Vermont beekeeper tells committee draft neonic rules lack IPM thresholds, urges stronger disposal, notification and aerial‑spray limits

Andrew Munkress, a commercial beekeeper from Cornwall and the immediate past president of the Vermont Beekeepers Association, told the Agriculture, Food Resiliency & Forestry committee that draft agency rules implementing H.706 do not reflect how integrated pest management operates in the field and omit clear action thresholds that would justify insecticide use.

Why it matters: Munkress said the missing thresholds undermine the point of IPM and leave beekeepers exposed to systemic seed treatments that persist in soil and water and can poison pollinators across the season.

Munkress said the draft definition of integrated pest management in the rules is “boilerplate” and “doesn’t include the 4 basic steps,” starting with a clear action threshold. He told lawmakers that, in practice, beekeepers accept annual colony losses and that “the general agreed upon threshold is somewhere between 15–25% loss of colonies,” a level he said would normally justify stronger control measures in crop IPM frameworks.

He criticized language in the draft that describes best management practices as recommended actions available “where reasonable and practical,” saying that many provisions “should say shall rather than should” and that making measures voluntary through 2029 leaves beekeepers at continued risk. The draft BMPs mentioned in testimony are set to begin as recommendations on July 1, 2025, with a statutory ban referenced for 2029.

On disposal of treated seed, Munkress said burying leftover seed is unsafe because neonicotinoids are water soluble and persistent and recommended sealing leftover seed in a clay‑lined landfill rather than on‑site burial. He told the committee he had seen “spectacular bee kills when neonics have been disposed of incorrectly throughout the country.”

Munkress urged a ban on aerial applications of neonics in the rules, saying drift from aerial sprays creates unacceptable risk to honeybees and native pollinators and that, if broadcast spraying is permitted, ground application is less likely to drift into adjacent habitat. He said, “VBA would really like to see the aerial spraying of neonics banned in the rulemaking process.”

On notification, Munkress noted a draft communication section that would require 48 hours’ advance notice to apiculturists “who have established apiary on the premises.” He told the committee that a planting‑event notice is of limited use because neonic exposure occurs over months through dust, nectar and pollen uptake and that effective notification should be tied to exemptions to the ban rather than to planting events. “If I got a notification from a farmer saying ... I got an exemption to plant clothianidin treated seed in this field that’s 500 yards from your apiary, then I would have the choice,” he said, arguing that notice at the time an exemption is granted would allow beekeepers to move colonies before planting.

Munkress recommended that notification be distance‑based because pesticides “don’t respect property lines,” citing pollen tests showing impacts from roughly a half‑mile up to 1.5 miles and noting Vermont regulations that generally have beekeepers register apiaries and space them two miles apart. He suggested using existing mapping tools such as FieldWatch or the Agency of Agriculture’s apiary map to automate notices to beekeepers within a proposed radius.

Committee members asked about sublethal and cumulative effects of neonics; Munkress agreed that damage is often “death by a thousand cuts,” describing how low‑level neonic residues in pollen can weaken queens, reduce brood productivity and cause colonies to dwindle over a season. He cited a tested apiary that recorded 9.5 parts per billion of imidacloprid and clothianidin in pollen and said all 34 hives in that yard were dead by fall.

This was testimony and discussion only; no committee action or vote occurred. Munkress said the Vermont Beekeepers Association intends to submit comments during the public comment period when agency BMPs are posted, and committee members said they will continue to monitor the rulemaking process.

The committee heard related testimony earlier in the session from representatives of the Xerces Society and from Agency of Natural Resources staff; witnesses and lawmakers referenced Act 182 and H.706 as the legislative basis for the rules now in agency rulemaking.