In January 2015, the Ontario Federation of Agriculture (OFA) submitted comments on an Ontario Discussion Paper released in November 2014 entitled Pollinator Health – A Proposal for Enhancing Pollinator Health and Reducing the Use of Neonicotinoid Pesticides in Ontario. In March 2015, a Regulation Proposal Notice was posted on the Environmental Registry entitled Regulatory Amendments to O. Reg. 63/09 under the Pesticides Act to reduce the Use of Neonicotinoid Insecticides. The purpose of this letter is to provide OFA’s comments on proposed amendments to O. Reg. 63/09.

Recall that OFA took a lead role in developing the Agriculture and Agri-Food Business Sector Strategy of Ontario’s Open for Business Initiative in 2010. OFA took that responsibility very seriously and continues to believe that our industry can benefit greatly from the prudent and consistent application of sound regulatory principles. Thus, our comments on the proposed amendments to O. Reg. 63/09 are provided through the lens of sound regulatory principles.