The Conservation Council of Ontario recognizes the importance of pollinators and supports the proposed Pollinator Health Action Plan. However, they recommend several additions to strengthen the plan. These include: requiring those granted exemptions for pesticide-treated seeds to also plant pollinator-friendly wildflowers, expanding the pesticide ban to all crops, ensuring independent third-party review of exemption requests, increasing research on factors impacting pollinator health, and controlling costs for farmers to avoid circumventing the regulations. The CCO believes these suggestions will help ensure the goal of protecting and promoting pollinator health is achieved.

1. 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.

2. 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.