The need for Science-based decisions
On Nov. 25, 2014, the Ontario government announced a 60 day public consultation on a proposal for regulatory action in Ontario. The document: Pollinator Health: A Proposal for Enhancing Pollinator Health and Reducing the Use of Neonicotinoid Pesticides in Ontario has two main objectives: to reduce the over-winter honeybee mortality rate in Ontario to 15 per cent by 2020 and to reduce the number of corn and soybean acres in Ontario planted with neonicotinoid treated seed by 80 per cent by 2017.
That very same day, Health Canada’s Pest Management Regulatory Agency released preliminary results of its bee health monitoring project. PMRA found that the number of bee deaths reported during planting in Canada was down 70 per cent in 2014, compared to 2013. In Ontario, the number of incidents reported during planting was down 79 per cent. PMRA’s full report is available at www.hc-sc.gc.ca/cps-spc/pubs/pest/_factfiche/neonicotinoid/neonicotinoid-eng.php.
The Canadian Seed Trade Association immediately expressed its disappointment that the government of Ontario appeared to completely disregard science with this proposal. In a CSTA news release, President Dave Baute said: “Seed suppliers and farmers were the first to take action when dust from the planting of treated seed was shown to have a negative impact on bees in Ontario and Quebec. The collaboration and commitment was unprecedented. But all of that work and its positive results, as shown in PMRA’s assessment, seem to have been completely ignored.”
Shortly after Ontario’s announcement, Statistics Canada released its data on beekeeping, which showed that the number of bee colonies in Canada increased by four per cent in 2014 from 2013, and by 12 per cent from five years ago. In Ontario, the number of bee colonies in 2014 is 15.7 per cent higher than last year, and 25.7 per cent higher than five years ago.
Neonicotinoid seed treatments have been a very useful tool for farmers during the past decade. Because the active ingredient is applied directly to the seed and incorporated into the soil, seed treatments reduce the risk of exposure to beneficial insects, targeting only the pests in the soil that can cause up to a 30 per cent crop loss. Seed treatments also have a much smaller environmental footprint, because the amount of active ingredient introduced into the environment is substantially lower — one per cent of foliar sprays. The technology also facilitates a no-till, precision agricultural system that protects our fragile soils.
While the goal to substantially reduce overwintering bee losses in Ontario is commendable, CSTA and our partners in the value chain, including beekeepers, know that bee losses are the result of many factors. Insecticide use inside and outside of the hive is just one of those factors. Science shows that the use of insecticide-treated seed is consistent with best management practices to reduce the exposure of pollinators to insecticides and has actually enhanced environmental sustainability.
The use of neonicotinoid-treated seed has allowed for expanded use of conservation tillage and zero-till systems and an expanded use of cover crops in Ontario to reduce erosion and enhance soil health. Crop damaging insects thrive under these conditions, but seed-applied insecticides protect the seed and the emerging plant. Without them, Ontario farmers will have to return to tillage to control insects, which will result in increased greenhouse gas emissions — both from decreased soil carbon sequestration and increased fuel use — and will reduce soil health. It will also likely require the increased use of fertilizers and might require a return to in-furrow and foliar applications of insecticides, which will have a negative impact on the environment. This does not align with the provincial government’s stated goals on climate change and environmental stewardship.
“The seed industry and the farmers it serves don’t take this ‘business’ of farming lightly,” says Baute. “It’s not just our business; it’s our way of life. We carry a heavy responsibility to produce high quality and affordable food for a growing world population in a way that minimizes risk to nature. We can’t do that without using innovative and specialized tools in an environmentally sustainable way. We will continue to trust in the science, and urge our provincial and federal policy makers to do the same.”
Public consultations are being held in Toronto, London, and Kingston through Jan. 15. CSTA will take part in these consultations to ensure that our voice is heard. We urge the provincial government to reconsider this approach, and begin working with the agricultural sector on collaborative approaches that provide solutions for the environment.