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Letter to the USEPA from the Director of the film Nicotine Bees

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I have received a copy of the "Letter to the USEPA from the Director of the film Nicotine Bees"

Excerpts from the letter:

> To: Mr. Stephen A. Owens Assistant Administrator Office of Prevention, Pesticides and Toxic Substances US Environmental Protection Agency

> Dear Mr. Owens: I am the Director of a new film called Nicotine Bees, a documentary just released on the serious worldwide, simultaneous die‐offs of the honeybee.

> Worldwide, simultaneous bee dieoffs are easily explained by nicotine pesticide use. The ‘body of evidence’ for problems with nicotine pesticides is substantially larger now than at the time of most of their current registrations, for most of their current uses.

> Major crop losses from reduced honeybee pollination services can clearly exist at sub-lethal neonicotinoid concentrations – please see the well‐known work of Professor Dr. Jürgen Tautz in Germany.

* I had a very hard time finding anything by Dr. Tautz about CCD or neonics. There was this from the National Wildlife Federation

> "When bees are healthy, people are happy," says Tautz. But lately, some honeybees have seemed anything but healthy. For the past two years, many North American beekeepers have reported abrupt disappearances of all adult bees from colonies, with some losing bees in as many as two-thirds of their hives. Though U.S. beekeepers have been hardest hit by CCD, apiarists in Europe have reported similar honeybee problems. "We don't have a really good explanation" for what causes CCD, says Tautz.

> "Our goal is to understand the complex natural fighting of diseases by honeybees," adds the scientist. The group's RFID technology helped researchers discover one such strategy the insects have evolved to protect colonies from viruses or other pathogens. "When individual honeybees are infected, they undergo fairly quickly a change in their nervous system," explains Tautz, "and change in nervous system means change in behavior, and change in behavior in this case means there are problems in orientation and navigation." In short, the sick bee gets lost. Unable to find its way home, it conveniently dies away from the colony. "This is a very, very clever measure of nature to clean the colony of such carriers of pathogens," Tautz adds.

* Dr. Tautz co-authored a paper on "Immune-Related Proteins Induced in the Hemolymph After Aseptic and Septic Injury Differ in Honey Bee Worker Larvae and Adults" in Insect Biochemstry and Physiology 69:155–167 (2008).

> Because of their social lifestyle with a very high population density in their hives, honey bees are especially vulnerable to infection by pathogens.

* Not to belabor the point but Dr. Tautz clearly is not the poster child for neonicotinoids. He not only states that we don't know why bees are dying in large numbers but he suggest an alternative hypothesis (to neonics): they're sick.