NACD submits comments on EPA bee risk proposal



WASHINGTON, Aug. 28, 2015 — NACD submitted comments today on the EPA’s Proposal to Mitigate Acute Risk to Bees as part of the National Strategy to Promote the Health of Honey Bees and Other Pollinators released on May 19, 2015.  The strategy is a response to President Obama’s June 2014 memorandum calling for the formation of a Pollinator Health Task Force made up of Federal agencies charged with developing a coordinated and more comprehensive strategy for improving honey bee and other pollinator health.

The overall goals of the strategy are to reduce the honey bee overwintering losses to less than 15 percent within 10 years; restore monarch butterfly populations to 225 million by 2020; and restore and enhance 7 million acres of land for pollinator habitat in the next 5 years. Under this strategy, the EPA has proposed a rule to change the labeling on pesticide products so that the spraying of pesticides that are acutely toxic to honey bees would be prohibited when crops being pollinated are in bloom and bees are under contract for pollination services on those lands. The rule also recommends that on land where there are no existing pollinator contracts, states and tribes must develop state-level pollinator protection plans (Managed Pollinator Protection Plans) and best management practices to protect native pollinators.

As the established national voice for the more than 3,000 local conservation districts across the United States, NACD encourages the EPA to consider the benefits of voluntary measures before implementing mandatory protocols/practices and additional restrictions on pesticide labels. Conservation districts have an established record of voluntary, incentive-based natural resource conservation success and a proven track record of working with farmers, landowners, and local stakeholders in the widespread voluntary adoption of beneficial conservation practices. In fact, many producers across the country are already involved in voluntary, incentive-based programs through the work of conservation districts and Natural Resource Conservation Service (NRCS) programs specifically targeted toward supporting wildlife and pollinator habitat growth and management.

“Conservation districts understand the importance of protecting both our managed and wild pollinators, as well as the many benefits provided to production agriculture by both pollinators and crop protection products,” said NACD President Lee McDaniel. NACD believes a voluntary-based approach to protecting pollinators that utilizes the relationships and reputations of locally-led conservation districts would yield the greatest level of success. A voluntary approach should also include contract provisions that address the issue, voluntary communication, and best management practices.

NACD supports the development of Managed Pollinator Protection Plans (MP3s) by states and tribes, but believes a locally-led approach, as opposed to a nationwide solution, would best address complex ecological, geographic and other underlying issues. By enabling local decision making, states and tribes can create plans that best fit the needs and concerns of producers, beekeepers, and applicators in the state or tribe. States with independently-developed pollinator protection plans or state-level regulations have had recent successes, and NACD would like to see other states develop these as well.

MP3s should be developed with input from as many local stakeholders as possible and should be created in cooperation with conservation districts. Conservation districts are uniquely poised to engage local stakeholders as a result of their capacity to address local resource concerns and their long-standing relationships working in partnership on local level natural resource issues. Districts have the expertise and local connections beneficial in developing MP3s and educating landowners, beekeepers, applicators, and the public about their state’s MP3.

“Conservation districts have been and will continue to be a local conduit for the successful adoption of voluntary, incentive-based conservation efforts,” said NACD President Lee McDaniel. “Our proven track record demonstrates the success of voluntary, locally-led measures versus prohibitive, mandatory practices.  We hope the EPA will take our success into consideration as they move forward in creating a national strategy to promote the health of our nation’s honeybees and other pollinators.”

Click here to read the comments letter.


The National Association of Conservation Districts is the non-profit organization that represents the nation’s 3,000 conservation districts, their state associations and the 17,000 men and women who serve on their governing boards. For more than 70 years, local conservation districts have worked with cooperating landowners and managers of private working lands to help them plan and apply effective conservation practices. For more information about NACD, visit:

Latest News

Calendar of Events

Find your Local District

Accessibility Toolbar