GUELPH – Grain Farmers of Ontario has written the provincial government urging them to move the consultations regarding the Regulatory Amendments to Ontario Regulation 63/09 under the Pesticides Act to Reduce the Use of Neonicotinoid Insecticides outside of the planting season for corn and soybean farmers.
“The proposed regulations amount to a ban on the product and state that close to 100% of corn farmers and 60% of soybean farmers will be impacted,” says Mark Brock, Chair of Grain Farmers of Ontario. “Our organization represents
28,000 grain farmers across the province and most farm both of these crops in a rotation — nearly all of our farmer members will be affected.
The government has set May 7th as the final date to comment on the proposed regulations, making this only a 45 day comment period. They also intend to move forward with the regulations before July 1, 2015 — which would be a record fast decision for the Ministry of Environment and Climate Change compared to similar decisions.
The Ministry of Agriculture acknowledges May 7th and 10th as key dates for farmers to be planting corn, and notes the first ten days of May as being critical for soybean crops.
“This is one of the busiest times of the year for grain farmers,” says Brock. “It’s unnecessary to force farmers to choose between planting Ontario’s crops or providing input to regulations that will dramatically impact their future.”
In reviewing other relevant ministry decisions, Grain Farmers of Ontario noted that the proposed seven week window between the end of comments and implementation of the regulation is ten times faster than the Ministry typically takes to consider less contentious issues that lack much engagement. Few decisions, even the non-controversial, could be found to have been made in less than six months.
- EBR posting 012-1394 where a policy decision (Water Supply Well – Requirements and Best Management Practices Manual) took 379 days with just two comments having been received through the EBR process.
- EBR posting 012-1559 where a regulation decision (Reducing Coal Use In Energy-Intensive Industries) took 318 days with just 77 comments received through the EBR process.
- EBR posting 011-8075 where a regulatory decision (Regulatory Discussion Paper under the Nutrient Management Act, 2002, to allow for the Land Application of Nutrient Feedwater in Ontario) took 614 days with just 12 comments received through the EBR process.
Ontario’s Agricorp crop insurance requires fields be planted by June 30th to be eligible for coverage. Grain Farmers of Ontario is asking the government to demonstrate good faith consideration of this issue by extending comments to this date, and removing any prejudgment on when they will implement their decision to show they are actually listening.
This request is within the spirit of the rules for the Environmental Registry consultations, which say on their own website: ‘ Some proposals may provide more time (e.g. 60 days or 90 days).’