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.
If you want to do something to help the plight of insect pollinators in your community, create a native plant garden. Pollinators thrive on native plants, whereas they do not thrive on non-native, or alien plants. Most of our garden and landscaping plants are alien species. Native plants provide ample nectar and pollen for insect pollinators, such as bees, to eat. Most (not all) alien plants also provide nectar and pollen. But the key difference between native and alien plants lies in the leaves of the plant. Insect pollinators such as butterflies (and most all native leaf-feeding insects), can feed only on the leaves of the particular native plants they coevolved with. The classic example is the monarch butterfly. The monarch caterpillars can feed only on native milkweeds. They cannot feed on the leaves of alien plants. The adult butterfly will take nectar from alien plants, but the caterpillars require native milkweed leaves to survive. Most of us plant in the spring, but fall is a great time to plant. If you are wary of native plants, pick just one or two species and try them out. What are you waiting for? The time to plant your native pollinator garden is now!
Click beetles, or elaterids, are so-named because they can move their body in such a way as to cause a snap or click that is both forceful and noisy. The use of their specialized body parts, located on the underside of their body, and a threatening situation, such as being grasped by a predator, brings on the clicking behavior. The species pictured, the eyed elater, Alaus oculatus, is native to the eastern deciduous forest ecosystem of North America. The eyespots, or false eyes on the thorax also undoubtedly help to deter visually searching predators, such as birds. This beetle, like many other insects, fungi and other organisms, requires dead wood as habitat. The larvae live in dead wood on the forest floor, and are predators of other insects, including wood-boring beetle larvae. When a tree falls, it does not go to waste in nature. It becomes a new home for native biodiversity such as the eyed elater. Read more about this beetle on the University of Florida IFAS Extension page.
This post is about an opportunity to protect and conserve biodiversity within our own City of London, Ontario, and the related topic of how things work downtown at City Hall. This is one of those rare situations where there is "something for everyone".
The topic is the "Pen Equity Significant Woodland" near the 401 in the south end of the city. I am involved in the process of trying to protect this wetland and woodland, and I am asking you to take a few minutes of your time to write a letter. There are many facets to this issue and the conservation of biodiversity is only one of them. Other factors to consider, especially if you are a permanent resident of London, are: urban design, i.e., do we want yet another mall in London, and even if we do want another mall, do we want it at the outskirts of the city? And, do we want it at the expense of a wetland and a forest? Also, do we accept that our City Councillors and Mayor Fontana have disregarded our own Official Plan and the Provincial Policy Statement on the protection of Ontario's biodiversity? Finally, the proposed development of a shopping mall and cinema has been called "the Gateway to London". Do we want the "Gateway" to London to be a shopping mall? I have an idea. How about this? We leave the forest and the wetland, and we make it the gateway to our Forest City.
Please feel free to use my letter, copied below, or write your own. You may find additional information on this issue at the following links:
Reforest London, http://reforestlondon.ca/news/penequity-woodland-update
Citizen Corps, London, http://citizencorps.ca/post/61610799647/penequity-appeal-to-david-otoole
London Free Press (there are many articles on topic, this is mine),
Send an email letter (copy mine below, copy one from links above, or write your own) to one or all of the following people:
David O'Toole, Deputy Minister, MNR (firstname.lastname@example.org)
Laurie LeBlanc, Deputy Minister, MMAH (email@example.com)
Hon David Orazietti, Minister of Natural Resources (firstname.lastname@example.org)
Hon Linda Jeffrey, Minister of Municipal Affairs and Housing (email@example.com)
Time is of the essence and letters should be emailed asap, but no later than Tuesday, 25 September.
David O'Toole (firstname.lastname@example.org)
Deputy Minister, MNR
Whitney Block, 6th Fl, Rm 6643
99 Wellesley St. W.
Toronto, ON M7A1W3
Dear Deputy Minister:
A recent decision by the City Council of London, Ontario has approved the destruction of a parcel of land that not only contains a wetland, but has been evaluated as a Significant Woodland. This parcel of land is now known as the "Pen Equity Significant Woodland".
The proponent's own consultant, the Ecological and Environmental Planning Advisory Committee of the City (EEPAC), and City staff all agree that the parcel of land is a Significant Woodland; it exceeded the minimum requirements to be deemed "Significant" per London's Official Plan (OP). London's OP is consistent with the Provincial Policy Statement (PPS) 2005. London City Council's decision to allow development within a Significant Woodland is in direct contravention of London's OP and the PPS on preserving Ontario's biodiversity and natural heritage.
The City of London's actions should comply with their own OP, which is approved by the Ministry of Municipal Affairs and Housing, and with the PPS that protects Significant Woodlands. As a citizen of London I am at a loss to understand how elected officials are allowed to not follow their own OP, and the PPS. I am asking you to use all means available to stop the destruction of this wetland and woodland, and to enforce the requirements of the Official Plan of the City of London, and Ontario's Provincial Policy Statement.
Thank you very much for your immediate attention to this matter. I look forward to hearing from you.
(add your full name and address)
Thanks, and have a great weekend!