AWA Letter: Proposed Re-evaluation of Imidacloprid
December 14, 2016
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December 14, 2016
Pest Management Regulatory Agency
Health Canada
2720 Riverside Drive
Ottawa, Ontario
K1A 0K9
Re: Proposed Re-evaluation Decision PRVD2016-20, Imidacloprid
Dear Sirs and Madams:
Thank you for the opportunity to comment on the Proposed Re-evaluation Decision PRVD2016-20, Imidacloprid.
Alberta Wilderness Association (AWA) works throughout Alberta towards more representative and connected protection of the unique and vital landscapes that are the source of our clean water, clean air, and wildlife habitat. We have been working in Alberta for more than fifty years to raise the profile of Alberta’s spectacular wilderness. AWA helps Albertans learn more about the value of our wilderness and wildlife, and participates in opportunities to protect and care for the legacy that we will leave for future generations. With over 7,000 members and supporters in Alberta and across Canada, AWA remains committed to ensuring protection of wildlife and wild places in Alberta for all Canadians.
AWA is concerned with the use of neonicotinoid pesticides, such as imidacloprid, and their adverse affects on Canada’s terrestrial and aquatic wildlife. We would like to commend the Pest Management Regulatory Agency (PMRA) for listening to the scientific community and, in doing so, proposing elimination of imidacloprid from the vast majority of commercial and home uses. AWA supports this proposed ban.
However, AWA does not support the PMRA’s proposal to phase out imidacloprid over three to five years. As confirmed in your proposal, the levels at which imidacloprid has accumulated in the short time since its Canadian introduction in 1995 (~21 years to date) have been shown to be harmful to aquatic insects and the organisms that rely on them for a food source. An extension of three to five years, equivalent to 14-24% of the product’s use to date, is not justified when the significant negative effects of its use has been thoroughly documented through scientific study. To set a strong example of science-based decision-making, PMRA’s proposal must call for an immediate ban. Any lengthy phase-out simply cannot be supported by science.
We thank you for your consideration of our feedback.
Sincerely,
ALBERTA WILDERNESS ASSOCIATION
Nick Pink
AWA Conservation Specialist
