PETITION | Support EPA reforms for Bee and Bird Killing Pesticides

To: Office of Pesticide Programs, The U.S. Environmental Protection Agency (EPA)

I strongly support the petition by 65 groups, led by PEER and the American Bird Conservancy, to reverse EPA’s decision to issue a regulatory waiver in 1984 allowing companies to register pesticides without submitting “efficacy” data substantiating the products’ claimed benefits.

That shocking decision has led to the overuse of pesticides, the death of birds and bees, and the contamination of the environment. EPA should not allow the nationwide use of systemic pesticides that have not first shown to be effective.

EPA’s current posture of presuming pesticides to be beneficial is factually inaccurate as many studies show their use provides no measurable economic benefit for farmers – and in some cases, they even harm crop yields.

More importantly, EPA’s current regulation results in hugely excessive applications of pesticides that are environmentally destructive.

This petition will help protect honeybees, bumblebees, other beneficial insects, and farmland birds, which are disappearing from America’s farms. It will also help protect the health of our waterways and aquatic life.

This petition allows EPA to rectify a major mistake it made 40 years ago in registering these powerful systemic insecticides without first requiring data on their efficacy. It is not only plain common sense but also is the only ecologically responsible course of action.


In February 2023, PEER, the American Bird Conservancy (ABC), and 63 other groups filed a rulemaking petition with EPA asking the agency to amend its existing regulation for registrations of all neonicotinoid insecticides and other systemic insecticides to require companies to provide efficacy data when registering pesticides to ensure that the benefits of their products exceed their costs, including to society and the environment.

The petition carefully documents how EPA’s failure to require efficacy data for pesticides has led to extensive environmental harm, including the overproduction of tons of surplus neonicotinoid-coated seeds. One seed coated with a neonic can kill a songbird, which is to say nothing of the millions of birds impacted by the loss of beneficial invertebrates from neonic pollution.

EPA is now accepting comments on PEER and ABC’s petition until March 25, 2024, before deciding how it will respond to our petition. Making your voice heard is critical to changing EPA harmful rules on the use of pesticides.

We will keep you posted on EPA’s response to this petition.



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