Claire Bleakley Pigeon Bush Rd3 Featherston 5773 027 348 731 - - PDF document

Claire Bleakley Pigeon Bush Rd3 Featherston 5773 027 348 731 p.bleakley@orcon.net.nz 3 December 2015 Re: Poncho Votivo Dear Chair and member of the EPA, THE EPA under HSNO has to abide by the principles under HSNO section 5, 6, & 7 in that they must prevent the adverse effects of hazardous substances. They are charged with safeguarding the life supporting capacity of the air, water in relation to the sustainability of the native and valued introduced flora and fauna soil and ecosystems. The precautionary approach now has been superseded by the confirmation of serious harm from the active ingredient in Poncho Votivo. The requirements under section 28 have not been met. However there does not appear to have been any discussion on this pesticide in relation to Maori and their tikanga and taonga. The information on Poncho Votivo is seriously deficient in fulfilling the principles and purposes of environmental and ecosystem protection. In the last few years since the application was made information on the toxicity to pollinators and non-target insects from clothianidin have confirmed its lethal effects. It has a with holding period of 42

• days. Therefore the precautionary approach must be taken to avoid the detrimental

effects on the ecosystems and environment and decline this application. These are the points I would like to make. I would like to highlight –

• 1. Adjuvants
• 2. Native pollinators
• 3. EFSA report on clothianidin
• 1. Adjuvants - The EPA has failed to assess the impacts of the toxicity of the full

commercial formulation. There has been no assessment provided on Poncho Votivo’s full compound formulation of clothianidin and Bacillus Fermis and its secret adjuvants and how they work synergistically. Studies by Mesnage et al found that adjuvants in formulations increase the toxicity of the active ingredients by up to 10,000 times. (Mesnage, R., Defarge, N., Spiroux de Vendômois, J., & Séralini, G.-E. (2014). Major Pesticides Are More Toxic to Human Cells Than Their Declared Active

• Principles. BioMed Research International, 2014, 179691.

http://doi.org/10.1155/2014/179691) Therefore section 28 has not been met in relation to information on the possible adverse effects of the formulation substance on the environment and ecosystems.

• 2. Native Pollinators -Clothianidin dust from seed treatments is highly toxic to

non-target insects. We focus on bees, as they are an economic necessity for horticulture pollination and honey. However, native insects, butterflies and ecosystems that are vital for biodiversity and ecosystem function have not been assessed. The failure to assess Poncho Votivo’s impacts on all pollinators native and exotic has not taken into account the deleterious nature of clothianidin on native insect species. Clothianidin dust from seed treatments is highly toxic to non- target insects. The Beekeepers association provided information on honeybees, as they are an economic necessity for horticulture pollination and

• honey. However, native insects, butterflies and ecosystems that are vital for

biodiversity and ecosystem function have not been assessed. New Zealand has 29 native species of bees in three genera.

• They are similar to other native bees around the world
• Non-aggressive and they do not sting
• Smaller and different than honey bees and bumble bees
• All species nest in a cluster of small holes in the ground,
• Solitary bees with one family living in a nest,
• Each female lays three to 10 eggs before dying.
• Females from these eggs go on to build their own nests.
• They forage on natives such as pohutukawa, ti tree and native mistletoe

have also adapted to exotic weed flower species & kiwifruit and ragwort. 18 species of Leioproctus bees, they are robust and hairy, looking similar to honeybees but smaller (5–12 millimeters’ long). All are black except for the South Island species Leioproctus fulvescens, which is covered with dense

• range–yellow hair. They are often seen in summer carrying pollen on their

back legs, like honeybees and bumblebees. They dig nest holes in the ground. A small pile of soil is the usual sign of individual nest tunnels. Each species prefers a specific type of soil. For example, Leioproctus fulvescens needs fine-grained soil, while Leioproctus metallicus nests in coastal sand. 7 species of Hylaeus bees -They are 7–9 millimeters’ long, and slender. Almost hairless, they are black with small yellow markings on the face and thorax. They make nests in blind tunnels in twigs and branches, or in old beetle holes in logs. They have no special pollen-carrying structure on the back legs, so carry pollen in the stomach. 4 species of Lasioglossum bees the smallest (4–8 millimeters’ long) they are black or greenish, only moderately hairy, and nest in the soil. At least one species, Lasioglossum sordidum, has adapted well to modified habitats. Its nests are often found along fence lines, on horticultural land sprayed bare with herbicides, and on stop banks and ditch sides above water level. Up to four species of native bees were found nesting along side each other in thriving communities. Large nest aggregations indicated bees return to the

same location to nest generation after generation. Primary resources required by native bees included suitable nest sites and local forage. Results also indicate there are possible variations in nest provisioning requirements, forage preferences or foraging strategies between species found in different local

• habitats. Community floral analyses show that for most species foraging range

is limited (less than 100 m). Ngaire Hart in her thesis (2007) “Industrious native bees: A case study in Whangarei” studied the foraging, pollination, flower and nesting of New Zealand native bees over multiple seasons. The results of the study indicate native bees could be contributing much to New Zealand pollination systems, especially in regenerative forests such as Mt.

• Parihaka. However, Dr. Hart said nest numbers dropped 61 per cent at

Parihaka, 45 per cent at Mt Tiger and 26 per cent on Memorial Drive over three years 2010 -2013. The reasons for the decline could be due to toxins such as pesticides in the environment, disease, loss of habitat or resource competition with other insects. http://www.stuff.co.nz/auckland/local-news/northland/whangarei- leader/9412020/Our-bees-are-dying Brosi & Briggs (2013) paper found that loss of a single pollinator species reduces floral fidelity (short-term specialization) in the remaining pollinators, with significant implications for ecosystem functioning in terms of reduced plant reproduction, even when potentially effective pollinators remained in the system. Our results suggest that ongoing pollinator declines may have more serious negative implications for plant communities than is currently assumed. More broadly, we show that the individual functional contributions of species can be dynamic and shaped by the community of interspecfic competitors, thereby documenting a distinct mechanism for how biodiversity can drive ecosystem functioning, with potential relevance to a wide range of taxa and systems. Berry J. Brosi and Heather M. Briggs Single pollinator species losses reduce floral fidelity and plant reproductive function PNAS 2013 110 (32) 13044-13048; doi:10.1073/pnas.1307438110 Therefore section 28 has not been met in relation to information on the possible adverse effects of Poncho Votivo on native pollinators and the effects on their health and the loss of their floral foraging environment and ecosystems.

• 3. There is no assessment of the considerations of the findings by International

Governments in relation to this product. The EFSA findings at on their Meta analysis of clothianidin have caused them to ban the pesticide. Dust, guttation, and pollen nectar all contained toxic level of clothianidin causing them to die within 2-9 minutes of exposure. Mortality went from 50% in low humidity to 92% in high humidity. High bee mortality in all studies could be a leading factor of bee colony collapse http://www.efsa.europa.eu/sites/default/files/scientific_output/files/main_docume nts/756e.pdf

Clothianidin (25% under recommended rate) 37.50g/ha. Mortality in all treatments with mortality at 1, 4 and 8h aged residues 46.67%, 11.67% and 3.33% respectively (control mortality was 18.33%, 15.00% and 3.33%

• respectively. Mortality at 1h reported to be significantly different from controls.

37.50 g/ha (642) Bee mortality was 90% after one day in bees feeding on nectar from flowers contaminated with pesticide. p. 647 Apis cerana indica Clothianidin 50% WDG. Mortality at 0% - 0.005, 20% - 0.009, 70.7% -0.016, 90.7 % - 0.029 and 100% - 0.052µg/bee. 24h LD50 was 0.014 µg/bee, LD95 was 0.03 µg/bee. Fed Farmers point 4.4: talk about labels these are totally inadequate –as the clothianidin is systemic meaning - systemic pesticides are taken up by the plant and transported to all the tissues (leaves, flowers, roots and stems, as well as pollen and nectar) Girolami V1, Mazzon L, Squartini A, Mori N, Marzaro M, Di Bernardo A, Greatti M, Giorio C, Tapparo A. Translocation of neonicotinoid insecticides from coated seeds to seedling guttation drops: a novel way of intoxication for bees. J Econ

• Entomol. 2009 Oct; 102(5): 1808-15.

Summary: As the adverse effects outweigh the beneficial ones in relation to environmental, ecosystem and economic effects. As no testing has been conducted on the full formulation no beneficial effects can be ascertained. As said there are already many similar insecticides on the market so there is no advantage for having another one. As the positive effects cannot be compared to the negative effects as they have not been conducted on the exotic or native fauna Therefore the EPA agency has not met the full requirements under HSNO purpose and principles 5, 6 & 7. The submitter and agency have not been provided with the full information on adverse effects needed to satisfy HSNO Sec: 28 (2) (a) (b), and due to these omissions they also cannot use their discretion as they cannot impose controls

• n a substance they know is toxic to the exotic and native fauna so cannot possibly

approve the application under 29 (a) (i) (ii) The EPA Authority must decline the application Yours sincerely, Claire Bleakley