Guidance for the development of State Pollinator Protection Plans

The State FIFRA Issues Research and Evaluation Group (SFIREG), with input from the EPA,  published a guidance document to aid in the development and implementation of state Managed Pollinator Protection Plans (MP3). The purpose of the document was to advise state lead pesticide regulatory agencies, (State Lead Agencies or SLAs) on the critical and recommended aspects to include for developing a successful MP3.

The critical  and recommended elements suggested by SFIREG are as follows:

Critical Elements of a State Managed Pollinator Protection Plan (MP3)

1.  Public stakeholder participation process

  • Direct discussion between beekeepers, farmers, pesticide appliers, and other stakeholders
  • Must represent input from a balanced (representative) cross-section of stakeholders when plans are being developed and prior to it being finalized

2.  A method for growers/ applicators to know if there are managed pollinators near a treatment site

  • Ability of appliers to contact beekeepers to alert them to planned applications
    • Needs to be timely
  • Should define the distance from the application site in which an applicator should contact a beekeeper (pollinator awareness zone)
    • Typically a ~1 to 2 mile radius
  • Should define the method or means by which an applicator can identify the location and owner of managed apiaries nearby.
    •  Mandatory/ voluntary hive or apiary registration that identify geographically where hives are located
    • Other strategies to visually identify the location of hives (bee flags)
    • Some registrations very specific (GPS points), other list a township, section, or area and beekeeper has to be contacted directly to learn exact location

3. A method for growers/ applicators to identify and contact beekeepers prior to application

  • Need to be able to contact beekeepers and give them adequate time to manage hives and prepare for application
  • Plan needs to identify minimum time prior to pesticide application to contact beekeeper within defined action zone
    • Minimum timeframe used by several other states is 48 hours prior to scheduled application
  • Clearly describe how to obtain beekeeper contact information. Other plans have included:
  • Web- based apiary databases or self-registry websites in which applicators can quickly and easily obtain contact information for hives in a given location
  • Prominently display beekeeper contact information via signage on the colony location

4. Recommendations on how to minimize risk of pesticides to bees

  • Mitigate risk of pesticides to bees while managing pests
  • Best Management Practices (BMP’s)
    • Managing flowering weeds in crops
    • Making applications when bees are less active (dawn or dusk)
    • Using more targeted application (drip irrigation)
    • Using products less toxic to bees when possible
    • Minimizing or reducing pesticide drift
    • Utilizing Integrative Pest Management (IPM)

5. A clear defined plan for public outreach

  • Only be successful if there is a vast and robust adoption of the plan
  • Adequate outreach to publicize the plan and its recommendations
  • Meetings with organized stakeholder groups and beekeeper organizations
  • Posting plans on website for easy access by the public

6. Mechanisms to measure the efficacy and effectiveness of the MP3 and a process to periodically review and modify each plan

  • Goal is reduced exposure to bees through enhanced communication and collaboration among stakeholders
  • Include measure to determine if goals are being met
    • Communication / collaboration has increased
    • Pesticide exposure has decreased
  • Requirement for periodic review that is no longer than 3 years between reviews and submission to EPA for acceptance

Optional/ Recommended Elements of State MP3’s

1. Strategy to deal with hives without identified owners

  • Options will depend on individual state laws and regulatory authorities
  • Seek stakeholder input on reasonable approaches and actions for when unidentified colonies are found

2. Communication with crop advisors and agricultural extension services

  • Engaging with technical experts who make management and best practice recommendations
  • Often aware of local pest pressures and crop production needs of the area and able to make a realistic and specific recommendations

3. Clear information as to the applicability of the MP3

  • States may want to develop separate or modified MP3’s for specific cropping systems
  • Crop-specific approaches if needed
  • Clearly defining cropping/ beekeeping systems to which MP3s apply

4. Addressing urban beekeeping and pesticide use in non- agricultural settings

  • Depends if state has significant urban beekeeping or managed bees in/ near urban or residential areas
  • Some states may want to address non-agricultural pesticide use patterns

5. Recommendations for more formalized agreements between beekeepers, crop producers, and property owners, especially in situations with a financial agreement

  • Exchange of contact information
  • Agreements for capture responsibilities, notification requirements, expectations, etc