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019-0601

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37131

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This comment is related to https://ero.ontario.ca/notice/019-0601 .

I disagree with the proposal to reduce the regulatory burden associated with the sale and use of NNI-treated corn and soybean seeds. Given the broad scientific consensus around the harm to our pollinators from neonics, there is no way that we should be making it easier for people to use these harmful pesticides. We should be making it much harder for anyone to justify their use and definitely we need to know who uses them, where, and how much on an ongoing basis. Vendors absolutely must be required to submit to the government a list of Class 12 pesticides for sale, Annual Sales Data Report of NNI​​​​​​​-treated and non-treated corn and soybean seeds, and copies of PARs received by farmers. The Ministry must be required to post sales data related to NNI​​​​​​​-treated seeds on a regular and frequent basis.

Ideally, we should be outright banning the use of neonics, NNI-treated corn and soybean seeds in our province.

We need to be making our decisions based on scientific research and not let vendors sway us.
A good contact would be someone like Professor Nigel Raine at Ontario's University of Guelph who has done a lot of research in this area. We have scientific experts in Ontario. Let's use them.