As an informed citizen and a concerned taxpayer I want to express my opinion and concern against the implementation of a pesticide by-law in the City of Guelph.
The implementation of a pesticide by-law is misguided, a duplication of existing regulations and a waste of taxpayer dollars. Pesticides are strictly regulated in Canada by Health Canada. It is the responsibility of the trained scientists at the Pest Management Regulatory Agency (PMRA), which is part of Health Canada, to critically review all scientific data on a pesticide before it can be approved for use in Canada. Only pesticide products that are determined to not pose an unacceptable risk to humans and the environment are approved for use under the Pest Control Products Act.
I enjoy the benefits pesticides bring in controlling pests and maintaining the value of my property. I use pesticides responsibly, along with other cultural methods, to control pests in my lawn and garden. Yes, I fully support IPM – Integrated Pest Management – and I support educating others in our community on pest management. But we can’t forget that IPM includes the option to use federally-registered products on our property. Let us choose.
I grew up on a fruit and vegetable farm in Ontario. I have a B.Sc. in Environmental Biology and an M.Sc. degree in Plant Pathology, both from our University of Guelph. I know first-hand the role pesticides play in producing the safe and affordable food supply we all enjoy. I understand the role pesticides play in maintaining our private properties and public spaces. I expect access to these benefits.
The regulation of pesticides is outside the expertise and authority of a municipal government. As a taxpayer in the City of Guelph I feel that Council should focus on more relevant issues affecting our city. HW
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I am a homeowner and citizen of Guelph, and have information and concerns regarding the proposed banning of lawn and garden care products that I would like to have considered relative to any bylaw relating to this.
I believe I have important information and insight to offer in these areas, and can do so from a balanced perspective with significant expertise due to my education and experience in the fields of organic products and pesticides.
I have extensive experience in research and development in pesticide products. I have been involved internationally in several areas including designing the end use products, regulatory, toxicology and biological testing. This includes pesticides that are used as lawn and garden care products, such as 2, 4-D, mecoprop, dicamba, and others. This has provided me with a solid background in the technology of pesticides, which is of course relevant to the current discussion.
I also spent six years working on the research and development of organic products. Since I have worked extensively in the area of organic products, I think I have a significant appreciation for their merits and limitations, and have an understanding of the values and expectations of users of such products. Such products can be a viable option for some aspects of lawn maintenance, but do not offer a complete and practical solution to lawn care.
It should be noted that I do not currently work in the field of lawn and garden products and have no vested interest. My interest is in having the tools available to protect the value of my exterior landscape, to maintain a reasonable appearance and to avoid economic loss.
During the last Guelph debate on these products, I had written a series of commentaries on the proposed by-law, to illustrate concerns on various aspects of the proposal. These include scientific, legal, and practical issues relating to the by-law. I have summarized various points on these, and added other comments below. Details of any of these areas are available, and trust that they will be considered and that the councilors will take the time to fully understand the implications prior to developing and implementing any regulation with respect to this matter.
Economic Loss: Homeowners have invested money in establishing and maintaining their landscapes. Loss of this due to removing access to necessary and approved products is not acceptable. In the previous debate on this issue, maintenance of the lawn bowling greens was considered an economic loss, but homeowner losses were not considered. This lack of consideration of the financial loss by the homeowner is unfathomable.
Double Taxation: We are taxed so that the Pest Management Regulatory Agency (PMRA) can review and approve pesticides for use. We would be paying additional taxes to support any bylaw which prohibits their use. Double taxation for approving then prohibiting products is unacceptable.
Process: I am highly disappointed with the process so far. For example, there was an announcement that the environmental sub-committee was having a meeting regarding the implementation of the previous plan, but instead resulted in a directive to have the administration develop a bylaw to ban pesticides. Public input needed to be sought before the drafting of the plan. There has been little opportunity or encouragement for public input since that time, and this simply must change.
Freedom: I consider a ban on pesticides as a usurpation of my freedom, primarily driven by media sensationalism and new age mysticism, both of which are reprehensible reasons. New age mysticism is particularly unpalatable given that this is a value system and imposition of such values is equivalent to imposition of a religion. This causes me much stress and anxiety, and since the impact of stress on health is quantifiably deleterious, this necessitates the evaluation of the benefits and detriments to the health of our society of the proposed ban.
Precedent: A ban would set a precedent that a by-law can be based on alleged harm rather than actual or reasonably probable harm. This is not equivalent to the smoking bylaw ban, where health hazards were identifiable and quantifiable. However, now I am sorry I supported the smoking ban since it is being used as a precedent for other alleged harm, as I was afraid it would be. Dogs and chainsaws both could be banned on the basis of potential harm using this precedent. You may consider this to be an extreme comparison, but in reality, dogs and chainsaws are far more hazardous than lawn and garden pesticides.
Impact on Pesticide Exposure: Our population is exposed to pesticides through our foods. Most pesticides used on lawn and gardens are also approved for use on foods. I contend that any potential exposure to residents of Guelph who are opposed to pesticide use is inconsequential relative to the overall exposure from other sources, hence there would be no meaningful impact to the ban.
The possible argument that some people choose to eat organic products is not relevant, as pesticides are approved for and used in production of organic foods. One reference which confirms this is found at the link below, which includes 53 pages of chemical products that are approved for use in “organic” production.
http://www.omri.org/crops_generic.pdf
Organic Alternatives: Previously it had been proposed that only “organic” products be permitted under the bylaw. This is unworkable and may be contrary to the best interests of our citizens. What organization would Guelph put in place to determine which products meet a definition of “organic”, and what would the definition of “organic” be? Different organizations define “organic” differently – it’s really not as easy to define as one might think at first glance.
Whatever is done, the city is responsible for making responsible choices if they are to impose this, and it is incumbent upon them to ensure they do not mandate a more hazardous choice than something else that may be available. For example, Bordeaux mixture is commonly accepted as an organic alternative, whereas based on review of the hazards of this chemical, it would be my last choice for pest control.
Enforcement Issues:
On the assumption that the council does not intend to charge people under the bylaw for spraying something that may be a pesticide; or by someone alleging that they saw their neighbour spray something, enforcement is an extremely complex subject. If the City of Guelph is to have an enforcement plan that meets a reasonable standard for proof of guilt, they will need to be able to positively identify that it was indeed a pesticide that was applied, and they would need infrastructure capable of doing so. In addition, in order to prove guilt after the fact (e.g. the day after spraying), the City would need to establish allowable residue levels for each pesticide, so that if any pesticide found on a homeowners landscape it could be reasonably differentiated if this was due to residual from previous use; or from spray drift from someone else spraying their lawn; or from the homeowner spraying their lawn. Establishing such levels for all pesticides, and having the technical capability of measuring this, is costly and technically very challenging.
And if you’re not going to enforce the bylaw, don’t make the bylaw.
Re-evaluation: One of the concerns brought up last time the bylaw was debated was that one of the most common lawn pesticides (2,4-dichlorophenoxyacetic acid, or 2,4-D), was under re-evaluation by PMRA. It should be noted that 2,4-D has passed this evaluation with no significant findings and lawn use continues to be approved. The standards for approval by PMRA are amongst the highest in the world, and 2,4-D has passed all of these standards during this review, as it has done so in many other jurisdictions that have evaluated it to modern standards. If we can’t accept this as sufficient, we are saying we have no faith in science at all, and I’m sure we would agree that this would be an unacceptable position for educated leaders of our community to take.
Vocal Minority: I contend that supporters of a ban are vocal minority and do not reflect the wishes of most citizens of Guelph. If the councilors believe differently, then I would request that they take the time to determine this in an unbiased way. If you walk around most neighbourhoods in Guelph, you will find most of the lawns substantially weed free. I am confident that pesticides have been used on at least 95% of such lawns, and since the use of pesticides are voluntary, I don’t see how anyone with their eyes open can believe that there is a majority of people who are opposed to using pesticides when they use them routinely and voluntarily.
Regardless of this, I would not support the values of people opposed to using pesticide being opposed on those of us who don’t, even if they were in the majority,
Disposal:
There has previously been talk of the City of Guelph collecting pesticides after the ban for disposal. This is the most irresponsible thing imaginable. There is well established knowledge and practice that in the event of discontinuing a pesticide that whatever is in the users hands be allowed to be used for their intended purpose.
The cost of disposal for these pesticides needs to be carefully determined, including doing research to determine the number and quantity of pesticides that would be disposed of by the average homeowner. Have the legal and engineering requirements for such a waste collection and transfer station, and the costs thereof, been determined? I would hope that we will not see another City of Guelph waste facility charged by the Ministry of the Environment for illegal and irresponsible actions.
Water:
Our current water restrictions are such that we are not allowed to water our lawns sufficiently to have the healthiest lawns possible so as to minimize the needs for pesticides. Indeed, by the time watering ones lawn becomes essential, a complete watering ban is always in place. Add a ban on pesticides to this, and our lawns will undoubtedly be the worst in the province and unacceptable to anyone who cares about the appearance of the neighbourhood in which they live.
Grubs:
The prevalence of grub infestations is very apparent to the residents of Guelph. Infestations can be severe and result in the loss of a lawn. To the best of my knowledge, the most environmentally benign way of controlling these is to apply Merit 0.5G as a preventative treatment prior to egg hatch. It is preferable to do this than to attempt to control the pest after the lawn is infested and damage is done. Any bylaw should allow such preventative use to help minimize pesticide use and to avoid economic loss to the owner of the lawn.
Decision Making Process:
I encourage all councilors to take the effort to understand the scientific and legal issues associated with the proposed by-laws, as well the issues of freedom, in addition to the alarmist and sensationalized claims of the vocal minority proposing the ban. It is a complex issue, and one that has taken myself 25 years in research and development to fully appreciate and understand the issues that are involved. Indeed, I consider expecting local councils to make decisions on such matters to be inappropriate and should be left with federal departments with the resources and science staff to be able to fully grasp the subject and make the right decisions.
I understand concerns regarding previous council’s lack of ability to reach consensus. Do not be coerced into making a decision to ban pesticides on the basis of trying to prove the council is working with consensus.
By-Law Alternatives:
I am fully confident that a by-law is not necessary, will expend considerable resources and will not make an appreciable difference to the health, safety or environment of Guelph. My preference is to abandon a ban.
The previous recommendation of education and limitations of the environmental conditions of application is more than what is required, but would be a consensus that I could live with.
The most extreme by-law that I could imagine would be to limit the choice of pesticides to those that are approved for use on food. Anything beyond this is ridiculous. It would be saying that it is okay to eat these pesticides in our food, but we can’t allow our neighbour to spray a bit on their roses. If there is absolutely any sense of proportion to the issue, this cannot be denied.
Thank you for your consideration of the above points in developing city council’s position on pesticides. I will be highly disappointed if council chooses to impose an outright ban, as this is not justifiable and is an unreasonable imposition and loss of freedom. I encourage you to contact me if you have any questions or would like any further information. JK
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I would ask you to reconsider the total ban of pesticides on our own
personal property. Chemicals properly used are a benefit to us and when one
realizes the chlorine in our water is a chemical. Pesticides and
insecticides are very important to the farming industry in providing food
for all of us.The health problems in society are mainly created by our lifestyles (lack of
exercise), trans fats in our foods and our diet in general with the fast
food industry’s growth over the past 50 years being a large part of the
health problems.A home is every family’s major investment and to deny one the right to
safely use tested and approved products for the maintenance of our property
would be most unfair.There are chemical products in every home whether it be for cleaning,
washing, germ disinfectants even mouthwash to kill germs and bacteria.All of my neighbours have expressed deep concern and are strongly opposed to
a total ban. TS~~~~~~~~~~~~~~
I have spent yet another sleepless night ruminating over the proposed by-law to ban lawn and garden care products. Why is this so important to me? Because it is an issue of freedom and of tolerance of values and philosophy, and a matter of democratic principle. The ban is an imposition of the natural/organic mysticism values that I do not hold.
I have developed my personal values and philosophy based on extensive reading of philosophies of all sorts, history, science and human nature. Banning the use of duly tested products of science made for the purpose of maintaining my view of what constitutes beauty on my own property greatly insults my values. My values may not be protected by a religion or a defined cultural heritage, but I am offended to the same extent as one would be to have another religion or culture imposed on them. Tolerance can only be accomplished if it is applied equally to everyone, and this imposition based on unfounded fears is not justifiable.
This week, I decided to post a sign on my lawn encouraging others to oppose the ban, and on it I included a few basic facts based on the currently proposed by-law. I included our councilors’ names and email addresses (which are publicly available so I felt this was acceptable in consideration of their privacy) and encouraged others to write to them. People did seem interested. Many people did take the names I had provided, at least with good intentions to voice their opinion. Interestingly but not surprisingly, today someone took the three signs I had posted away. A sure sign of fanaticism is the belief that others should not be exposed to an opposing point of view, and it is particularly fanatic to enter someone else’s property to take action to stifle such a view. I can think of no better example and proof that the ban is no more than imposition of zealotry on others.
I do not accept that the proposed ban is driven by any need to protect health, safety or the environment, and the by-law is not designed for that purpose. I asked Derek McCaughlan at city hall and he confirmed that products on Schedule A of the proposed by-law are all organic based, confirmation that the process is natural/organic value driven. It indeed is not safety nor environmentally driven, as there are equally or more environmentally friendly products available to control the pest spectrum represented by the Schedule A products that are not organic. If it were a safety or environmental issue, as purported in the preamble to the by-law, there would be specific criteria of safety and environmental standards to meet for inclusion on Schedule A.
Finally, I again object to the process. The by-law draft was issued last Friday and the committee review is Thursday morning, far too short a time to gain significant public or stakeholder input. Holding the meeting during normal work hours is an additional insult to the democratic process, and a continuation of a non-democratic process that has been followed thus far.
I sincerely hope a majority of councilors can see the reality of the nature of the ban and will work to develop a much more moderate by-law that reflects the opinions and values of all members of our city and on which reasonable consensus can be achieved. JK