Activism often rejects nuance. In environmental activism, the story is often that an evil corporation is destroying the environment or your health with the support of a corrupt regulator. Elected officials don’t care either because they’re ignorant or paid off. The public has no power, often due to active misinformation spread by the corporate bad guy.

But I’ve come to see this a bit differently. For many of the issues I’ve looked into, while there is a problem, the activist explanation of the cause is too simple and the proposed solution is easily ignored. The thousands who believe the simple story will not ultimately be heard. Take as an example the comments on the petition to stop use of the pesticide clothianidin based on believed risks to bees. These comments represent a real problem with how the public influences policy. Citizens feeling ignored is not good for democracy.

The public comments in favor of a ban are just too simple. Many are variants of text offered by activist groups. The greatest number of comments come from petitions tallied together from petition campaigns). Many comments are so simple — “Suspend Clothianidin. Stop killing bees.” — that I can’t imagine regulators will give them any weight. Some are just incoherent:

I strongly oppose the aerial spraying of Clothianidin or any other insecticide for any reason whatsoever. This is a violation of personal rights for every person exposed to toxic chemicals against his or her will, for most of us without our knowledge and for all of us without consent. … Further, not being made aware of treatment, its risks and benefits, and then being given no choice in the matter is in frank violation of the Nuremberg Code. Thanks, but no thanks, Big Brother.

Clothianidin’s most common uses don’t involve widespread spraying and, so far as I know, not aerial. Opposing all pesticides is of course utterly impractical. Bringing up Nuremberg is just absurd. Other comments blamed Monsanto erroneously (it’s actually Bayer that makes clothianidin):

Your decision to continue to allow Clothianidin to poison bees is short-sighted and wrong and makes one think that someone in the EPA must be taking a bribe from Monsanto.

Some comments do try to provide an original argument around sustainable farming but then make claims that EPA scientists would know are unproven and suggest alternatives that are laughable:

I am a future sustainable, diversified farmer. I support the ban of the use of clothianidin. Studies show this pesticide to be the culprit of colony collapse disorder in bees. … The use of more wholesomely derived pesticides such as Pyrethrin, Sabadilla, insecticidal soaps or garlic sprays could be supported.

By contrast, a comment from an entomologist both acknowledges that the pesticide may be overused but that suspension of use isn’t supportable by the evidence:

Because they provide a useful instrument in the IPM[integreated pest management] toolbox, I fully support the recent decision by EPA to deny the suspension requested to suspend the use of clothianidin. While still a toxic insecticide that can cause concerns when used inappropriately, and perhaps overused, removing it from grower’s use will only cause them to return to more toxic and problematic materials, viz., a return to greater use of soil insecticides…

In my review of the literature and from discussions with those associated with bees, clothianidin would NOT be considered a cause of colony collapse, albeit it is a possible cause of a number of bee kills that have been reported. And while significant, recent published research has indicated that hives can easily survive the bee kills associated with an insecticide, albeit a cause and effect relationship has yet to be firmly established even for that. More research is needed on that specific question. But bee kills, while a major concern, is NOT colony collapse per se.

Comments by a farmers group sound much more reasonable, even though I know they have a vested interest:

A strong majority of our state’s corn farmers have chosen to invest in clothianidin, which has improved grower productivity, income and efficiency. For these reasons our organization supports its continued use. Controlling pests has always been a big issue for farmers, but doing so in an environmentally conscious and sustainable manner is just as important. Clothianidin is an important tool in controlling agricultural pests. It is proven to control wireworms, black cutworms, white grubs and other early season pests that attack corn seeds and seedlings at a period when they are most vulnerable. Because of this early control, farmers don’t have to apply as many chemicals or make as many passes through fields. That means there is less potential runoff, energy use, emissions and soil compaction.

I really recommend paging through the comments and getting your own impression. But let’s take this comment as it represents the simplistic story in a couple sentences:

We must stop using this harmful chemical! There is absolutely no excuse not to. It’s harmful to bees, and without them our food supply is devastated. Show that you care more about people than the corporations lining your pockets. The corruption you’re demonstrating is disgraceful.

That’s the activist story in short. I’ve paged through around two thirds of the comments. The overwhelming majority of those in support of the petition are this simplistic story. Sometimes it’s dressed up with a couple cherry-picked studies.

In stark contrast, arguments in opposition of the petition are usually well argued. They list benefits to the farmer (for whatever crop the author cares about), but most at least acknowledge risks to bees, with varying degrees of complexity in understanding them. If the comments supporting a ban were similarly nuanced, they would note at least some benefits to farmers even if the conclusion of the comment was still that clothianidin shouldn’t be used. Which kind of comment is more likely to have influence on the EPA’s decision?

It may be usual that public comments read this way, but I think it is a sign of a larger problem. At least a hundred thousand people (or more) voiced a belief that clothianidin should be banned because it’s one of the greatest risks to bees. They really believe that. They may not know much more than what PANNA or the Center for Food Safety said in a blog or petition, but they believe it. However, in all likelihood they are not going to influence the EPA’s decision. It didn’t have to be this way.

Current research (in my opinion¹) supports both stronger limitations on how clothianidin is used (e.g. to reduce risks during planting) and a lot more research, both into low-dose effects and just general effectiveness². The anti-pesticide groups could be arguing for specific limitations on clothianidin use or new research on it. They could be trying to get laws passed to make pesticide use approvals require more data on effectiveness before approval³. Instead, they waste energy and the good will of hundreds of thousands of people on the unlikely request of a ban. Instead, they beat a drum saying that a ban is the only way to save the bees which unsurprisingly leads many people to believe it. The EPA has already rejected emergency restrictions on clothianidin. The agency is unlikely, given current evidence, to ban it outright. Concerned citizens who commented will feel disenfranchised, fulfilling the other part of the story that the regulators are corrupt. That’s not good for democracy⁴.

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