The following is a review I submitted via email (to: email@example.com) on 23 January. I thought my readers would find my comments of interest. Relevant to everyone is the very last comment -- How individuals can take action -- which I've made bold so you can find it easily.
"To Whom it May Concern:
The following are my comments on "Pollinator Health: A Proposal for Enhancing Pollinator Health and Reducing the Use of Neonicotinoid Pesticides in Ontario".
The primary issue is that the report lumps the introduced/alien/non-native and invasive honey bee ("Apis mellifera") in with native insect pollinators, i.e., it defines "pollinators" as native bees and the invasive alien honey bee, and other native insects such as butterflies. My first argument is that if you want to tackle "pollinator health" you can't lump the honey bee with native pollinators. The honey bee was brought to North America to pollinate crops. Agriculture, or converting natural, wild habitat to cropland is one of the major causes of habitat loss, which has lead to a decline in native pollinators (of all types). E.g., there are fewer places for ground-nesting native bumble bees to nest, fewer rotting logs for native halictid bees to nest in, fewer patches of native flora that the 100's of species of native Lepidoptera (moths and butterflies) depend on for food (caterpillars can eat only leaves of native plants; monarch butterfly is only one of ~ 170 butterfly species in Ontario). Furthermore, honey bees compete with native bees and other native pollinators for floral resources (pollen and nectar). We've all seen honey bees in our gardens and conservation areas. They don't stay on agricultural lands when they forage. Also, some species of native plants cannot be pollinated by honey bees, but require bumble bees for pollination (buzz pollination, which honey bees cannot perform).
In addition to ignoring this inherent conflict, the report favours the honey bee over all other pollinators in that it gives more attention to the honey bee -- much of the report is devoted to the honey bee. I haven't counted words, but it is apparent when reading it. And it lacks information explaining the vastly different types of biologies/life cycles found in different pollinators, namely that all bees are specialized on pollen and nectar and their young require pollen to develop, whereas immature lepidopterans (caterpillars) require fresh green leaves of their native host plants to develop, and adults require nectar only to drink to remain active (p. 6: 4. Exploring the "Four Stressors": Pollinator Habitat and Nutrition). It sometimes uses terms that are too generic (e.g. "bee" or "pollinator"). The very first sentence of the report, in the introduction states, "Improving bee health in Ontario...". There, at least, it should say "Improving pollinator health...".
Scientific names should be used at the first mention of a species. Scientific names serve an essential purpose of informing the reader of the species being discussed, and it is not acceptable to leave them out entirely. It should be stated in parentheses, after the common name, e.g.,"...the honey bee ("Apis mellifera")". If a reader is not interested in the scientific name, then they can ignore it.
On p. 1 above the photo of the bumble bee it states "Approximately 75 percent of all flowering plants...". This figure is too low. There is no citation (and I don't have a reference for you, but you can certainly find one by looking), but I'm sure this is incorrect and the correct is somewhere between 80-90%.
A token nod to Species at Risk in Ontario is at the very end of Section A, p. 8. -- Rusty-patched bumble bee. Please provide a more in-depth discussion of this SAR species, somewhere in section A. As mentioned above, include the scientific name ("Bombus affinis").
Section B: Reducing Neonicotinoid Use: what a great idea! This couldn't happen soon enough. If you want an excellent, outside starter read go to: "A large and growing body of research demonstrates that these pesticides harm multiple bee species..."
p. 17: Next Steps – How to Respond: How individuals can take action: Other ways you can help:
This section is misleading and lacking in information. The first part of this section should be directed to all people: farmers, beekeepers and everyone else, and it should urge all people to create pollinator habitat by native plant gardening, native plant landscaping and ecological restoration. Loss of pollinator habitat is everyone’s problem, and anyone who owns land, or has permission to plant a garden on someone else’s land (e.g., via a community garden, or permission to garden on a rental property or place of work), can easily be a part of the solution. The act of planting just one native flowering plant matters, and the cumulative effect of each person in Ontario doing so would be enormous.
Thank you for the opportunity to comment.