January 23, 2015
Ministry of Agriculture, Food and Rural Affairs, Policy Division
Food Safety and Environmental Policy Branch
1 Stone Road West, Floor 2
Guelph Ontario N1G 4Y2
Re: Pollinator Health – A Proposal for Enhancing Pollinator Health and Reducing the Use of Neonicotinoid Pesticides in Ontario.EBR Registry Number: 012-3068
The National Farmers Union in Ontario (NFU-O) welcomes the opportunity to submit comments through the Environmental Registry to the Ministry of Agriculture, Food and Rural Affairs on the discussion paper Pollinator Health – A Proposal for Enhancing Pollinator Health and Reducing the Use of Neonicotinoid Pesticides in Ontario. Please see the attached document for our detailed comments.
As farmers in Ontario, the members of the NFU-O are deeply committed to working with nature to produce healthy food and to protect and enhance biodiversity within and around our farms. We advocate for agricultural practices that are economically, socially and environmentally sustainable and built on the principles of food sovereignty. By working with and building our own knowledge and skills of agro-ecology we strive to protect the many organisms, including bees and wild pollinators, which provide economic benefits to our farms and contribute to a more beautiful countryside. Based on our commitments above, the NFU-O supports the approach taken by the Government of Ontario in its Pollinator Health proposal. We support the move to restrict the use of neonicotinoid treated corn and soybean seed to those acres which can demonstrate the need for treated seed and the commitment to increase the practice of Integrated Pest Management.
Respectfully submitted by
The National Farmers Union – Ontario
cc: Premier Kathleen Wynne
cc: Hon. Jeff Leal, Minister of Agriculture and Rural Affairs
cc: Hon. Glen Murray, Minister of Environment and Climate Change
cc: Mr. Toby Barrett, PC Agriculture Critic
cc: Mr. John Vanthof, NDP Agriculture Critic
Section A: Improving Pollinator Health
This is the non-regulatory part of the Ontario Government’s proposal and includes actions already being taken by the Ontario Ministry of Agriculture, Food and Rural Affairs and farmers.
|Questions from Discussion Paper||Comments|
|1. Four key stressors related to pollinator health have been identified. From your perspective, are there any other key pollinator health issues that need to be addressed in order to meet the overwinter mortality target of 15 per cent?
a. Pollinator Habitat and Nutrition
b. Pesticide Exposure
c. Diseases, Pests, Genetics
d. Climate Change and Weather
|2. Looking at the four areas, what are some actions or activities that industry, individuals, organizations, government and others could take to improve pollinator health?||
|3. How can we improve our outreach and education on the importance of pollinators?||
|4. What are the benefits of improving pollinator health?||
Section B: Reducing Neonicotinoid Use
This is the regulatory part of the proposal. Under this proposal the sale of neonicotinoid treated corn and soybean seed would be restricted. In order to purchase neonicotinoid treated seed a person would have to:
- be a “Qualified Farmer” or licensed agriculture exterminator
- complete focussed Integrated Pest Management Training for growing corn and soybeans
- document pest management activities taken to reduce pest threats
- obtain verification of the assessment by a third party
- complete a credible risk assessment that demonstrates the need to use neonicotinoids
- treated corn and soybean seed
|Questions from Discussion Paper||Options/Comments|
|1. What are the positive and negative impacts of this proposed regulation?||
|2. Is this regulatory proposal sufficient to reduce the acreage of treated corn and soybean seed by 80% by 2017?
Do you have any other suggestions?
|3. Are there any alternative conditions of use for treated corn and soybean seed that should be considered?
How would the requirement to demonstrate need change a farmers approach to assessing level of risk for soil pests?
What additional tools would farmers need to better assess risk and determine need?
Are some geographic areas always going to be high risk?
Are there other ways that a farmer could demonstrate treated seed is needed?
What kind of documentary proof would be reasonable to demonstrate need?
|3. continued …
Farmer/User Education and Training – re. requirement to be a qualified farmer
Do you have any comments on the proposal for the buyer to be a qualified farmer or agricultural exterminator?
Should the training/education requirements be the same as what is required now to buy and use pesticides on-farm?
What about requirements for custom operators?
|3. continued ….
Farmer/User Education and Training – re. completion of IPM training and documentation of IPM activities
Will IPM training be an effective means of conveying that NNI-treated seed be used as a measure of last resort?
Should focussed IPM training be (a) stand-alone or (b) a new component of the existing Grower Pesticide Safety Course?
Are there barriers to completing the training/education? E.g. on-line course or home study?
What kinds of IPM activities would be reasonable for farmers to document in writing?
Should documenting IPM activities be required on a field-by-field basis?
Does it matter if fields are owned, rented, sharecropped?
Barriers faced by farmers in practicing IPM?
Are there ways to minimize record-keeping and paperwork?
|3. continued …
Considerations for sellers of NNI treated seed
Suggestions regarding proposals for disclosing information to farmers before buying seed?
What information would help farmers when ordering seed?
Are there ways to minimize costs and barriers for those who sell seed?
|4. Are there alternative management practices or rules for use that could minimize immediate and long-term exposure of pollinators to NNIs that should be included in the regulation?
Any comments on proposed rules for using NNI-treated seed?
Are they management practices that most farmers already use?
Are there additional or alternative rules that should be considered?
What kinds of barriers or costs due to the rules? Are there ways to minimize costs?
|The proposed regulation would require farmers to use deflectors on negative vacuum planter, to follow label directions set by seed supplier or PMRA, the use of fluency agent, proper disposal of seed bags, cleaning up any spilled or exposed seed or dust.
|5. Are there other factors such as environmental considerations that could be incorporated into the decision of the need to use NNI insecticides?
Environmental considerations might include setbacks from surface water or bee colonies.
How can environmental considerations be brought into decision-making around NNI-treated seed?
Are there special circumstances where a farmer might have to take additional precautions?
|6. Are there any related geographic considerations that could be incorporated into the regulatory proposal?
Is it practical to treat some areas of Ontario differently under this regulatory proposal?
How could the proposal be modified to incorporate geographic considerations?
|7. What qualifications would be appropriate for third parties to support this regulatory proposal?
What individuals would be in a position to provide this third party confirmation? Could CCA’s serve as third parties?
Are there any other categories of people who could provide this third party confirmation?
What kinds of professional or other qualifications should be required of these individuals?
|Who is going to do the third party verification?
Who is going to pay for this verification?
|8. Please provide any comments on the proposal or related issues that you feel have not been addressed in the questions above.||