1. Submission APP202077 Poncho Votivo 3 rd 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 60.96 g/80,000 seeds versus Poncho 60 g/80,000 seeds.

4. ISO31000 Risk Management Process Reference: Figure 1, ASNZSISO31000-2009 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.

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 OctNovDecJanFebMarAprMayJuneJulyAugSeptOct Maize Crop Planting Treated SeedCrop growing Grain Harvest Time of bee hive losses Stubble Planting 2015 Surveyn = 4n = 45 Sampling Dates First Survey: June 29 th – Stubble and soil samples n= 4 Second Survey: September 29 th & 30 th – Soil samples n=45 n = number of samples tested

8. First survey ‘Jump the fence’ samples taken on 29 th June One single stubble plant analysed and 3 soil samples. Chemicals detected SampleAnalysisClothiandin Stubble of maizeHills Labs #1444176 < 0.02 mg/kg Soil sample 1AUT35 ng/g wet weight Soil Sample 2AUT30 ng/g wet weight Soil Sample 3AUT30 ng/g wet weight 8

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

10. Second survey September 29/30 th 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 1 st October. 9/11/201510

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). 9/11/201511

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 SitePaddock sample numberSamples n clothianidin Mean ng/g clothianidin SD ng/g Matamata 101517.512.06 Awakeri 11154.72.74 Poroporo 121511.24.63 TeTeko 13152.80.55 Poroporo 15152.12.4 Whakatane 16152.52.4 TePuke 17153.80.8 Te Puke 17652.20.35 GisborneC1526.746.48 Instrument Detection Limit 0.44 calculated 03-11-15 ©2015 This data is Copyright of Auckland University of Technology. ©2015 Publication is not authorised without the permission of the Copyright holder. The analysis presented in these results is being repeated to verify the results. The chart is the Phase 1 testing results only.

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. 13

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. 9/11/201514

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 CompanyMin Seeds per hectare Max Seeds per hectare % Poncho Votivo Above min EPA80,000None Corson Seed80,000120,00050% + Pacific Seeds80,000115,00044% + Pioneer Seeds88,000110,00027.5% + 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.

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. 17