Thank you for this…

Thank you for this opportunity to comment on Amendments to the Pesticide Regulation (63/09 General) EBR 019-0601. The comment period is open for 45 days and that it is related to another regulation ER0 019-0481. It is only when you click on that link that is shows that ERO comment period is closed and only had a 30 day comment period. Please consider keeping the same length of comment period for related regulations or at least provide the date within the same page. I would have commented on that as well if I had known earlier.

So many regulations this government has put forward takes us backwards in terms of the environment. There is so much evidence (Science) to show how dire the situation is with climate change and biodiversity loss. It appears this government only has economic growth in mind and short term financial gain instead of looking at the overall long term cost and a coordinated approach to the issues we face. It is wrong to state that there are no financial impacts to Ontarions associated with this proposal when you have not considered the long term effects on the environment.

Globally. we are losing biodiversity and there are scientists that believe we are already in the 6th mass extinction. This one has been caused by humans though. Globally, vertebrate populations have declined by 60% on average in less that 50 years. In Canada, according to the World Wildlife Fund, one half of Canada's wildlife species are declining (83% decline) and state everyone including government must act NOW to reverse this decline.

Also, globally, one third of insect are endangered and more than 40 percent of insect species are declining which is even more alarming. All ecosystems require insects for pollination, nutrient recycling and are food for many other creatures. Amongst bird species, grassland and aerial insectivores ( Insect eating birds) are showing the greatest declines. Why? Research is showing only a small percentage of neonics make it into the plant and the rest goes into the soil, groundwater and seeps into wetlands. Research is being conducted to determine if neonics are affecting the aquatic insects that breeding birds need. Scientists believe that agricultural intensification is the cause of insect and bird decline.

This regulation states it wants to help farmers. Making it easier to use pesticides will not help farmers. Insects are on the decline, and agriculture is becoming more dependent on managed pollination services.The main cause of insect decline according to an analysis by Francisco Sanchez-Bayo at the Universiy of Sydney, Australia and Kris Wychhuys at the China Academy of Agricultural Sciences in Beijin is agricultural intensification and damaging impacts from insecticides including neonicotinoids and fipronil. They conclude these persist in the environment and essentially sterilize the soil. Climate change of course is also having an impact. Many bumble bees are in decline and yet Canada has done COSEWIC studies for 4 out of 40 Canadian Bombus species. There is a lot of pollinator research that shows that there are a number of stresses on pollinators such as climate change, habitat loss, disease/parasites from managed bees, invasive species and pesticides. They are all playing a role, all are happening because of what we are doing and together are likely causing all the declines.

Only 2 % of insects are considered pests yet pesticides that farmers apply impact all insects including predatory insects and pollinators. Pollinators are responsible for 80-95% of all flowering plants and include agricultural crops such as berries, apples, lettuce , onion, tomatoes, peas, beans, broccoli, cauliflower, flax, cotton, alfalfa, and clover. One out of every 3 bites of food or drink are due to pollinated crops.Without these, we would have to survive on wheat, corn and barley which are wind pollinated. Penn State Researchers have found that neonicotinoids reduce predatory insect populations by 10-20 %. Predatory insects eliminate crop pest insects and contribute billions of dollars a year to agriculture. Many scientists as well as conservation organizations such as the Xerces Society believe IPM Intergrated Pest management is the best option to deal with pests in agricultural settings and conserve beneficial insects. If farmers are having pest problems, it is a symptom and not the root of the problem. Applying pesticides to kill pests kills the insects that control that pest....Crop Rotations are used to prevent pest problems. Spot control methods can also be used rather than treating a whole field.

This government prioritizes money and profit. Pollinators add 217 billion dollars to the global economy. In southwest China, due to excessive pesticide use and habitat loss their wild bees have disappeared and farmers now have to hand pollinate their apple and pear orchards. Is this what Ontario wants?

Historically most of the research of risk assessment of pesticides on bees deal with commercially managed Eastern bumblebee or the honey bee and are lab studies. Honey bees are not native. Not as much research with been done with wild bees. Different wild bee species have different routes of exposure, may be different in terms of how susceptible they are (ie most of the canadian bees that have/are declining are from the same subgenus.)Some species nest above ground, others below ground so exposure rate may be different. Wild bees also have smaller colonies and only the mated Queens survive the winter so impacts are more dramatic wheras honeybees are managed by humans and being larger colony sizes can afford to lose more of their workers. Some bees collect soil, mud or leaves for their nests and some bees only forage on a single crop.Majority of wild bees are solitary so if they are exposed to pesticides may not successfully reproduce. Research also suggests neonics affect bumblebees and solitary bees more severely than it does honeybees particularily sub-lethal effects. And exposure to more than one pesticide can occur and must be considered. So much work is with honey bees yet it is bumblebees that can buzz pollinate and will be out in more inclement weather which we are to expect with climate change.
Some University of Guelph researchers, studied neonics on ground nesting hoary squash bees and found that the liklihood they were exposed to lethal amounts of clothianidin in soil was over 36% in squash fields. The acceptable threshold is 5%. One of the researchers, Nigel Raine, said these findings were applicable for many other wild bee species that nest on or near Canadian farms and that soil exposure should be used for assessments. They also found that 58% of the ground nesting bees that build their nests in corn and soybean fields would be exposed to a lethal dose of clothianidin during nest building even if only 25% of the soil enters the bee

neonics-
Only some of the compound is taken up by the plant(5-20%) The rest accumulates in soil and seeps into groundwater and wetlands and to the aquatic insects which is why the federal government is looking into this. These aquatic insects are food for grassland birds.
In one study, Canadian researchers have found at least one neonic in 91% of wetlands they studied.
Studies have shown neonics are persistent, and spread within the environment and are taken up into the nectar and pollen of flowering plants. Following label does not mean that pollinators will be okay. Fungicides are considered non toxic but still cause harm. Wild bee populations have decreased with fungicide use with bees not being able to fight disease and showing signs of malnutrition. With insecticides present as well, the impact is even greater. Herbicides limit the forage available to pollinators.

Bumblebees are also at a much higher risk of extinction once populations decline due to something called haplodiploid sex determination so populations can crash quickly. This is why bee researchers are stating the the bees in decline now must get protection now or they will likely become extinct. Certainly making pesticide use easier can't help that situation? In fact rather than add cemetaries, this government should remove golf courses and parks as exemptions to the pesticide regulations as they can provide suitable habitat to pollinators.

Science has shown that crop yields are higher on farms that are closer to natural habitat supporting pollinators. In a publication titled Native Pollinators and Agriculture in Canada, written by Agriculture and Agri-Food Canada it also speaks of better quality produce or more uniform maturation from insect pollination. One of their recommendations to protect wild pollinators is to "Save what you've got." They also recommend to create new habitat and manage to benefit pollinators including an easy solution of providing rock and brush piles to provide over wintering sites for bumble bees. Isn't this something the Ontario government can do alongside highways or waterways? Under the last recommendation they state " Many pesticides are toxic to insects, so whether and how they are used can make a great difference to pollinators." They advise to minimize the use of pesticides.

Some anecdotal evidence. A landowner up the road had beekeepers on either side of his property. A farmer was working his land. He said that whenever the farmer sprayed the land, both neighbours immediately complained of bee losses. The lawnowner decided he did not want his family exposed to those chemicals and stopped the farmer from working the land anymore. Also spray drift happens.

This amendment should not include Method 3 for the Pest Risk Assessment. Just because there are risk factors in a certain soil or landscape does not mean there are pests. Fact is due to erosion risk and low fertility, sandy soils should not be tilled frequently and planted to corn anyways. Intensive farming practices of today are not sustainable. Farmers need to work more with nature rather than try and control it through chemicals, fertilizers etc. Also just because there is one pest present in a field does not mean that it requires a pesticide. Making a pest risk assessment once per farm and only completed once is not right. A problem with pests one year does not guarantee there will be the same problem the next year.

Health Canada has proposed a ban on all agricultural uses of imidacloprid and and special review of canola neonic. (You state Ontario would consider further amendments if Health Canada restricted NNi's to protect aquatic species. Why not just follow their lead?) The United States has suspended any new uses of neonics until they assess their impacts on bees and the U.S Fish and Wildlife is phasing our more than 50 million acres of public land. Perhaps this government can get on board too? Pesticides should be a last resort. Don't make them so convenient. The Ontario government should continue to post sales date related to NNI treated seed. It is important for pollinator researchers and to see if Ontario is going in the right direction. Unless of course this government wants to be less transparent?
Low risk pesticides do not mean no risk. What qualifications does the Director have to assess pesticides and how is that person held accountable? Also notice requirements should be consistent to all users.

How ironic you have a bumblebee on your website. It appears that it may be a Bombus Pensylvanicus (American bumblebee) which York University bee researchers believe is critically endangered. Increasing pesticide use certainly won't help in the conservation of this species. And if you make it easier to get pesticides , more of it will be applied ( especially by adding cemetaries to exemptions). But then again, this government is not really concerned about species at risk. Just like another notice on this website.... the benefits of a Maple Leaf Meat Plant in Hamilton provides more benefit than keeping threatened grassland birds Eastern Meadowlark and Bobolink.....

Heard an interesting and hopeful piece of news the other day on the radio. New York officials are making developers install bird friendly glass on their new buildings which help reduce number of birds killed by flying into the glass on buildings. What a great legislation that makes a world of difference for nature. Wouldn't it be great for Premier Ford to get a few cheers from environmentalists by doing something great like that?
Perhaps if this government wants to help farmers perhaps government can pay farmers to keep a portion of pollinator habitat free from pesticides or insist it a requirement in exchange for a pesticide permit? Or instead of just having manicured parks, have developers put in pesticide free pollinator habitat (meadows) which would also support threatened grassland birds. This would make sense for climate change too (carbon sequestration).
Thank you.