The petition maintains that the federal government has not effectively used the protective provisions in its legislative mandate to regulate the effects of neonicotinoid crop pesticide products on non-target species, such as wild pollinators, including native bees, butterflies, bats, as well as migratory birds, and their habitats. The petition is concerned that other species are exposed to the neonicotinoids when they consume affected non-target species or drink from water systems polluted by these pesticides.
The petition raises concerns that the Minister of Environment and Climate Change and the Minister of Health are not meeting their responsibilities under domestic environmental protection legislation and Canada’s international obligations, such as the United Nations Convention on Biological Diversity. In particular, the petition suggests that the ministers have not properly used the following acts to protect non-targeted species from exposure to and harm from neonicotinoids: the Canadian Environmental Protection Act, 1999; the Migratory Birds Convention Act, 1994; the Pest Control Products Act; and the Species at Risk Act. It questions whether neonicotinoid effects on non-targeted species and the larger ecosystem have been adequately tested and considered during the approval and continued use of these pesticides. The petition also suggests that Environment and Climate Change Canada has not used its powers to protect migratory birds from the harmful effects of neonicotinoids when they migrate and use agricultural lands.
The petition asserts that Environment and Climate Change Canada uses a “hands-off” approach to the re-evaluation and special review of pesticide products and avoids assessing the harmful effects of pesticide products on non-target species. Moreover, the petition questions whether the ministers have followed legislated requirements to collaborate, exchange information, and consult with each other on the decisions made related to the testing and approval of these pesticides. It seeks details on what, if any, legislated consultation, cooperation, and information exchanges the ministers have carried out over the past 10 years regarding neonicotinoid risks to wild pollinators, and migratory birds. The petition also asks about ministerial action on the effects of these pesticides within the broader ecosystem and whether any neonicotinoids should be added to the list of toxic substances in Schedule 1 of the Canadian Environmental
Protection Act, 1999.