We at the Conservation Council of Ontario recognize the valuable contribution pollinators play in our ecosystem and are greatly interested in the proposed Pollinator Health Action Plan. Overall we feel that you have a strong document that should have a real impact on pollinator health if it is implemented in its current form. With that being said there are several things we would like you to consider to ensure the strongest possible plan of action based on a cumulative consensus from our membership.

When considering granting permission for the use of NNI-treated seed it is important to account for the surrounding region. If there is a large amount of crops in the immediate vicinity that would be served by the same pollinators it is important to assess the risk of damaging these by hurting their pollination services. A cost benefit analysis should be done to determine whether allowing for the exemption would open surrounding crops to a high probability of significant negative impacts. The third party that reviews applications for exemptions would likely do this most effectively. Another potential addition to the action plan would be to require those receiving exemptions to engage in extra practices that promoted pollinator health. This could be as simple as planting small sections of wildflowers that provided food for pollinators. This would help to ensure the strongest possible colonies, in hopes of reducing the negative effects of the pesticides. In addition it should be considered as to whether the ban should apply to all NNI-treated seed. If the treated seed provides little benefits as research suggests there is no reason not to apply this regulatory proposal to all crops.

In regards to the third party investigators that would review applications for exemptions it is important that they would be independent from both the seed provider and the farming operation. They should see no financial gain based on their decision going one way or the other. Either government officials or independent environmental investigators could accomplish this.

The proposed action plan should also include funding for research in to several areas. It is essential that more research be performed on geographic effects on pollinators’ health. During these investigations the effects of pesticides on pollinators in varying geographic regions should also be considered. More research should be done on honeybee mortality to determine what the major factor is and if there are other factors affecting pollinator health that have not been discovered. It is also important that ongoing research is done to determine the effectiveness of the action plan to ensure that pollinator health is rebounding appropriately.

One negative impact of the proposed regulation that should be carefully considered is the increased costs to farmers. While farmers are invested in pollinator health, as it is a valuable service for them, they will be concerned with the additional costs of mitigating measures and third party review. It is important that these new costs are kept low so individuals are not forced to circumvent the regulations. If fees are too high farmers could seek NNI-treated seed from other sources that would not require documentation approving its use, such as distributors outside the province where these regulations don’t exist.

While we at CCO think you have a strong proposal to protect and promote pollinator health we have included several suggestions that we feel would help ensure the stated goal was reached. This along with education programs to help promote pollinator health not only in rural areas, but also urban areas, should alleviate current pressure on an integral part of Ontario’s ecosystem.