Center for Regulatory Effectiveness Comments on the Welsh Government Action Plan for Pollinators

May 31, 2013

CRE Comments to the Welsh Government on Pollinator Action Plan

Members of the Biodiversity Team:

The Center for Regulatory Effectiveness appreciates the opportunity to participate in the activities of the Welsh Government to develop an Action Plan for Pollinators.

Our comments are based upon two recently completed landmark studies conducted in the United States:

(1)  A United States Government state of the science report on bee health prepared jointly by the US Department of Agriculture and the Environmental Protection Agency titled Report on the National Stakeholders Conference on Honey Bee Health; and

(2)  A study conducted by the National Academy of Sciences on Data Quality and Sublethal Risks.

A reading of the aforementioned reports clearly demonstrates that the decline in bee health is related to a multitude of factors the most dominant of which we believe to be the Varroa Destructor.

The study conducted by the National Academy of Sciences is significant because it gives invaluable guidance regarding the assessment of sublethal effects and the need to develop data quality metrics to assess studies dealing with  bee health decline.

Additional information on our organization is available at

A hard copy of our comments is being sent by mail.


Jim Tozzi
Member, Board of Advisors
Center for Regulatory Effectiveness
Washington, DC USA

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