ASA reiterated support for pollinator health and the benefits of neonicotinoid seed treatments to soybean farmers in comments to the Environmental Protection Agency (EPA) this week.EPA released an analysis in October, contending that neonicotinoid seed treatments do not contribute to improving soybean yield; however, ASA has heard from farmers, especially in the northern and mid-south growing regions, that growers are seeing benefits from the use of neonicotinoid seed treatments.“ASA cannot support efforts to restrict or ban neonicotinoid seed treatment products,” ASA states in the comments. “Such efforts would unquestionably lead to additional and more costly input applications than the more limited use of seed treatment products.”The comments also underscored that soybean producers use neonicotinoid seed treatments where they are needed and effective, and don’t use them where they are not. That approach to the use of crop protection products should be rewarded, not penalized.“Farmers who use seed treatments for soybean seed note that the withdrawal of registration for neonicotinoids would harm the sustainability of those who genuinely need this tool,” ASA states. “Seed treatments both protect the soybeans from insects in the soil after planting as well as protecting the seedlings as they emerge. A below-ground insect infestation has no rescue options except replanting, and in the northern growing regions, replanting is not often an option. And farmers in the south report that since the advent of seed treatments, their need to apply a foliar insecticide on seedlings to 3rd tri-foliate soybeans is eliminated.”ASA pointed to reports of falling oilseed production in Europe, attributed to the EU’s restriction on the use of three neonicotinoids: clothianidin, imidacloprid and thiametoxam, citing reports of many farmers having to plow up their autumn-sown crops after failing to keep flea beetle attacks at bay.ASA urged EPA not allow political pressure to lead to restrictions on crop protection tools.“As farmers, we recognize our responsibility to stewardship,” ASA said in comments. “We are engaged with other stakeholders in educating farmers about seed treatment stewardship, and we are committed to promoting USDA’s programs to promote and protect pollinator health and habitat to our farmer members. We urge EPA to maintain its commitment to science in evaluating crop protection tools.”After an extension of the comment period, Friday, Jan. 23, 2015 is the deadline for comments to be submitted on EPA’s “Benefits of Neonicotinoid Seed Treatments to Soybean Production” document. Comments can be submitted here. Supporting documents and the Federal Register notice are at here.ASA continues to urge those farmers with direct, tangible success stories regarding the use of neonicotinoid seed treatments to submit those examples to EPA. Late last year, ASA also submitted comments to the related “Pollinator Health Task Force.” Those comments are available here.Click here to read the entire letter.