 We're all here because I'm able to talk to you, so I'm going to do it. Okay, well thank you everybody. We're the other house together. We're the other house. Well, you're upstairs, so we'll lock the other house into the truth. We'll take it. So, thank you everybody for coming today to hear a presentation on Neonocatinoid research for Treated Sea to the Environment. And we appreciate our witnesses, our guests today. And this is a joint hearing with the Senate Agriculture Committee. And our first witness is Erika Cummings. And Erika, if you want to identify yourself for the record, we'd appreciate it. Sure. Erika Cummings, Erika Cummings, I'm the policy specialist for Neonocatinoid research. Thank you for having me to speak with you today. My presentation is titled Evaluation of Neonocatinoid's Treatments in the Environment Part 2. So, I'm going to do a quick overview. I'm going to go through what Neonocatinoids are, why they're used, some of the risks and challenges associated with them. Laura Kliber from Minor Institute is on the phone line and she's going to be talking about a project that we've collaborated on. I have some research updates, some new behind wax analysis results, and then moving forward. So, Neonocatinoids are a family of chemicals that are based off of nicotine. And they're popular because they have low human intoxicity and they're systemic insecticides, meaning that they are taken into the plant and they persist within the plant tissue. So, anytime an insect pest feeds on that plant, the insect dies. So, one way in which Neonocatinoids enter the state is as seed treatments, primarily on corn and soybeans. The Neonocatinoids use a corn, a plant that's in and close to the anodine, and then soybeans emit a flow grid. And it was estimated in 2018, we had about 120,000 acres of corn plant in Vermont and 3,000 acres of soybeans. And currently, we are getting data for the 2019 seed sold, both genetically engineered and also trade seed. The dealers have until February 15th to get us those numbers. I can ask, is this on paper? I do. I can send you a paper copy, yes. This is on our website. Wow. Bobby wants a paper copy. So, the purpose of these treatments is to protect seed and seedling from insect pests, like white grubs, corn seed maggots, and wireworms. I mean, they're just lovely pictures of those feathers. So, what increases pest pressure? So, corn seed maggots like manure application, cover crops, old forage stands, weeds, grubs and wireworms, like plow down sod, pasture, hay fields. What they all have in common is a light plant cover. When I worked for UVM Extension and we would get calls early in the season about corn damage, we would go out. And the first thing we would look for is field condition. Were there areas where cover crop or pasture wasn't plowed down? There was weedy areas. Usually the damage coincided with where the plant coverage was remaining. Erica, could I ask you a question? Sure. Where do wireworms come from? Is there a fly that lays eggs that creates wireworms? We're not. I'm not. Gary, can you... I can get you that information. Gary, where are those? Gary, because every once in a while they show up in my chicken coop and the chickens love them. You turn over a flake of manure or something, and there they are. I do believe that there's definitely an adult, but I'm not sure what it looks like. Okay, thank you. So one of the unintentional consequences with new farming practices to improve water quality is we've created large refuges for these insect pests. So we have increased cover crops, increased no-till, and we have increased pest pressure. So the next slide is just some damage. As you can see, we have... There's wireworm damage, which is that green, like it looks like a snowflake corn leaf, and it can go from minimum to complete decimation of the crop. So some of the challenges, pest pressures are hard to predict. The pre-planning scouting protocols that are available right now are very time-consuming, and their efficacy is still being determined. It's difficult to detect pest damage until the damage is done. And for those of you who are familiar with corn, when a corn plant is down, 99.9% of the time it's not coming back up. There are alternative controls. There are various ad-planting insecticides that can be applied that could include carbamates, organophosphates, pyrethroids, and neonicotinoids. So the problem with these is that they can increase exposure to non-target insects and also human exposure. So some of the alternative control measures... I took this from the University of Tennessee, and it's funny that the first thing they have listed is chlorpherophosphate, which is not registered for use in Vermont anymore. But this gives you a sense of the application rates to control these pests. And these are amounts at 1,000-foot-row, and remember that there was 43,560 square feet in the nacre. So the next slide just compares how much insecticide that is being applied in seed treatment versus an ad-planting broadcast application. So significantly more. So the first two in your slide shows that it must be... Is there pounds per acre? So these are ounces per acre. Ounces per acre? Yeah. I want to just read those numbers. Sure. So poncho 250, which is a cookie ended in, at 0.25 milligrams per seed, at a seeding rate of 33,000 seeds per acre, which in 30-row spacing, which is standard, you would get 0.29 ounces per acre. If you went with a high rate of poncho, which is the 1250, which is 1.25 milligrams per seed, same seeding rate, same spacing, you would have 1.46 ounces per acre compared with capture, which is a bifenthrin product. The range rate is 0.2 to 0.78, and you would be applying 8.7 to 34 ounces per acre depending on the concentration of these. So significantly more. So are those comparing different types of... The table down below is comparing different types of pesticides, or is it comparing, and or is it comparing different types of application? It's different types of application is the primary thing. It's a seed treatment application amount versus a broadcast supply. But there are also different kinds of pesticides, so raise it both. Well, so I used the rate, it would not be a both. It would be an either or. You would either do an out-planting or a seed treatment. And I used just one of the products and the range that they put from is 0.2 to 0.78 ounces for 1,000 foot. But not all of them can be applied as a seed or a broadcast. Can you go back to the other table? Sure. Because you have different on the products. You have different products and you have... So it's unclear what you're trying to compare. So I'm just trying to compare the amount of... If you were going to apply an insecticide as a seed treatment as a neonician, it would be that rate. And if you were going to apply another insecticide, instead of a neonic, you would be applying a lot higher concentration of insecticide. Are the other insecticides available as seed treatments? Some of them. There are some and we do have one. I'm just trying to figure out if you're doing an apples or anything. No, I'm just... It's basically just a comparison of an atlantic broadcast applied insecticide versus a seed treatment. That's really what I'm getting at. And so not all of the alternatives are labeled for seed treatment. The ones that are primarily would be the chlorpyrifons. Yeah. I'm just a stickler for good tables. You've heard me ask these questions before. So if you're going to put something on a table, you need to make it consistent across the categories. So I'm going to briefly talk about environmental benchmarks. They indicate the toxicity levels for different organisms. Acute is a one-time exposure versus a chronic, which is continual exposure over time, which is usually at least 21 days. So as you can see, for acute toxicity of a metacloprid, we have 0.385 for metacloprid, 0.17.5 and close the evidence in 11. The last product in that table is not a neunicotinoid, but it was used as a seed treatment in 2019 at Minor Institute, and it is Chlorin-Traniloprol. Say that five times fast. And I put on the list because it is more cutely toxic than the other two seed treatments used to treat corn. And for all of the water samples that I'm going to go over the results, we will be using the aquatic converter for it value because it is the most conservative and also because the closest related to terrestrial insects. And is it going to be all in parts per billion? Parts per billion. Billion. Yup. Yup. So now... I was just wondering what vascular and non-vascular plants were. So I think non-vascular would be like algae and vascular would be like a terrestrial plant. And next up we have Laura Kliber on the line from Minor Institute, which she'll be talking about a collaborative project we've been working on. Are you there, Laura? All right. Yes. Thank you, Erica. So you have Laura Kliber here from Minor Institute. Thank you for letting me speak to you today. So I'm going to have Erica advancing my slides for me. Until about three years ago, we began collaborating with the agency of Ag to take advantage of a field site that we were already monitoring so that we could gain some insight into whether the seed treatments that we were using were making their way into the runoff from these fields. So we established this site for a six-year NRCS at the field of water quality monitoring studies where, for that study, we were measuring the phosphorus, nitrogen, and sediment exports in both the tile drainage and surface runoff. So we figured it would be a great opportunity to take advantage of this site and gain some further information on some water quality metrics. So the practice we're evaluating for that NRCS project is drainage water management. This is the practice that allows us to manipulate the tile drainage system in one of these fields and I'll get to the specifics of that in more detail in a minute. We've been sampling for three years next month and during that first year, during the first year of exactly the same, one of these fields is managed with drainage water management. So as far as field out systems, they're spaced laterally at 35 feet and at an average of four feet depth. The fields are planted with corn that are harvested for silage. Following the corn harvest in the fall, we fill that in with a dish taro. The dish taro is considered conservation tillage because it does leave quite a bit of plant residue on the surface, which is beneficial for erosion control. Those two pictures on the bottom right are roughly equivalent to what the fields will look like following that fall tillage. We have the smaller fields, field T5, and then sort of that reverse L shaped field, the field T9. So one field is about four and a half acres, the other is about eight acres. So the purple squiggling line of surface runoff in these fields, and those monitoring locations are represented by those lime green polygons into a main line at the southernmost edge of sight. You can see represented by those pink ovals. The smaller fields T5 are the drainage water management reasons. Next slide. It works by installing on the main tile outlet from the field. We can install plates in these structures and those plates forces the water to rise to a higher level in the field before it is able to flow out of that tile system. So instead of the soil being drained to whatever the depth of the tiles are in those fields, we can adjust it so that anywhere between the depth of the tiles and the soil surface is being drained. So once we have finished all field activities in the fall, we install the plates so that there's only one foot of soil that is now being drained. And we'll keep at that rate throughout the remainder of the non-growing season. So in that first picture, you can see how those plates allow the water to back up into the fields before finally correcting those plates and flowing out. So by doing this, we should be able to significantly reduce the volume of water that is being drained from the field when we have these plates in place. Then in the spring, about a week or two before the field work starts, we'll remove the plates and allow the tiles to flow freely again so that we can make sure that the field is dry and ready for equipment traffic. Then shortly after planning, those plates can installed again at this time, allowing two and a half feet of drainage since there is a growing crop and we want to make sure that we're not stressing it if there are large rain events. So then those plates are left in until shortly before harvest, at which point they're removed so that we can allow the fields to fully drain before we get that equipment back out on the fields again. And then after that harvest again, loop back to the front to install those plates to one feet so that we don't quit non-growing season. Next slide. So here's some actual pictures of what these structures look like. There's a control structure being installed intercepting that main tile line. On the right you can see the installed structure. Typically they stick out of the ground by about a few feet. And then at the bottom left, you can see the control structure which have the two runners going down the sides of those structures where we can insert those plates. And then over the years that we've been monitoring, one of the fields, field T5 has been managed with this drainage water management practice. Next slide. You can see on the right-hand side that black structure is what we call an H-flume. So all of the surface runoff from the fields flows through this flume and we have equipment that is measuring the height of the water in that flume. And then we can convert that water height to a flow rate. And then next to the flume you can see the sampling cut which houses all of our monitoring equipment. The equipment that is continuously measuring the flow of the water can communicate with the automated sampler that we have in that cut so that for a predetermined amount of flow a sample is taken. So for the larger fields that 80s are fields we're sampling every 3,000 gallons of runoff and the smaller fields is being sampled every 1500 gallons of runoff. So every time a sample takes about 8 ounces of runoff water adds that sample to a large sampling bottle. And so then we go out to the field and retrieve those samples every 3 to 4 days. So we have a large composite sample that pretty well represents the water quality over that period of time. So by having this type of sampling method we're able to get a very representative sample of the water that is leading the fields as compared to sampling at preset time intervals where we would be sampling low flow frequency at high flows and likely overestimating the influence of those low flow samples. Next slide. So now we're looking at the, so the equipment is basically all the same. We have the same samplers, the same electronic flow measuring equipment. We sample at exactly the same intervals the only difference being how we measure the flow. So instead of that black H-flume we have a 55 gallon drum you can see down in the bottom portion of the picture so this drum has this D notch coming to the front of it so that as the water flows into the back of the barrel and the rate of flow increases the water will rise up higher in that barrel. And then we've developed a relationship between the height of the water in the barrel which we'll see on the next slide. So advanced to the next slide. So here we can see along that mistakenly says flume height that should say barrel height as this is for the flow barrel it's not the flumes. And then along the vertical axis we have the rate of flow. So each of those flume points you're looking at on the graph represents field measurements were taken on both the height and flow. And then once we plot all of these points we can plot a best fit line through those points and the equation of that curved line allows us to take those water height measurements that we're getting from the field close those type measurements into the equation and then we get the corresponding flow rate. Next slide. We have red and I just want to be sure to point out that we do have two different vertical axes on this graph. So this is because the surface flow rate is so much higher than the tile that we wouldn't be able to take up much from the the max for the tile for the tile flow than what we see for the surface runoff. However they do flow much more continuously than the surface runoff. So in the top right you can see those numbers that tile flow generally is responsible for anywhere from 60 to into the 90 percent of the total runoff from the field. Growing season so you can see those brackets with NGS above those periods of time between October 1st November 1st and April 30th represent somewhere between 50 to 30 percent of the total aim consistently at these sites that we've monitored at the minor institutes and it's also well documented in the scientific literature in first studies that are in similar climates as ours. So this is because colder temperatures significant snow melts and no crop growth to remove water from the soil the fields are generally much wetter and much more prone to generating runoff during these cold weather months that we saw from the first field those tiles flow contributing over 40 meters and again the growing season in the field. I'm going to take you through some of the results from the sampling program. Thank you Laura. Thank you very much. Thank you. So a word went through most of the background of the project I just wanted to point out that in 2017 and 2018 the E-Nicotinoid sea treatments were used and in 2019 there was non-needentinoid use called Lumovia which is that Chlorotraniloprol Chlorotraniloprol So the results we've gotten thus far from 2017 to 2019 there was 169 subsurface or tile drain water samples analyzed and 29 surface water samples analyzed. There were no detections in ecloprine and all detections of clotheanidin and thymothoxin were both low acute toxicity levels for aquatic invertebrates. The detections occurred during planting or in the fall when plant debris was being incorporated and there were no implications of chronic exposure exceedances. So wait. Those are all neonicotinoids that there was no detection of and that I'm not going to be able to say these that's a neonic and the other ones are neonics as well. So yes all three of those are neonicotinoids. So from between 2014 and 2019 382 surface water samples were tested from areas of high agricultural use during that time we had one positive detection of ecloprine which was below the acute benchmark for aquatic invertebrates. We did see more detections of thymothoxin and clotheanidin as you can see we had 15 detections of thymothoxin and 18 of clotheanidin. These were all usually during the time of planting and they were all below the acute toxicity level. Acute toxicity for who? Aquatic invertebrates because of the aquatic invertebrates. So those are because it's the most restrictive. In 2016 soil samples were taken from four different cropping systems on three different dates and at three different depths and they were next to title during outlets. So in the cornfields we saw several positive detections of thymothoxin and clotheanidin ranging between 2.08 to 14.13 first per billion. Most of the detections were in June during planting and they were in the top 12 inches of soil. In the soil infield we found one detection of a metacloprid which was 6.43 parts per billion and again it was in the top 12 inches of soil. The question was asked are new nicotinoids being taken up by non-crop plants? So in 2015 and 2016 vegetation was collected from areas of high agricultural use in Franklin County. The plant primarily collected was goldenrod because it is seen as a late season food source for pollinators. And we had one positive control which was corn leaves from treated seed and we had one positive detection which was the corn leaves. How many acres tons did you survey? We did. It was in Franklin County that there was this study on between 2015 and 2016. I don't care if you have more information on the numbers sampling sites. I don't have a number of sampling sites with me. This was in around one field where we were looking at if we could see the migration of the new nicotinoids from the field to the tile drainage ditches and into the forage that was growing in those ditches and our positive control was the corn that was treated and growing in the field. Typically, yeah, but that was the positive was the corn leaves. Can I understand that better? So you were saying it showed up in the corn leaves. Right, but it didn't show up in the non-crop vegetation. Okay, so it wasn't transferred that way. But isn't these these are helpful? These pollinate corn? Not too many. And who sets the toxicity rates? The EPA. And what is the toxicity rate for the eunuch? Are there multiple depending on your product? So for minocloprid it's 0.385. For thymothoxym it's 17.5. For the anodin it's 11. For acute toxicity. That's all parts per billion. So now I'm going to switch gears and I'm going to talk about beehive wax analysis that was found in 2018. It was sponsored by the USDA and the B informed partnership. Wax was collected from five hives that were sampled twice once in the spring and once in the fall. The hives were from commercial beekeepers in Addison, Franklin The wax samples were analyzed for 193 different pesticides. Out of that in Vermont we had 10 reportable levels of pesticides, five of which were found are primarily beekeeping pesticides. And there were no neonicitinoids detected. So for the beekeeping pesticides those were for the varroa mites? Yeah. Next slide. So there were five varroa sites that were detected. Amitrized, Kumafoss, Kumafoxos and Fluvalinate and Limol. And you can see the different detection ranges in the number of positive detections. And out of five in the fall. And this is not an apples to apples ratio. It's a different medium but the aquatic and verbat toxic acute toxicity is marked for amitrized is 17.5 and for Kumafoss it's 0.037 parts per billion. So the additional pesticides that were detected, atrophy was detected in the spring but we did not see it in the fall. NBC is a fungicide used in ornamental trees and Digeron is another herbicide. It's a broad spectrum that is also used primarily in landscaping. And it was interesting that the Flumaturon is actually a cotton herbicide and the purgate is an insecticide right-of-side that was not, there was no registered use in Vermont in 2010 to 2018 so we believe these hives were shipped south and brought back up. That's our hypothesis. So in addition we had 14 unquantifiable pesticide detections. And what that means is is that they did not determine trace but they did not define what trace meant. So there were trace amounts of these 14 different pesticides. There's four fungicides, five herbicides, four insecticides and one burrowicide. And I thought it was interesting that deep was one of the insecticides that was and trace one of these. Could it be that you're not detecting neonics in the hives because the bees are dying before they get back? The reason they use wax is because it's thought that the pesticides can accumulate over time in the beeswax. But if the bees are dying prior to getting back they wouldn't be touching the wax. So how did Vermont do versus the national average? As you can see we are quite high in our bee pesticides. And the one thing that we are higher in the national average was the fungicide that's used primarily in ornamental treats. It's just there's a lot more use of these different burrowicides in hives. I would suggest that it's harder to keep bees in Vermont than it is down south. You know you can have say ferrule populations of bees in say Florida and we don't have ferrule or wild populations of honey bees in Vermont anymore and if you're going to keep bees in Vermont you really do need to control the mites. So our beekeepers are excessively controlling their mites with lethal and what we would consider pesticide misuse options. That's what this data sort of demonstrates. So of this on this table which ones are the burrowicides? So the 2-4 DMP is ametras. The clumafoss, the clumafoss oxen, the cluvalinate and the triangle. Okay so all the ones that are really high are burrowicides and the ones that are low are other or low are relatively speaking. The agency moving forward will continue to monitor waters throughout the state to determine if an important action is needed. Minor Institute will continue donating their time and resources to increase our data set and literally three days ago the EPA proposed new interim registration decisions for neonicotinoids and that is currently open for public comment. And with that with our questions did you report this morning on the difference between surface runoff and tile? I didn't include the tile drinking data because it was we had no new data for this year. So the surface water was just the updated surface waters that we had analyzed for this year for 2019. But I can get you the report from last year. We saw the report last year but I think it's real important that we keep tracking that into the future because it keeps surfacing that these tile drains are terrible. Right. And you know we need to test from minor and other institutions that are non biased reporting so that we can make you know good determinations of whether tile drainage is bad as what we hear or as good as what we hear. And we hear it both ways. So the 169 subsurface water samples those are tile drains from minor. Yeah. But I didn't have any report on that. Okay. Just to be clear the toxicity of the neonics coming out of the tile drains is in a safe level for aquatic insects. It's below the age of toxicity. I just want to relate that to my five fishing buddies and friends. Sorry. I have two questions. It sounds like it was just a couple days ago but I'm wondering what the EPA was changing with neonics and then I maybe have three questions. What your recommendations are based on this analysis and then what would you make recommendations that would change our oversight of ferroicides since those seem to be high in beeswax or should we not be concerned about that? Sure. I'm going to let Linda speak to the new neonics. This is Linda Vapuzzo from the agency. Linda Vapuzzo. I've only read it over quickly. They did suggest some change labeling language for some of the not seed treatment necessarily but other products that are neonicotinoids. There was a decision to reduce the vegetable to remove that as a seed treatment option and there were a couple other mitigating factors that they proposed and that is open for 60 days or 57 days now for that. It's as far as I got on that. It just came out two days ago. We will dig into that. The other question about ferroicides, you did give us authority to regulate the beekeeping industry a little more heavily and we are looking more for misuse than we had been in the past. Based on that it occurs a lot more often than we saw. And then, you know, the elephant in the room, what do we do with this data? We appreciate this body's authority to regulate treated articles. We're the only state in the country currently with that authority. We don't want to use it. But certain folks are holding us accountable. We can't use it unless we demonstrate harm. We're trying to do that. We're looking for the worst case scenarios and we're not seeing where harm is being implicated. So that's where we are. We're going to keep looking. We've looked at water, both surface and ground. We've looked at vegetation in field and how we feel. We've looked at soils and soil migration and then we've got, you know, the ability to actually gauge how much is leaving the field through tile drainage. What I really wanted you to take home from the partnering with Minor is we can calculate a volume that's leaving those fields because she's monitoring these fields so tightly. That's where we are and we appreciate the opportunity to keep you guys up to date with the area. Like I said, we have this authority. It'll be interesting to implement it when we can, but we're currently not demonstrating that we need to. Anthony? It's a sort of a policy question. Policy slash scientific. I'm not sure which, but you're finding these acceptable levels yet in places around the world these things have been banned or restricted to use. Do they find any other evidence in Canada where they should get used to the endicanoids? What are they, why are we finding such acceptable levels when in fact places are other places that are finding unacceptable levels doesn't seem to job. Well, our cropping our agricultural styles are different. Our soils are different. We've got a lot of organic matter in our soils where you're finding issues with these. The acreages they plant are larger. There's less organic matter in the soils and their depth to groundwater is also different. So we're talking Midwest or I'm not familiar with European style agriculture, but if this body wants to send somebody from the agency, I'll check it out. Well, I would expect picking up on that that, you know, back in the 20s and 30s it was the dust bowl out west because they basically ruined their top soils and so their top soils are pretty thin compared to our top soils here in the northeast. You know, you take our forages we grow more forages per acre than out there. The only way they beat us is because they do four, five, six crops. Well, that strips their soils of their nutrients and their filtering capacities and we're pretty fortunate that we have good ad practices and more so we're fortunate that we've had farmers over the decades that took care of their soils. I have a follow up question. So I appreciate that you're able to give us actual real data, not just modeled data. So, you know, I appreciate that you showed us the methodology that you see as actual data and I get just to follow up on my question about the varroa sites. I mean, I hear what you're saying that you're not finding the levels of toxicity perhaps in neonicotinoids but maybe in other areas and so this has been my question all along, Carrie, is you know, what are the things that we are, what are the things that you're finding in higher levels than we should be comfortable with that we should maybe maybe it's not neonics, I don't know, but maybe it's something else and, you know, overall in our usage of pesticides and herbicides in the state, what are the concerning areas that you're finding through this data? Maybe we're not asking about the right ones and so I'm trying to figure out what are the right ones that we should be looking at and then I also have a concern about always following the EPA toxicity recommendations. I know that those are the best you have but as we found out last year with lead levels in drinking water for students in our schools their levels of lead were much more much higher and much you know, less health based and concerning and we took our levels down way much much lower so the EPA is not necessarily on the case for this stuff very very much and they are backing away from a lot of their stricter standards even so always following the recommendations of the EPA may not be what we want to do in Vermont so so sometimes it is and sometimes it isn't there is, I'm sorry there are so many questions. I know I'm just I'm high maintenance but come on so the lead levels and the other levels the PFOA levels that are established by EPA they're established outside of FIFRA and FIFRA is the federal set or debt to set act which is bound to the food quality protection act which in the food quality protection act is where those standards get set. The lead level, the PFOA levels those are set differently and those are based on different criteria than the pesticide levels that are established with the food quality protection act which has to include health values and they have to get revaluated for every active ingredient every 15 years and they are using all the data available so I understand you 15 years is a long time when it comes to science not when you're so those, I'll go over the schedule of you and that 15 years was the impetus behind us arguing for the ability to regulate treated articles when EPA found out that copper chromatid or pressure treated wood was an issue it took EPA 15 years to get that out of the market with the ability to regulate treated articles to just demonstrate harm and remove that from the marketplace for the owners so we do have flexibility here that EPA doesn't have a schedule with you the re-registration schedule the reason that it takes 15 years is the amount of active ingredients in there on a constant cycle you know the triazines review they went after zines, simazines, cyanazines all into one package that review took 10 years so in 5 years that needs to be re-reviewed on the data you have are there things that we're missing that we should be paying attention to? I think not with regard to treated seeds and those are conversations that I think we can have outside of talking about neonics I know you've asked before I'd be glad to come in and chat go over some of the use data what we're seeing the data was presented here that amatras, chlorpherophosis amatras also the only use left for amatras is for use in hives I think they've eliminated everything else and in hives and on the back of cattle are the only two uses for amatras there are no food uses it's not so the tops package associated with amatras is more concerning than some of the other minus sides thymol is time oil less concern about the high levels of thymol than I do about amatras they just brought amatras back for use in high minus side two years ago that use had been eliminated but the beekeepers pleaded for another tool to control lights and prior to that beekeepers were misusing amatras with going by this cattle cattle spray on treatment dip something in it and stick that in the honey we have seen amatras carry through the honey and when we did it it was a misuse so if tools aren't available people will use tools that aren't available so can you remind us that to to plant treated seeds do they do we consider that like a pesticide the same way that there's treated we don't there was some consideration at EPA to register a treated seed as a pesticide but it's currently considered a treated article that application takes place in St. Louis wherever the seed is manufactured gets shipped as a treated article and you don't need an applicator license to plant that seed and so nobody has to demonstrate any need that's what they want they go buy or plant it correct and what about for other pesticides that people do have to go through they have to get license to plant and to be a license applicator they have to have some training to be following the direction but even there do they have to prove a need or they just once we believe that they're going to do it responsibly it depends on our level of regulation to a permit program the agency grounds or not the golf courses for instance there's a written but every golf course in Vermont needs a permit in order to use pesticides on that golf course and there are IPM protocols built into their permitting but if you're not operating under a permit IPM isn't required what's IPM sorry I thought that's what you were asking well I was sorry so proof that you need to use a pesticide it's usually an economic driver you see it a lot of the farms do implement IPM for insecticide use but it's not a requirement but it usually is financial driven when you're talking about that other uses hospitals use a disinfectant we don't make up proof that there's MRSA on the counter they can go ahead and use a disinfectant and we also mandate those uses without proof that there's a pathogen that needs to be killed so it depends on what sort of use pattern you're talking about whether not IPM triggers are used you know the other earlier this week I read a report probably about our atrazine uptake and how we're using a tremendous amount of that and then there was in that same story there was something to the effect that we have a manufacturer of certain products in this state they're using one of these herbicides or something and that's what drove the number not is that accurate it is is data that the agency published on our website that it took years for us I mean Eric has been working on that data for over a year getting it as best at the best data set we could and it's it tells lots of different stories looking at the atrazine data to me it kind of looks flat well I thought we were headed away from using atrazine and reports that I read in prior years but this showed an intake so we're looking at a snapshot if you go back to the mid 90s when the federal government cut the rate of atrazine and how we used to have we did 15 years ago but we're only looking at 10 years worth of data and it's been pretty flat it's roughly around 8,000 pounds of atrazine but if you did the math what could be used on our program just to make it easy we have about 100,000 acres of corn and the label rate for atrazine right now is the upper label rate is 3 pounds per acre so we could potentially see 300,000 pounds of atrazine to get used and still be legal but we're at 80 and that's because the cocktails that are being offered there's the current sort of weed management options are mixed, the blue mask is popular right now and it's a mix of mesotrile atrazine and metoloblor that's what people are using what people have found effective I did appreciate in the article that they asked Jeff Carter a lot of questions and I didn't have to answer them so it would be appropriate to have extension answering some of those questions I thought of having Jeff come in maybe next week we're going to have some testimony on this so if we work toward cutting that 80,000 pounds you know say by 10-12% I mean I'm wondering if that would be possible and still allow crops to grow so atrazine's got an 18 month plant-back restriction which means it's active in the soil for a year and a half so you're working on that? no but as we incentivize overcropping and no till you're going to see people shifting away from atrazine use because it's detrimental so if we keep incentivizing the conservation tillage and other practices we will see atrazine use decline but we need to understand that because Rodney's the only one that grows probably anything in a garden so we need you do a problem yeah you do a problem so I have a question so I'm interested about the high levels of atrazine it's a growing outside in the wax so I use for my hives I use I have a life bar and I think the other one is formic pro and where does that fit in is is that any of that? is it equal life bar yeah I'll look at the label because I could say what I think it is but I might be wrong but what's formic pro? formic acid and formic acid leaves no residue so formic acid is basically an acid and it works to drive the minds out of the house the tile drainage monitoring the grass look like you are monitoring all year round and this equipment looks like it would be really unhappy if it freezes how do you protect the equipment? Laura are you still on the line? yes I am did you hear it? could you repeat it please? the tile drainage monitoring equipment how is it kept protected from freezing doesn't look like it would be happy at all if it froze so we do have some sort of geothermal to keep those things warm additionally what you didn't see was that we now have a keep the wind down and then just for sight we run some heat paste which provides some additional heat around the more sensitive areas and keeps things from freezing up so we are able to confidently collect that day to year round thank you doc for bringing that up the rest of the story are there any other questions or comments? historically were there when did farmers do to diminish the facts of the magnets and wires and in places where they are now so we use coal or elm and copper so lindane which was going down then that was replaced by science and currently the florid trinilla is an option for seed treatment so what percentage was getting filled off before pesticide? or was it always like 15% or something? so i've never grown a field corn myself yeah that middle photo is a good representation of the area as you could expect on the left side it must have been a fight and or something increased corn yields i think that number is 6% and that's from 5 years thank you thank you all thank you for your presentation and thanks Laura thank you thank you