1. Submission APP202077 Poncho Votivo
3rd December 2015
Apiculture Industry Technical Focus Group (AITFG)
(National Beekeepers Association (NBA) Technical Committee)

2. Bacillus firmus The application has no manufacturing information;
On the cultivation and growing of the micro-organism.
How is it quarantined during manufacture?
There is a biosecurity risk to NZ bees, if other harmful micro-organisms piggy back a ride to NZ on shipments of Poncho Votivo.
We acknowledge the existence of this micro-organism in NZ.
Why did Bayer not source this organism locally?
The biggest risks to NZ bees are further importations of micro organisms that can harm our bees.

3. Poncho Votivo Application
Reference 7.2E, Page 29 Application. This statement is misleading;
“The key difference is that Poncho Votivo has B. firmus I-1582 added and a reduced amount of clothianidin.”
True, the concentration in the drum has been reduced to 508 g/l from 600g/l in Poncho.
There is no reduction in the amount of clothianidin used on the crop as the seed treatment rate has been increased by 20%.
From 100 ml Poncho/80,000 maize seeds to 120 ml Poncho Votivo/80,000 maize seeds.
There is marginally more clothianidin used per 80,000 maize seeds when using clothianidin.
Poncho Votivo g/80,000 seeds versus Poncho 60 g/80,000 seeds.

4. ISO31000 Risk Management Process
Missing in New Zealand
There is no EPA monitoring and review process of what is actually happening in NZ’s environment.
(E & R Report Sect 6.3)
Clothianidin first registered as a seed treatment in NZ in June 1993.
I would like to point out that the EPA has acknowledged this concern in the E & R report, Section 6.3.
I ponder why the applicant has not done any of this monitoring, knowing they may wish to have approved new products such as Poncho Votivo.
Reference: Figure 1, ASNZSISO

5. “Maize flats disease” beehive losses
Beekeepers have been aware that their hives near maize crops die out at the time of maize harvest and for some months afterwards
Major maize cropping areas that this effect has been observed – Eastern Bay of Plenty, Gisborne plains, around Te Puke and the Waikato.
Beekeepers call it “maize flats disease”...but it appears to not be a disease.
No conclusive explanation to date.
This is the first data from an Environmental analysis conducted by AUT and the AITFG.

6. The Data
Paul Badger

7. Maize Crop Calendar Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept
Planting
Treated Seed
Crop growing
Grain Harvest
Time of bee hive losses
Stubble
2015 Survey
n = 4
n = 45
Sampling Dates
First Survey: June 29th – Stubble and soil samples n= 4
Second Survey: September 29th & 30th – Soil samples n=45
n = number of samples tested

8. First survey ‘Jump the fence’ samples taken on 29th June
One single stubble plant analysed and 3 soil samples.
Chemicals detected
Sample
Analysis
Clothiandin
Stubble of maize
Hills Labs #
< 0.02 mg/kg
Soil sample 1
AUT
35 ng/g wet weight
Soil Sample 2
30 ng/g wet weight
Soil Sample 3
30 ng/g wet weight

9. Site 121
Site 121
Site 111
Site 176
Site 151

10. Second survey
September 29/30th this year soil samples were taken from 9 maize stubble paddocks.
Paddocks were not selected on any basis of past history. We did not survey growers/owners first to determine the history of the seed treatments used.
Paddocks sites have been mapped by latitude and longitude.
5 samples were randomly removed from each paddock. Wet areas were avoided. Uncultivated stubble areas were preferred – but some paddocks had been cultivated – see photos.
Samples were removed by a trowel, depth of sample 150mm, diameter of sample 50mm. We used a normal soil fertility test selection method (Ravensdown).
Each sample is more than 10 metres from the next one.
Each sample is packed in a marked plastic bag, kept in a chilly bin and delivered to the lab on 1st October.
9/11/2015

11. School of Applied Sciences Analytical Laboratory
Supervised by Dr Chris Pook, Chemical Ecologist
Neonicotinoid residues extracted from soil and analysed by liquid chromatography with tandem mass spectrometry (LC- MS/MS).
9/11/2015

12. Analysis of neonicotinoid residues in soil samples
5/11/2015
Dr Chris Pook, AUT
Results are in nanograms of clothianidin a.i. per gram wet weight of soil
Site
Paddock sample number
Samples n
clothianidin Mean ng/g
clothianidin
SD ng/g
Matamata
101 5
17.5
12.06
Awakeri
111
4.7
2.74
Poroporo
121
11.2
4.63
TeTeko
131
2.8
0.55
151
2.1
2.4
Whakatane
161
2.5
TePuke
171
3.8
0.8
Te Puke
176
2.2
0.35
Gisborne C1
26.7
46.48
Instrument Detection Limit 0.44
calculated
©2015
The analysis presented in these results is being repeated to verify the results. The chart is the Phase 1 testing results only.
This data is Copyright of Auckland University of Technology. ©2015
Publication is not authorised without the permission of the Copyright holder.

13. Survey Results No organophosphates or carbamate chemicals detected.
All samples taken when analysed showed both clothianidin and imidacloprid.
We did not look for the metabolites of clothianidin.
We did not survey growers/owners first to determine the history of the seed treatments used.
We did expect to find some non contaminated paddocks. This chemicals seem to be widespread in the environment.
Persistence of these neonicotinoids in these NZ soils is we believe significant. 11 months after date of sowing.
There is enough chemical in this environment to give a lethal dose to a bee, which weighs 0.1 to 0.12 grams.

14. Future Plans – continue the study.
Complete Phase 2 – check and verify the test results achieved to date.
Two more stages are planned;
Stage 2 Return to these same paddocks at harvest
Introduce hives to the area prior to harvest and monitor the harvest and period immediately after.
Sample and test – soils, stubble, beehive (nectar, wax and bees), for pesticides.
Observe bee foraging behaviour in the stubble.
Stage 3 – repeat Stage 1 testing (repeat these tests in September 2016).
A funding requirement of $20,000 is required to complete the project.
All donations gratefully received. See me afterwards.
9/11/2015

15. 77A Control – Application Rate
EPA has set a maximum seed treatment rate of 120ml / 80,000 maize seeds. Okay for maize, what about grass seed and forage brassicas?
This is the extra amount of Poncho Votivo released for a farmer sowing maize at maximum recommended rate versus 80,000 seeds /hectare.
Seed Company
Min Seeds per hectare
Max Seeds per hectare
% Poncho Votivo
Above min
EPA
80,000
None
Corson Seed
120,000
50% +
Pacific Seeds
115,000
44% +
Pioneer Seeds
88,000
110,000
27.5% +
The EPA needs to use an Environmental Exposure Limit for soils as the control

16. Request for the EPA
The EPA to encourage the use of NZ environmental testing when conducting a risk assessment.
Apply to clothianidin an Environmental Exposure Limit (EEL) for soils.
Review the use of neonicotinoids with respect to their use.
Is the prophylactic use of these pesticide widespread?
What needs to be done so use of these products for curative purposes?
Have the EPA make better decisions with NZ data in their risk assessments.
Clothianidin appears to be more persistent in NZ soils than imidacloprid, which has an EPA EEL for soil.

17. Acknowledgements
Apiculture Industry Technical Focus Group (AITFG) (NBA Technical Committee)
Beekeepers; Mossops Honey, Whai Hua Bees, Barry Foster for providing samples, history of problem and introductions.
Farmers and Maize contractors who permitted sampling of their paddocks.
AUT School of Applied Science for funding the research to date.
Dr Chris Pook and Iana Gritcan for conducting the scientific analysis.