I believe that new innovation should follow The Precautionary Principle this means that there is convincing evidence of both a need and the safety of a product. The current rush to apply new ideas can be hugely dangerous. Poncho Votivo, as the product information states, protects the WHOLE plant, above and below ground, protecting early-season seedlings and roots before pests can strike. Poncho Votivo is in 2 parts, and the inclusion of Bacillus Firmus is designed to kill root nematodes which attack crop plants. It is a bit puzzling that Bayer classify Bacillus Firmus as an “ insecticide ” in their application when it is a bacterium. What guarantee is there this product will not kill the thousands of beneficial nematodes living in the soil, the loss of which would be - catastrophic. These microscopic little worms that no one really cares or even knows about - collectively do an enormous job of delivering nutrients.
Bacillus firmus is found in New Zealand soil BUT the strain being introduced is from a wild strain found in Israel. o What protections have been put in place to ensure that this bacterium doesn’t destroy the many beneficial native nematodes which we rely on for soil fertility and natural pest control. o To destroy the soil ecosystem could be catastrophic resulting in barren and unproductive soil. Also if you increase the level of this bacterium into the ecological system, what does that do to natural balance? It ’s toxic to other soil and aquatic invertebrates, Could n’t we plant marigolds along with the food crop which to have a similar effect?
The other part is clothianindin, a neonicotinoid insecticide. When I started my research on what I wanted to say today, I was surprised to find that neo-nics had already been approved for use in NZ when there is such a lot of controversy and uncertainty attached to them. There are many scientific studies posted online on this subject and the only one I found which was pro neo-nics is funded by Bayer and Monsanto, this is biased because of the economic benefit to these companies. Some of the problems with neo-nics, and the effects on bees are: Impaired ability to navigate back to the hive. Colony Collapse Disorder. Breeding more female workers instead of males to make up for losses - producing a gender imbalance. Reduction in sperm count in bees. The Harvard School of Public Health in the US has set up a sperm bank to collect bee genetics. Contaminated pollen, nectar, and that water exuded in early morning, reduces the immune response
making bees more likely to get diseases caused by bacteria and viruses. Bees have to cope with Varroa, and other unpronounceable pathogens, o pollinator brood disease, o foulbrood, o small hive beetles (which could be the next big threat), o parasites, o paralysis virus, o loss of food sources, and o insecticides.
ARTICLES online show the dangers of neo-nics. This year in Sept in the US, a Californian court said that the EPA had relied on “ limited and flawed data ” . As a result Dow Agroscience has had its neo- nic banned until it can PROVE it does n’t harm bees. The Ontario Government ’s decision is to use neo- nics sparingly - like chemotherapy, and only in critical situations. In the EU there is a temporary 2 year ban which is due to be reviewed this month. Has our EPA seen the results of this study which should have been done by now? I have provided a list of some of the website addresses I have visited for my research.
IN NZ The cost of replacing bee pollinators by other methods in NZ would be impossible. The outcome would be a drop in crop production, huge rise in food prices, and probable loss of international markets – which we rely on for our standard of living. In Bayer’s application they say that approving the use won’t have any negative impact on New Zealand’s international obligations. But declining the approval may be seen as placing technical barriers to trade. – What does this mean?
EPA STAFF REPORT The scientific studies would appear to have been provided by the applicant - and the test information accepted. No information is available in many of the areas covered in the report. By not having this information how do you protect the environment. The report states there is no study which makes conclusions about the likely impact of trace residues of neo-nics on bees. This is patently rubbish as there are MANY references to scientific studies which do conclude there is a link. There is to be no check on the impact of this product on the environment, by Bayer or the EPA - due to being too costly. I hope this is not too costly to the environment in the future. Poncho Votivo will have less clothianidin - so does this mean the affect on bees is less? And how does this work? Bacillus has been tested on animals, but where are the tests results on beneficial nematodes, in soil and waterways? This seems to be missing.
THE WAY FORWARD We need a better understanding of how neo-nics affect pollinators, and Bacillus affects nematodes, and creatures in the food chain. We need discussions about methods of pest control in agriculture, as part of the environment WITHOUT PROFIT colouring the decision making. The quick buck. We need to take a look at the whole picture affecting our environment instead of ONE product or threat at a time.
ENDANGERED SPECIES The Bumblebee Conservation Trust UK is a charity trying to reverse bumblebee decline. It’s started to reintroduce the short-haired bumblebee, extinct in the UK since the 1980s, from a population that survives in New Zealand. Do we have the right to endanger this last bastion of these bumblebees? From learning about bees in school, I know that a colony of bees is far more than the sum of its parts. The hive functions as a whole, performing all of the processes that support life. Bees have that collective hive intelligence. We don’t have the right to endanger the perfect functioning of hives.
RECOMMENDATION I recommend that you set up a banned list so that international companies will know not to apply for certain types of import permissions. I recommend that you ban Poncho Votivo.
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