2 Albinari Din Austria Brief an Tonio Borg in Englisch

7/27/2019 2 Albinari Din Austria Brief an Tonio Borg in Englisch

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A-1010 Wien, Georg Coch Platz 3/11 a

Telefon (+43 1) 512 54 29, Telefax (+43 1) 512 54 29-4, e-mail: [email protected]

Homepage: www.imkerbund.at PSK-Konto 1896.471, BLZ 60000 ATU 39422503

ZVR 682681379

Wien, 11. Mrz 2013

Dear Mr. Commissioner Tonio Borg!

The Austrian beekeepers had to recognize with growing concern the issue

of the effects of neonicotinoids on our honeybees, but also on wild bees

and other pollinators.

Already before the disaster in 2008 in the Upper Rhine Valley

unexplicable colony collapse was observed in intensive maize growing

areas in addition to other damage to bee colonies.

From 2009 to 2012 the beekeepers in Austria took part in the research

project Melissa. Through intensive cooperation the damages were

scientifically examined and clear connections between the effects of

neonicotinoid seed treatments on colony collapse and colony damage were

observed.

Also from the EU mandated monitoring for 2012 has unambiguously proved

in more than 50% of the examined cases that the damages reported by the

beekeepers could be traced back to the use of neonicotinoids.

Numerous scientific investigations over the last few years have shown

unambiguously that the neonicotinoids used mainly in agriculture are

able to kill bees. Also very low concentrations of these active

substances will damage the coloniey as a whole and influence it in

negative way, so that the bees can no longer carry out their duties in

the colony.

For the beekeepers it was a positive and hopeful sign that you have

proposed to suspend the registration for neonicotinoid seed treatments

responsible damage to honeybees (and many other pollinators) for 2 years.

This is already a compromise compared to our justified demand of a

complete ban of the entire group of these active ingredients.


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Your proposal represents a big chance to reach an European solution for

the health of the bees and it is high time for those responsible to

agree to your proposal at the next Scofcah meeting on the 14th-15th of

March.

Now I it has come to my attention that Copa-Cogeca in a recent letter tothe EU member states tried to lobby for the introduction of the

so-called " leeway-diminishing measures " (Mitigation Measures) and

Austria should hold out as an example of a success of these measures.

Especially in Austria these measures were cited over and over again to

justify the application of these substances and it had been claimed that

they had been success.

The opposite is the case:

As the Italian investigation APENET proves, the use of deflectoreswhich should direct the toxic dust on the ground result in a

substantially higher concentration of these poisons in the surface of

the soil. A case of massive damage documented in the Austrian monitoring

in 2012 suggests that in the end this massive concentration of the toxic

dust has caused the poisoning of bees engaged in the water collecting

especially after a subsequent rainfall.

Looking back in time the 42 colonies of the affected apiary had

developed well up to the time of the maize sowing as a result of a good

honey flow from rape normally and also had collected honey (beesoccupied the brood box in the Dadant size; about that 2 3 half-height

honey supers). From the time of the incident it went downhill with the

colonies. Queens and drones died, the colony strength decreased and

after approx. 14 days the frames were without bees in about 40 colonies.

Also in the two surviving colonies the queens had dropped dead. These

two hives could only be revived by adding new queens.

According to the beekeeper the main damage had appeared with a time

delay to the maize sowing. At the time of the strongest deathrate of the

bees the maize in the field in the immediat vicinity of the apiary hadalready developed (fig. 5 b) and it had strongly been raining after

longer drying spell.

In the course of the survey of the site by an employee of the

department for bee research and bee protection bees could be observed in

the corn field which apparently tried to soak up humidity with

outstretched trunk from the ground. The affected beekeeper had already

made the same observation.


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From the results of the residue analysis and these observations

however, guttation drops as well as contaminated soil moisture have to

be considered as possible exposition sources./ (Austrian Monitoring

Report Page 15).

Investigations conducted in the year 2011 with regard to the driftmitigation measure Sowing only with wind speed smaller than 5 m/s

conclude that during this particular year in no region at no time the

sowing of maize could have taken place in compliance with this measure.

"/The maximum permitted wind speed of 5 m/sec (= 50 tenth meters / sec

in the pictures) required by the registration since 2011 for the sowing

of insektizide treated maize or pumpkin seed was exceeded during all

three project years during most days for three time frames studied (7

o'clock, 12 o'clock, 19 o'clock daylight savings time not taken into

consideration) crossed. When applying the registration requirements ineffect since 201 for these days, or at these times, no sowing of

insektizide treated maize or pumpkin should have taken place. The actual

peak wind speeds recorded at the time of the maize sowing were in

numerous cases about double and less frequent around fourfold the

permitted value of 5 m/sec/

(Melissa Final Report Page 154 157)

Even if in 2012 less cases of damage were reported the causes for this

were not examined: Weather related? frustration of beekeepers who had

suffered repeated damage? the results of the monitoring show for 2012that the measures enacted by the authorities have been insufficient:

there were again clear cases of damage and more than half of these were

also unambiguously attributable to neonicotinoids:

In all cases with positive residue test results in bees or bee bread

the exposition of the bee colonies with the examined active substances

was shown unambiguously. Also the damaged bees showed typical poisoning

symptoms in the affected apiaries. On account of the temporal

coincidence of the bee's damages at the beginning of the maize

cultivation in the affected areas and the detected active substancesin particular to the active insecticide ingredients Clothianidin and

Thiamethoxam used as seed treatment in maize, a causal connection

arises with their application in this crop.

The frequency of the damage reports in April and May, as well as the

substantially higher share of tests with positive residue results -

compared to the period June till September-, is another unequivocal

inducation for this.


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As to the decline of the reported cases of damage:

Interestingly, in the percentage of the apiaries with positive residue

results for the active substances Clothianidin, Thiamethoxam,

Imidacloprid and Fipronil (incl. Fipronilsulfon) this decline is not

reflected. While from 2009 to 2011 in the project MELISSA thepercentage of the apiaries with positive results for the active

substances in question continuously declined from 93% to 71% down to 52%

, the survey carried out this year shows a *stagnation at 51%.*

(Monitoring Projekt Report).

The experiences of the Austrian beekeepers show that mitigation measures

required by the farmers have brought no essential improvement, and

present for the farmers only difficulties and requirements which cannot

be complied with in the practice of the everyday work.

The damage to bees recently shown in the 2012 monitoring indicate thisalso objectively.

Hence, dear Mr. Commissioner, we ask you to be steadfast with your

original proposal in the interest of the honeybees, the wild bees,

butterflies and all pollinating insects, to benefit biodiversity in our

European landscape.

With many thanks for your efforts

sincerely

Maximilian Liedlbauer

President Austrian Beekeepers Association

Documents

2 Albinari Din Austria Brief an Tonio Borg in Englisch