would then find themselves in the position of planting attractive gardens for bees and other pollinators, only to have those same plants release neonicotinid pesticides into the environment, to the detriment of the bees.
Alaskan beekeepers are working to create more sustainable culture methods for honeybees in Alaska. Currently, the vast majority of honeybees in Alaska are imported annually from the Lower 48. While domestic honeybees do regularly overwinter in Alaska where the beekeeper goes to considerable lengths to prepare the bees for winter, there are few, if any feral colonies of bees in Alaska. Thus, the availability of bees in Alaska on an ongoing basis is primarily dependent upon the ability of beekeepers to reliably overwinter their bees, and the availability of package bees from the Lower 48. The cost of imported bees has increased by 50 percent or more in the last ten years, in part because of economic competition related to the need to replace large losses of commercial bees in the lower 48. There is evidence that these large commercial losses are related to the ubiquity of neonicotinid pesticides in agriculture. Creating and improving a sustainable beekeeping culture in Alaska is dependent upon the creation and refinement of Alaska-hardy strains of bees, and to reduce the challenges of overwintering. The presence of neonicotinid pesticides in Alaska would be detrimental to these efforts, and would also have impacts on Alaska’s native, non-domesticated bees.
From an economic standpoint, Alaska beekeepers are in the envious position of being able to allow bees to forage in mostly untainted ranges. Bee products, such as beeswax, from sources in the lower 48 have been shown to have significant concentrations of neonicotinid pesticides, as well as glyphosate. These chemicals tend to occur together because genetically-modified seed are often treated with neonicotinds, and often these GMO plants are Round-up Ready, so they are later treated with glyphosate, which the bees bring back to the hive and store. In the process, these chemicals are stored in the wax, which the bees secrete from their bodies. Alaskan beekeepers can produce very clean beeswax (as well as other bee products, honey, etc). The existence of neonicotinids in the environment make uncontaminated bee products more difficult or impossible to produce. Even if one ignores the potential economic benefit of producing clean beeswax, processed beeswax is an important constituent in the creation of new colonies. Maintaining a clean source of beeswax is good for Alaska beekeepers as well as consumers.
I urge that the Resource Committee amend the language as I have suggested above, and refer the bill to the House for approval.