The Ontario Soil and Crop Improvement Association says the provincial government's approach to the pollinator health issue is too aggressive.
The OSCIA is also concerned the approach will have dangerous and far-reaching consequences in Ontario's farm community.
The Association sets out a number of concerns and makes four major recommendations in it's response to the EBR posting on the proposed neonic regulations.
It argues there are not enough qualified individuals to make the professional pest assessments the regulations propose.
To deal with that, the submission calls for a staged implementation of the regulations.
The Association feels the protocol for determining insect pressure is too rigid and is not science-based.
It's submission urges the regulations should, instead, follow the established methodologies and thresholds set out in OMAFRA's own publication - A Guide to Early Season Field Crop Pests.
The submission also recommends the government commit to a review to determine whether the regulations have had any measurable benefit to pollinators.
The OSCIA's final recommendation warns the government of the risk producers may turn back to conventional tillage practices to cope with the lack of seed treatments.
It calls for clear messaging from the government to reinforce the benefits of adopting conservation practices.
