From a release
The Ontario Soil and Crop Improvement Association (OSCIA) has engaged at every opportunity to learn about the government’s comprehensive pollinator health action plan and has committed to meaningful dialogue. We acknowledge the government’s determination, but there is much at stake here and the OSCIA has serious concerns. The OSCIA feels the government has taken too aggressive of an approach on the issue, and appears to sidestep science in favor of appealing to the desires of the majority population.
Insufficient time has been invested in exploring alternate approaches and we feel this will have dangerous and far-reaching consequences in the farm community.
We have strived to be concise in identifying issues, and offer four recommendations.
1. Capacity to Provide Professional Pest Assessments
– Notwithstanding references to professional organizations acceptable by MOECC to carry out pest assessments, there are simply too few qualified individuals to provide prompt and timely service to producers. The window to carry out these assessments can be very narrow, particularly in the spring of the year before planting.
– The cost of these assessments will be a burden to the farm community.
RECOMMENDATION: Staged implementation. A few counties in each geographic region of Ontario should be engaged at the launch of 2016, rather than all of Eastern Ontario. This would better accommodate capacity building to perform the pest assessments.
2. Pest Assessments
– The protocol for determining insect pressure is too rigid and is not science-based.
OMAFRA has just recently published methodologies and thresholds (A Guide to Early Season Field Crop Pests) based upon the best science available. The proposed assessments appear not to follow the government’s own official publications.
RECOMMENDATION: At minimum, the proposed regulation should follow the established methodologies and thresholds as set out in A Guide to Early Season Field Crop Pests.
3. Measuring Performance
– It is unclear how the impact of the proposed regulations will be measured in terms of pollinator health. What system has been set up for verification of effectiveness of reducing neonicotinoid seed treatments to improve pollinator health? Will the outcomes of the regulation be justification for the added burden, risk, cost and reduction in productivity?
RECOMMENDATION: The government should continue to support science-based research to accurately measure and better understand the specific reasons for declines in pollinator health and should commit to a review to determine if the regulation has had any measurable benefit to pollinator populations.
4. Promoting Best Management Practices
– Conservation tillage, cover crops and the inclusion of forages in crop rotations have been promoted by OMAFRA and adopted by producers in growing numbers. These Best Management Practices (BMPs) for soil conservation and water quality protection can also create an environment that may result in escalated populations of wireworms, grubs and other insects. There is real concern that producers will abandon these BMPs in favour of more extensive tillage to create “clean” soil conditions to reduce the risk of insect damage to crops where insecticide seed treatment is not available.
RECOMMENDATION: The government should recognize the risk that producers may turn back to conventional tillage practices to cope with the lack of insecticide seed treatments, and develop clear messaging to reinforce the benefits of adopting conservation practices.