Chairman Finnigan, Co-Chair Brosseau, and members of the committee, thank you very much for this opportunity today.
After almost 30 years with the Ontario Ministry of Agriculture, 18 years working for the Ontario Fruit and Vegetable Growers' Association dealing with pesticide issues, and more than 20 years as a member of the Ontario Pesticides Advisory Committee, I'm here today to share my experiences with pesticides. I'm here to represent the 2,500 fruit and vegetable growers across Ontario and more than 10,000 across Canada.
Growers are Canada's prime environmentalists. They live on the land, not in city apartments. They raise their families there and drink the water from the wells on their land. They no-till their land. They plant grass waterways and buffer strips. They do not want to spoil that land. They, in fact, want to pass it along in better condition to their children, for the next generation. They know what their environment is because they live in it every day.
Growers of fruits and vegetable crops across Ontario and Canada have been using imidacloprid since 1995, starting first with an emergency use on potatoes when every other registered insecticide had failed due to pest resistance.
Over the next 20 years, growers came to rely on this chemistry for a wide array of crops and for many insect species. In fact, an emergency use was just granted this past fall, a few weeks before the PMRA decision came out, and this was to control a new invasive species called brown marmorated stink bug, which can attack over 200 crops. I've seen it destroy 100% of an apple crop and a peach crop in Pennsylvania, which is pretty close to Ontario, so I know how devastating this insect can be.
If all the currently labelled uses are lost, it will be an enormous task to register effective and suitable alternative chemistries for the over 200 crops and multiple insect species that it controls. Although there are currently some registered alternatives for many of these pests, imidacloprid is the product of choice. As a result, a single application of imidacloprid may need to be replaced with three or even four applications of other products. You lose one, and then you have three or four alternatives each time you have to control pests.
Most of the other registered products have shortcomings that effectively preclude their use in commercial production systems. Even after 22 seasons of use, resistance to imidacloprid has not been an issue here. Many of the alternatives, on the other hand, need to be broad-spectrum products in a pesticide rotation program to prevent the pests from developing resistance. Imidacloprid has done this very well to date.
Since all horticulture is considered minor use, the pressure on Agriculture Canada's minor use program could be way beyond current capacity. None of our horticultural crops attract the research investment needed to register pesticides directly from the registrants. That's why we have the program. Even worse, many other products still face re-evaluation. Until they are reapproved, nobody wants to invest in their future, only to face double jeopardy.
I have many other comments on what I feel about the review, how it was done, the lack of time for meaningful input into the process, the lack of time to conduct new research to question some of the conclusions made by the PMRA, and their undue haste to publish a final decision by December of this year, nine months after our final comments are in. That's a full 12 months earlier than most of the re-evaluations over the past several years.
We have great concern that the 2015-2016 monitoring data, which was not included in making their decision, shows very different—in fact, lower—residue numbers in those same locations. This has not been taken into account.
Mesocosm studies that were rejected by the PMRA for various reasons need to be looked at again. What we call the weight of evidence shows up to 25 times less toxicity in the real environment as compared to pristine studies done in a laboratory. Perhaps a whole new look at the data used to condemn imidacloprid is warranted.
I also have concern that just last week Environment Canada announced they will not be conducting any further monitoring in these locations, even though they’ve expressed concern. This needs further consideration as well.
Just to close, bird counts done at Point Pelee have shown an increase in birds, and especially in fish feeders, and fishing quotas in Lake Erie have been rising. The fishing industry, in fact, has shifted down to the west end of the lake, so if there was really a problem, these would be the indicators, in my mind. This tells me a different story from the one portrayed by the PMRA in their proposal. Maybe if there is time later, I could add to the discussion.
I'll turn it over to Justine.